ID: nht74-5.4

DATE: 02/19/74

FROM: AUTHOR UNAVAILABLE; A. G. Detrick; NHTSA

TO: White Motor Corporation

COPYEE: J. W. MURRAY; MR. PESKOE; MR. VINSON

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of February 4, regarding the proposed owner defect notification letter for defect notification campaign #73-0140.

Your letter fails to conform to 49 CFR, Part 577 as it states in the second sentence that the defect exists in equipment items manufactured and supplied by Rockwell International Corporation. We do not consider this statement to be responsive to 577.4(b)(1). As White Motor Corporation in the manufacturer of the motor vehicles involved, its determination and the statement required pursuant to 577.4(b)(1) must be to the effect that it has determined that a defect exists in the vehicles you identify in the following sentence.

The wording used by White Motor Corporation in the owner letter for defect notification campaign #73-0242 is an example of a letter which does conform to the regulation.

The National Highway Traffic Safety Administration (NHTSA) is aware that there is a disagreement between White Motor Corporation and Rockwell International as to the exact cause of the defect. The NHTSA does not wish to become a party to this disagreement and in our opinion we cannot allow White Motor Corporation to use the owner notification letter as a forum to air their views.

I trust that you will make the appropriate changes to the owner notification letter and submit a revised copy to this office.

ID: nht74-5.40

DATE: 04/03/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: House of Representatives

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 19, 1974, request for information in behalf of Mr. Robert J. Jones, concerning the commercial offer he received for a device that would defeat the ignition interlock device found on 1974 model passenger cars.

The National Traffic and Motor Vehicle Safety Act of 1966 authorizes the issuance of motor vehicle safety standards, one of which requires occupant crash protection, one aspect of which is the ignition interlock system. Section 108(a)(1) of the Act prohibits the sale, offer for sale, introduction into interstate commerce, or the importation of any motor vehicle which does not conform to the standards. Our regulatory authority over new vehicles ends, however, with the first purchase of the vehicle in good faith for purposes other than resale. While we can prohibit arrangements between a dealer and a purchaser to disconnect the interlock, where they are part of the sales transaction, we have no remedy against arrangements to defeat the safety features made after the sales transaction.

Nevertheless, while selling devices intended to defeat safety equipment may be legal, we consider such practices reprehensible since they increase the chances of death and injury on the highways. We are considering a variety of remedies for the situation reported by Mr. Jones.

ENCLS.

Congress of the United States

House of Representatives

Washington, D.

March 19 1974

Congressional Liasion National Highway Traffic Safety Administration 400 Seventh Street S.W. Washington, D.C. 20590

Sir:

The attached communication is sent for your consideration. Please investigate the statements contained therein and forward me the necessary information for reply, returning the enclosed correspondence with your answer.

Yours truly,

Frank Thompson, Jr.

M.C.

Re: Mr. Robert J. Jones

FEBRUARY 27, 1974

Honorable Francis Thompson House of Representatives Washington, D.C.

Dear Mr. Thompson:

The enclosed letter arrived in the mail today.

Could you have someone on your staff direct this letter from Merit Enterprise to the proper "Consumer Advocate Bureau" or governmental watch dog agency as a register of my protest against obvious effort to thwart the new safety laws?

I protest this crazy bridgefree enterprise that allows groups like Merit Enterprise to make a buck by devising ways to short cut and render unworkable good laws.

Sincerely yours,

Robert J. Jones Lawrenceville, N.J.

Dear New Car Owner:

We trust that you are pleased with your 1974 automobile. We are not so sure that you are pleased with the seal belt-starter interlock system which is standard equipment under a Congressional mandate.

There are times when this system is not only inconvenient, uncomfortable, and impractical, but also unsafe. For instance, when a child is buckled in the passenger's seat, there is a chance that his face or neck can be severely injured in a collision by the shoulder harness.

We are sure that you have already found that an article in either the passenger or center seat makes it necessary to buckle the article up to start the vehicle. This is most inconvenient for those of us who transport a briefcase, a bowling ball, or even a bag of groceries.

Recognizing these shortcomings in the seat belt interlock system, Merit Enterprises manufacturers and markets BELT-MATE, a product which allows you, the vehicle owner to temporarily override the system when it isn't prudent for personal safety.

If you feel the decision, "To Buckle or Not to Buckle", should be made by you instead of Congress, send $ 4.98 in cash, check or money order for your BELT-MATE to Merit Enterprises, Box 4068, Hampstead, N. C. 28443. Your Belt-Mate comes complete with instructions - no wiring needed, and your satisfaction is guaranteed.

Allow 2 to 3 weeks for delivery. North Carolina residents add 4% sales tax.

Awaiting your reply.

Very truly yours,

John R. Merit

ID: nht74-5.41

DATE: 03/29/74

FROM: AUTHOR UNAVAILABLE; LAWRENCE R. SCHNEIDER; NHTSA

TO: TIRE RETREDING INSTITUTE

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 22, 1974, concerning an article in the November 1973 Retreader's Journal entitled "Repairing Torn Beads." You ask whether the article is correct when it states that casings with cord exposed in the bead area may be retreaded.

Standard No. 117 (S5.2) prohibits the retreading of any casing on which bead wire or cord fabric is exposed before processing. "Processing" encompasses the entire process, including the making of any needed repairs, by which a casing is retreaded. The NHTSA has taken the position that the only exception to this prohibition is that casings with exposed chafer fabric may be retreaded. A casing that before processing has any exposed bead or cord material other than chafer fabric, however, may not be retreaded. Therefore, insofar as the Retreader's Journal article states that casings with exposed cord in the bead area may be retreaded it is incorrect.

We have sent a copy of this letter to the Retreader's Journal.

CC: RETREADER'S JOURNAL

TIRE RETREADING INSTITUTE

February 22, 1974

Edward Wallace National Highway Traffic Safety Administration

Several of our members have questioned thie practice of repairing damaged beads on passenger tires.

It has been our interpretation of Standard 117 that a damaged bead is an exposed bead and therefore can not be retreaded.

At a recent meeting of retreaders, a group of them took exception to our interpretation and quoted an article appearing in the Retreader's Journal. A copy of that article is enclosed.

Please let us know how to handle the question.

Philip H. Taft Director

Enclosure Omitted.

ID: nht74-5.42

DATE: 03/20/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Western Auto Associate Store

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your request for information on Standard 119, New pneumatic tires for vehicles other than passenger cars, and on a "Petition #2" concerning exemption of "Mopeds" from the motorcycle regulatory category.

Standard 119 applies to tires, not vehicles, and therefore it regulates only the manufacturer of the tire, not a retailer of vehicles like yourself.

The "Petition #2" to which you refer was filed by Mr. Robert Smith of Ohio Bikes, 631 Broad Street, Columbus, Ohio 43215, asking for a redefinition of "motorcycle" to exclude Moped-type vehicles, and a change in the lighting standard to exclude Moped-type vehicles from the present motorcycle requirements.

Yours truly,

WESTERN AUTO ASSOCIATE STORE

RICHARD B. DYSON A'SST. CHIEF COUNSEL DEPT. OF TRANSPORTATION

I thank you for your responsive letter Feb 4, 1974 concerning my inquiry on Status of Solex reports. In your letter you(Illegible Word) to a new standard affecting tires on mopels. Standard #119 effective March 1, 1975. Could you please furnish me with the specific requirements of this standard.

Also(Illegible Words) of a new Petition, referred to as Petition #2 which is currently before the D.O.T. asking that some of these requirements on mopels be(Illegible Word) to the extent that they not be classified with motorcycles but more in the cycle classification. Could you please furnished us with more detailed information regarding this Petition.

THANK YOU.

ID: nht74-5.43

DATE: 08/01/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 1, 1974, letter concerning Volkswagen's petition to exempt its pre-bent vacuum hose from some requirements of Standard No. 106-74, Brake hoses. You requested that we confirm that an in-line vacuum check valve is not regulated under the standard, and that the standard's use of "light duty" and "heavy duty" vacuum hose terminology corresponds to the use of those terms in the SAE Standard J1403a. We responded to the Volkswagen petition in a letter of July 2, 1974, to Mr. J. W. Kennebeck of Volkswagen.

You are correct in your conclusion that an in-line check valve like the valve in Volkswagen's pre-bent vacuum line is not a brake hose fitting subject to the requirements of Standard No. 106-74.

The National Highway Traffic Safety Administration tends to make the same distinction between light and heavy duty vacuum hose types as is made by the SAE Standard J1403a, which is based on the thickness of the hose wall. In addition to those sizes listed by the SAE we have added 9/32-inch hose.

YOURS TRULY,

VOLKSWAGEN OF AMERICA, INC.

July 1, 1974

Tad Herlihy, Esq. Office of Chief Counsel NHTSA

This will confirm our recent telephone conversation concerning FMVSS 106 applicable to brake hoses.

I understood you to say that Notice 11 of Docket 1-5 was not intended to serve as a response to our letter of April 26, 1974, which raised several questions concerning the applicability of S 9.2, 9.2.2, 9.2.3, 9.2.7 and 9.2.10 to certain pre-bent non-metallic vacuum hoses used by Volkswagen. You indicated that a separate response would be forthcoming in the near future.

You also confirmed that vacuum line check valves, regardless of where they are located in relation to the engine, whether in line, such as Volkswagen's, or directly connected to the engines, are exempt from Section 106.

In a separate telephone conversation, Mr. Ziwica raised the question as to whether the substance of the definition of "light and heavy duty vacuum brake(Illegible Word)" was identical to that used in SAE J 1403. I understand that it was the NHTSA's intent to incorporate the SAE definitional elements although somewhat different language was chosen. If my understanding is incorrect, please let me know as soon as possible.

Gerhard P. Riechel Attorney

cc: Mr. K.-H. Ziwica

ID: nht74-5.44

DATE: 08/01/74

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Lieberman; Tratras & Markowitz

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 16, 1974, forwarding to us a second sample defect notification letter regarding the failure of certain trailers manufactured by Bill's Trailer Manufacturing Company to conform to Standard No. 108.

Your notification letter still fails to conform to applicable requirements (49 CFR Part 577, copy enclosed for your further reference). Particularly, Part 577 requires a specific opening statement, which you have omitted, and a specific second statement, which you have altered. We refer you to the regulation regarding the opening statement. With respect to the second, it must state, following the regulatory format, that the manufacturer, Bill's Trailer Manufacturing Company, has determined that a safety related defect exists. We also prefer, in the case of a defect resulting from a noncompliance, that, in addition to describing the equipment that is missing and that will be installed (as you have done), the notification include a statement that the defect results from the failure to conform to Motor Vehicle Safety Standard No. 108. This information could come at the end of the second sentence of your first paragraph, which we assume will be rewritten to conform to this letter. In other respects your letter does conform to Part 577.

For your information, any future defect reports should be sent to the Office of Defects Investigation rather than to this office.

NHTSA has discontinued its mailing list concerning new regulations. I enclose a copy of an information sheet on how to obtain our standards and other regulations.

ID: nht74-5.45

DATE: 08/01/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Bayerische Motoren Werke AG

TITLE: FMVSS INTERPRETATION

TEXT: This responds to BMW's June 20, 1974, question whether 7/16-inch vacuum tubing may be manufactured and sold although it does not appear in Table V of Standard No. 106-74, and if so, what Table V values would be used in testing it.

Table V establishes test values for vacuum hose but does not limit the vacuum hose sizes which may be manufactured and sold in conformity with the standard. You are free to utilize 7/16-inch vacuum hose, and the Table V test values for 15/32-inch hose should be used to test 7/16-inch hose.

We are considering the addition of an entry in Table V to cover 7/16-inch hose in the near future.

YOURS TRULY,

Bayerische Motoren Werke KTIENGESELLSCHAFT

AIR MAIL

Docket Section

National Highway Traffic Safety Administration

June 20, 1974

Betreff: Standard 109; Vacuum Brake Hose Tests

With reference to Table V (38 FR 31308) of the subject standard, BMW would like to forward the comments and requests contained below.

Table V lists various values relating to vacuum brake hoses of different inside diameters. We are presently contemplating the use of such a hose whose I.D. is 11.1 mm, or 7/16 of an inch, which is not included in the table.

There is concern here that it may have been omitted if, for some reason, this size is not approved.

If use of the 7/16 inch size is permitted, we would like to have written statement to that effect - since it is not part of the present table - and would further request that, in the interest of completeness, this size be included in future tables.

Accordingly, we await your reply.

ppa. i.v.

(Kraft) (Fellerer)

ID: nht74-5.46

DATE: 08/22/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Universal Tire

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of August 6, 1974, asking what registration procedures apply to tires manufactured before May 22, 1971, but sold after that date.

We interpret Part 574 of the Code of Federal Regulations, which establishes the tire registration requirements, as applying only to tires manufactured after the effective date of the regulation, May 22, 1971. Therefore, tires manufactured before that date need not be registered.

YOURS TRULY,

Universal Tire

National Highway Traffic Safety Administration Department of Transportation

Attention: Dick Dyson, Acting Chief Counsel

August 6, 1974/Letter #3747

I have just finished conversing with Mr. Cassanova who was very helpful; however, he referred my question to your department for legal advice.

Universal Tire is contemplating purchasing a number of containers of tires of foreign manufacture which have the old type serial number used prior to May 22, 1971. I am advised by Mr. Cassanova that we can sell these tires in view of the fact they have the old type serial number. They also are marked "D.O.T." and, of course, meet all D.O.T. specifications. We would be happy to have a letter to this effect written by the manufacturer if you suggest we do so.

Would you please reply by mail as to whether these tires would require registration as applies to the current system.

Your quick response and time is appreciated.

Thanking you in advance, I remain

Bruce Ladson Assistant Division Manager

ID: nht74-5.47

DATE: 04/22/74

FROM: AUTHOR UNAVAILABLE; James B. Gregory; NHTSA

TO: American Safety Equipment Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 3, 1973, petitioning for amendments to paragraphs S4.9 and S5.3.1 of Motor Vehicle Safety Standard No. 213 which would allow the use of a buckle release mechanism design that requires, before release, some foreshortening of the belt system to reduce the load on the release mechanism. This design cannot meet the existing requirements of S4.9 of Standard No. 213 with the device under load. We wrote to you on August 20, 1973, and on December 17, 1973, requesting additional data. We have not received a response from you to either letter.

We have decided that your petition should be denied. Our objection to the design you wish to employ is that it cannot be released when the belt restraint system is under load. The NHTSA believes, and has adopted its position in Standard No. 213, that a fundamental safety requirement for any occupant restraint release mechanism is the ability to release when it is under a load imposed by the weight of the occupant. In many vehicle crashes restraint systems may be loaded in this fashion when occupants must be removed.

We do not disagree with your argument that mechanisms which release under load may more readily be released by children when release is undesirable. We believe the greater safety problem, however, is presented by designs which are difficult to operate because they require a prior unloading of the release mechanism. These systems may not be able to be released, even by adults, in crash situations. Data we have received indicates substantial difficulty in the ability of adults to release a child from a child seat in situations (total darkness) simulating emergencies. The study in question has been conducted by the National Swedish Road and Traffic Research Institute and is on file in Docket No. 2-15.

Moreover, we believe buckle release mechanisms should be operable by older child occupants, particularly in situations such as in upside-down configurations where a load is imposed on the mechanism. This purpose is met by the existing requirements of the standard but would not be met were we to grant your petition.

In your petition you argue that even a lower release force does not necessarily mean that the occupant will be able to escape easily from the restraint system. While this may be true, as no requirements are specified in Standard No. 213 regarding ease of belt removal, it is not a justification for increasing the difficulty of operating the buckle release mechanism.

SINCERELY

August 3, 1973

Administrator National Highway Traffic Safety Administration Subject: Petition for Rule Making

Reference: MVSS213, S4.9 and S5.3.1

American Safety Equipment Corporation is a major developer and manufacturer of safety belt restraint systems for automobile manufacturers. American Safety personnel have a great deal of experience designing aircraft and automotive restraint systems, particularly hardware such as buckles, retractors and associated items. The Company has been active since 1966 in the business of designing and producing restraint harnesses and complete seating systems for children in the 20 to 40 pound size range. The Company has been working on development of a new child safety seat since 1970 basing the basic design criteria on dynamic performance under simulated crash testing, while also observing the current static testing regulation. Final testing of prototype models has been completed on the design considered optimum for performance, economy and simplicity of use.

This petition is submitted in accordance with the procedure described in Subpart B Section 553.31. This proposal is to add a performance requirement and test procedure for an occupant harness release mechanism not currently considered by the Child Seating Systems regulation. The mechanism is not of a nature normally classified or described as a "buckle", but for purposes of MVSS213, is being considered a release mechanism.

The proposed additions and revisions to MVSS213 are shown underlined:

S4.9 (b) Release when a force of not more than 20 pounds is applied when tested in accordance with S5.3 expect for systems described by S4.9 (c).

2 (c) Release when a force of not more than 10 pounds is applied when the release mechanism requires foreshortening of the webbing restraint components to activate and is tested in accordance with S5.3.1 (d).

S5.3.1 For forward-facing child seating systems where foreshortening of the webbing restraint components is not required by the release mechanism -

(a) -- unchanged --

(b) -- unchanged --

(c) -- unchanged --

When foreshortening of the webbing restraint components is required to actuate the release mechanism -

(d) Test the system with a 1,000-pound force as specified in S5.1, remove the force completely and then release the mechanism in a manner typical of that employed in actual use.

Photographs are enclosed showing the release mechanism actuation under normal and simulated emergency conditions and a typical testing set-up to determine release force. The application of force to release the occupant harness must simultaneously pull down on the abdominal pad and the shoulder straps thereto attached and upwards under the metal latch. This is very simply described as a "pinching" action of the thumb and first and/or second finger. The shoulder straps are thereby foreshortened and the occupant will be forced rearward (unless lifted or pushed) toward the back surface of the child seat. The hand not activating the release mechanism can be used to move the child's torso away from contact with the restraint straps. The actuation of the release mechanism with the belts in a slackened condition is an easy one-hand operation with a low force requirement.

The performance criteria on which our restraint release mechanism design is based are as follows:

1. The mechanism must be capable of restraining the occupant when the system undergoes dynamic forces of an auto crash without distortion of any kind which could result in a jammed or difficult-to-release condition.

2. Child must not be able to easily release himself.

3. The mechanism must be extremely easy to understand from the standpoint of an adult learning how to actuate. Similarity to current production adult safety belt hardware assures the shortest possible learning time by an adult.

3 These criteria were formulated after studying field experience of consumers and consulting with experienced people in various phases of the child and adult restraint business. This experience indicated to us that -

1. A common possible problem with many child seat harness buckle release mechanisms is that the release mechanisms could be easily actuated by the child occupant. The child is protected only while sitting in the seat with the harness secured.

2. Emergency removal of a child occupant from a wrecked automobile should be accomplished within a minimum time. Emergency removal always involves supporting at least a portion of the child's weight while releasing the harness mechanism. After an accident the child's weight is forced against the restraining straps if the car has overturned or if the car seat back is exerting pressure on the child and/or child's seating system.

3. Restraint harness buckles which have a low release force (even under occupant's weight load) may not completely detach all components of the harness system from the occupant. Such components as shoulder and/or lap belts may remain wholly or partially attached to the buckle and could interfere with the removal of the occupant from the seating system.

Much subjective information from consumers was also evaluated by us to finalize the release mechanism design since it is considered one of the key components of the overall child seating system. Real-world data is scarce on crash performance of child restraint systems, but accident experience is reasonably hypothesized from experience with children and emergency post-crash situations. It is considered reasonable by us that release mechanisms which actuate under the test procedures now in effect are likely to be released wholly or partially be a child prior to a crash. Protection in low speed, as well as high speed crashes, is important and a securely fastened harness is mandatory for protection. Driver distraction by unrestrained children can also cause accidents which is minimized by a release mechanism not easily operable by the child. Supporting the child's weight or otherwise relieving pressure of the child's body from the harness webbing during emergency removal is consistent with a majority of conceivable accident conditions and always would be a requirement with the impact-shield type restraints (no harness) where the occupant would be expected to be wrapped around the impact shield after a crash. Self-removal from a harness restraint under emergency conditions by a child in the 20 to 40 pound age group

4 is not reasonable unless the child is taught expressly for this purpose. In such a case, training in body articulation and hardware manipulation is probably difficult for the proposed release mechanism.

American Safety is planning procurement of the necessary tooling for manufacturing the child seat design incorporating the proposed release mechanism. The proposed child restraint release mechanism and release procedure is nearly identical to the release of the detachable shoulder harness pin-connector in production for adult restraints in certain cars for three years. The pin and plastic grommet used on the child restraint mechanism proposed are parts produced for several different 1973 model cars. The Company requests the addition of the proposed requirements to MVSS213 to permit it to manufacture and sell the child restraint product.

Gordon M. Bradford Vice President, Corporate Development

enclosures

(Graphics omitted)

PHOTOGRAPH NO. 1

Restraint release mechanism -- This general view shows the similarity to the established pin and connector design now in production for shoulder belts on adult restraints. The two straps above the release mechanism are adjustable upper torso restraints. The release mechanism is affixed to the abdominal pad and the adjustable crotch strap is sewn permanently to the release mechanism connector.

PHOTOGRAPH NO. 2

Release mechanism activation -- The initial step in activating the release is as shown. The thumb depresses the abdominal pad and foreshortens the upper torso restraints. The index finger or middle finger holds up the connector while the pin is forced downward.

PHOTOGRAPH NO. 3

Release mechanism activation -- The completion of the releasing operation shows the pin and grommet now moved downward into the enlarged opening of the connector where it is completely separated from the crotch strap and connector. A slight forward pull with the finger finishes the release. The connector is then dropped and the abdominal pad with upper torso straps attached is swung upward over the occupant's head for removal when the seat is situated in a normal horizontal attitude.

PHOTOGRAPH NO. 4

Release force requirements -- A possible form of measurement device which operates the release mechanism in a manner typical of that employed in actual use is shown. This test would be performed after the child seating system had been subjected to a static load of 1,000 lbs in accordance with MVSS213, S5.1. Following this the release force test would be done in accordance with the proposed procedure S5.3.1(d).

PHOTOGRAPH NO. 5

The position illustrated simulates a nose-down car attitude. The child's full weight is resting on the harness. The adult is about to release the harness.

PHOTOGRAPH NO. 6

The adult has pushed upward with her left hand on the abdominal pad. This slackens the crotch strap allowing normal operation of the buckle with her right hand. The load required to release the buckle in this way is no greater than normal.

PHOTOGRAPH NO. 7

The buckle has opened and the adult has begun to lower the child. The abdominal pad has slid naturally from her left to her right hand. Her left hand continues to support the abdomen.

PHOTOGRAPH NO. 8

The adult's right hand continues to guide the abdominal pad while the left hand continues to support the abdomen. The crotch strap is completely clear of the child.

PHOTOGRAPH NO. 9

The child is out of the harness and is now on what would be either the car's dash or front seat back, depending on where the child seat was installed in the vehicle. The harness is clear of the child. No force greater than the child's weight was exerted. There were no "practice" runs after instructions on how to correctly release the child were given to the Mother.

ID: nht74-5.48

DATE: 05/17/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Renault, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 3, 1974, requesting an interpretation of the test procedure specified in Standard No. 301 (Docket No. 73-20; Notice 2) concerning the operation of the vehicle's fuel pump during testing.

Paragraph S7.1.3 of the standard requires that electrically driven fuel pumps be in operation during the barrier crash tests if they normally operate with the activation of the vehicle's electrical system. If the pump is incapable of functioning with the independent activation of the electrical system and requires the operation of the vehicle's engine, then the pump should not be running during the barrier crash tests.

Thus, the interpretation of the requirement expressed in your letter is correct.

YOURS TRULY,

May 3, 1974

Mr. Lawrence R. Schneider Chief Counsel -- NHTSA

SUBJECT: REQUEST FOR CLARIFICATION - FMVSS 301-75

We would appreciate receiving a confirmation that our interpretation of @ S.7.1.3 of FMVSS 301-75 (Docket No. 73-20; Notice 2) is correct.

@ S.7.1.3 says, "If the vehicle has an electrically driven fuel pump that normally runs when the vehicle's electrical system is activated, it is operating at the time of a barrier crash".

Our understanding is that while the ignition switch is in the "ON" position, the engine is stopped since the fuel tank is filled with an ASTM type 1 solvent. However, some vehicles equipped with an electrically driven fuel pump include a switch device that shuts off the fuel pump after 1.5 seconds, should the engine stop for any reason.

This means that during the test at the time of the crash the fuel pump will not be running even though the ignition key is turned "ON".

Thank you for your assistance in this matter.

Francois Louis Manager Technical Standards Department