Interpretation ID: aiam3880
Daihatsu Motor Co.
Ltd.
No.7
2-Chome
NIHONBASHI-HONCHO
Chuo-ku
Tokyo
Japan;
Dear Mr. Tsujishita: This responds to your letter of November 26, 1984, requesting severa interpretations of Standard Nos. 201, 208, and 210. The answers to your questions raised in Attachments I, II, and III of your letter are discussed below.; In attachment I of your letter, you asked about the requirement o S3.5.1(c) of Standard No. 201. You were specifically concerned about the language which provides that the length of the armrest is to be measured vertically in side elevation. You provided a drawing of an armrest and asked if the length is to be measured as shown in section (dimension) b of your Figure 1.; The purpose of the requirement is to ensure that there is at last inches of coverage within the pelvic impact area. For this requirement to be meaningful, the covered surface must be contactable by the vehicle occupant. The vehicle occupant would not contact the base of the arm rest illustrated in your drawing. Therefore, the measurement should be made at dimension a in section A-A or dimension c in section B-B as shown in your Figure 1.; On question one of Attachment II, you asked about the application o Standard Nos. 208 and 209 to a safety belt system you are developing to meet S4.1.2.1 of Standard No. 208. The system consists of a two point automatic belt and a Type 1 manual safety belt. You asked which requirements of Standard No. 209 apply to such an automatic belt. I have enclosed an interpretation letter of August 7, 1981 to Volkswagen which explains the application of Standard No. 209 to an automatic belt.; In question two of Attachment II, you state that your vehicle will hav four anchorages for each front outboard seating position (two anchorages for the automatic belt and two for the Type 1 seat belt assembly). You said that S4.4.1 of Standard No. 210 requires seat belt anchorages for Type 2 safety belts at each front outboard seating position and you asked what is meant by anchorages for a Type 2 belt. You also asked whether you must install any other anchorages at those positions in your vehicle.; Paragraph S4.1.1. of Standard No. 210 requires anchorages for a Type seat belt assembly to be installed for each forward-facing outboard designated seating position in passenger cars. This is true regardless of whether the seating position is equipped with an air bag and a lap belt, with a single diagonal automatic belt or with any other system. Safety Standard No. 210 is independent of Safety Standard No. 208, *Occupant Crash Protection*. A Type 2 belt requires three anchorages (two for the lap portion of the belt and one for the upper torso restraint). The presence of the Type 2 anchorages in vehicles will allow vehicle owners to install easily Type 2 belts at their own initiative if they desire to do so for whatever reason. For example, if a single diagonal automatic belt system has been damaged, an owner may wish to replace it with a Type 2 manual belt system.; Under paragraph S4.3 of Safety Standard No. 210, anchorages fo automatic belts are exempted from the location requirements of the standard. This exception was provided for in the standard to allow manufacturers to experiment with various automatic belt designs to determine the optimum anchorage locations in terms of both effectiveness and comfort (43 FR 53440, Nov. 16, 1978). If, however, anchorage points for an automatic belt do not fall within the location specified in the standard for Type 2 belts, the manufacturer would have to provide additional anchorage points that could be used by a properly located Type 2 manual belt. Thus if your lap belt and upper torso anchorages fall within the location requirements for Type II belts, you would not have to provide any additional anchorages.; In question three of Attachment II, you asked what strength tes applies to anchorages used with an automatic belt and to the manual lap belt used in your system. You illustrated the test procedures you plan to use in your Figure 3. As explained below, the procedure shown in Figure 3(1) is correct and the procedure shown in Figure 3(2) is partially correct.; The agency has stated in an interpretation letter of July 23, 1980 t Mazda that the anchorages for a single diagonal automatic belt should be tested with a 3,000-pound force for purposes of Standard No. 210, in accordance with the test procedures of paragraph S5.2. This is the same force that is required for testing the upper torso portion of a Type 2 seat belt system. This force requirement is applicable whether the single diagonal automatic belt is used alone or whether it is used in conjunction with a manual lap belt. The anchorages for the manual lap belt, however, would be required to withstand test forces of 5,000 pounds under paragraph S4.2.1 for Standard No. 210. The anchorages for the manual lap belt and for the automatic belt must separately meet their respective force requirements and would not have to be tested simultaneously since they are separate systems.; In question one of the Attachment III, you requested the agency t clarify the words 'fold' and 'tumble' used in S7.4.6 of Standard No. 208. You stated your understanding that 'fold' means to move the seat back forward as shown in your Figure 4-a and 'tumble' means to move both the seat cushion and seat back forward as shown in your Figure 4-b. Your understanding of both words is correct.; In question two of Attachment III, you asked the meaning of the wor 'receptacle' as used in paragraph S7.4.6.2 of Standard No. 208. The word 'receptacle' refers to the devices into which an occupant would insert the tang of a safety belt to fasten the belt.; I hope this satisfactorily answers your questions. Sincerely, Frank Berndt, Chief Counsel