Interpretation ID: nht71-5.28

DATE: 12/23/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of July 2, 1971, points out an apparent conflict within the upper torso seat belt anchorage location requirement of standard No. 210. The conflict is between the provision of S4.3.2 that the range of permissible locations is established with the seat back in its most upright position and the provision that the 2 dimensional manikin shall have its "H" point on the seating reference point. The manikin's "H" point may not be capable of being positioned on the seating reference point if the manufacturer has used a "nominal design riding position" other than the "most upright position" in establishing the seating reference point.

We agree that the conflict exists and intend to eliminate it by appropriate amendment in the Federal Register.

We will advise you upon issuance of the amendment.