Interpretation ID: 86-3.31

TYPE: INTERPRETATION-NHTSA

DATE: 05/27/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Toshio Maeda

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Toshio Maeda Executive Vice President & Chief Operating Officer Nissan Research & Development, Inc. P.O. Box 8650 Ann Arbor, MI 48104

Dear Mr. Maeda:

Thank you for your letter of April 11, 1986, requesting an interpretation of the comfort and convenience requirements of Standard No. 208, Occupant Crash Protection. Your specific question is whether the retraction requirements of S7.4.5 of the standard apply only to the front outboard seating positions. As explained below, the answer is yes.

The April 12, 1985 notice proposed changes to the comfort and convenience requirements in response to petitions for reconsideration. In the case of the retraction requirements, the proposed language of S7.4.5 said that the requirement would only apply to a safety belt system installed at the "front outboard designated seating position." In the November 6, 1985 final rule adopting the retraction requirement, the agency dropped the reference to the "front outboard seating position." However, S7.4.5 still referred to conducting a compliance test on a test dummy which has been positioned "in accordance with S10." S10, in turn, references the test dummy positioning requirements of S8.1.11. S8.1.11.1 and S8.1.11.2 provide for positioning test dummies in the front outboard seating positions. Thus, the minor change in the language of the requirements did not change the applicability of the requirement. However, to eliminate any possible ambiguity about the application of the retraction requirement, the agency is planning to amend S7.4.5 to provide explicitly that it only applies to the front outboard designated seating positions.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel April 11, 1986 Ref : W-159-H

Ms. Erika Jones Chief Counsel National Highway Traffic Safety Administration 400 7th St., S.W. Room 5219 Washington, D.C. 20590

Dear Ms. Jones:

Re: REQUEST FOR INTERPRETATION 49 CFR Part 571 Docket No. 74-14; Notice 42 Seat Belt Comfort and Convenience

On behalf of Nissan Motor Co., Ltd. of Tokyo, Japan, Nissan Research & Development, Inc. herewith requests interpretation of a somewhat ambiguous phrase in the NHTSA's final rule on the performance requirements for seat belt assemblies (Federal Motor Vehicle Safety Standard 208).

S571. 208. S7.4.5, Retraction, reads, in part, ". . .the torso and lap belt webbing of any of those seat belt systems shall automatically retract when the adjacent vehicle door is in the open position, or when the seat belt latchplate is released, to a stowed position." (Emphasis added)

Question:

In the case of a 2-door vehicle, what would be considered the "adjacent" door for either the rear outboard seat or the rear center seat? Or is the retraction performance requirement intended to be applicable to rear seating positions at all?

Since the effective date for this requirement is already less than six months away, any urgency with which you can address our concern is highly appreciated.

If you have any questions, please contact Mr. Tomoyo Hayashi of my Washington, D.C. staff at (202) 466-5284.

Thank you very much. Again, we would be grateful for a prompt response.

Respectfully submitted,

Toshio Maeda Executive Vice President & Chief Operating Officer

TM:TH:mab cc) Mr. Steve Oesch, Chief Counsel Office, NHTSA