Interpretation ID: nht90-3.69

TYPE: Interpretation-NHTSA

DATE: August 27, 1990

FROM: William Shapiro -- Manager, Regulations and Compliance, Volvo Cars of North America

TO: Paul J. Rice -- Chief Counsel, NHTSA

TITLE: Re FMVSS 210, Request for Interpretation

ATTACHMT: Attached to letter dated 11-9-90 from P.J. Rice to W. Shapiro (A36; Std. 210)

TEXT:

Section 4.3.2 of FMVSS 210 sets forth the anchorage location requirements for the upper torso portion of type 2 seat belt assemblies. Section 3 defines seat belt anchorage as the provision for transferring seat belt assembly loads to the vehicle structu re.

Volvo is currently designing a type 2 seat belt assembly for the rear seating positions of a proposed vehicle. The retractor is mounted within the seat back, in order to improve the seat belt geometry, to increase the comfort of the occupants, and to al low movement of the seat back. The retractor is located outside of the zone specified in Section 4.3.2, figure 1. However, the shoulder portion of the belt travels from the retractor through a device we are calling a "belt anchor", which is the functio nal equivalent of a d-ring. Kindly see the attached drawings, Appendices A & B, for clarity.

The belt anchor is located within the specified zone. Its function is to transfer the seat belt assembly load to the vehicle structure, and to determine the angle the belt crosses the vehicle occupant.

This belt anchor complies with the force requirements of the standard. Please see the attached drawings, Appendices C, D & E for the forces in the proposed design. For comparison, Appendices F & G show the forces on a current vehicle.

Volvo believes that a correct interpretation of FMVSS 210 in this case is that the belt anchor is the upper anchorage point for this seat belt system. Please confirm this for us.

Our engineers must finalize the design by this Fall. As such, we respectfully request that you reply by November 1, 1990.

Thank you for your attention to this matter. Should you have any questions, kindly contact Linda Gronlund of my office at 201-767-4815.