Interpretation ID: nht74-3.48

DATE: 05/31/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mitsubishi Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your verbal request to Mr. Herlihy of this office for a determination that a 3-point, continuous loop, Type II seat belt assembly would meet the requirements of @ 4.1.2.3.1(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 of @ 4.1.2.3.1, it would conform to @7.1 or standard No. 208 and @4.1(g) of Standard No. 209 with the emergency-looking retractor mounted at the outboard floor anchorage. The upper torso restraint would "adjust by means of an emergency-locking retractor" within the meaning of @7.1 as long as the continuous loop permitted slack from the floor-mounted emergencylocking retractor to reach the upper torso portion of the assembly.