Interpretation ID: nht74-1.24

DATE: 01/16/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Toyota Motor Sales, U.S.A., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your December 17, 1973, letter to the Administrator of the National Highway Traffic Safety Administration, asking whether a "sling" attachment of the upper end of an upper torso restraint to the roof rail is subject to Standard 210's requirements for seat belt anchorage location.

The ring, webbing, and attachment hardware you describe function together as a seat belt anchorage and as such are subject to the appropriate strength and location requirements of Standard 210. Because the location requirement of S4.3.2 is intended to strictly limit the placement of the fixed point from which a belt passes across an occupant's torso, and because the flexible portion of your sling anchorage duplicates the uninterrupted deployment of an upper torso restraint, only the fixed portion of such a sling anchorage would be subject to S4.3.2's location requirements.

YOURS TRULY,

TOYOTA MOTOR SALES, U.S.A., INC.

December 17, 1973

James B. Gregory Administrator National Highway Traffic Safety Administration

Dear Dr. Gregory:

Attached is a drawing of one of the seat belt systems that we are considering using on some of our models in the near future.

Regarding the "sling" of this system, we interpret as follows:

If the sling is composed of a ring (A), fabric webbing (B), and attachment hardware (C) as depicted in the drawing, only the attachment hardware (C) is subject to the requirement of @ 4.3.2 which specifies that " . . . the seat belt anchorage for the upper end of the upper torso restraint shall be located within the acceptable range . . ." since the nature of the webbing allows the ring (A) and the fabric webbing (B) to move with reasonable freedom, thereby removing them from the (Illegible Word) of anchorage expected in @ 4.3.2.

We believe that our interpretation meets the intent of @ 4.3.2 of Standard 210, but we need the confirmation of the Administration before we start tooling for production.

Your consideration of the above will be greatly appreciated.

Keitaro Nakajima Director/General Manager Factory Representative Office

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