TUEV Rheinland Kraftfahrt GmbH - Comment

Dear Sir or Madam, After the presentation of the NRPM in Geneva at the GRSP session last week, the representative of NHTSA asked me to submit my comment, made at the session. Regarding the NPRM FMVSS 210 Seat Belt Assembly I would like to inform you about a concern we as Technical Service in Germany do have with the use of the new FAD. Please find four pictures as annex to my comment. On two the four pictures you will see a seat belt anchorage test with a seat, where one of the lower anchorages is attached to the seat and the other one as well as the upper anchorage are attachted to the vehicle body. After the test the seatback is deformed in a critical way which could lead to severe injuries of the occupant. On the other two pictures you will find a seat belt anchorage test of a bus seat with fully seat integrated belt system. After the test you can see a critical deformation of the seat back which also could lead to severe injuries. If for these tests the new FAD would be used, the FAD would reinforce the seat structure. This could lead to a total different result of the test if performed with the new and the old equipment. We think that the new FAD will not represent the deformation which would occure in a real accident. In many tests we have seen, that due to the deformation of the seat and the seatback the seat or the anchorages could not hold the load and broke. We think, that he new FAD could reinforce the seat and lead to a positive test result in the same test. In case of further questions, do not hesitate to contact me.