Interpretation ID: aiam2605
BSG International
Britax (Wingard ) Limited
Chichester West Sussex PO19 2UG
England;
Dear Mr.Barlow: This responds to your letter of May 5, 1977, requesting clarificatio of the relationship between paragraph S5.3 of Safety Standard No. 208, *Occupant Crash Protection*, and Safety Standard No. 216, *Roof Crush Resistance*. It is your understanding that Standard No. 216 becomes 'obsolete and ineffective' after August 15, 1977.; Your interpretation is incorrect. Standard No. 216 is a separate independent standard from Standard No. 208 and remains effective in its present form regardless of the amendment of Standard No. 208 according to any of the three alternative proposals issued by Secretary Adams (42 FR 15935, March 24, 1977). Standard No. 216 is applicable to all passenger cars except those that conform to the rollover test requirements of paragraph S5.3 of Standard No. 208 by totally passive means.; Under existing Standard No. 208, a manufacturer must meet the rollove requirements of paragraph S5.3 only if he chooses to use option S4.1.2.1 (total passive protection). If the manufacturer chooses this option he can meet the requirements of Standard No. 216 instead of the rollover requirements of S5.3 until August 15, 1977, but not after that date since the alternative then expires. A manufacturer choosing to use either option S4.1.2.2 or option S4.1.2.3 of Standard No. 208 does not have to meet the rollover requirements of paragraph S5.3, at all. As a manufacturer of seat belts, you are undoubtedly aware that a majority of vehicle manufacturers choose to comply with Standard No. 208 by means of option S4.1.2.3.; If Secretary Adams' Alternative proposal I or Alternative proposal II becomes a final rule, Standard No. 208 will remain in the form just described above. The Secretary's Alternative II (mandatory passive restraints) proposes to make the lateral (S5.2) and rollover (S5.3) requirements of Standard No. 208 optional. A manufacturer would be permitted to use a totally passive system (meeting S54.1, S5.2, and S5.3) or to install lap belts and only meet the requirements of S5.1. If Alternative II were made final, most vehicle manufacturers would probably choose to install lap belts rather than to provide passive protection that would satisfy S5.3. As you noted, Alternative II also proposes to extend the option in paragraph S5.3 (complying with Standard No. 216 instead) from August 15, 1977, to August 31, 1980.; You are correct in your statement that the Secretary does not expect t reach a final decision on his alternative proposals until July.; Sincerely, Joseph J. Levin, Jr., Chief Counsel