Interpretation ID: nht67-1.32

DATE: 06/14/67

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA

TO: Mercedes-Benz of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of April 10, 1967, clarifying the intent of your petition for reconsideration of Federal Motor Vehicle Safety Standard No. 210, and seeking a review of Order No. 12, dated March 29, 1967, denying your petition.

At your request I have reviewed your petition for reconsideration and wish to(Illegible Word) for the record, as you have asked, that your company did not seek to be relieved from the requirements of Standard No. 210, but rather sought permission to provide upper(Illegible Word) restraint anchorages in addition to those required by the standard. After reviewing Order No. 12, I have concluded that with respect to your company the order was intended as a(Illegible Words) paragraph(Illegible Words) is unnecessary, however, for the reason that Standard No. 210(Illegible Words)(Illegible Word) anchorages in addition to those required in paragraph 4.1. The location criteria for the anchorages as outlined in accordance with paragraph 4.1, and not to any additional anchorages provided by the manufacturer.

I believe the foregoing interpretation will enable your company to continue its practice of furnishing additional(Illegible Word) restraint anchorages on the(Illegible Words) large persons(Illegible Words) you have further questions concerning the(Illegible Word) please do not(Illegible Word) to let me know. MERCEDES - BENZ OF NORTH AMERICA, INC.

Lowell K. Bridwell Federal Highway Administrator United States Department of Transportation

I have Dr. Haddon's letter of April 4, 1967, enclosing a copy of your order of denial regarding our petition for reconsideration of Standard No. 210, dated March 3, 1967.

It is important to indicate that it was not the intention of our petition to request relief from the requirement of Standard No. 210 (S 4.3.2.1) as stated in Order No. 12 issued on March 29. Our request was simply that Standard No. 210 be amended to allow a second upper torso restraint anchorage point -- in addition to an anchorage point complying with Standard No. 210 -- in order that such an additional point be available for persons of unuaually large body dimensions.

I think it important that the record clearly show that Mercedes-Benz of North America did not seek relief from Standard No. 210, but rather sought permission to comply with the Standard and at the same time provide for optimum restraint and comfort of persons of unusually large size. It has been standard practice in our company to furnish at least two upper torso restraint anchorages when they are mounted in the B--pillar of sedans and we sought in our March 3, 1967 petition to continue this practice.

Inasmuch as the relief denied in Order No. 12 is not the relief sought by Mercedes-Benz of North America, Inc., I would greatly appreciate your reviewing the Order in the hope that since we comply with Standard No. 210 the inclusion of an additional anchorage would be allowed to enhance the safety and comfort of unusually large persons.

Sincerely,

PEUGEOT, INC.

May 26, 1967

Mr. O'Mahoney National Traffic Safety Agency

Regarding our telephone conversation of May 26, I am in need of legal interpretation concerning Standards 208 and 210.

According to Standard 208, paragraph S3.1.1, Type 2 seat belt assembly should be installed in each outboard passenger car in the front seat position, including the windshield, within the impact area, which, in my mind includes the front seats only. Thus, the rear seats should have only Type 1 (lap belt).

From Standard 210, table 1, it seems to clearly indicate that we must have seat belt anchorages for a Type 2 seat belt in outboard seats in the rear, but it does not expressly state that the Type 2 seat belts should be installed in the outboard seats in the rear.

Would you kindly let me know if my interpretation is correct: on a 4-passenger car, we should have Type 2 seat belts in the front, Type 1 seat belts in the rear, but anchorages in the rear for Type 2 and Type 1 seat belts.

Thank you very much in advance for your reply.

Henri B. Combe Executive Vice President