Interpretation ID: aiam1216
Director
Overseas Department
Takata Kojyo Company
Ltd.
No. 10 Mori Bldg. 28
Sakuragawa-Cho Nishikubo Shiba
Minato-Ku
Tokyo
Japan 105;
Dear Mr. Hiramine: This is in reply to your letter of July 31, 1973, concerning th meaning of the term 75 percent extension' as used in S5.2(j) of Motor Vehicle Safety Standard No. 209.; The 75 percent extension point used in S5.2(j) is intended to represen the belt's extension during its use in a vehicle. The measurement of extension is therefore begun with the webbing retracted as fully as the design of hardware and the size of the retractor permit. It may be that when the belt is retracted to this point a considerable amount of webbing remains outside the retractor, as shown in Figure 2 of your letter. The measurement of extension nonetheless begins at this point, so that 75 percent extension' is 75 percent of the incremental webbing length between this point and the point of fullest extension.; To refer to the figures accompanying your letter, the measuremen technique shown in Figure 2 is correct. That shown in Figure 1, which is based on 75 percent of the total length of the belt, is incorrect.; Yours truly, Richard B. Dyson, Assistant Chief Counsel