Interpretation ID: aiam0476
Director/General Manager
Factory Representative Office
Toyota Motor Company
Ltd.
1099 Wall Street West
Lyndhurst
NJ 07071;
Dear Mr. Nakajima: As indicated to you in the November 1 meeting in Mr. Laskin's office the seat belt retractor demonstrated by Toyota and shown on page 9 of the attachment to your letter is considered by the National Highway Traffic Safety Administration to be an automatic locking retractor. The classification of a retractor is determined by its operation, not by its design, and the Toyota retractor, however unconventional in design, operates in the manner prescribed for automatic locking retractors.; With respect to the test procedure of S5.3(a)(6), it is the intent o the test to load the seat belt assembly in a manner that represents the type of tension encountered in use. It is our opinion that the test set up shown on page 9 of the attachment to your letter is a correct application of the procedure to the Toyota retractor.; Please advise us if we can be of further assistance. Sincerely, Lawrence R. Schneider, Chief Counsel