Interpretation ID: nht73-6.18

DATE: 03/02/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Ford Motor Company

COPYEE: J. G. WOMACK; MR. TOMS; MR. HARTMAN; MR. CARTER

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 16, 1973, concerning the safety standard applicable to the sling for the upper torso belt used in Ford's 1974 model restraint system.

The schematic drawing attached to your letter shows that the sling attaches to the roof rail and serves the function of an upper torso belt anchorage. We agree with you that the sling is subject to the requirements of Standard No. 210 and not to the requirements of Standard No. 209. Although the sling is made of fabric webbing, its function is that of an anchorage and it is therefore subject to the anchorage standard.

Yours truly,

Ford Motor Company

February 16, 1973

Douglas W. Toms Administrator National Highway Traffic Safety Administration

Dear Mr. Toms:

An inquiry has been raised by certain of our suppliers with regard to one feature of Ford's 1974 model year restraint system. Ford believes an interpretative statement by the Administration would be desirable to resolve questions that now exist, or may in the future arise, with regard to this type of item.

The attached schematic shows a typical 1974 Ford restraint system. The non-detachable upper torso portion of the restraint system is looped through a "sling" attached to the roof rail of the vehicle. The "sling" is depicted in more detail in View-A of the attached drawing.

This sling is an an anchorage for purposes of Standard No. 210 for several reasons. First, Standard No. 210 defines a seat belt anchorage as the provision for transferring seat belt assembly loads to the vehicle structure. The sling clearly serves this function. Second, as the sling location determines the angle at which the upper torso restraint crosses the occupant's chest, the sling would fall within the acceptable range for upper torso anchorage locations specified in Standard No. 210.

As we have chosen to use webbing in the sling (as opposed to a cable or some such material), the concern expressed involves the question as to whether a potential conflict could arise in interpreting what requirements this sling must meet. If the sling were to be considered by an independent testing laboratory to be part of the seat belt assembly as defined in Standard No. 209, it would apply the

webbing requirements set forth in Section S4.2 of Standard No. 209 to the sling webbing. We would urge that it should not be necessary to meet these webbing requirements as the sling is part of the anchorage and meets the strength requirements of Standard No. 210.

We request, therefore, that the Administration concur in Ford's interpretation that the sling as depicted in the attached schematic is a part of the anchorage and not a part of the seat belt assembly.

Respectfully submitted,

J. C. ECKHOLD

Director

Automotive Safety Office

Attachment

(Graphics omitted)

(Graphics omitted)

FORD-MERCUPY MODEL 65 SHOWN

TORINO-MONTEGO-COUGAR

T-BIRD-MARK IV-LINCOLN

MODELS 65 TYPICAL