Interpretation ID: nht71-4.44

DATE: 11/10/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Toyota Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: As indicated to you in the November 1 meeting in Mr. Laskin's office, the seat belt retractor demonstrated by Toyota and shown on page 9 of the attachment to your letter is considered by the National Highway Traffic Safety Administration to be an automatic locking retractor. The classification of a retractor is determined by its operation, not by its design, and the Toyota retractor, however unconventional in design, operates in the manner prescribed for automatic locking retractors.

With respect to the test procedure of S5.3(a)(6), it is the intent of the test to load the seat belt assembly in a manner that represents the type of tension encountered in use. It is our opinion that the test set up shown on page 9 of the attachment to your letter is a correct application of the procedure to the Toyota retractor.

Please advise us if we can be of further assistance.