Interpretation ID: 1985-03.22

TYPE: INTERPRETATION-NHTSA

DATE: 07/24/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Richard H. Lucki -- Peugeot, U. S. Technical Research Company

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Richard H. Lucki U.S. Factory Representative PEUGEOT U.S. Technical Research Company 33 Garland Way Lyndhurst, New Jersey 07071

This responds to your letter of March 7, 1985, concerning Standard No. 208, Occupant Crash Protection. I regret the delay in our response. You noted that sections S4.1.2.71(c)(2) and S4.1.2.2(d) of the standard require a seat belt warning system that conforms to S7.3 of the standard to be installed at each front outboard seating position of automatic restraint-equipped cars that have manual belts also at those positions. You pointed out that S7.3, however, only sets requirements for a warning system for the driver's seating position. You asked whether the requirements of S4.1.2.1(c)(2) and S4.1.2.2(d) can be met by providing a warning system conforming to S7.3 at only the driver's seating position. The answer is that those requirements can be met by a warning system for the driver only.

In December 1974 (39 FR 42692), the agency amended Standard No. 208 to establish new safety belt warning system requirements for vehicles manufactured after February 24, 1975. As discussed in the preamble, the agency decided against requiring a warning system at both the driver's seating position and the right front passenger's position. Instead, the agency adopted a requirement in S7.3(a) for a warning system at only the driver's seating position. (In July 1977 (42 FR 34299), the agency renumbered S7.3(a) to become the current S7.3).

In July 1976 (41 FR 29715), the agency proposed language concerning the safety belt warning system in automatic restraint-equipped cars. The proposed language was subsequently adopted, an July 5, 1977 (49 FR 34299), in S4.1.2.1(c)(2) of the standard. The agency explained in the preamble of the July 1976 notice that the proposed safety belt warning system was to parallel the existing requirements for passenger cars. Thus, the intent was to require a warning system for only the driver's position. Requiring a warning system for the driver's position only is also consistent with the separate warning system requirement set in S4.5.3.3(b) for automatic belts. S4.5.3.3(b) requires a warning system only for the driver's position.

If you have any further questions, please let me know.

Sincerely, Jeffrey R. Miller Chief Counsel

March 7, 1985

RE: Federal Motor Vehicle Safety Standard 208 - Request for Interpretation

Dear Mr. Berndt:

Paragraphs 4.1.2.1(c)(2) and 4.1.2.2(d) of Federal Motor Vehicle Safety Standard 208 requires a seat belt warning system which conforms to paragraph 7.3 at each front outboard seating position.

Paragraph 7.3 requires that a seat belt assembly provided at the driver's seating position shall be equipped with a warning system and conditions activation of the audible signal to use of the driver's belt.

We request confirmation that the requirements of S.4.1.2.1(c)(2) and S.4.1.2.2(d) are met by providing a warning system conforming to S.7.3 at the driver's seating position only.

Thank you.

Very truly yours, Richard H. Lucki U.S. Factory Representative PEUGEOT

USTR/RHL/jg/070