Interpretation ID: nht79-3.38

DATE: 03/01/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent petition to amend Safety Standard No. 210, Seat Belt Assembly Anchorages, to exempt active lap belts installed in conjunction with passive upper torso restraints from the anchorage location requirements of the standard.

The agency has determined that amendment of the standard as you request is unnecessary since active lap belts and their associated anchorages are not required to comply with Federal safety standards if installed voluntarily by a manufacturer in addition to a single, diagonal passive belt. The passive restraint requirement of Safety Standard No. 208 will require passive protection in frontal crashes and, either passive protection in lateral and rollover crash modes or the provision of Type I or Type II active belts for protection in lateral and rollover crash modes. The agency has previously stated, most recently in a letter to Volkswagen dated August 1, 1977, that the provision in S4.5.3 of Standard No. 208 allowing the substitution of any passive belt system (whether or not including a lap belt) for any other belt system otherwise required, is intended to apply to the provisions of S4.1.3(c) that specify either passive protection or the provision or Type I or Type II belts.

Since active lap belts installed in conjunction with single, diagonal passive belts are not required, they are voluntary additions by the manufacturer. The agency has stated in past interpretations that systems or components installed in addition to required safety systems are not required to meet Federal safety standards, provided the additional components or systems do not destroy the ability of required systems (the passive belt in this case) to comply with Federal safety standards. This means that your proposed restraint system would have to meet the frontal crash protection requirements of Standard No. 208 both with and without the active lap belt fastened.

Since the change you requested is unnecessary in light of this interpretation, the agency will consider your petition withdrawn.

SINCERELY,

Ford Motor Company

December 14, 1978

Joan B. Claybrook Administrator Nationalk Highway Traffic

Safety Administration

Dear Ms. Claybrook: Re: Petition for Amendment of Federal Motor Vehicle Safety Standard No. 210 - Seat Belt Assembly Anchorages

Ford Motor Company (Ford), pursuant to Section 124 of the National Traffic and Motor Vehicle Safety Act, as amended, and 49 CFR, Section 552.3, submits this Petition for Amendment of Federal Motor Vehicle Safety Standard (FMVSS) No. 210, Seat Belt Assembly Anchorages (49 CFR 571.210) hereinafter "the Standard". Ford requests the Standard be amended to exempt active lap belts used in conjunction with passive upper torso restraints from the location requirements specified in S4.3.1.1.

Ford plans to offer in two of its 1980 passenger cars an optional passive belt restraint system for front seat occupants. This optional passive belt system will include a passive upper torso restraint, knee bolsters and an active lap belt. The active lap belt when used will provide additional protection to occupants in side and rollover type accidents. The passive belt system will comply with the passive restraint criteria required by Section 4.5.3 of FMVSS 208 with the without the active lap belt being employed. One of the design configurations of the active lap belt being developed, however, does not meet the anchorage location requirements of the Standard.

In this design, the lap belt retractor will be located on the inboard side of the bucket seat and its anchorage is located forward of the zone specified in Section 4.3.1.1 of the Standard. This configuration will permit forward motion (translation) of the occupant in a crash, which in turn will allow the occupant's knees to contact the knee bolster -- a desirable circumstance. We believe permitting increased forward translation of the occupant will result in more efficient distribution of impact forces during a frontal collision.

As the Administration indicated in its preamble to Docket 72-23; Notice 5, published November 16, 1978, ". . . the agency has determined manufacturers should be given wide latitude in passive belt design in order to facilitate the early introduction of passive systems. . . ." In a similar sense, this request for amendment will contribute to earlier introduction of passive systems. Further, if this petition is not granted on a timely basis, it could hinder our efforts to introduce a passive belt option prior to the required incorporation date.

As Ford intends to certify that vehicles equipped with the passive belt meet the injury requirements of Standard 208 with and without the active lap belt, and because the additional active lap belt will provide added protection in side and rollover accidents, we believe this petition, if granted, should contribute to the safety of front seat occupants.

Ford, therefore, respectfully requests that the last sentence of S4.3 of Standard 210, Seat Belt Assembly Anchorages (49 CFR 571.210) be amended as follows (added text indicated by underlining):

"S4.3 . . . Anchorages for passive belt systems that meet the frontal crash protection requirements of Standard No. 208, and active lap belt systems, installed in conjunction with such passive belt systems, are exempt from the location requirements of this section."

J. C. Eckhold Director Automotive Safety Office (Graphics omitted)