Interpretation ID: nht71-5.18

DATE: 12/09/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 26, 1971, in which you asked our opinion on how to position a 50th percentile 6-year-old child in determine the conformity of a seat belt warning system to S7.3.1(c) of Standard No. 208. Our opinion is that the child should be positioned with his back against the back of the seat and his head upright, in the posture in which he would be held by the seat belt if it were buckled around him as specified in S7.1. This is the position that will be used in our tests for conformity to S7.3.1(c).

The language that you cite from S8.1.11(b) of the standard ("normal upright(Illegible Words) to the positioning of test devices during the dynamic tests specified in S4 and S5, but is not applicable to the belt adjustment and warning system requirements of S7. The position that we intend to use under S7.3.1(c) is therefore not based on any definition of normal upright sitting posture."