Interpretation ID: aiam3442
Volkswagen of America
Inc.
27621 Parkview Boulevard
Warren
MI 48092;
Dear Mr. Haenchen: This responds to your recent letter asking which of the specifi requirements of Safety Standard No. 209, *Seat Belt Assemblies*, must be met by an automatic seat belt assembly that is installed in a vehicle in accordance with the automatic restraint requirements of Safety Standard No. 208, *Occupant Crash Protection*.; The agency has stated in the past that automatic seat belt assemblie must meet the adjustment requirements of paragraph S7.1 of Safety Standard No. 208, and those parts of Safety Standard No. 209 that are incorporated by reference in S7.1, whether or not the automatic belts are installed to meet the frontal crash protection requirements of paragraph S5.1 or Safety Standard No. 208. Automatic belts that are installed to comply with the frontal crash protection requirements are excepted from the other requirements of Safety Standard No. 209 by paragraph S4.5.3.4 of Safety Standard No. 208. As noted in your letter, paragraph S7.1 of Safety Standard No. 208 requires the automatic belt assembly to have a retractor that complies with Safety Standard No. 209. However, the requirements for retractor performance in Safety Standard No. 209 are based on other tests in the standard which are used for preconditioning or as prerequisites. Therefore, you state that it is not clear which requirements must be met by a retractor on an automatic belt assembly.; Paragraph S7.1 of Safety Standard No. 208 is only intended t incorporate by reference those provisions in Safety Standard No. 209 that are directly related to retractor performance. Therefore, all automatic belt retractors are required to comply with the following provisions of Safety Standard No. 209, S4.3(j), S4.3(k), and S5.2(a), (b), (j), and (k). Please note, however, that the retractors do not have to comply with paragraph S4.4 which is incorporated by reference in S4.3(k), since S4.4 relates to the performance of entire belt assemblies.; I hope this has been responsive to your inquiry. We apologize for th delay.; Sincerely, Frank Berndt, Chief Counsel