Interpretation ID: nht90-2.99

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 16, 1990

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TO: WILLIAM SHAPIRO -- MGR., REGULATIONS AND COMPLIANCE, VOLVO CARS OF NORTH AMERICA

TITLE: NONE

ATTACHMT: LETTERS DATED 4-18-89 AND 7-11-88 TO ERIKA Z. JONES FROM WILLIAM SHAPIRO ATTACHED; (OCC-3422).

TEXT:

This responds to your letter seeking an interpretation of Standard No. 210, Seat Belt Assembly Anchorages (49 CFR S571.210). Let me begin by apologizing for the delay in this response. Specifically, you indicated that Volvo is currently designing a Type 2 seat belt assembly (lap/shoulder belt) that has an anchorage for the upper end of the shoulder belt located within the area specified in S4.3.2 of Standard No. 210. Volvo also would like to install an additional anchorage for the upper end of the shoulder belt outside of the area specified in S4.3.2. The purpose of this additional anchorage was said to be to "increase the stability of the mounting." You stated your belief that this additional anchorage would be permitted even though it does not satisfy the location requirements specified in S4.3.2, because the additional anchorage "is not required for the seat belt assembly to comply with the strength requirements" of Standard No. 210. The answer to your question depends upon whether the lap/shoulder safety belt is required to be installed at the particular seating position.

My response assumes that this additional anchorage is not an anchorage for an automatic or dynamically tested manual safety belt that meets the requirements of S5.1 of Standard No. 208, Occupant Crash Protection. Anchorages for those belts are explicitly exempted from the anchorage location requirements by S4.3 of Standard No. 210.

If the seating position in question is one that is required by Standard No. 208 to be equipped with a lap/shoulder belt, the additional anchorage described in your letter would appear not to comply with Standard No. 210. Section S3 of Standard No. 210 defines a "seat belt anchorage" as "the provision for transferring seat belt assembly loads to the vehicle structure." As I understand your letter, both the anchorage that satisfies the location requirements of Standard No. 210 and the addi- tional anchorage would transfer seat belt assembly loads to the vehicle structure. Therefore, both of these points would be the "seat belt anchorage," per S3 of Standard No. 210, and both points would have to comply with the location requirements of S4.3.2 of Standard No. 210.

Since your letter states that the additional anchorage would not comply with the anchorage location requirements of standard No. 210, each vehicle that used this additional anchorage point at seating positions required to be equipped with a lap/shoulder safety belt would appear not to comply with Standard No. 210.

On the other hand, if the seating position is one that is not required by

Standard No. 208 to be equipped with a lap/shoulder safety belt (such as the rear center seating position in passenger cars), Standard No. 210 might not prohibit the use of an additional anchorage point that did not comply with the location requirements of the standard. At seating positions where a lap/shoulder safety belt is not required, section S4.1.2 of standard No. 210 gives manufacturers the option of installing either anchorages for a Type I (lap-only) or Type 2 seat belt assembly. Hence, at these seating positions, Volvo could satisfy all requirements of the safety standards by installing lap-only belts at these seating positions. Accordingly, Volvo's decision to install lap/shoulder belts and an additional anchorage point at these seating positions would be purely voluntary, not a response to any regulatory requirement.

NHTSA has long said that systems or components installed in addition to required safety systems are not required to comply with Federal safety standards, provided that the additional systems or components do not destroy the ability of the required safety systems to comply with the safety standards. In a December 1, 1986 letter to Mr. Francois Louis, this agency stated that manufacturers are permitted to locate the anchorages for voluntarily installed lap-only belts outside of the area specified in Standard No. 210 for lap belts required to be installed by Standard No. 208, provided that the voluntarily installed lap-only belts do not destroy the ability of the required belt systems to comply with the requirements of the safety standards. The same reasoning would apply in this situation. That is, if Standard No. 208 does not require a lap/shoulder belt to be installed at a seating position, the upper anchorage for a shoulder belt (in Volvo's case, both anchorage points for the upper end of the shoulder belt) may be located outside of the area specified in S4.3.2 of standard No. 210, provided that the voluntarily installed anchorages and shoulder belts do not destroy the ability of the required anchorages for lap-only belts and the lap-only belts themselves to comply with the requirements of the safety standards. I would like to note, however, that NHTSA believes that shoulder belt anchorages located within the area specified in S4.3.2 of standard No. 210 offer the greatest safety benefits, even though the anchorages of voluntarily-installed shoulder belts are not required to be located within that area.

I hope this information is helpful. If you have any additional questions or need further information, please let me know.