Interpretation ID: aiam4033
Esq.
Dean Hansell
Esq.
Donovan
Leisure
Newton & Irvine
333 South Grand Avenue
Los Angeles
CA 90071;
Dear Mr. Waimey and Mr. Hansell: Thank you for your letter of September 12, 1985, concerning th applicability of S7.4.5 of Standard No. 208, *Occupant Crash Protection*, to manual Type 2 safety belts in passenger cars. As explained below, S7.4.5 is not currently applicable to manual Type 2 belt systems in passenger cars. However, as a result of a recent amendment to Standard No. 208, the comfort and convenience requirements of the standard will be applied to manual Type 2 belt systems in passenger cars, beginning on September 1, 1989, if the automatic restraint requirements are rescinded.; As you pointed out, S7.4(b) of Standard No. 208 requires vehicles wit gross vehicle weight ratings of 10,000 pounds or less to meet the comfort and convenience requirements of the standard, including the requirements of S7.4.5. However, S7.4(b) specifically excludes manual Type 2 safety belts installed in the front seats of passenger cars from the comfort and convenience requirements. Thus, you are correct that a manual Type 2 safety belt installed in the front outboard seating position of a passenger car currently does not have to meet the requirements of S7.4.5.; In April of this year, the agency issued a notice of propose rulemaking (50 FR 14580) proposing that if the automatic restraint requirements of Standard No. 208 are rescinded for passenger cars, then manual Type 2 safety belt systems in those vehicles would have to meet all of the comfort and convenience requirements, including the requirement of S7.4.5, beginning on September 1, 1989. On November 6, 1985 (50 FR 46056), the agency issued a final rule adopting that requirement.; I hope this information is of assistance to you. If you have furthe questions, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel