Interpretation ID: nht79-2.32

DATE: 10/15/79

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood for F. Berndt; NHTSA

TO: United States Testing Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

OCT 15 1979

NOA-30

Mr. Frank Pepe Assistant Vice President Engineering Division United States Testing Company, Inc. 1415 Park Avenue Hoboken, New Jersey 07030

Dear Mr. Pepe:

This responds to your recent letter concerning the testing procedures specified in Safety Standard No. 209, Seat Belt Assemblies. Specifically, you ask about the proper sequence of requirements and testing procedures provided in paragraphs S4.3(j), S4.3(k), S5.2(j) and S5.2(k).

Paragraph S4.3(j) provides that a retractor must meet certain requirements when tested in accordance with S5.2(j). Compliance with this paragraph should be determined initially. Then, paragraph S4.3(k) provides that the same retractor must be able to comply with paragraph S4.3(j) after being tested in accordance with S5.2(k), except that the retraction force is only required to be 50 percent of its original value. This original value was determined, of course, during the compliance procedure of S5.2(j). Therefore, the first interpretation included in your letter is correct.

Sincerely,

Frank Berndt Chief Counsel

August 22, 1979

Mr. Joseph J. Levin, Jr. Chief Council National Highway Traffic Safety Administration 400 7th Street Washington, D.C. 20590

RE: FMVSS No. 209 Seat Belt Assemblies, Interpretation Emergency Locking Retractor, Test Sequence

Dear Mr. Levin:

Several manufacturers have raised questions pertaining to the testing of Emergency Locking Retractors in accordance with FMVSS No. 209. The specific paragraphs in question are S4.3 (j), S4.3 (k), S5.2 (j) and S5.2 (k).

One interpretation of the standard is as follows:

S4.3 (j) and (k) are Requirement paragraphs and S5.2 (j) and (k) are Demonstration paragraphs. Keeping this in mind, it appears that S4.3 (j) requires an Emergency Locking Retractor (ELR) to be tested for lock up distance and retraction force in accordance with the procedures of S5.2 (j) in the "as received" condition. Paragraph S4.3 (k) requires an ELR to be tested for performance (environmental conditioning and cycling) in accordance with S5.2 (k) and then again comply with S4.3 (j) and also with paragraph S4.4.

Another interpretation is that paragraph S4.3 (j) and (k) specify the requirements for an ELR and paragraph S5.2 (j) indicates what to test and S5.2 (k) specifies when to test for conformance with S4.3 (j) and (k). Therefore, retraction force measurements are made prior to performing the cycling testing. After cycling, lock-up distance and final retraction force are measured.

I would appreciate your prompt review of the above interpretation and your opinions as to which is the proper meaning and intent of FMVSS No. 209.

Very truly yours,

Frank Pepe Assistant Vice President Engineering Division

FP:mg