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Interpretation ID: 86-6.1

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Francois Louis -- Governmental Affairs Director, Renault USA

TITLE: FMVSS INTERPRETATION

ATTACHMT: 10/13/88 letter from Erika Z. Jones to Paul Utans (Std. 208); 8/11/88 letter from Paul Utans to Erika Z. Jones (occ 2405); 8/18/78 letter from Joseph J. Levin to D. Black (Std. 210)

TEXT:

Mr. Francis Louis Governmental Affairs Director Renault USA 1111 19th Street, NW Suite 1000 Washington, DC 20036

Thank you for your letter of October 17, 1986, to Dr. Richard Strombotne of this agency concerning Standard No. 208, Occupant Crash Protection. Your letter was referred to this office for reply. You have asked a number of questions concerning how the requirements of the standard apply to the automatic restraint system Renault intends to use in one of its vehicles. The answers to your questions are discussed below.

You explained that Renault plans to use, at both front outboard seating positions, an automatic restraint system consisting of a motorized, detachable, two-point automatic belt and a knee bolster. You stated that the automatic restraint system meets all the Injury criteria of the standard when tested in the 30 mile per hour frontal barrier test of S5.1 of the standard. You also explained that Renault has decided to install voluntarily a manual lap belt with your automatic restraint system. You further stated that the addition of the manual lap belt does not affect the performance of the automatic restraint system, since your testing shows that the automatic restraint system can meet the injury criteria in a 30 mile per hour frontal barrier crash test both with and without the manual lap belt fastened.

As I understand your first question, you are, in essence, asking the agency to confirm that under S4.5.3 of the standard an automatic belt system with a single diagonal torso belt can be used to meet the frontal crash protection requirements of S4.1.2.1(a) and can also be substituted for a Type 1 or Type 2 safety belt to meet the requirements of S4.1.2.1(c)(2). As provided in S4.5.3 of the standard, an automatic safety belt system can be "used to meet the crash protection requirements of any option under S4 and in place of any seat belt assembly otherwise required by that option." Thus, you are correct that an automatic safety belt can be substituted for the Type 1 or Type 2 safety belt otherwise required by S4.1.2.1 (c)(2) of the standard. This means that a Renault vehicle equipped with an automatic safety belt would not be subjected to the lateral crash test of S5.2 or the dynamic rollover test of S5.3.

Your second and final question concerned how our safety standards, in particular Standard No. 210, Seat Belt Assembly Anchorages, would apply to a manual lap belt voluntarily installed by manufacturers with an automatic safety belt system. In a March 1, 1979 letter to Ford Motor Company, NHTSA stated that "active lap belts and their associated anchorages are not required to comply with Federal safety standards if installed voluntarily by a manufacturer in addition to a single, diagonal passive belt." In responding to Ford, NHTSA also noted that in past interpretations the agency has stated that "systems or components installed in addition to required safety systems are not required to meet Federal safety standards, provided the additional components or systems do not destroy the ability of required systems (the passive belt in this case) to comply with Federal safety systems." In Renault's case, the addition of the manual lap belt does not appear to affect the automatic safety belt, since you stated that Renault can meet the frontal crash protection requirements of Standard No. 208 both with and without the manual lap belt fastened.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

October 17, 1986

Dr. Richard Strombotne Office of Vehicle Safety Standards National Highway Transportation Safety Administration Room 5320 400 Seventh Street, SW Washington, DC 20590

Reference: FMVSS 208 - Request for Interpretation

Dear Dr. Strombotne:

As of September 1, 1987, Renault intends to sell on the US market a vehicle equipped with a passive restraint system at both front out-board seating positions consisting of:

- a motorized detachable thoracic diagonal belt, with a 2-point anchorage on the body of the vehicle, and - a knee bolster.

As required by Standard 208, all injury criteria are satisfied when the vehicle is tested in accordance with S.5.1.

Since a webbing is an integral part of our passive protection device, S.4.5.3 is applicable. We interpret S.4.5.3 to say that "the torso webbing offers a similar level of protection in lateral/rollover crashes as does a single lap belt mounted in conjunction with the knee bolster".

In other words, this means that "in passive systems including a knee bolster, a webbing that is exclusively pelvic or the addition of a lap belt to the existing torso belt would not appreciably upgrade the quality of protection that is offered to the occupants in lateral/rollover crashes by a purely thoracic webbing".

We voluntarily chose to comply with S4.1.2.1.c.2 of Standard 208, that is. to furnish a lap belt, so that compliance with the lateral/ rollover test requirements would not be necessary. Consequently, the upper webbing is no less efficient than a lap belt. Therefore, we are not obligated to provide a lap belt at all, and if we do, it is purely on a non-compulsory basis (this obviously does not apply to air bags when no torso webbing is supplied). However, in order to cover the widest range of crash situations, we decided to offer a seat-mounted lap belt anyway. The requirements of S.5.1 are still met with or with- out that additional belt. As our lap belt is not compulsory, it is installed voluntarily, and thus does not have to comply with any other requirement.

Could you please confirm to us that our interpretation as stated here is correct in its entirety? If it is incorrect, how are we to interpret S.4.5.3 properly and what requirements then apply to our active lap belt? In particular, what loads and location requirements have to be considered in order to meet FMVSS 210?

Thank you in advance for your response to these questions.

Sincerely,

Francois Louis Governmental Affairs Director Washington, DC