Interpretation ID: aiam0753
Nissan Motor Co.
Ltd.
560 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Nishibori: This is in reply to your letter of June 21, 1972, in which yo requested our interpretation of the phrase in S4.3.1.3 of Motor Vehicle Safety Standard No. 210 which states that the angle of the belt is to be measured from the seating reference point to the 'nearest contact point of the belt with the hardware attaching it to the anchorage'.; The language in question was adopted in response to petitions fo reconsideration of the amended rule as published in 1970 (35 F.R. 15293, 35 F.R. 18116). Several petitioners had stated that measuring the angle from the seating reference point to the anchorage, as the standard then specified, would not accurately reflect the true angle of the belt because of the intervention of rigid attachment hardware between the anchorage and the webbing. The section was therefore amended to refer to the point at which the belt touched such attachment hardware.; In the diagram which you provide of a seat belt system in which th buckle is attached to the seat by means of a rigid bracket, we would consider the buckle itself to be a part of the attaching hardware. The contact point would therefore lie on the interface between the tongue and the buckle at the point nearest the seating reference point.; It does not appear from Figures 2 and 3 of your letter that any of th designated angles correspond exactly to the angle that should be measured under S4.3.1.3. In both figures the angle would be determined by the line between the reference point and the nearest point to it on the forward end of the buckle.; Please advise us if you have further questions on this point. Sincerely, Richard B. Dyson, Assistant Chief Counsel