Interpretation ID: aiam1364
Director/General Manager
Factory Representative Office
Toyota Motor Sales
U.S.A.
Inc.
1099 Wall Street
West
Lyndhurst
NJ 07071;
Dear Mr. Nakajima: This responds to your December 17, 1973, letter to the Administrator o the National Highway Traffic Safety Administration, asking whether a 'sling' attachment of the upper end of an upper torso restraint to the roof rail is subject to Standard 210's requirements for seat belt anchorage location.; The ring, webbing, and attachment hardware you describe functio together as a seat belt anchorage and as such are subject to the appropriate strength and location requirements of Standard 210. Because the location requirement of S4.3.2 is intended to strictly limit the placement of the fixed point from which a belt passes across an occupant's torso, and because the flexible portion of your sling anchorage duplicates the uninterrupted deployment of an upper torso restraint, only the fixed portion of such a sling anchorage would be subject to S4.3.2's location requirement.; Yours truly, Richard B. Dyson, Assistant Chief Counsel