Interpretation ID: aiam2958
Director
Automotive Safety Office
Ford Motor Company
The American Road
Dearborn
MI 48121;
Dear Mr. Eckhold: This responds to your recent petition to amend Safety Standard No. 210 *Seat Belt Assembly Anchorages*, to exempt active lap belts installed in conjunction with passive upper torso restraints from the anchorage location requirements of the standard.; The agency has determined that amendment of the standard as you reques is unnecessary since active lap belts and their associated anchorages are not required to comply with Federal safety standards if installed voluntarily by a manufacturer in addition to a single, diagonal passive belt. The passive restraint requirement of Safety Standard No. 208 will require passive protection in frontal crashes and, either passive protection in lateral and rollover crash modes or the provision of Type I or Type II active belts for protection in lateral and rollover crash modes. The agency has previously stated, most recently in a letter to Volkswagen dated August 1, 1977, that the provision in S4.5.3 of Standard No. 208 allowing the substitution of any passive belt system (whether or not including a lap belt) for any other belt system otherwise required, is intended to apply to the provisions of S4.1.3(c) that specify either passive protection or the provision of Type I or Type II belts.; Since active lap belts installed in conjunction with single, diagona passive belts are not required, they are voluntary additions by the manufacturer. The agency has stated in past interpretations that systems or components installed in addition to required safety systems are not required to meet Federal safety standards, provided the additional components or systems do not destroy the ability of required systems (the passive belt in this case) to comply with Federal safety standards. This means that your proposed restraint system would have to meet the frontal crash protection requirements of Standard No. 208 both with and without the active lap belt fastened.; Since the change you requested is unnecessary in light of thi interpretation, the agency will consider your petition withdrawn.; Sincerely, Frank Berndt, Acting Chief Counsel