Interpretation ID: aiam2459
Manager - Safety Engineering
BMW of North America
Inc.
Montvale
NJ 07645;
Dear Mr. Ziwica: THis is in response to your October 29, 1976, request for confirmatio that a recent NHTSA interpretation regarding the buckle crush requirements of Standard No. 209 (as stated in a letter to Volvo dated August 31, 1976) is applicable to BMW seat belt buckles.; Our letter to Volvo stated that the existing S4.3(d)(3) buckl requirements are not applicable to buckles that are located between bucket seats and attached to the console or to the end of a rigid cable or bar.' This interpretation constitutes an explanation of S4.3(d)(3) as its provisions apply to all seat belt buckles regulated by the standard. The interpretation is not applicable only to Volvo belt buckles or to buckles produced by any other individual manufacturer. It is the responsibility of each manufacturer to determine, in the first instance, whether or not his products fall within any standard's provisions, including provisions that are explained by means of an interpretation.; I am enclosing a copy of our August 31, 1976, letter to Volvo for you information. As requested, we have withdrawn your petition for rulemaking.; Sincerely, Frank A. Berndt, Acting Chief Counsel