Interpretation ID: aiam3712
P.E.
Manager
Regulatory Affairs
North American Car Operations
Product Planning and Development
Volvo of America Corporation
Rockleigh
NJ 07647;
Dear Mr. Shapiro: This responds to your letter of May 24, 1983, requesting a interpretation concerning the retraction force requirements of Safety Standard No. 209, *Seat Belt Assemblies*. You are considering a Type 2 seat belt design which includes an emergency locking retractor for continuous loop webbing and an emergency locking retractor for additional webbing at the inboard buckle portion of the system. You state that this inboard webbing is extended only if the belt is used by an extremely large occupant. You ask whether the retraction force requirements of the standard allow testing with the webbing of the *entire system* extended 75%, i.e., even if this means that no webbing is extended from the inboard retractor, so that the retraction force is actually only measured from the retractor for the continuous loop portion of the belt.; Paragraph S4.3(j) of Safety Standard No. 209 specifies that a emergency locking retractor of a Type 1 or Type 2 seat belt assembly, when tested in accordance with the procedures specified in paragraph S5.2(j) shall:; >>>***** (4) exert a retractive force of at least 0.6 pound under zer acceleration when attached only to the pelvic restraint,; (5) exert a retractive force of not less than 0.2 pound and not mor than 1.1 pounds under zero acceleration when attached only to an upper torso restraint,; (6) exert a retractive force of not less than 0.2 pound and not mor than 1.5 pounds under zero acceleration when attached to a strap or webbing that restrains both the upper torso and pelvis.<<<; The test procedures of paragraph S5.2(j) specify that these retractio forces are to be measured with the belt webbing extended from the retractor to 75% of its length.; The requirements of S4.3(j) apply to *each* retractor on a Type 1 o Type 2 belt system. There is no exception in the standard for a system which includes two or more retractors which exert force on the same belt webbing. Thus, both retractors on your proposed system would have to comply with the requirements of the standard independently of one another. Under the test procedure you suggest, the retraction force of the inboard retractor would not be measured. This is contrary to the explicit language of the standard.; Both retractors on your proposed system would have to comply with th force requirements of paragraph S4.3(j)(6). This is true because both retractors are attached 'to a strap or webbing that restrains both the upper torso and the pelvis.' Therefore, the retraction force on your inboard retractor must be not less than 0.2 pound and not greater than 1.5 pounds when the webbing on that retractor is extended to 75% of its length. The same is true for the retractor on the continuous loop portion of the system.; I hope this has clarified any misunderstanding you might have ha concerning these requirements.; Sincerely, Frank Berndt, Chief Counsel