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Interpretation ID: aiam2927

William Shapiro, P.E., Manager, Regulatory Affairs, Volvo of America Corporation, Rockleigh, NJ 07647; William Shapiro
P.E.
Manager
Regulatory Affairs
Volvo of America Corporation
Rockleigh
NJ 07647;

Dear Mr. Shapiro: Please excuse the delay in responding to your letter of October 25 1978. You asked whether a webbing guide you are planning for the rear seat belt in station wagon vehicles would have to comply with the strength requirements of Safety Standard No. 210, *Seat Belt Assembly Anchorages*.; The agency has examined the drawings included in your letter an discussed this new webbing guide with Volvo engineers. We have concluded that the webbing guide would not qualify as an 'anchorage' and, therefore, would not have to comply with the Standard 210 requirements for anchorages. The standard defines 'anchorage' as a device that transfers seat belt assembly loads to the vehicle structure. Your proposed webbing guide is not intended to transfer loads to the vehicle structure, and will only be added to increase the comfort of the assembly. As you indicated, the device marked 'B' on your drawings would qualify as an anchorage and would have to meet the strength requirements of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel