Interpretation ID: 1985-01.20

TYPE: INTERPRETATION-NHTSA

DATE: 01/29/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: DAIHATSU MOTOR CO., LTD.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of November 26, 1984, requesting several interpretations of Standard Nos. 201, 208, and 210. The answers to your questions raised in Attachments I, II, and III of your letter are discussed below.

In attachment I of your letter, you asked about the requirement of S3.5.1(c) of Standard No. 201. You were specifically concerned about the language which provides that the length of the armrest is to be measured vertically in side elevation. You provided a drawing of an armrest and asked if the length is to be measured as shown in section (dimension) b of your Figure 1.

The purpose of the requirement is to ensure that there is at least 2 inches of coverage within the pelvic impact area. For this requirement to be meaningful, the covered surface must be contactable by the vehicle occupant. The vehicle occupant would not contact the base of the arm rest illustrated in your drawing. Therefore, the measurement should be made at dimension a in section A-A or dimension c in section B-B as shown in your Figure 1.

On question one of Attachment II, you asked about the application of Standard Nos. 208 and 209 to a safety belt system you are developing to meet S4.1.2.1 of Standard No. 208. The system consists of a two point automatic belt and a Type 1 manual safety belt. You asked which requirements of Standard No. 209 apply to such an automatic belt. I have enclosed an interpretation letter of August 7, 1981 to Volkswagen which explains the application of Standard No. 209 to an automatic belt.

In question two of Attachment II, you state that your vehicle will have four anchorages for each front outboard seating position (two anchorages for the automatic belt and two for the Type 1 seat belt assembly). You said that S4.4.1 of Standard No. 210 requires seat belt anchorages for Type 2 safety belts at each front outboard seating position and you asked what is meant by anchorages for a Type 2 belt. You also asked whether you must install any other anchorages at those positions in your vehicle.

Paragraph S.4.1.1 of Standard No. 210 requires anchorages for a Type 2 seat belt assembly to be installed for each forward-facing outboard designated seating position in passenger cars. This is true regardless of whether the seating position is equipped with an air bag and a lap belt, with a single diagonal automatic belt or with any other system. Safety Standard No. 210 is independent of Safety Standard No. 208, Occupant Crash Protection. A Type 2 belt requires three anchorages (two for the lap portion of the belt and one for the upper torso restraint). The presence of the Type 2 anchorages in vehicles will allow vehicle owners to install easily Type 2 belts at their own initiative if they desire to do so for whatever reason. For example, if a single diagonal automatic belt system has been damaged, an owner may wish to replace it with a Type 2 manual belt system.

Under paragraph S4.3 of Safety Standard No. 210, anchorages for automatic belts are exempted from the location requirements of the standard. This exception was provided for in the standard to allow manufacturers to experiment with various automatic belt designs to determine the optimum anchorage locations in terms of both effectiveness and comfort (43 FR 53440, Nov. 16, 1978). If, however, the anchorage points for an automatic belt do not fall within the location specified in the standard for Type 2 belts, the manufacturer would have to provide additional anchorage points that could be used by a properly located Type 2 manual belt. Thus if your lap belt and upper torso anchorages fall within the location requirements for Type II belts, you would not have to provide any additional anchorages.

In question three of Attachment II, you asked what strength test applies to anchorages used with an automatic belt and to the manual lap belt used in your system. You illustrated the test procedures you plan to use in your Figure 3. As explained below, the procedure shown in Figure 3(1) is correct and the procedure shown in Figure 3(2) is partially correct.

The agency has stated in an interpretation letter of July 23, 1980 to Mazada that the anchorages for a single diagonal automatic belt should be tested with a 3,000-pound force for purposes of Standard No. 210, in accordance with the test procedures of paragraph S5.2. This is the same force that is required for testing the upper torso portion of a Type 2 seat belt system. This force requirement is applicable whether the single diagonal automatic belt is used alone or whether it is used in conjunction with a manual lap belt. The anchorages for the manual lap belt, however, would be required to withstand test forces of 5,000 pounds under paragraph S4.2.1 for Standard No. 210. The anchorages for the manual lap belt and for the automatic belt must separately meet their respective force requirements and would not have to be tested simultaneously since they are separate systems.

In question one of the Attachment III, you requested the agency to clarify the words "fold" and "tumble" used in S7.4.6 of Standard No. 208. You stated your understanding that "fold" means to move the seat back forward as shown in your Figure 4-a and "tumble" means to move both the seat cushion and seat back forward as shown in your Figure 4-b. Your understanding of both words is correct.

In question two of Attachment III, you asked the meaning of the word "receptacle" as used in paragraph S7.4.6.2 of Standard No. 208. The word "receptacle" refers to the devices into which an occupant would insert the tang of a safety belt to fasten the belt.

I hope this satisfactorily answers your questions.

SINCERELY,

DAIHATSU MOTOR CO., LTD.

OCC 1578

Ref. No. 84-007 Date Nov. 26, 1984

Office of Vehicle Safety Standards National Highway Traffic Safety Administration

Dear sir,

Subject: Questions with respect to Federal Motor Vehicle Safety Standard Nos. 201, 208 and 210

We, DAIHATSU MOTOR CO., LTD., plan to export our vehicles to U.S.A. We have some questions to conform our vehicle to Federal Motor Vehicle Safety Standards. We would like to ask you to answer the questions described in Attachment I, Attachment II and Attachment III.

Your earliest and kind response will be greatly appreciated.

H. Tsujishita Chief Co-ordinator of Technical Administration Dept. DAIHATSU MOTOR CO., LTD.

Attachment I: Standard No. 201

The underlined part of the paragraph S3.5.1(c) of Standard No. 201 as follows is not clear at which section the armrest shall be measured vertically.

S3.5.1(c) "Along not less than 2 continuous inches of its length, the armrest shall, when measured vertically in side elevation, provide at least 2 inches of coverage within the pelvic impact area."

We understand it shall be measured at the section b shown in Fig. 1. If our understanding is wrong, please explain or illustrate in detail.

Fig. 1

(Graphics omitted)

Attachment II: Standard Nos. 208 and 210

We are developing an occupant protection system shown in Fig. 2. It consists of an automatic belt and optionally Type 1 seat belt assembly to meet the requirements of S4.1.2.1 of Standard No. 208.

Fig. 2

(Graphics omitted)

Question 1.

We understand that the paragraph S4.5.3.4 of Standard No. 208 means "An automatic belt furnished pursuant to S4.5.3 that is required to meet the perpendicular frontal (Illegible Word) protection requrements of S5.1 neet not conform to the webbing, attachment hardware, and assembly performance requirements of Standard No. 209." Then, shall the automatic belt conform only to S4.1.2.1 (including S5.1), S4.5.3.3(including S7.1) and S4.1.1 of Standard No. 208, and need not conform to any requirements of Standard No. 209?

Question 2.

Our vehicle with the automatic belt will have four anchorages for one front seating position (two anchorages for the automatic belt and two for the Type 1 seat belt assembly), and have no anchorages for a three-point manual seat belt assembly. Paragraph S4.4.1 of Standard No. 210 requires that seat belt anchorages for a Type 2 seat belt assembly shall be installed for each forward-facing outboad designated seating position in passenger cars. We cannot understand what the seat belt anchorages for the Type 2 seat belt assembly mean. Are the anchorages of the vehicle regarded as the anchorages for a Type 2 seat belt anchorages? To conform to Standard No. 210, shall the vehicle install any other anchorages?

Question 3.

We cannot find any requirements about the strength test of anchorages for an automatic belt. To conform to Standard No. 210, we will test the anchorages of the vehicle by the way shown in Fig. 3 according to the test procedures for the anchorages for a Type 2 seat belt assembly described in Standard No. 210. If our test procedure is wrong, please explain it in detail.

Fig. 3

(Graphics omitted)

Attachment III

Question 1.

The difference of meanings between "fold" and "tumble" in the paragraph S7.4.6 of Standard No. 208 is not clear. We understand that the meaning of the word "fold" is to move the seat back forward shown in Fig. 4-a, and that the meaning of the word "tumble" is to move both the seat cushion and the seat back shown in Fig. 4-b. If our understanding is wrong, please explain the meanings.

Question 2.

We cannot understand the word "receptacle" in paragraph S7.4.6.2. So please explain what the phrase "the inboard receptacle end of a seat belt assembly" means.

(Graphics omitted)