Interpretation ID: nht72-4.20

DATE: 02/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 7, 1972, in which you stated your understanding of how Standard 210 applies to two shoulder belt assembly configurations.

In Figure 1, you show a shoulder belt that passes through a slotted plate (A) bolted to the roof rail. Contrary to the impression you have received, the plate is not a part of the anchorage, but is rather a part of the seatbelt assembly. The anchorage consists of the reinforced roof rail structure, including the bolt hole and any retaining ridges or projections on the roof rail. Plates such as Hardware (A) that bolt onto the roof rail are similar in function to the floor mounted attachment plates that have always been considered as part of the seatbelt assembly, and are similarly treated.

The same remarks apply to the plate shown as (B) in Figure 2. This is also a part of the seatbelt assembly, and not part of the anchorage.

The anchorage strength test should be conducted as you show in Figure 3 and 4, using the complete Type 2 assembly provided with the vehicle.

We regret the misunderstanding about the classification of the attachment hardware and hope that it has not caused you inconvenience.

YOURS TRULY,

NISSAN MOTOR CO., LTD.

February 7, 1972

Lawrence Schneider National Highway Traffic Safety Administration

This is in confirmation of my discussion with Mr. Hunter and Mr. Hitchcock on February 2, 1972, regarding MVSS 210.

Through the above meeting, we understood the following:

1. In the case of Figure 1, the hardware (A) attached on the roof side rail should be treated as an upper torso seat belt anchorage.

2. In the case of Figure 2:

a. The hardware (B) should be treated the same as Figure 1.

b. The intermediate hardware (C) should not be treated as a seat belt anchorage, but handled as a hardware which must conform to MVSS 209 requirement.

3. Seat belt anchorage strength test should be conducted by using the actual Type 2 seat belt set including retractors, and hardware as described in Figure 3 and 4.

NISSAN MOTOR COMPANY, LTD.

Satoshi Nishibori Engineering Representative Liaison Office in U.S.A.

Fig 1

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Fig. 2

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FIG 3

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