Interpretation ID: 1985-01.2

TYPE: INTERPRETATION-NHTSA

DATE: 01/02/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: B. Henderson -- Automobile Importers of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. B. Henderson Automobile Importers of America, Inc. 1735 Jefferson Davis Highway, Suite 1002 Arlington, VA 22202

This responds to your letter of November 8, 1984, asking numerous questions concerning Standards No. 208, 209 and 210. The answer to your questions, numbered as presented in the attachment to your letter, are as follows:

1.) S.7.4.4 of Standard No. 208 sets requirements concerning access to the latchplate on the outboard side of a seat. The purpose of the requirement is to make safety belts more convenient to operate by requiring the latchplate to be accessible. You asked, in effect, whether the requirements of S7.4.4 also applies to an inboard mounted buckle located between the seat and a console. The answer is no. An inboard mounted buckle, however, must comply with the requirements of S7.4.6.

2.) You asked what is the meaning of the terms "comfort clip and window-shade" in section 7.4.2 of Standard No. 208. The terms refer to elements of a safety belt system which are used to relieve tension in the torso portion of a Type 2 lap-shoulder belt. A comfort clip is a device which attaches to the belt and can be positioned by an occupant to introduce and maintain slack in the belt system by physically preventing the belt slack from being taken up by the belt's retractor. The term window-shade refers to a type of device in a safety belt retractor which allows an occupant to introduce and maintain slack in the belt once it has been adjusted around the occupant.

3.) You asked if it is considered, "Action", if the driver hangs the webbing of an automatic belt on a manual convenience hook. An automatic belt must provide protection by means that require no action by the vehicle occupants. Manual vehicle convenience hooks used with an automatic belt system must comply with S 7.4.1 of the Standard, which requires a convenience hook to automatically release under specified conditions.

4.) You asked if it is mandatory to use 7/16-20 UNF 2A or 1/2-13 UNC-2A bolts for automatic belt mounting hardware. The answer is no. Automatic belts meeting the frontal crash protection requirements of Standard No. 208 are not required to meet all of the requirements of Standard No. 209. The enclosed interpretation letter of August 7, 1981, to Volkswagen more fully explains the application of Standard No. 209 to automatic belts.

5.) You asked if the retractor of a rear lap belt is a 2 point mounting type, are both points considered to be anchorage points? You also asked if both points must be within the range specified in S 4.3.1.1 of Standard No. 210.

Standard No. 210 defines an anchorage as "provision for transferring seat belt assembly loads to the vehicle structure." If by a two point mounting you mean a retractor that has two means for transferring the belt loads to the vehicle structures, then both points are anchorages and must conform to Standard No. 210. The range specified in S4.3.1.1. is measured from the seating reference point to the point of contact of the webbing with its attachment hardware. It does not require the anchorage points to be within that range.

6.) Finally, you asked what is the definition of the term "most upright position" used in S 4.3.2.1 of Standard No. 210. In referring to the "most upright position" of the seat back, the agency means the seat back adjustment position which most closely approximates a vertical position.

I hope this information is of assistance to you.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

November 8, 1984

Office of Chief Counsel NOA-30 National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590

Dear Sir or Madam:

Please provide a written interpretation of the following question:

FMVSSS 210, Section 4.3.2. requires that the seat back be "in its most upright position". Please define the phrase "in its most upright position".

Also please provide answers for the questions on the attached page.

Thank you for your prompt reply.

Automobile Importers of America, Inc.

B. Henderson

BH:js Attachments

QUESTIONS ON FMVSS 208, 209, 210.

1. FMVSS 208 S.7.4.4. states "the side of the vehicle interior to allow unhindered transit of the test block defined in Figure 4 of this standard to the latch plate or buckle......"

Does it mean that the whole buckle should be in the test block area as illustrated in Fig. A below?

What if the only push-button of the buckle fall in that test block area as illustrated in Fig. B below?

"INSERT"

Figure A Figure B

2. What is the meaning of comfort clip and window-shade? (in FMVSS 208 S.7.4.2)

3. Is it considered to be 'Action' if the driver hangs the webbing on the hook of the passive belt with manual convenience hook?

(New regulation FMVSS 208 5.4.1.2.1.1)

4. Is it mandatory to use 7/16-20 UNF-2A or 1/2-13 UNC-21 for the passive belt mounting hardware? (FMVSS 209 S.4.1(f)).

5. If the retractor or reel of the rear lap belt is 2 point mounting type, are both points considered to be anchorage points? Should both points be in the range defined in the FMVSS 210 S.4.3.1.1?

6. What is the definition of 'most upright position' of seat back in the FMVSS 210 S.4.3.2.1?