Interpretation ID: aiam3200
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 asking whether a manual, Type 1 la belt assembly installed in conjunction with an upper torso automatic belt can qualify as the pelvic portion of a Type 2 belt assembly for purposes of the elongation requirements of Safety Standard No. 209, *Seat Belt Assemblies*.; Safety Standard No. 209 limits the elongation of webbing in a Type lap belt to 20 percent, but allows the webbing in the pelvic portion of a Type 2 belt assembly to elongate 30 percent. The standard defines a 'type 2 seat belt assembly' as a combination of pelvic and upper torso restraints. Although a manual lap belt installed in conjunction with an automatic upper torso belt is not in fact a 'combination' belt as originally contemplated by the definition, the function of the system is equivalent to the Type 2 belt. Therefore, since the pelvic portion of a Type 2 belt may elongate up to 30 percent under the requirements of the standard, we conclude that a lap belt installed in conjunction with an upper torso automatic belt should be considered the pelvic portion of a Type 2 system and subject to the same requirement.; To assure that all interested persons are aware of this interpretation the agency intends to amend Safety Standard No. 209 to clarify that manual lap belts installed in conjunction with automatic upper torso belts may meet the elongation requirements specified for Type 2 belts. The amendment will also specify that such lap belts must be labeled to indicate they are only intended for use with an automatic upper torso restraint. Rulemaking in this regard will be initiated in the near future.; Sincerely, Frank Berndt, Chief Counsel