Interpretation ID: aiam4102
P.E.
Manager
Regulatory Affairs
Volvo Cars of North America
Rockleigh
NJ 07647;
Dear Mr. Shapiro: Thank you for your letter of November 14, 1985, requesting a interpretation of Standard No. 210, *Seat Belt Assembly Anchorages*. You explained that Volvo is planning to voluntarily add an extra anchorage for a Type 2 safety belt in the middle rear designated seating position, which is already equipped with two anchorages for a Type 1 safety belt. You asked whether the third anchorage point would have to meet the anchorage location requirements set forth in S4.3.2 of the standard. As explained below, the additional anchorage would not have to comply with the location requirements of the standard.; As you correctly pointed out, S4.1.2 allows manufacturers the option o installing anchorages for either a Type 1 or Type 2 safety belt at the center rear designated seating position. Thus, by providing anchorages for a Type 1 belt at that seating position, Volvo has met the installation requirement of S4.1.2. The agency has stated in past interpretations, such as in a March 1, 1979 letter to Ford, that systems or components installed in addition to required safety systems are not required to meet Federal safety standards, provided the additional components or systems do not destroy the ability of required systems to comply with the standards. Thus, you may install a third anchorage if it does not affect the ability of the required anchorages to meet the standard.; Sincerely, Erika Z. Jones, Chief Counsel