Interpretation ID: aiam4955
Esquire Margolis
Sakayan & Holtz 915 Fifteenth St.
N.W. Tenth Floor Washington
D.C. 20005-2302;
"Dear Mr. Russo: This responds to your letter seeking an interpretatio of Standard No. 210, Seat Belt Assembly Anchorages (49 CFR 571.210). Specifically, you were interested in the requirement in S4.1 that 'seat belt anchorages' for particular types of seat belts shall be installed at particular seating positions. You asked for an explanation of precisely what this requirement obliges a vehicle manufacturer to do. The term 'seat belt anchorage' is defined in S3 of Standard No. 210 as 'the provision for transferring seat belt assembly loads to the vehicle structure.' When S4.1 of Standard No. 210 requires a 'seat belt anchorage' for a seat belt to be installed at a given seating position, the manufacturer must provide a point or points for that seating position that comply with the strength requirements of S4.2 applicable to that type of anchorage and with the location requirements of S4.3 applicable to that type of anchorage. The designated point may simply be a point on the vehicle structure (floor, sides, or roof), or a point on the seat itself, for instance. The point designated by the vehicle manufacturer in response to the requirement in S4.1 need not be a prepunched or prethreaded hole, it need not be visible, and it need not include the anchorage hardware. If the agency were seeking to impose these additional conditions on anchorages, it would have included specific language to that effect in the standard. See, for example, the proposal to amend Standard No. 210 at 45 FR 81625, December 11, 1980. When these additional conditions are not expressly set forth in the text of the standard, they are not required to be included as part of the anchorage at that seating position. I hope this information is helpful. If you have any further questions or need some additional information on this subject, feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure";