Interpretation ID: nht79-1.37

DATE: 04/03/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

APR 3 1979

NOA-30

Mr. Hisakazu Murakami Nissan Motor Co., Ltd. P.O. Box 1606 560 Sylvan Avenue Englewood Cliffs New Jersey 07632

Dear Mr. Murakami:

This responds to your letter of January 23, 1979, concerning a new design belt system for rear seat lap belts that you would like to use in future vehicles. You ask if the proposed design would comply with the requirements of Safety Standard No 208.

The answer to your question depends in which seating position in the rear seat of the vehicle the proposed belt system would be used. The new design would not comply with paragraph S7.1.1 of Safety Standard No. 208 if installed at outboard designated seating positions in the rear seat. That paragraph requires lap belts to adjust by means of an emergency-locking or automatic-locking retractor to fit persons whose dimensions range from those of a 50th-percentile 6-year-old child to those of a 95th-percentile adult male. In some cases your proposed design would not adjust automatically to fit a 95th-percentile adult male.

The proposed design would comply with the standard, however, if installed in the center seating position of the rear seat, since paragraph S7.1.1.2 specifies that a seat belt assembly installed at any designated seating position other than the outboard positions of the front and second seats shall adjust either by a retractor or by a manual adjusting device.

Since your new belt system design would currently be precluded for outboard designated seating positions, you may wish to petition for amendment of Safety Standard No. 208. Any petition should include an adequate description of the belt design, including: (1) seating positions for which the belt system would be applicable, (2) advantages of the system, (3) size of the belt system hardware, and (4) problems, if any, associated with automatic retraction of the belt system.

The National Highway Traffic Safety Administration hereby grants your request for confidentiality of the new belt system design described in your letter. Please notify us if the design becomes public in the future. Also, please note that if you petition for rulemaking in this area, the details of your belt design would probably have to be disclosed to the public, at least in general terms.

Sincerely,

Frank Berndt Acting Chief Counsel