Interpretation ID: nht78-3.15

DATE: 07/17/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Automobile Importers of America

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking whether passive safety belts are exempt from the requirements of Safety Standard No. 209, Seat Belt Assemblies.

The answer to your question is yes, with one exception. Paragraph S4.5.3.4 of Safety Standard No. 208, Occupant Crash Protection, specifies that passive safety belts that are not required for the vehicle to meet the perpendicular frontal crash protection requirements of the standard must meet the requirements of Standard No. 209. Therefore, only passive belts that are installed to meet the frontal crash protection requirements of Standard No. 208 are exempted from the requirements of Standard No. 209.

Sincerely,

June 8, 1978

Joseph Levin Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Levin: Subject: Request for an Interpretation FMVSS 208/209

In reviewing the requirements presented in FMVSS 209, Seat Belt Assemblies in connection with the design of passive belt systems, there appears to be no distinction between the applicability of the standard as to active and passive belt systems. In reviewing FMVSS 208, Occupant Crash Protection however, paragraph 4.5.3.4 appears to exempt passive belt systems from compliance in any manner with the requirements of FMVSS 208. Since such an exemption would provide the design latitude necessary in the development of an optimum passive belt system, I would appreciate your confirmation that this exemption is intended.

In view of the extensive development efforts now underway in the engineering departments of many manufacturers, an expeditious response to this request would be appreciated.

George C. Nield President