Interpretation ID: nht81-1.19

DATE: 02/19/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Toyota Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

FEB 19 1981

NOA-30

Mr. Jiro Kawano General Manager U.S. Representative Office Toyota Motor Co., Ltd. One Harmon Plaza Secaucus, NJ 07094

Dear Mr. Kawano:

This responds to your recent letter regarding a new emergency locking retractor design that incorporates, within the retractor housing, a separate webbing lock mechanism. You ask for confirmation that the one-inch locking requirement of S4.a(j)(1) of Safety Standard No. 209, Seat Belt Assemblies, applies only to the retractor itself and not to a separate webbing lock that is incorporated in the retractor housing.

Your interpretation is correct. Provided the retractor as a whole complies with the one-inch locking requirement of S4.3(j)(1), the webbing lock is permissible and would not have to comply with the requirement as a separate component. The agency would view the webbing locking device as a voluntary component not required by the standard.

We have recently issued an interpretation to the American Testing Company which deals with a similar subject. That interpretation discusses the requirements of S4.3(j) as applicable to dual sensitive retractors (i.e., retractors that have both vehicle sensitive and webbing sensitive mechanisms). I am enclosing a copy of that interpretation for your information. It explains more fully the requirements of section S4.3(j). If you have any further questions after reviewing this information, please feel free to contact Hugh Oates of my staff (202-426-2992).

Sincerely,

Frank Berndt Chief Counsel

Enclosure

December 1, 1980

Frank Berndt, Esquire Chief Counsel National Highway Traffic Safety Administration Washington, D. C. 20590

Dear Mr. Berndt:

This is to seek confirmation of our interpretation of FMVSS 209 paragraph S4.3(j)(1) as it applies to a new emergency locking retractor (ELR) design which incorporates, within the same housing, a separate webbing lock.

As we explained in our September 30, 1980 informal meeting with Mr. Ralph Hitchcock and others of the NHTSA staff, this additional webbing lock improves overall seat belt performance and, for space and weight saving considerations, is built into the same housing as the ELR itself.

Therefore, we ask NHTSA to confirm that the one (1) inch locking requirement of paragraph S4.3(j)(1) of FMVSS 209 applies only to the ELR itself, and not to a separate webbing lock that may physically be incorporated into the same housing as the ELR.

We trust you will treat the above as confidential and should you have any questions concerning this matter, please contact our counsel, Donald M. Schwentker, at (262) 347-6007.

Sincerely,

TOYOTA MOTOR CO., LTD.

Jiro Kawano General Manager U. S. Representative Office

JK:dd

cc: Donald M. Schwentker