Interpretation ID: aiam4150
Director
U.S. Engineering Office
Alfa Romeo
250 Sylvan Avenue
Englewood Cliffs
NJ 07632;
Dear Mr. Black: Thank you for your letter of March 24, 1986, to former Chief Counse Jeffrey R. Miller about the requirements of Standard No. 208, *Occupant Crash Protection*. You explained that Alfa Romeo intends to install automatic safety belts in its two seat convertible model and asked how the requirements of Standard No. 208 apply to such an automatic crash protection. In essence, all of your questions concern whether an automatic belt system can be substituted for a Type 1 or Type 2 safety belt system under 4.1.2.1(c)(2) of the standard. The answer is yes, and automatic safety belt can be used to meet the frontal crash protection requirements of S4.1.2.1(a) and can also be substituted for a Type 1 or Type 2 safety belt to meet the requirements of S4.1.2.1(c)(2).; As provided in S4.5.3 of the standard, an automatic safety belt syste can be 'used to meet the crash protection requirements of any option under S4 and in place of any seat assembly otherwise required by that option.' Thus, an automatic safety belt can be substituted for a Type 1 or Type 2 belt system under S4.1.2.1(c)(2). Therefore, an Alfa Romeo convertible equipped with an automatic safety belt would not be subjected to the lateral crash test of S5.2 or the dynamic rollover test of S5.3.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel