Interpretation ID: aiam3971
Manager
Technical Operations Section
Overseas Operations Dept.
Tokai Rika Co.
Ltd.
Oguchi-Cho
Aichi Pref.
480-01
Japan;
Dear Mr. Ito: Thank you for your letter concerning the buckle release requirements o Standard No. 208, *Occupant Crash Protection*. I apologize for the delay in responding to it. You asked for an interpretation of the requirement in S4.5.3.3(a) of the standard that automatic belts must have an emergency release mechanism that is 'readily accessible to a seated occupant.' The following discussion addresses the specific questions you asked.; The purpose of the 'readily accessible' requirement is to ensure that seated occupant can quickly and easily grasp and then release the buckle in an emergency. You explained that you have been reviewing the accessibility of possible installation locations for the emergency release by using a 5th percentile female and 50th percentile male test dummy in various seating positions. You ask whether in determining if the buckle is readily accessible, you can move the pelvic portion of the test dummy or move the seat back to permit the grasping of the buckle.; The purpose of S4.5.3.3(a) is twofold. First, it is intended to mak sure automatic belts are adjustable to fit a wide range of vehicle occupants, as specified in S7.1 of the standard. In addition, it is meant to ensure that the emergency release mechanism for the automatic belt is readily accessible to that same range of occupants. Thus, the release mechanism should be accessible to those occupants with the seat in any design position without the occupant having to take special steps, such as moving the seat back, to grasp and operate the release. I noted that the drawing you attached to your letter indicates that your emergency release is located within the latchplate access zone specified in S7.4.4 of the standard. Although S7.4.4 does not apply to the emergency release mechanism of automatic belts, its purpose is to make it easy for occupants to reach the latchplate of a safety belt system. We would consider any emergency release mechanism required by S4.5.3.3(a) that is within the latchplate access zone of S7.4.4 to be readily accessible as long as the occupant does not have to take any special steps to grasp and operate the release.; If you have any further questions, please let me know. Sincerely, Jeffrey R. Miller, Chief Counsel