Interpretation ID: aiam3845
Schnader
Harrison
Segal & Lewis
Suite 1100
900 Seventeenth Street
N.W.
Washington
D.C. 20006;
Dear Mr. Schwentker: This responds to your letter of May 9, 1984, concerning the applicatio of Standard No. 208, *Occupant Crash Protection*, and Standard No. 209, *Seat Belt Assemblies*, to an emergency locking retractor designed by one of your clients. The following discussion addresses the application of those standards to the retractor.; You explained that the purpose of the new emergency locking retracto (ELR) is to facilitate the securing of a child restraint in a vehicle. The ELR would only be installed in forward-facing passenger seating positions. The new ELR is designed so if the belt is pulled all the way out of the retractor, the ELR will convert into an automatic locking retractor (ALR). Once all but 1393-1493 mm of the belt retracts, the retractor will revert automatically to the ELR mode.; You further explained that the continuous loop lap and upper torso bel used with this retractor is 380 mm longer than the belt system provided for the driver's seating position. You explained that the extra 380 mm of belt webbing is meant 'to permit normal occupant movement without inadvertent actuation of the ALR mode while still rendering it convenient for manual extension when the ALR mode is desired for child restraint use.'; You specifically asked whether the retractor designed by your clien would be considered an ELR for the purposes of S7.1.1 of Standard No. 208. In addition, you asked about the retractor durability tests of S5.2(k) of Standard No. 209. As a part of that test, a retractor is subjected to '45,000 additional cycles of webbing withdrawal and retraction between 50 and 100 percent extension.' You asked whether, for the purposes of the section 5.2(k) test, the length of the driver's belt, which is 380 mm shorter than the passenger's belt, could be used to determine what constitutes 100 percent extension of the belt. You alternatively asked whether the test could be stopped before complete extension of the passenger belt.; As we understand your client's seat belt assembly, the amount o webbing in the driver's side assembly complies to the adjustment requirements of section 4.1(kg) of Standard No. 209. The 380 mm's of extra webbing that is included in the passenger's seat belt assembly has been voluntarily added as a precaution to reduce the possibility of an occupant inadvertently actuating the ALR mode of the retractor. Based on the information you have provided, it appears that in normal operation by occupants covered by the adjustment requirements of Standard No. 209 the retractor functions exclusively as an ELR and thus can be used to meet the requirements of S7.1.1 of Standard No. 208. The agency views the 380 mm's of extra webbing as a voluntary addition not required by the standard. Therefore, for the purpose of section 5.2(k) of Standard No. 209, the agency will use the length of the driver's belt to determine what constitutes full extension of the webbing.; Sincerely, Frank Berndt, Chief Counsel.