Interpretation ID: nht88-2.67

TYPE: INTERPRETATION-NHTSA

DATE: JULY 11, 1988

FROM: WILLIAM SHAPIRO -- MGR., REGULATIONS AND COMPLIANCE, VOLVO CARS OF NORTH AMERICA TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: FEDERAL MOTOR VEHICLE SAFETY STANDARD NUMBER 210; SEAT BELT ASSEMBLY ANCHORAGES - REQUEST FOR INTERPRETATION

ATTACHMT: ATTACHED TO LETTER DATED 4-16-90 TO WILLIAM SHAPIRO FROM STEPHEN P. WOOD; (A35; STD. 210). ALSO ATTACHED TO LETTER DATED 4-18-89 TO ERIKA Z. JONES FROM WILLIAM SHAPIRO; (OCC-3422). TEXT:

Section 4.3.2 of FMVSS 210 sets forth the location requirements for the upper torso portion of Type 2 seat belt assemblies. This section requires the seat belt anchorage for the upper end of the upper torso restraint to be located within the acceptable r ange shown in Figure 1 of FMVSS 210.

Volvo is currently designing a Type 2 seat belt assembly that has its upper torso anchorage point located in the acceptable range as defined in Figure1. The function of the seat belt and all strength requirements specified in FMVSS 210 are met using thi s anchorage point.

Volvo believes that an extra set of hardware at the upper torso anchorage would increase the stability of the mounting. The location of this extra set of hardware would fall outside the acceptable range as specified in Figure 1.

Volvo believes that a correct interpretation of FMVSS 210, with respect to the extra set of hardware for the upper torso anchorage, would be that it is acceptable for it to fall outside the range as specified in Figure 1, because the extra set of hardwar e is not required for the seat belt assembly to comply with the strength requirements as specified in FMVSS 210. Please confirm this for us.

Thank you for your attention to this matter. If you require any additional information, please feel free to contact me.