Interpretation ID: nht92-9.45

DATE: January 21, 1992

FROM: William F. Russo -- Margolis, Sakayan & Holtz

TO: Steven P. Wood -- Assistant Chief Counsel for Rulemaking, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/18/92 from Paul Jackson Rice to William F. Russo (A39; Std. 210)

TEXT:

I am an attorney practicing in the area of automobile products liability, who is in need of your assistance in interpreting one of your agency's regulations. Specifically, I have a question concerning the definition of "Seat belt anchorage," as contained in 49 C.F.R. S 571.210 S3.

According to this provision, the definition "means the provision for transferring seat belt assembly loads to the vehicle structure." Basically, I need to know if this definition requires a motor vehicle manufacturer to include anchorage plates or similar devices in the car during the manufacturing process, or if it would be sufficient for the manufacturer to simply provide instructions to its customers and dealers on how to punch holes in a certain spot in the vehicle interior to create an anchorage location, should they wish to install the optional shoulder harness kit.

I hope I have stated my question clearly, but please feel free to call if you have any questions. Thank you for your assistance and I look forward to hearing from you.