Interpretation ID: nht95-1.45

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: NONE

ATTACHMT: ATTACHED TO 3/22/95 LETTER FROM PHILIP RECHT TO RANDAL BUSICK (A43; STD. 208)

TEXT: Dear Ms Versailles:

This is in response to the letter of Mr. Philip Recht to Vehicle Science Corporation dated January 5, 1995 regarding our previous request for an interpretation of S7.1.2 of FMVSS 208.

In the final paragraph of his letter, Mr. Recht indicated that the agency's technical staff raised concerns about the "SLIDER BAR" to which the outboard lower end of the seat belt is attached (see attached diagram, "Attachment # 1"). Mr. Recht further st ated that the staff is concerned that the bar allows the seat belt webbing to slide freely fore and aft longitudinally. Mr. Recht concluded by saying that this design may prevent the belt system from meeting the occupant protection requirements of FMVSS 208 as well as prevent the anchorage from meeting the location requirements of S4.3 of FMVSS 210.

Enclosed for your review are more detailed photographs and diagrams of the slider bar ("Attachment # 2"). Please note that the purpose of the slider bar is to allow ingress and egress to and from the rear seats of a 2-door vehicle. This system is very s imilar to the system used in the 3 series BMW coupe. The seat belt assembly (with slider bar) contemplated herein will be crash tested with an air bag under the requirements of FMVSS 208.

The forward (hooked) end of the slider bar is the point at which the belt always comes to rest when in use (buckled). This point is within the angle required by FMVSS 210 S4.3.1.1(b), and we therefore believe that the anchorage location requirements of Standard 210 are met.

In sum, once the crash test requirements and injury criteria of FMVSS 208 are met, together with applicable requirements of FMVSS 209 and 210, we do not see how the system "may prevent" the belt system from meeting the occupant protection requirements of FMVSS 208 or the anchorage from meeting the location requirements of FMVSS 210.

Kindly respond to the Vehicle Science Colorado office, P.O. Box 1015, Golden, CO 80402-1015 (Tel. 303 279 0203) so that we can discuss this further and swiftly resolve the issues presented herein.

Thank you for your attention to this matter.

Sincerely,

Attachments: (Drawings and Photos omitted)