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Interpretation ID: 24439Suzuki_tether_anchor_zone


    Mr. Kenneth M. Bush
    American Suzuki Motor Corporation
    3251 East Imperial Highway
    P.O. Box 1100
    Brea, CA92822-1100


    Dear Mr. Bush:


    This responds to your letter concerning Federal Motor Vehicle Safety Standard (FMVSS) No. 225, "Child Restraint Anchorage Systems" (49 CFR 571.225).I regret the delay in responding.You ask whether a certain user-ready tether anchorage location would meet the location requirements of S6.2.1 of the standard. Our answer is yes.

    S6.2.1 of Standard No. 225 states: " the part of each tether anchorage that attaches to a tether hook must be located within the shaded zone shown in Figures 3 to 7 of this standard."Figure 3 shows the front edge of the zone as extending along the torso line reference plane under the seat and then following the contour of the vehicle seat bottom and seat back up to a point on the seat back.You ask about locating an anchorage in a recessed area of the seat back.You do not believe that the standard intended to disallow locating the tether anchorage in that area.

    With one exception, a recessed area in the seat back is acceptable for locating the tether anchorage. Figures 3 to 7 do not provide dimensions as to the location of the front edge of the shaded zone, except with regard to the "strap wrap-around area" at the top of a vehicle seat back.The agency did not intend to exclude part of the seat back from the shaded zone; thus, a tether anchorage that is recessed in the seat back is permitted.However, the shaded zone does not include the strap wrap-around area at the top of the vehicle seat back.Thus, the anchorage must not be located in that wrap-around area. We will be issuing a technical amendment to include in the shaded zone the part of the seat back that is below the strap wrap-around area.

    You also ask for confirmation that, for the area under the vehicle seat, the forwardmost edge of the shaded zone is defined by the torso line reference plane.Your understanding is correct.

    Please contact Deirdre Fujita of my staff at (202) 366-2992 if you have further questions.

    Sincerely,

    Jacqueline Glassman
    Chief Counsel

    ref:225
    d.11/8/02