Interpretation ID: nht87-2.94

TYPE: INTERPRETATION-NHTSA

DATE: 09/17/87

FROM: WILLIAM E. LAWLER -- INDIANA MILLS AND MANUFACTURING INC

TO: ERICA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 10/14/88 TO WILLIAM E. LAWLER FROM ERIKA Z JONES, REDBOOK A32, STANDARD 208, STANDARD 209

TEXT: Dear Chief Counsel:

We are writing to you to request an official interpretation of portions of FMVSS 208 and 209 with regard to a Type 2 Seat Belt Assembly designed by a customer and ordered by him for installation at a static (non-suspension) driver's seat in a vehicle wit h a GVWR exceeding 10,000 pounds.

The proposed seat belt assembly incorporates an automatic locking retractor to be mounted at the left of the driver's seat and a free-sliding latchplate engineered to remain in view and easy reach when not in use. The webbing is continuous from the retr actor to the anchored end of the upper torso restraint which would be installed above, slightly behind and to the side of the seat occupant. The strengths of all components and the strength of the assembly itself comply with FMVSS 209.

The latter half of 49CFR 571.209 S5.2(i) deals with automatic-locking retractors and their tendency to cinch the seat belt assembly webbing against the occupant while riding on rough roads. In addition, 49 CFR 571.208 S4.2.2, S4.1.2.3, and S7.1, though dealing with lighter vehicles, seem to imply the intent of minimal upper torso restriction. These sections of FMVSS 208 and 209 have been discussed with our customer.

In our opinion, two modifications to the customer's design will convert the continuous webbing feature into separate lap belt and upper torso restraints which will allow his proposed design to comply with the sections of FMVSS 208 and 209 referenced abov e: 1. sew the latchplate to the webbing at a specified location in order to create a standard lap belt 2. place a manual adjusting device in the upper torso restraint.

Our customer has agreed to postpone the order on his original design and use the option we are suggesting until we have received an official opinion from The National Highway Traffic Safety Administration.

If you have further questions, please contact me.

Sincerely,

ATTACHMENT

[DRAWING OMITTED] ALR, 3PT. SYSTEM