Interpretation ID: 3197yy
Parker, McCay & Criscuolo
Suite 401
Three Greentree Centre
Route 73 & Greentree Road
Marlton, NJ 08053
Dear Mr. Baldwin:
This responds to your September 25, 1991, letter in which you asked "the specific date when 2-point seatbelts were outlawed." Lap, or 2-point, belts have never been outlawed by this agency. Rather, 3-point, or lap/shoulder belts have been required at certain seating positions in certain vehicles. Lap belts are still permitted as the only occupant restraint at a seating position in all vehicles at some seating positions. Such seating positions include all seating positions that are not outboard seating positions and all seating positions that are not forward-facing. Your letter mentioned that you are specifically interested in this information for pending litigation regarding a 1984 passenger car convertible. Passenger car convertibles manufactured in 1984 were permitted to have lap belts installed at all seating positions. The following discussion should clarify NHTSA regulations regarding safety belts.
S4.1.2 of Standard No. 208 gives vehicle manufacturers a choice of three options for providing occupant crash protection in passenger cars. Option 1, set forth in S4.1.2.1, requires vehicle manufacturers to provide automatic protection at the front outboard seating positions, lap or lap/shoulder safety belts at all other seating positions, and either meet the lateral crash protection and rollover requirements by means of automatic protection systems or have manual safety belts at the front outboard seating positions such that those positions comply with the occupant protection requirements when occupants are protected by both the safety belts and the automatic protection. Option 2, set forth in S4.1.2.2, requires vehicle manufacturers to provide a lap or lap/shoulder safety belt at every seating position, have automatic protection for the front outboard seats, and have a warnin