Interpretation ID: nht94-2.60

TYPE: Interpretation-NHTSA

DATE: April 26, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Michael E. Klima -- Managing Engineer, Failure Analysis Associates, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 3/29/94 from Michael E. Klima to Edward Jettner (OCC-9832)

TEXT:

This responds to your letter of March 29, 1994, to Mr. Edward Jettner of this agency concerning the dynamic testing requirements of Standard No. 208, Occupant Crash Protection. Your questions concern the application of this standard to a pickup truck ma nufactured in April 1988 with a gross vehicle weight rating (GVWR) of 4,400 pounds. You asked whether the injury criteria in S6 apply to this truck, whether a 35 mph fixed barrier crash test is required, and which sections of Standard No. 208 apply to t his truck.

The safety belt installation requirements for all vehicle types are set forth in Standard No. 208. Section S4.2.1 of standard No. 208 gives vehicle manufacturers a choice of three options for providing occupant crash protection in trucks and multipurpos e passenger vehicles with a GVWR of 10,000 pounds or less, manufactured on or after January 1, 1976 and before September 1, 1991. Option 1, set forth in S4.1.2.1, requires vehicle manufacturers to provide automatic protection at the front outboard seati ng positions, and either meet the lateral crash protection and rollover requirements by means of automatic protection systems or have manual safety belts at the front outboard seating positions such that those positions comply with the occupant protectio n requirements when occupants are protected by both the safety belts and the automatic protection. Option 2, set forth in S4.1.2.2, requires vehicle manufacturers to provide a lap or lap/shoulder safety belt at every seating position, have automatic prot ection for the front outboard seats, and have a warning system for the safety belts provided. Option 3, set forth in S4.1.2.3, requires the manufacturer to install lap or lap/shoulder safety belts at every seating position and to have a warning system f or those belts.

According to your letter, the manufacturer installed Type 2 seat belt assemblies at the front outboard seating positions. This suggests that the manufacturer chose to comply with Option 3. Under this option, the only requirements in Standard No. 208 th at those belts were required to comply with were S7.1, S7.2, and S7.3. The belts were also required to comply with the requirements of Standard No. 209, Seat Belt Assemblies. The manufacturer was not required to certify that the vehicle complied with t he dynamic testing requirements of Standard No. 208. The injury criteria in S6 of the standard are applicable only to vehicles which must comply with the dynamic testing requirements.

Standards No. 208 does not include a 35 mph fixed barrier crash test requirement. The dynamic crash test in Standard No. 208 is barrier crash test at any speed up to 30 mph. NHTSA does perform some 35 mph barrier

crash tests as part of the New Car Assessment Program (NCAP). NCAP is a consumer information program, not a safety compliance test. NHTSA does not test every vehicle under this program. In the 1993 model year program, NHTSA tested 37 new vehicles and released results on 68 additional vehicles which had been tested previously and had not changed significantly in model year 1993.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.