THE "STANDARD SEAT ASSEMBLY" AS DEFINED BY FIG-1A OF FMVSS 213 DEFINES SEAT/SEAT-BELT GEOMETRY SUCH THAT A SEATBELT BUCKLE SHALL NOT EXTEND BEYOND175MM (~6IN) FROM THE SEAT BIGHT. THE STANDARD SEEMS TO ALLOW CAR MANUFACTURERS TO UTILIZE SEAT BELT BUCKLE ASSEMBLIES ANYWHERE IN THE 0 TO 175MM RANGE FROM THE BIGHT. A BIGHT-TO-BUC…
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THE "STANDARD SEAT ASSEMBLY" AS DEFINED BY FIG-1A OF FMVSS 213 DEFINES SEAT/SEAT-BELT GEOMETRY SUCH THAT A SEATBELT BUCKLE SHALL NOT EXTEND BEYOND175MM (~6IN) FROM THE SEAT BIGHT. THE STANDARD SEEMS TO ALLOW CAR MANUFACTURERS TO UTILIZE SEAT BELT BUCKLE ASSEMBLIES ANYWHERE IN THE 0 TO 175MM RANGE FROM THE BIGHT. A BIGHT-TO-BUCKLE (B2B) DISTANCE OF 175MM MAKES IT DIFFICULT (OR IMPOSSIBLE) TO PROPERLY SECURE CHILD CAR SEATS, USING THE VEHICLE'S SEAT BELT, IF THE CHILD SEAT DEPTH IS SHALLOWER THAN 175MM. THIS HYPOTHESIS WAS DEVELOPED AFTER I WAS UNABLE TO PROPERLY SECURE A DIONO RADIAN RXT CAR SEAT (FORWARD FACING MODE) IN MY 2014 HONDA ODYSSEY. THE BUCKLES IN THE HONDA (SEE ATTACHED) APPEAR TO BE CLOSE TO THE 175MM THRESHOLD. HOWEVER, I WAS ABLE TO SECURE THE SAME DIONO SEAT IN MY 2007 AUDI A6 BECAUSE THE AUDI'S BUCKLES ARE FLUSH MOUNTED IN THE SEAT CUSHION (I.E. B2B OF ~0MM). I DO NOT BELIEVE THIS PROBLEM IS A "HONDA" PROBLEM, BUT A PROBLEM WITH THE LACK OF SPECIFICITY OF FMVSS-213 WRT HOW CHILD SEATS ARE TO BE TESTED. FMVSS 213 S6.1.2 SIMPLY STATES THAT THE "STANDARD SEAT ASSEMBLY" IS TO BE USED, AND MAKES NO MENTION OF ENSURING COMPATIBILITY OF FIT THROUGHOUT THE B2B RANGE. THE DIONO MANUAL (SEE PG-19, ATTACHED) INDICATES THAT THEIR SEATS ARE NOT COMPATIBLE WITH "...ANCHOR POINTS FORWARD OF THE SEAT CREASE." I REVIEWED OTHER CHILD CAR SEAT MANUFACTURER INSTRUCTION MANUALS AND FOUND SIMILAR WARNINGS. WHILE THE HONDA SEAT BELTS CONTAIN FMVSS-209 CERTIFICATION TAGS, AND THE DIONO IS LABELED WITH FMVSS-213 TAGS, I BELIEVE THAT THESE TWO STANDARDS ARE NOT COMPATIBLE. RECOMMENDATIONS: (1)UPDATE "STANDARD SEAT ASSEMBLY" OF FMVSS-213 SUCH THAT B2B IS EXPLICITLY FIXED AT 175MM OR (2) FMVSS-209 MUST RESTRICT B2B< 25MM. FMVSS-209 S4.1.E ONLY SPECIFIES, "...BUCKLE OR BUCKLES READILY ACCESSIBLE TO THE OCCUPANT TO PERMIT HIS EASY & RAPID REMOVAL..."
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