Interpretation ID: nht72-4.23

DATE: 05/12/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: United States Testing Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 5, 1972, in which you suggested that S4.3(d)(3) of Motor Vehicle Safety Standard No. 209 is not appropriate for buckles located between the front seats.

Although you are correct in saying that the requirement was originally developed to guard against the buckle's being opened by the pressure of the steering wheel, there is a chance that compressive forces will also affect buckles located between the seats. Even though the tests may be more difficult to administer, these buckles are not exempt under the present version of the standard, and it is not correct to say that the requirement is not applicable to them.

We do not suggest by this that the requirement could not be changed in response to an adequately supported petition. However, the requirement as it now stands applies to all buckles, wherever located.