Interpretation ID: 2854o
Director, Automotive Safety Engineering
General Motors Corporation
General Motors Technical Center
30400 Mound Road
Warren, MI 48090-9015
Dear Mr. Rogers:
This responds to your recent letter seeking an interpretation of Standard No. 209, Seat Belt Assemblies (49 CFR 571.209). Specifically, you stated that you believe that Standard No. 209 does not specifically address remotely actuated emergency-locking retractors. You explained that you were referring to retractors that are actuated by a deceleration sensor that is located some distance from the retractor itself. You stated that the existing uncertainty discourages vehicle manufacturers from considering the introduction of this technology. Additionally, your letter claims that it is not clear whether the test procedures in Standard No. 209 are compatible with remote sensors. NHTSA does not agree that there are existing uncertainties with respect to the applicability of Standard No. 209 to remotely actuated retractors.
The agency first addressed this issue many years back. In a letter to Mr. Nakajima of Toyota, dated March 16, 1973 (copy enclosed), NHTSA explained that Standard No. 209 does address the issue of remotely actuated retractors. In that letter, we explained that both the remotely located sensor(s) and the individual solenoids, or other actuating devices on the retractor mechanism itself, would be considered seat belt assembly hardware for the purposes of Standard No. 209. All assembly hardware must be certified as complying with the requirements of S4.3 of Standard No. 209, including corrosion resistance and temperature resistance. This 1973 letter is still an accurate expression of the agency's opinion on this subject. Accordingly, there is no need to initiate rulemaking for Standard No. 209 to "ensure compatibility with the remotely actuated retractor concept."
If you have any further questions or need more information on this subject, please contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.
Sincerely,
Erika Z. Jones Chief Counsel
Enclosure
ref:209 d:3/21/88