Interpretation ID: 2810o

Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing, Inc. 18881 U.S. 31 North Westfield, IN 46074

Dear Mr. Lawler:

This responds to your request for an interpretation of Standard No. 208, Occupant Crash Protection (49 CFR 571.208). Specifically, you noted that a July 5, 1988 final rule (53 FR 25337) requires that the safety belt systems on heavy trucks, multipurpose passenger vehicles and buses manufactured on or after September 1, 1990 must comply with S7.2 of Standard No. 208. S7.2(c) requires the latch mechanism on safety belts to "release at a single point by a pushbutton action."

Your company's comments on the proposal to adopt this requirement stated that you supported the proposal, but assumed that the requirement for a push button release would permit the continued use of slide button releases. In the preamble to the final rule, the agency responded to your comment as follows:

Some releases that comply with the requirements of S7.2(c) could be described as "slide-button releases." On the other hand, some designs that could be described as "slide-button releases' would not comply with S7.2(c), because they would not release by a "pushbutton action." If IMMI is uncertain whether the release machanism that it called a 'slide-button release" complies with the requirements of S7.2(c), it should request an interpretation of that section with respect to its release mechanism, and enclose pictures and diagrams of the release mechanism with the request for interpretation. 53 FR 25341.

In response to this invitation, you enclosed a photograph of several different safety belt buckles. You stated that the release button on these buckles moves parallel to the plane of the webbing and tongue, and that the buckle is mounted vertically and the button moves vertically when the occupant pushes it. Based on your description and the enclosed photograph, it appears that these buckle designs would comply with the requirement of S7.2(c) for release by a "pushbutton action."

Sincerely,

Erika Z. Jones Chief Counsel

ref:208

/NCC-20:SKratzke:mar:62992:8/25/88 OCC 2363, Wang # 2810o cc: NCC-01 Subj/Chron, NCC-20 SK, NRM-01, NEF-01 Interps: Std 208, Redbook (2)