Interpretation ID: aiam1032
Assistant Attorney General
Office of the Attorney General
State of Minnesota
St. Paul
MN 55155;
Dear Mr. Herr: This is in reply to your letter of January 19, 1973, concerning th Federal requirements governing safety belt length.; Federal Motor Vehicle Safety Standard No. 208, Occupant Cras Protection, regulates the length of safety belts installed in cars made after January 1, 1972. There are two safety belt length requirements of this Standard that may enter into the case enclosed with your letter. The first requires that the manufacturers provide, as a minimum, sufficient safety belt length to fit at least a 95th percentile adult male with the seat in any (i.e., all) adjusted positions. A 95th percentile adult male weighs 215 pounds and has a 42.5 inch waist with 47.2 inch hips (sitting dimensions).; The second requirement concerns the length of the inboard end of th safety belt. In this case, the Standard requires that the intersection of the shoulder belt with the lap belt shall be at least 6 inches from the front vertical centerline of the average-size occupant, with the seat in the rearmost adjusted position. While this may result in an inboard belt length that may be somewhat more difficult to fasten than in some previous model cars, it significantly reduces the possibility that the shoulder belt could pull the lap belt up off the pelvis into the abdomen in a crash, possibly causing abdominal injuries.; With regard to the particular case at hand, our experience has bee that the vehicle manufacturers are usually willing to provide longer belts to fit very large new car buyers. With respect to inboard belt length, our experience has been that belts which approach the permissible 6 inch dimension mentioned above are usually satisfactory in terms of convenience. However, shorter inboard belt lengths, exceeding the minimum safety requirements of the standard, are permissible. In these cases, the customers may want to seek adjustment by the dealer or vehicle manufacturer.; In regard to the allegation made in the case that the belts cannot b changed, there is no Federal law or regulation that would prevent the dealer from modifying the safety belts. The National Traffic and Motor Vehicle Safety Act grants us the authority to regulate the safety of new motor vehicles. Although a dealer may not sell a new vehicle that does not conform to the standards, once the vehicle is sold and delivered the customer may have it modified by the dealer. In such a case, the dealer would not violate Federal law.; The dealer in question may well have had reasons for declining t modify the safety belts. He may be unsure of his ability to do a proper job and may fear incurring civil liability to the customer if someone should be injured as a result of his work. We would not encourage modification of a vehicle's mandatory safety features unless it is done with expert advice, or according to the manufacturer's recommendations.; Please contact this office if you desire any further discussion of thi matter.; Sincerely, Lawrence R. Schneider, Chief Counsel