Interpretation ID: nht71-5.9

DATE: 12/01/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Penn-Ohio Chapter

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of November 23, 1971, you asked how your members could make sure that the seat belts they install in their trucks conform to the applicable motor vehicle safety standards. As far as the belts themselves are concerned, each belt made after the seat belt standard (No. 209) became effective in 1967 is required to marked with the year of manufacture. So long as the belt bears a date after 1967, it will have had to conform to the seat belt standard and your members should use the date as a guide in purchasing belts.

The provision of anchorages for the belts is a somewhat more complex problem. A new truck - manufactured after July 1, 1971 is required to have anchorages for lap belts at all seating positions (and, in some cases, anchorages for shoulder belts). Although older trucks were sometimes provided with anchorages, many were not, and for these you will have to follow the location and instructions of Standard No. 210 in order to comply with the Motor Carrier Safety Regulations. Although the Motor Carrier Safety Regulations do not establish strength requirements for anchorages, their strength should be of concern to you and in this area you may have to rely on the manufacturer, rather than the dealer, for advice on reinforcement of the vehicle structure.

Our legal staff is centralized in Washington and there are no field representatives of the agency who could assist you in matters relating to the standards. As much as we would like to send someone to address your group, the workload of the upcoming

months prevents such a trip. However, we have found that many questions can be satisfactorily answered by letter. If your group could assemble a detailed list of questions, we will try to answer them as fully as possible.