Interpretation ID: nht73-6.19
DATE: 05/22/73
FROM: AUTHOR UNAVAILABLE; James E. Wilson; NHTSA
TO: Ford Motor Company
TITLE: FMVSS INTERPRETATION
TEXT: By petition for rulemaking dated November 15, 1973, the Ford Motor Company requested an amendment of Motor Vehicle Safety Standard No. 210 with respect to the strength required of the anchorages for the pelvic portion of a Type 2 seat belt assembly. After considering the merits of the requested amendment, we have decided to deny your petition.
As stated in your petition, the anchorages for the pelvic portion of a Type 2 assembly are presently subject to two strength requirements under Standard 210. Section S4.2.2 provides that, when tested in conjunction with the upper torso anchorage, the pelvic anchorages must withstand a force of 3,000 pounds applied through the seat belt assembly. Section S4.2.1 provides that, when tested separately from the upper torso anchorage, the pelvic anchorages must withstand a force of 5,000 pounds applied through the seat belt assembly.
It is Ford's position that the 5,000 pound requirement of S4.2.1 was intended to be applicable to anchorages used with Type 2 assemblies having detachable shoulder belts, and that it was not intended for use with integral Type 2 assemblies. Although the NHTSA would agree that the most widely used Type 2 assembly at the time of the standard's adoption had a detachable shoulder belt, the agency does not agree that the 5,000 pound requirement should be limited to anchorages used with such belts.
The 1974 model year will be the first in which integral Type 2 belts are installed in all passenger cars. We anticipate that a measurable percentage of persons riding in cars with the new belts will somehow avoid using the shoulder belt, thereby placing
the lap belt under the same potential stress as any other lap belt when used by itself. In light of this possibility, and in consideration of the fact that keeping the pelvic anchorage force at the currently required level of 5,000 pounds will not impose additional manufacturing costs on manufacturers, we do not consider it advisable to grant the requested amendment at this time.
The petition of Ford Motor Company for an amendment of S4.2.1 of Motor Vehicle Safety Standard No. 210 and for a complementary amendment to the test procedures of S5.1 of the standard is therefore denied.
November 15, 1972
Douglas W. Toms Administrator National Highway Traffic Safety Administration
Re: Petition for Amendment of Federal Motor Vehicle Safety Standard No. 210 - Seat Belt Assembly Anchorages
Ford Motor Company, with offices at The American Road, Dearborn, Michigan 48121, as a domestic manufacturer of motor vehicles, hereby submits this Petition for Amendment of Federal Motor Vehicle Safety Standard No. 210 - Seat Belt Assembly Anchorages (hereinafter "the Standard"). This Petition is filed pursuant to Section 553.31 of the procedural rules of the National Highway Traffic Safety Administration.
The purpose of this Petition is to request an amendment to S4.2.1 and S5.1 of the Standard that would eliminate the requirement of applying a 5000-pound force to the anchorages of the pelvic portion of a Type 2 seat belt assembly with a non-detachable upper torso portion. Sections S4.2.2 and S5.2 of the Standard adequately cover the anchorage loading for such a Type 2 seat belt assembly. This 5000-pound test criteria was developed originally for seat belt restraint systems that were independent of upper torso restraints and is still applicable to such systems as well as those that include a detachable upper torso belt system.
Ford Motor Company plans to incorporate non-detachable upper torso straps as required by S4.1.2.3 of Federal Motor Vehicle Safety Standard 208 in its 1974 model vehicles. The present requirements of Federal Motor Vehicle Safety Standard 210 cause the restraint system to be dismantled before it can be tested, resulting in redundant and unnecssary tests and, therefore, are not practicable for this type of restraint system.
Ford test and development programs for these vehicles are now at that point where prototype bodies incorporating 1974 restraint system component designs are available for tests according to Federal Motor Vehicle Safety Standard 210 demonstration procedures to determine that design levels are appropriate for production tooling. We urge your prompt attention to this matter to assure that our current product programs are not affected.
Respectfully submitted,
J. C. Eckhold
Director, Automotive Safety Office