Interpretation ID: 1985-01.39

TYPE: INTERPRETATION-NHTSA

DATE: 03/01/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Hiroshi Shimizu

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of December 19, 1984, concerning the requirements of Federal Motor Vehicle Safety Standard No. 209, Seat Belt Assemblies. You noted that section S4.1(e) of the standard provides that "A Type 1 or Type 2 seat belt assembly shall be provided with a buckle or buckles readily accessible to the occupant. . . ." [Emphasis added]. You asked whether the standard would permit a seat belt assembly with two buckles as shown in the schematic attached to your letter. The answer is that while Standard No. 209 would permit such an assembly, whether such an assembly can be installed in a particular vehicle is determined by Standard No. 208, Occupant Crash Protection.

Standard No. 208 specifies performance requirements for the protection of occupants in a crash. Section S4.1.2.3.1 provides that Type 2 lap and shoulder belt systems used in passenger cars must have a nondetachable shoulder belt. Likewise, S4.2.2 provides that certain trucks and buses with Type 2 belts must have a nondetachable shoulder belt. The belt system you illustrated in your diagram consists of one continuous loop of webbing which serves as both the lap and shoulder belt. However, your design provides a separate buckle for the shoulder anchorage and thus an occupant could release the shoulder buckle and use the belt solely as a lap belt. Thus, we would not consider your design to have a nondetachable shoulder belt.

In addition, section S7.2 of the standard sets requirements for the latch mechanism of non-automatic seat belt assemblies used in passenger cars and certain trucks and buses. Section S7.2(c) requires that the latch mechanism used in those vehicles must release at a single point. Therefore, a two buckle system could not be used in those vehicles.

I hope this answers your question.

Sincerely,

ATTACH.

December 19, 1984

Diane Steed -- Administrator, National Highway Traffic Safety Administration

Dear Sirs:

This is to ask for your confirmation that a design of seat belt assembly having two buckles is allowed by Federal Motor Vehicle Safety Standard 209.

Section S4.1(e) of the standard sets forth "A Type 1 or Type 2 seat belt assembly shall be provided with a buckle or buckles readily accessible to the occupant . . . . .". Based on that provision, we believe that FMVSS 209 permits such a seat belt design as shown in the schematic enclosed as long as they meet all the applicable provisions in the regulation.

We should appreciate your confirmation letter.

Very truly yours,

TOKAI RIKA CO., LTD.;

Hiroshi Shimizu, Asst. Manager -- Overseas Operations Dept.

Encl.

(Graphics omitted)

Schematic of Seat Belt Assembly having Two Buckles