Interpretation ID: nht71-3.39

DATE: 07/16/71

FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY RICHARD B. DYSON

TO: Toyota Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 20, 1971, to Administrator Douglas W. Toms, requesting an interpretation of paragraph S5.2(h) of Federal Motor Vehicle Safety Standard No. 209, and particularly of the sentence containing the phrase ". . . the retractor and webbing shall be suspended vertically . . ."

Of the two interpretations you submitted, your interpretation 2 is correct. The retractor-webbing combination is suspended vertically -- there is no restriction on the attitude of the retractor with respect to the webbing. Thus, the retractor may be suspended in the position it will be mounted in the vehicle relative to the webbing when the webbing is in use.

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