Interpretation ID: 1983-1.44

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 20, 1983

FROM: F. MICHAEL PETLER -- HEAD, ADMINISTRATION, GOVERNMENT RELATIONS DEPARTMENT, SUZUKI

TO: OFFICE OF CHIEF COUNSEL -- NHTSA

TITLE: REQUEST FOR INTERPRETATION FMVSS NO. 210; SEAT BELT ASSEMBLY ANCHORAGES

ATTACHMT: MEMO DATED 5-6-83, TO F. MICHAEL PETLER, FROM FRANK BERNDT, NOA-30

TEXT: We are in urgent need of your confirmation of our interpretation of the seat belt assembly anchorage requirements for the rear seat.

Paragraph S4.1.1 of FMVSS No. 210 states:

"Seat belt anchorages for a Type 2 seat belt assembly shall be installed for each forward-facing outboard designated seating position in passenger cars other than convertibles, and for each designated seating position for which a Type 2 seat belt assembly is required by @ 571.208 in vehicles other than passenger cars."

In your agency's November 2, 1981 denial of Toyo Kogyo U.S.A.'s petition for rulemaking (46 F.R. 54391-54392) the following statement appears:

"The standard requires all passenger cars, lightweight trucks, and multipurpose passenger vehicles to be equipped with three-point anchorages for Type 2 belts (combination lap and shoulder belts) at each forward facing outboard designated seating position. Two-point anchorages for Type 1 belts (lap belts) are required at all other designated seating positions (center front and all rear positions)."

We interpret this standard to require that only Type 1 seat belt assembly anchorages must be installed for each seating position of a rear seat, such as in the case of a passenger car. We would appreciate a prompt reply as to whether we are correct in our interpretation of this standard.