Interpretation ID: aiam4140
Executive Vice President & Chief Operating Officer
Nissan Research & Development
Inc.
P.O. Box 8650
Ann Arbor
MI 48104;
Dear Mr. Maeda: Thank you for your letter of April 11, 1986, requesting a interpretation of the comfort and convenience requirements of Standard No. 208, *Occupant Crash Protection*. Your specific question is whether the retraction requirements of S7.4.5 of the standard apply only to the front outboard seating positions. As explained below, the answer is yes.; The April 12, 1985 notice proposed changes to the comfort an convenience requirements in response to petitions for reconsideration. In the case of the retraction requirements, the proposed language of S7.4.5 said that the requirement would only apply to a safety belt system installed at the 'front outboard designated seating position.' In the November 6, 1985 final rule adopting the retraction requirement, the agency dropped the reference to the 'front outboard seating position.' However, S7.4.5 still referred to conducting a compliance test on a test dummy which has been positioned 'in accordance with S10.' S10, in turn, references the test dummy positioning requirements of S8.1.11. S8.1.11.1 and S8.1.11.2 provide for positioning test dummies in the front outboard seating positions. Thus, the minor change in the language of the requirements did not change the applicability of the requirement. However, to eliminate any possible ambiguity about the application of the retraction requirement, the agency is planning to amend S7.4.5 to provide explicitly that it only applies to the front outboard designated seating positions.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel