Interpretation ID: aiam2847
Manager
Alfa Romeo
Inc.
250 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Black: This responds to your recent letter concerning Alfa Romeo's propose designs for Type 2 seat belt assemblies to be used on convertibles. You ask for clarification of the anchorage location requirements specified in Safety Standard No. 210, as they would apply to your proposed designs.; Paragraph S4.1.1 of Safety Standard No. 210, *Seat Belt Assembl Anchorages*, specifies that anchorages for a Type 2 belt shall be installed for each forward-facing outboard designated seating position in passenger cars *other than convertibles*. Manufacturers are permitted to install Type 2 belts in convertibles, however, under paragraph S4.1.2 of the standard which specifies that either a Type 1 or Type 2 belt may be installed for designated seating positions not required to have Type 2 belts under the previous section.; Since convertibles are only required to have Type 1 belts, only th pelvic portion of your proposed Type 2 designs must meet the anchorage location requirements of the standard. These location requirements are specified in S4.3.1, and the pelvic portion of your two proposed designs (Figures 2 and 3 in your letter) appear to fall within the 20 degree - 75 degree acceptable range. The upper torso portions of the belt designs do not have to comply with the 40 degree acceptable range specified in S4.3.2, since those portions are in addition to what is required by the standard.; In response to your general question, 'seat belt anchorage' is define in Standard No. 210 as the 'provision for transferring seat belt assembly loads to the vehicle structure.' For purposes of determining compliance with the anchorage location requirements of the standard, the agency interprets anchorage to include any load-bearing element of the seat belt assembly that is capable of meeting the force requirements of Standard No. 210. For example, in your Figure 1 you state that the lap belt is anchored 'at point 'C' within the 40 degree zone and then passes through a webbing guide anchorage.' The 40 degree zone is not the applicable location requirement for lap belts and if this were the only anchorage, the belt would not comply with the standard. However, since the 'webbing guide anchorage' appears to be within the applicable 20 degree - 75 degree zone, the belt would be in compliance if that anchorage is capable of meeting the force requirements of the standard. The agency considers an assembly to be in compliance if there is one force-complying anchorage within the acceptable ranges specified in the standard, and that anchorage is determinative of the angle the belt crosses the vehicle occupant.; To summarize, both of your proposed Type 2 seat belt assemblies woul comply with the location requirements of Standard No. 210 if used in convertibles, since only the pelvic portions of the assemblies would have to meet the requirements of the standard and the anchorages for those portions appear to be within the acceptable ranges. Further, either assembly design can be used in hard- top automobiles if it has one anchorage capable of meeting the force requirements of the standard that is located in the 40 degree acceptable range for upper torso portions of Type 2 belts.; Please contact Hugh Oates of this office if you have any furthe questions concerning this subject (202-426-2992).; Sincerely, Joseph J. Levin, Jr., Chief Counsel