Interpretation ID: aiam3690
Head
Administration
Government Relations Department
Suzuki Motor Co.
Ltd.
3251 E. Imperial Highway
Brea
CA 92621;
Dear Mr. Petler: This responds to your recent letter requesting information concernin the requirements for seat belt anchorages in passenger cars under Safety Standard No. 210. Specifically, you ask whether only Type 1 seat belt anchorages are required in rear seating positions in passenger cars.; The answer to your question is no. Under paragraph S4.1.1 of standar 210, Type 2 seat belt anchorages (for combination lap and shoulder belts) are required as follows: at each front and rear forward-facing outboard designated seating position in passenger cars other than convertibles, and at each front forward-facing outboard designated seating position in vehicles other than passenger cars where Type 2 belts are required by Safety Standard No. 208. All other seating positions in both passenger cars and other vehicles may be equipped with anchorages for either Type 2 belts or Type 1 belts (lap belts). Safety Standard No. 208, *Occupant Crash Protection*, requires Type 2 belts only in *front* outboard designated seating positions in passenger cars, but passenger cars still must be equipped with anchorages for Type 2 belts in rear outboard designated seating positions.; As to your reference to discussion of anchorages in the agency' November 2, 1981 denial notice to Toyo Kogyo (46 FR 54391), that discussion was misleading because it did not provide complete information or distinguish adequately between passenger cars and other types of vehicles. The agency intended to refer to the type of belts required by Safety Standard No. 208, i.e., Type 2 belts in front outboard designated seating positions and Type 1 belts in front center and all rear seating positions.; I hope this has clarified any misunderstanding you may have ha concerning the anchorage requirements. Please contact Hugh Oates of my staff if you have any further questions (202-426- 2992).; Sincerely, Frank Berndt, Chief Counsel