Interpretation ID: aiam3400
Manager
Certification Department
American Honda Motor Co.
Inc.
100 W. Alondra Blvd.
P.O. Box 50
Gardena
CA 90247;
Dear Mr. Gill: This responds to your recent letter regarding an emergency lockin retractor design which incorporates a secondary locking mechanism that is activated by webbing movement. The primary locking mechanism of the retractor is sensitive to both vehicle deceleration and webbing movement. You ask whether the secondary locking mechanism must be tested separately for compliance with Safety Standard No. 209, or whether it is sufficient that the retractor as a whole comply with the standard.; The secondary locking mechanism does not have to be tested separatel since it would be viewed by the agency as a voluntary system. I am enclosing a letter of interpretation on this same subject which was issued by the agency in February 1981 to Toyota Motor Company. I am also enclosing a copy of a letter of interpretation issued to the United States Testing Company regarding the application of Safety Standard No. 209 to dual- sensitive retractors. This second letter might also be of interest to you since you state that the primary locking mechanism on the Honda retractor is sensitive to both vehicle deceleration and webbing movement.; Sincerely, Frank Berndt, Chief Counsel