Interpretation ID: nht72-3.39

DATE: 03/02/72

FROM: ELWOOD DRIVER FOR ROBERT L. CARTER -- NHTSA

TO: Lindburg Cadillac

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 16, 1972, to Secretary John Volpe, concerning the length of seat belts in a 1972 Cadillac automobile.

Federal Motor Vehicle Safety Standard No. 203, Occupant Crash Protection, copy enclosed, specifies requirements for occupant restaint systems. Effective January 1, 1972, car manufacturers are required to provide Type 2 belt assemblies (lap-shoulder belts) at the front outboard seating positions and lap belts at other positions. The Type 2 belt assemblies may have either integral or detachable shoulder belts, but the distance between the intersection of the lap-shoulder belt and the vertical counterline of a 50th-percentile adult male occupant must be at least six inches when the seat is in its rearmost position. The purpose of this requirement is to reduce the possibility of the shoulder belt pulling the lap belt up onto the occupant's abdomen where it could cause serious injury in a crash.

We have examined several 1972 model cars and have found that some manufacturers have chosen belt designs that provide distances of ten inches or more between the lap-shoulder belt intersection and the centerline of the occupant. The (Illegible Word) not prohibit distances greater than six inches, but it is obvious that the greater this distance, the closer the inboard end of the belt is to the seat and the more difficult it is to buckle the belt. I am happy to inform you that we have already initiated rule making action to amend Standard No. 208 that would prohibit such excessive distances.

Under the requirements of the National Motor Vehicle and Traffic Safety Act, copy enclosed, it is a violation of the law to sell a vehicle that does not conform to an applicable standard. Although the Act does not prevent the purchaser of a vehicle from altering or removing a safety device, after he has completed the purchase, we strongly advise him against such action. A dealer who perform such services after he has sold the vehicle does not violate the law, but he does his customer a disservice.

In regard to the belts in the Cadillac you sold to Mr. and Mrs. T. Albert McCulley, we do not have the authority to grant or deny you permission to lengthen the inboard end of the belt. We can only suggest that perhaps you could lengthen the belt only to the extent that is necessary to provide a distance of not less than six inches between the interraction of the lap-shoulder belt and the centerline of a 50th-percencile adult (Illegible Word) occupant measured in accordance with paragraph s7.1.2 of Standard No. 206.

Thank you for your interest in motor vehicle safety. If we can be of further assistance, please do not hesitate to contact us.

Sincerely, LINDBURG CADILLAC

February 16, 1972

Honorable John Volpe Secretary of Transportation U. S. Dept. of Transportation

Dear Mr. Volpe:

Recently we delivered a new 1972 Cadillac S/N6D47R2Q-194774 to Mr. and Mrs, T. Albert McCulley, 434 Sherwood Forest, Belleville, Illinois 02225 fitted with the new seat belt warning system.

The center buckle section is so short that Mr. and Mrs. McCulley experienced difficulty in fastening the outside section to the center section. We have inquired from Cadillac the possibilities of lengthening the center buckle sections approximately eight inches which would still leave the warning system in operation and would greatly facilitate the fastening, put Cadillac informs us that the installation is strictly according to federal regulations and cannot be changed.

Would you grant us permission to add eight inches to the center buckle section for this particular vehicle?

VERY TRULY YOURS,

George A. Maty Vice President and Sales Manager.

CC: MR. AND MRS. T. ALBERT MCCULLEY; SEN. STUART SYMINGTON; SEN.THOMAS EAGLETON; REP. MELVIN PRICE