Interpretation ID: aiam3092
House of Representatives
Washington
DC 20515;
Dear Mr. Brooks: This responds to your note we received on August 29 enclosin correspondence from one of your constituents, Mr. Don Bush. Mr. Bush requests information concerning passive seat belts on a 1977 Volkswagen Rabbit. Apparently, he was told by the Society of Automotive Engineers that there are currently no standards for this type of restraint system.; The information given Mr. Bush by the Society of Automotive Engineer was incorrect. The National Highway Traffic Safety Administration issues safety standards and regulations governing the manufacture of new motor vehicles and motor vehicle equipment. Safety Standard No. 208, *Occupant Crash Protection*, specifies requirements for restraint systems in passenger cars and other vehicles (49 CFR 571.208). For 1977-model passenger cars manufacturers had three options: (1) total passive protection (protection by means that require no action by vehicle occupants), (2) head-on passive protection, (3) the installation of combination lap and shoulder belts for front, outboard seating positions and lap belts for center and rear seating positions.; Volkswagen apparently certified its 1977-model deluxe Rabbit under th second option of the standard. This option requires the vehicle to meet specified injury criteria in a perpendicular barrier crash test, and to either meet lateral and rollover criteria in dynamic impact tests by automatic means or to install lap belts at front, outboard seating positions. Volkswagen used a single, diagonal passive belt to comply with the automatic frontal crash protection requirement of the second option. Additionally, paragraph S4.5.3 of Safety Standard No. 208 allows a passive belt to be used in lieu of any other belt required by any option of the standard. Therefore, Volkswagen's single, diagonal passive belt also qualifies as a lap belt for purposes of complying with the lateral and rollover requirements of the second option.; I am enclosing a copy of Safety Standard No. 208 for Mr. Bush' information. Please have him contact Hugh Oates of my office if he has any questions after reviewing the standard (202-426-2992). Mr. Bush might also note that General Motors voluntarily installed an active lap belt in its Chevettes that have passive shoulder belts (these vehicles were introduced in the spring of this year). Active lap belts in these vehicles are not required by the standard, however.; Sincerely, Frank Berndt, Chief Counsel