Interpretation ID: nht73-3.43

DATE: 03/16/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Toyota Motor Sales, USA, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 9, 1973, concerning the application of Standard 209 to emergency locking mechanisms that Toyota intends to use in its 1974 models. Mr. Susuki of your staff presented Toyota's problem at greater length in a meeting with NHTSA on March 2, 1973, and the following response serves to confirm the opinion given him at that time.

Both the central G-sensing device (with its computer) and the individual(Illegible Word) on the retractors are considered to be seat belt assembly hardware for purposes of Standard 209. We do not find that the central position of the G-sensor is a sufficient reason to exclude it from the requirements of the standard applicable to hardware, including the corrosion requirements. However, any corrosion testing of the G-sensor would be performed with the sensor's(Illegible Word) in place. If the covering is imperious to water, as Mr. Susuki stated, there should be little difficult in passing the test.

A second question was raised by Mr. Susuki concerning the testing of the upper torso retractor. It is our opinion that the retractor should be subjected to the environmental tests in its installed condition, with its cover in place.

A final question presented by Mr. Suzuki concerns the allowable width for that portion of the upper torso belt that does not contact the occupant. As we informed him the August 1972 petition by JAMA on this subject is still open and we anticipate that the agency's action will be favorable.