Well, I dunno. I'm not an engineer but in this application, I'd prefer all the bolts to be in shear. I don't like the idea of the top rear bolts being in tension. The bolt won't break, that's not an issue, but I think that the plate into which the bolt is screwed should be mounted behind the metal panel and be large enough in area to not be pulled through in an accident.
When you look at the Milford fitting instructions you can see that getting a bolt into the side panel and having it in shear isn't easy. The metalwork is a long way behind the outer trim cover. That's why they have that dog-legged bracket. To be honest, I can't see an easy way to do it.
If you never carry rear passengers the upper seat belt bolts may be OK if you moved the attachment points on the barrier up to be in line with the bolts. However, this doesn't address the legalities of it.


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