Interpretation ID: aiam4049
2150 Hacker Road
Howell
MI 48843;
Dear Ms. Hill: Thank you for your letter of September 19, 1985, asking about th effect of our regulations on a safety belt design you have seen. You explained that the design uses 'a rigid member to support a webbing guide near the shoulder of a front seat occupant. This rigid member was rigidly attached to the roof of the vehicle.' You asked several questions about this design, which are answered below.; You first asked whether the rigid member would be considered a sea belt anchorage, a piece of attachment hardware or a common component for the purposes of our standards. We cannot provide a definitive answer without having further details about and preferably a drawing of the structure. Based on the information you have provided, it appears that the rigid member would be an anchorage.; Standard No. 210, *Seat Belt Assembly Anchorages*, defines a 'anchorage' as a device that transfers safety belt assembly load to the vehicle structure. Since the rigid member is attached to the roof at one end and to a safety belt webbing guide at the other, it appears to be intended to transfer loads to the vehicle structure. Thus, it would have to meet the strength and location requirements of the standard.; You also asked if one or both ends of the rigid member are required t meet the upper torso restraint location requirements of S4.3.2 of Standard No. 210. If, as discussed above, the rigid member is intended to transfer loads, then it would have to meet the location requirement of S4.3.2. That section states that the 'anchorage for the upper end of the upper torso restraint shall be located within the acceptable range' shown in Figure 1 of the standard. The purpose of the requirement is to specify the angle at which the shoulder belt crosses the occupant's chest. Thus, the portion of the anchorage that controls the angle of the shoulder belt must be within the zone specified in Figure 1.; I hope this information is of assistance to you. If you have an further questions, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel