Interpretation ID: nht79-1.11

DATE: 01/09/79

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

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

JAN 9 1979

NOA-30

William Shapiro, P.E. Manager, Regulatory Affairs Volvo of America Corporation Rockleigh, New Jersey 07647

Dear Mr. Shapiro:

Please excuse the delay in responding to your letter of October 25, 1978. You asked whether a webbing guide you are planning for the rear seat belt in station wagon vehicles would have to comply with the strength requirements of Safety Standard No. 210, Seat Belt Assembly Anchorages.

The agency has examined the drawings included in your letter and discussed this new webbing guide with Volvo engineers. We have concluded that the webbing guide would not qualify as an "anchorage" and, therefore, would not have to comply with the Standard 210 requirements for anchorages. The standard defines "anchorage" as a device that transfers seat belt assembly loads to the vehicle structure. Your proposed webbing guide is not intended to transfer loads to the vehicle structure, and will only be added to increase the comfort of the assembly. As you indicated, the device marked "B" on your drawings would qualify as an anchorage and would have to meet the strength requirements of the standard.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

October 25, 1978

Mr. Joseph J. Levin, Jr.

Chief Counsel National Highway Traffic Safety Administration 900 Seventh Street, S.W. Washington, DC 20590

RE: Request for Interpretation - FMVSS No. 210

Dear Mr. Levin:

Volvo is planning to modify the belt geometry of the rear seat belt in our station wagons. We will introduce an extra webbing guide, which is marked "A" on the enclosed sketch. This modification will improve the belt use comfort and will thereby encourage increased seat belt usage.

It is Volvo's interpretation that this webbing guide is not a seat belt anchorage and is therefore not required to meet the strength requirements of FMVSS No. 210, S4.2. Please confirm whether our interpretation is correct. The device which Volvo uses "for transferring seat belt assembly loads to the vehicle structure", is marked "B" on the enclosed sketch, and is designed to meet the strength requirements of FMVSS No. 210, S4.2.

If additional information is required on this issue, don't hesitate to contact me at your convenience.

Sincerely yours,

VOLVO OF AMERICA CORPORATION Product Planning & Development

Manager, Regulatory Affairs

WS/dpl ENCLOSURE (1)