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From Products Liability Law Daily, March 2, 2015

Alternative to new force application device for testing seat belt anchorages proposed

By Pamela C. Maloney, J.D.

In response to comments received on its proposal to amend Federal Motor Vehicle Safety Standard (FMVSS) No. 210, “Seat belt assembly anchorages,” to specify a new force application device (FAD) for use as a testing interface to transfer loads onto the seat belt anchorage system during compliance tests of anchorage strength, the National Highway Traffic Safety Administration has issued a supplement to that proposal which would allow retention of the body blocks testing currently set forth in FMVSS 210; however, the agency has proposed the establishment of specific procedures to be followed when using body blocks for testing. NHTSA has requested comments on this alternative proposal by May 1, 2015 (NHTSA Proposed Rule80 FR 11148, March 2, 2015).

Background. On March 30, 2012, NHTSA proposed an amendment to FMVSS 210 that would replace the pelvic body and the upper torso body blocks with a new Force Application Device (FAD) because the FAD was easier to use, was more representational of the human form, and it provided a consistent test configuration and load path to the seat belt assembly (see Products Liability Law Daily’s March 30, 2012 analysis). In the March 2012 NOPR, NHTSA identified a number of challenges associated with the use of the body blocks, including positioning the body blocks and variables in the test set-up.

Comments on the March 2012 NPRM. NHTSA received 13 comments in response to the March 2012 NPRM from vehicle manufacturers and groups, suppliers, and a test facility. While a number of the commenters’ concerns and questions could stem from a lack of familiarity with the new FAD, many raised concerns about the performance of their seat belt assemblies if tested with the FAD based on its more limited range of motion. Some commenters challenged the durability and strength of the FAD because the agency did not conduct failure tests, while others expressed concerns about slippage during testing because of the FAD’s polyurethane smoothness. There were also questions as to why a test device with a human form was superior to the current blocks, noting the increased width of the FAD as opposed to the body blocks.

Supplemental NOPR. In light of the comments received, the agency has decided to consider including an alternative test procedure that would maintain the current FMVSS No. 210 body blocks and to adopt procedures to ensure that the placement of the body blocks, at pre-load, was set forth with sufficient specificity. The specifications could include zones for the initial placement of the current body blocks along with separate zones for the torso and pelvic body blocks. The agency indicated that it did not intend to increase the stringency of the standard per se.

NHTSA emphasized that although it is considering this option of retaining the body blocks and refining the FMVSS test procedure, it was still considering replacing the body blocks with the FAD as initially proposed in the March 2012 NPRM.

Comment request. The agency asked for comments on the following topics: (1) how should these placement zones be established in the vehicle environment; (2) how it could be verified that the body blocks were within the specified zones during pre-load in the vehicle environment; and (3) was there any make/model-specific information or views it should consider.

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