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Interpretation ID: 23381ogm



    Mr. Robert Babcock
    Manager
    Government Affairs
    Hyundai America Technical Center
    5075 Venture Dr.
    Ann Arbor, MI 48108

    Dear Mr. Babcock:

    This responds to your electronic mail message of July 9, 2001, regarding the requirements of Standard No. 210, Seat Belt Assembly Anchorages. Your letter asks whether seat belt anchorages must meet the location requirements found in S4.3 of Standard No. 210 after the anchorages have been subjected to testing to determine if they comply with the anchorage strength requirements found in S4.2. Your message indicates that Hyundai believes that the anchorages are not required to meet the anchorage location requirements after testing for compliance with S4.2. You ask the agency to confirm that your company's interpretation is correct.

    The National Highway Traffic Safety Administration (NHTSA) agrees with your interpretation.

    Standard No. 210 applies to new vehicles and does not require that anchorages remain in their original positions after being subjected to the severe loads that may occur in a crash. Strength requirements for seat belt anchorages are found in S4.2 of the Standard. These requirements specify that seat belt anchorages must withstand a certain amount of force when tested in accordance with procedures found in S5. As you point out in your message, S4.2.3 of Standard No. 210 indicates that deformation of a seat belt anchorage or the surrounding area is not considered to be a failure if the forces required by S4.2.1 are maintained for a specified time. Therefore, Standard No. 210 anticipates that some deformation of an anchorage or the nearby structure is likely when an anchorage is subjected to the loads it would be exposed to in a crash. Such deformation may cause changes to the location or geometry of anchorages that complied with S4.3 prior to being tested for compliance with S4.2. NHTSA would not consider the post-test position of the anchorages to determine compliance with S4.3.

    I hope you find this information helpful. If you have any other questions, please contact Otto Matheke of my staff at this address or by phone at (202) 366-2992.

    Sincerely,

    John Womack
    Acting Chief Counsel

    ref:210
    d.1/17/02