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Interpretation ID: aiam3116

Mr. Frank Pepe, Assistant Vice President, Engineering Division, United States Testing Company, Inc., 1415 Park Avenue, Hoboken, NJ 07030; Mr. Frank Pepe
Assistant Vice President
Engineering Division
United States Testing Company
Inc.
1415 Park Avenue
Hoboken
NJ 07030;

Dear Mr. Pepe: This responds to your recent letter concerning the testing procedure specified in Safety Standard No. 209, *Seat Belt Assemblies*. Specifically, you ask about the proper sequence of requirements and testing procedures provided in paragraphs S4.3(j), S4.3(k), S5.2(j) and S5.2(k).; Paragraph S4.3(j) provides that a retractor must meet certai requirements when tested in accordance with S5.2(j). Compliance with this paragraph should be determined initially. Then, paragraph S4.3(k) provides that the same retractor must be able to comply with S4.3(j) after being tested in accordance with S5.2(k), except that the retraction force is only required to be 50 percent of its original value. This original value was determined, of course, during the compliance procedure of S5.2(j). Therefore, the first interpretation included in your letter is correct.; Sincerely, Frank Berndt, Chief Counsel