Interpretation ID: aiam4052
Director Mobility Assistance Program
Executive Office of Transportation and Construction
Commonwealth of Massachusetts
10 Park Plaza
Room 3510
Boston
MA 02116- 3969;
Dear Mr. Thatcher: Thank you for your letter of October 3, 1986, to NHTSA Regiona Administrator Jack Connors requesting an interpretation of Standard No. 210, *Seat Belt Assembly Anchorages*. Your letter was referred to my office for reply.; You explained that you are in the process of buying a number of van which will be outfitted with Republic Seating Corporation's Model D117 seats. You stated that questions have been raised about whether the safety belt placement on those seats complies with our standard. You enclosed a quarter-scale diagram of the seat in question showing the location of the safety belts and asked our opinion about whether the safety belt placement complies with our standard.; Under the National Traffic and Motor Vehicle Safety Act, which thi agency enforces, it is the responsibility of a vehicle manufacturer to certify that its products comply with the requirements of our standards. This agency does not have the authority to approve a manufacturer's design plans. We can offer our opinion, but it is the manufacturer's obligation to ensure that the finished vehicle complies with all of the applicable standards.; The standard which affects the mounting angle for safety belts i Standard No. 210, *Seat Belt Assembly Anchorages*. The drawing enclosed with your letters shows that the lap safety belt anchorage for this seat is installed on the frame of the seat. S4.3.1.3 of the standard provides:; >>>In an installation in which the seat belt anchorage is on the sea structure, the line from the seating reference point to the nearest contact point of the belt with the hardware attaching it to the anchorage shall extend forward from that contact point at an angle with the horizontal of not less than 20 degrees and not more than 75 degrees.<<<; According to the drawing enclosed with your letter, the line from th seating reference point to the nearest contact point of the safety belt, on the outboard side of the seat, with the hardware attaching it to the anchorage is 75 degrees. If the outboard portion of the safety belt is installed in a completed vehicle in the location shown in the drawing it would meet the requirement of S4.3.1.3, since its mounting angle is not more than 75 degrees.; We cannot offer an opinion as to whether the inboard portion of th safety belt would comply with S4.3.1.3, since the mounting angle for that portion of the safety belt is not depicted in the drawing. I want to emphasize again, that this letter represents the opinion of the agency based on the facts you have presented. It is a manufacturer's responsibility under the Vehicle Safety Act to certify that its completed vehicle complies with our standard.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel