Interpretation ID: 2255y
Manager, R & D Lab
The C.E. White Co.
417 N. Kibler Street
New Washington, OH 44854
Dear Mr. Hiler:
This responds to your letter seeking an interpretation of Standard No. 210, Seat Belt Assembly Anchorages (49 CFR /571.210). Specifically, you asked if the strength test set forth in that standard requires simultaneous testing of all the safety belt anchorages for a passenger seat in school buses with a gross vehicle weight rating (GVWR) of 10,000 pounds or less, when those anchorages are installed on the seat frame, or whether those anchorages can be tested individually. The answer is that such anchorages are tested individually under the current provisions of the strength test in Standard No. 210.
Standard No. 222, School Bus Passenger Seating and Crash Protection (49 CFR /571.222) establishes the occupant protection requirements for passenger seating positions in school buses. Section S5(b) of Standard No. 222 provides that school buses with a GVWR of 10,000 pounds or less shall meet the requirements of Standard No. 210, among other standards. Section S4.2 of Standard No. 210 sets forth the strength test for anchorages. Section S4.2.4 reads as follows: "Except for common seat belt anchorages for forward-facing and rearward-facing seats, floor-mounted seat belt anchorages for adjacent designated seating positions shall be tested by simultaneously loading the seat belt assemblies attached to those anchorages."
Note that the only anchorages subject to a simultaneous testing requirement are floor-mounted anchorages. The anchorages described in your letter and shown in the photographs enclosed with that letter are mounted on the seat frame. Therefore, those anchorages would not be tested simultaneously to determine compliance with Standard No. 210.
I should also point out that NHTSA has proposed to amend section S4.2.4 of Standard No. 210 so that all seat and floor-mounted anchorages common to one seat would be tested simultaneously during the strength test. I have enclosed a copy of that proposal for your information. The interpretation in this letter may no longer be correct after the effective date of any final rule adopting that proposal.
Sincerely,
Stephen P. Wood Acting Chief Counsel
Enclosure
/ref:210 d:l/l2/90