Interpretation ID: aiam1497
Mitsubishi Motors Corporation
24300 Southfield Road
Southfield
MI 48075;
Dear Mr. Shimizu: This responds to your verbal request to Mr. Herlihy of this office fo a determination that a 3-point, continuous loop, Type II seat belt assembly would meet the requirements of S4.1.2.3.1(a) of Standard No. 208 if its emergency-locking retractor were mounted at the outboard floor anchorage instead of at the roof rail. The belt is routed from the fixed upper torso end, through a slip-fitting latch and pelvic section, to the retractor.; Assuming the belt assembly meets any other adjustment requirement o S4.1.2.3.1, it would conform to S7.1 of Standard No. 208 and S4.1(g) of Standard No. 209 with the emergency-locking retractor mounted at the outboard floor anchorage. The upper torso restraint would 'adjust by means of an emergency-locking retractor' within the meaning of S7.1 as long as the continuous loop permitted slack from the floor-mounted emergency-locking retractor to reach the upper torso portion of the assembly.; Yours truly, Richard B. Dyson, Assistant Chief Counsel