Interpretation ID: 1982-1.20
TYPE: INTERPRETATION-NHTSA
DATE: 03/02/82
FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA
TO: Indiana Mills & Manufacturing, Inc.
TITLE: FMVSS INTERPRETATION
TEXT:
MAR 2 1982
NOA-30
Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing, Inc. 120 West Main Street Carmel, Indiana 46032
Dear Mr. Lawler:
This responds to your recent letter requesting an interpretation concerning paragraph S4.3(c)(1) of Safety Standard No. 209, Seat Belt Assemblies. You ask for clarification of the cases in which a 5,000-pound attachment bolt may be used in lieu of a 9,000-pound bolt.
Paragraph S4.3(c)(1) of Standard No. 209 specifies that attachment bolts used to secure the pelvic restraint of a seat belt assembly to a motor vehicle shall withstand a force of 9,000 pounds, except that "attachment bolts of a seat belt assembly designed for installation in specific models of motor vehicles in which the ends of two or more seat belt assemblies cannot be attached to the vehicle by a single bolt shall have a breaking strength of not less than 5,000 pounds." The intent of the requirement in S4.3(c)(1) is to assure that inadequate attachment bolts will not be used to attach seat belt assemblies to a vehicle. A 5,000-pound bolt may be used only if the belt assembly is designed for use in specific models of vehicles in which only one end of a belt assembly can be attached by a single bolt.
In answer to your question, the agency does not "have in mind" certain brands or models of vehicles which would qualify under this exception, and the exception is not limited to single-seat vehicles. Further, the requirement does not mean that a seat belt assembly that can be used in more than one application must be installed with a 9,000-pound bolt. If a particular assembly is designed for use in several different models in all of which only one end of the belt assembly can be attached by a single bolt, then a 5,000-pound bolt is sufficient. The distinction is that an aftermarket belt for universal application must be accompanied with a 9,000-pound bolt, because in some vehicle models it would be possible to mount two ends of seat belt assemblies with a single bolt.
You should note that paragraph S4.1(k) of Standard No. 209 requires the manufacturer of seat belt assemblies for aftermarket use to furnish an instruction sheet stating whether the assembly is for universal installation or for installation only in specifically stated motor vehicles. If you - provide 5,000-pound bolts for any of your assemblies, the instruction sheet required by S4.1(k) should specify that the assemblies are to be used only in the vehicle models you list.
I hope this has answered all your questions.
Sincerely,
Frank Berndt Chief Counsel
January 26, 1982
Mr. Frank Berndt, Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street S.W., Room 5219 Washington, D.C. 20590
Dear Sir:
Paragraph S4.3(c)(1) of Standard No. 209 (49 CFR 571.209) requires a 9,000 lb. breaking strength attachment bolt "...except that..." 5,000 lb. breaking strength attachment bolts may be used under certain conditions.
We are uncertain about the intent of two phrases in Paragraph S4.3(c)(1):
1. "...designed for installation in specific models of motor vehicles...", and
2. "...ends of two or more seat belt assemblies cannot be attached to the vehicle by a single bolt...."
With regard to the first phrase, does the National Highway Traffic Safety Administration have in mind certain brands, models, or types of vehicles? Does the phrase mean that a given seat belt assembly must be designed for a given application in order to attach it (in that application) by 5,000 lb. breaking strength bolts? Conversely, does the phrase mean that a seat belt assembly that may be used in more than one application must be installed using 9,000 lb. breaking strength bolts?
Phrase two raises questions, also. Does it mean that the 5,000 lb. breaking strength bolt may be used only with single seat vehicles? If a vehicle has more than one seat, must the seats be situated so that it is physically impossible to mount (for example) the right end of the left seat belt assembly and the left end of the right seat belt assembly to the same bolt? If the attachment hardware is designed to accomodate one and only one attachment bracket on a single attachment bolt, may a 5,000 lb. breaking strength bolt be used?
We would appreciate receiving from you an official written explanation of the intent of S4.3(c)(1) of Standard No. 209.
Thank you for your assistance.
Yours very truly,
William E. Lawler Specifications Manager
WEL:ld