Interpretation ID: nht92-6.50

DATE: May 18, 1992

FROM: William E. Lawler -- Manager, Specifications, Indiana Mills & Manufacturing, Inc.

TO: Mary Versailles -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7/23/92 from Paul J. Rice to William E. Lawler (A39; Std. 210)

TEXT:

Thank you for taking the time this afternoon to discuss some of the questions surrounding the inclusion of seat belt attachment hardware in the test requirements of FMVSS 210, "Seat Belt Assembly Anchorages". At your suggestion, we are submitting some questions to you for clarification so we can give appropriate guidance to our customers, the heavy truck OEM's as to how the FMVSS 210 test is to be performed and interpreted.

1. RETRACTOR FRAMES

a. If a test harness is used, can one end of the harness be attached to the attachment hardware (retractor frame), or must it be attached to the retractor spool?

b. If the harness must be attached to the spool, may it be attached around the spool as opposed to being inserted into the spool?

See Figure 1 (attached).

c. We assume it is the intent of the agency to test only the strength of the attachment hardware--not the locking mechanism of the retractor built in accordance with FMVSS 209.

2. BUCKLE ATTACHMENT

a. A commonly used design is the "cable buckle". The buckle assembly is positioned in convenient reach of the seat occupant by attaching the buckle to a cable by a method called swaging. The attachment hardware consists of a flat end containing a hole for an attaching bolt and a ferrule which is swaged to the cable. The ferrule and the flat end are made in one piece. See Figure 2 (attached).

Please confirm that the attachment ferrule bolted to the seat/ vehicle is what is required to withstand the forces dictated by FMVSS 210; separation of the cable from the ferrule would constitute malfunction of the test harness and not non-compliance to FMVSS 210.

b. Please confirm that the test harness could delete the buckle mechanism and attach directly to the upper end of the cable in the cable/ferrule assembly.

We appreciate your help in clarifying the interpretation of the standard with regard to these questions. As we discussed, we would appreciate receiving your answer by fax to save time.

Thank you for your help.

(Drawings omitted)