Interpretation ID: nht95-1.44

TYPE: INTERPRETATION-NHTSA

DATE: February 2, 1995

FROM: Randal K. Busick -- President, Vehicle Science Corporation

TO: Mary Versailles, Esq. -- Office of the Chief Counsel, NHTSA

TITLE: Re: Request for interpretations of FMVSS 210

ATTACHMT: ATTACHED TO 4/3/95 LETTER FROM PHILIP R. RECHT TO RANDAL K. BUSICK (A43; STD. 210)

TEXT: Dear Ms Versailles:

This is to request a clarification of several aspects of FMVSS 210 location requirements

1. Section 4.3 states that "Anchorages that meet the frontal crash protection requirements of S5.1 of Standard No. 208 . . . . are exempt from the location requirements of this section."

In a Federal Register notice of December 5, 1991, the agency stated that: "Since a March 14, 1988 interpretation letter to Mr. Karl-Heinz Faber of Mercedes-Benz, the agency has considered a manual 3-point belt installed at a seating position equipped with an SIR system to be exempt from the location requirements of Standard No. 210 . . . . the agency is amending S4.3 to clarify, consistent with agency interpretation this section, that the anchorages for all seat belt assemblies that meet the frontal crash protection requirements of S5.1 of Standard No. 208 are exempt from the location requirements."

Does this mean that if a vehicle with 2 front seating positions is fitted with an air bag and manual three-point seat belt at each position, and this restraint system meets the frontal crash protection requirements of S5.1 of Standard No. 208 with the air bags alone and with the belts and air bags together, but the belts alone are not crash tested under FMVSS 208, that the seat belt assemblies are exempt from the location requirements of Standard No. 210?

2. Could you please clarify what is meant, in sections S4.3.1.1 and S4.3.1.2, by an installation in which the "belt bears upon" or "does not bear upon" the seat frame? In addition to an explanation, a few examples would be useful.

3. As regards a rear non-adjustable seat, would the anchorage system set forth in the attached photographs and diagram comply with the location requirements of S4.3.1.1(a)? We believe that it would because the relevant angle is from the seating referen ce point to the point where the end of the belt fastens to the bracket (labeled "belt and buckle pivot/fixing").

On April 30, 1990, NHTSA amended section 4.3.1.1(a) to read: "If the seat is a nonadjustable seat, then a line from the seating reference point to the nearest contact point of the belt WITH THE HARDWARE ATTACHING IT TO THE ANCHORAGE shall . . . ." (Em phasis added.) By notice dated December 5, 1991, the agency deleted the phrase" hardware attaching it to the anchorage", because in that same notice, NHTSA amended the definition of "anchorage" to include "attachment hardware". The agency specifically stated that t he above phrase was therefore superfluous. This deletion, however, should not have changed anything substantively, and because the attached design would comply with the section as worded on April 30, 1990, we believe that the design complies with sectio n 4.3.1.1(a) as it reads today.

We look forward to your reply. Kindly direct your response or any questions to our Colorado office, P.O. Box 1015, Golden CO 80402-1015 (Tel. 303 279 0203). Thank you.