Interpretation ID: nht71-4.41

DATE: 11/05/71

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: General Motors Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 19, 1971, in which you asked whether the second and third options of Standard 208 require anthropomorphic test devices to be placed for the frontal crash tests only in the front designated seating positions, and not in the rear positions.

The answer is yes. The second and third options pose no requirements for testing that require dummies in the rear positions, hence dummies should be placed only in front positions. In the period from January 1, 1972 to August 15, 1973, they should in fact be placed only in the front outboard positions.

You also suggested that "if Option 1 is used, a test device must be at each designated seating position." This statement is true, in a strict sense. But the general requirements for the periods before August 15, 1975 (S4.1.1 and S4.1.2) explicitly allow the "mixing" of options, so that if belts are provided for the rear seating positions they may be considered as fulfilling option two or three, without dummies positioned there for the crash tests. In other words, dummies must be positioned in the rear seating positions only if and when the manufacturer elects to fulfill option one for the rear positions.