Interpretation ID: nht87-1.15

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Phil Rounds

TITLE: FMVSS INTERPRETATION

TEXT:

Phil Rounds, Esq. Rhodes, Hieronymus, Jones, Tucker & Gable 2800 Fourth National Bank Building 15 West Sixth Street Tulsa, OK 74119

Dear Mr. Rounds:

Thank you for your letter of October 22, 1986, requesting an interpretation of how the requirements of Standard No. 20B, Occupant Crash Protection, would apply to a model year 1982 vehicle. The answers to your two specific questions are discussed below.

You first asked about the requirements of S4.1.2.3 of the standard. You asked whether a manufacturer that has chosen to meet that provision of the standard by installing a Type 2 safety belt at each front outboard designated seating position is required to crash test those safety belts. As explained below, S4.1.2.3 does not require the Type 2 safety belts installed in accordance with that requirement to be subjected to a crash test.

S4.1.2 of the standard sets forth the requirements for passenger cars manufactured on or after September 1, 1973, and before September 1, 1986. Thus, those requirements would apply to a model year 1982 passenger car. S4.1.2 provides that a manufacturer s hall meet the requirements of either S4.1.2.1, S4.2.2.2, or S4.1.2.3. Under S4.1.2.3, a manufacturer has the option of installing "a Type 2 seat belt assembly with a nondetachable shoulder belt that conforms to Standard No. 209" at each front outboard de signated seating position. Although Standard No. 209 establishes performance requirements for a safety belt, it does not require the crash testing of the belt.

You also asked whether lap belts installed in accordance with the requirements of S4.1.2.3 in a vehicle's rear seat must be crash tested. The answer is no, rear seat safety belts installed in accordance with S4.1.2.3 do not have to be crash tested. S4.1. 2.3 (c) sets the requirements for rear seats. It provides that a manufacturer may install either a "Type 1 or Type 2 seat belt assembly that conforms to Standard No. 209. . . ." As explained above, Standard No. 209 does not require crash testing for safe ty belts.

As you requested, we are providing you with a certified copy of this letter. If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

Erika Z. Jones NHTSA Office of Chief Counsel, Room 5219 400 Seventh Street SW Washington DC 20590

Dear Ms. Jones:

Re: Interpretation Letter 49 CFR

Section 571.208 5.4.1.2.3

We are writing to request a certified copy of a letter of interpretation regarding conformity with FMVSS 208 as it applies to 1982 MY vehicles.

Specifically, please confirm that where a manufacturer of a 1982 MY vehicle has elected the third option (S.4.1.2.3) and employed type 2 seatbelts (i.e., three point belts), at each front outboard designated seating position, a dynamic crash test is not required. Further, that a 49 CFR Section 571.208 S 5.1 test is also not required with regard to lap belts in the rear designated seating positions where type 2 seatbelts are employed at each front outboard designated seating position.

Your immediate attention to this matter would be most appreciated. Enclosed is a check in the amount of $3.00 to cover administrative expenses.

Yours truly,

PHIL ROUNDS PLR/bv Enclosure