Interpretation ID: 3273yy
Brand & Lowell
923 Fifteenth Street, NW
Washington, DC 20005
Dear Ms. Russell:
This responds to your letter of October 24, 1991, concerning Safety Standard No. 210, Seat Belt Assembly Anchorages. You stated that Glaval Corporation, which you represent, recently notified NHTSA of its intention to conduct a notification and remedy campaign to respond to "an apparent noncompliance with the safety belt anchorage strength requirements as they apply to the rear bench seat in Glaval vans." According to your letter, these seats contain three designated seating positions, and each seat belt anchorage is "mounted on the seat, not the floor." You stated that in the course of evaluating potential remedies, you became aware of an April 9, 1990 interpretation letter sent by this agency to Mr. R.W. Schreyer of Transportation Manufacturing Corporation, in which the agency stated that only floor-mounted anchorages are subject to simultaneous testing. Because the Glaval van bench seat anchorages were tested simultaneously in NHTSA's compliance test, you asked the following questions:
1. Consistent with the Schreyer interpretation, should the seat-mounted anchorages of the Glaval bench seat have been loaded sequentially in NHTSA's test? If so, how does NHTSA's test on the Glaval bench seat, where the loads were applied simultaneously, affect NHTSA's tentative conclusion of noncompliance?
You are correct that, consistent with the Schreyer interpretation, only floor-mounted anchorages are subject to simultaneous testing under current requirements. However, based on our understanding of the Glaval design, and as discussed below, we consider the anchorages in the Glaval van to be floor-mounted. Therefore, the Schreyer interpretation is not relevant to whether the Glaval van is in compliance with Standard No. 210.
Based on photographs included in the Final Report of FMVSS 210 Compliance Testing of 1991 Glaval Van (Report No. 210-GTL-91-003), it appears that the seat belts are attached to a bar which runs along the floor behind the bench seat. The bar is directly mounted to floor brackets which run along each side of the seat.
Section S4.2 of Standard No. 210 specifies that floor-mounted seat belt anchorages for adjacent designated seating positions are simultaneously tested. The term "seat belt anchorage" is defined in section S3 as "the provision for transferring seat belt assembly loads to the vehicle structure."
In the design at issue, the seat belt anchorage, or provision for transferring seat belt assembly loads to the vehicle structure, includes the seat belt bar. Since the seat belt bar is mounted to the floor by means of the two brackets along the sides of the seat, the seat belt anchorage is "floor-mounted."
I note for your information that, on April 30, 1990, the agency published a final rule amending Standard No. 210 to, among other things, require simultaneous loading of all anchorages common to the same occupant seat. This amendment is effective on September 1, 1992.
2. Since Standard 207 requires simultaneous loading of the forces required by Standard 207 along with those required by Standard 210, does the Schreyer interpretation mean that, for a bench seat with seat-mounted anchorages, the proper loading for a test pursuant to FMVSS 207 should be 20 times the seat weight plus the proper load for one designated seating position on the bench seat?
Your understanding of the Standard No. 207 test is correct.
I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992.
Sincerely,
Paul Jackson Rice Chief Counsel ref:207, 210 d:1/14/92