Interpretation ID: aiam3491
Mr. John Osborne
Rolls-Royce Motors
Limited Car Division
Crewe Cheshire
CW1 3PL
England;
Dear Mr. Osborne: This is in response to your recent letter to the Administrator regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection, and its related requirements for the comfort and convenience of safety belts.; You stated in reference to paragraph S7.4.4, Latchplate Access, tha *the standard as written is design restrictive in not permitting inboard location of the latchplate when stowed by virtue of requiring the latchplate to be located within the outboard reach envelope...* You requested that the wording be changed to permit either inboard or outboard reach envelopes.; Paragraph S7.4.4 was not intended to limit the location of latchplate to outboard locations. Latchplates located in the outboard reach must be located within the reach envelopes as specified. However, the requirement would not be applicable to latchplates located inboard, since there should be no difficulty in reaching latchplates in this location. It should also be noted that the requirement is not applicable to automatic belts.; We believe the Agency's response to the petitions for reconsideratio of the comfort and convenience requirements will answer your remaining questions. We expect to issue that notice in the very near future.; You requested an early announcement of the final content of FMVSS No 208 as it would apply to automatic restraints. On October 23, 1981, the Department rescinded that portion of the standard that would require automatic restraints. We have enclosed a copy of the news release pertaining to that action for your information.; Please contact this office if you have further questions. Sincerely, Michael M. Finkelstein, Associate Administrator fo Rulemaking;