Interpretation ID: aiam4231
Governmental Affairs Director
Renault USA
1111 19th Street
NW Suite 1000
Washington
DC 20036;
Dear Mr. Louis: Thank you for your letter of October 17, 1986, to Dr. Richar Strombotne of this agency concerning Standard No. 208, *Occupant Crash Protection*. Your letter was referred to this office for reply. You have asked a number of questions concerning how the requirements of the standard apply to the automatic restraint system Renault intends to use in one of its vehicles. The answers to your questions are discussed below.; You explained that Renault plans to use, at both front outboard seatin positions, an automatic restraint system consisting of a motorized, detachable, two-point automatic belt and knee bolster. You stated that the automatic restraint system meets all the injury criteria of the standard when tested in the 30 mile per hour frontal barrier test of S5.1 of the standard. You also explained that Renault has decided to install voluntarily a manual lap belt with your automatic restraint system. You further stated that the addition of the manual lap belt does not affect the performance of the automatic restraint system, since your testing shows that the automatic restraint system can meet the injury criteria in a 30 mile per hour frontal barrier crash test both with and without the manual lap belt fastened.; As I understand your first question, you are, in essence, asking th agency to confirm that under S4.5.3 of the standard an automatic belt system with a single diagonal torso belt can be used in meeting the front 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 system can be 'used to meet the crash protection requirements of any option under S4 and in place of any seat belt assembly otherwise required by that option.' Thus, you are correct that an automatic safety belt can be substituted for the Type 1 or Type 2 safety belt otherwise required by S4.1.2.1(c)(2) of the standard. This means that a Renault vehicle 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.; Your second and final question concerned how our safety standards, i particular Standard No. 210, *Seat Belt Assembly Anchorages*, would apply to a manual lap belt voluntarily installed by manufacturers with an automatic safety belt system. In a March 1, 1979 letter to Ford Motor Company, NHTSA stated that 'active lap belts and their associated anchorages are not required to comply with Federal safety standards if installed voluntarily by a manufacturer in addition to a single, diagonal passive belt.' In responding to Ford, NHTSA also noted that in past interpretations the agency has stated 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 (the passive belt in this case) to comply with Federal safety systems.' In Renault's case, the addition of the manual lap belt does not appear to affect the automatic safety belt, since you stated that Renault can meet the frontal crash protection requirements of Standard No. 208 both with and without the manual lap belt fastened.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel