ID: nht79-2.27

DATE: 10/30/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bendix Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

October 30, 1979 NOA-30

Mr. R. W. Hildebrandt Group Director-Engineering Bendix Corporation 901 Cleveland Street Elyria, Ohio 44035

Dear Mr. Hildebrandt:

This responds to your September 20, 1979, letter asking the National Highway Traffic Safety Administration (NHTSA) to give you written confirmation that your tandem axle trailer brake system complies with Standard No. 121, Air Brake Systems.

The NHTSA does not provide advance determinations of compliance with the agency's safety standards. It is the manufacturer's responsibility to test for and certify the compliance of its vehicles or equipment. The agency cannot always tell by diagrams and word descriptions whether a system will or will not comply with applicable safety standards. Compliance of a braking system, such as yours, can only be determined when tested on a completed vehicle.

Our technical staff has reviewed the diagrams and the letter that you submitted. In their opinion, your system appears to comply with the requirements of the standard. However, this is merely an opinion based upon your submission and does not bind the agency in any way should your device fail any compliance tests conducted by the agency.

Sincerely,

Frank Berndt Chief Counsel

Office of Chief Counsel National Highway Traffic Safety Adm. 400 Seventh Street, S.W.

Washington, D.C. 20590

Sept. 20, 1979

Subject: Request for Confirmation - FMVSS 121

Gentlemen:

A customer of The Bendix Corporation, Heavy Vehicle Systems Group (Bendix), has requested that Bendix obtain written confirmation from the National Highway Traffic Safety Administration (NHTSA) that the two reservoir tandem axle trailer brake system (Bendix System) shown and described herein, meets the requirements of Section S5.2.1.1 and S5.2.1.2 of Federal Motor Vehicle Safety Standard 121 - Air Brake Systems. Previous Bendix studies concluded that based on the interpretation given by the NHTSA letter of January 22, 1976, to Wagner Electric Corporation (copy attached) the Bendix System is in compliance with these reservoir requirements.

The design objectives for the Bendix System were safety, performance, reliability, simplicity, and economy of cost and space. Two years of production installations of this Bendix System have proven that the design objectives have been met.

The Bendix System (Figure 1), utilizes two service reservoirs for normal service braking and reserves sufficient air pressure in one or the other to provide the required spring brake release in the event of a failure to a reservoir.

The major component of the Bendix System is the SR-4 Spring Brake Control Valve (Figure 2) whose operational functions are as described herein.

SYSTEM CHARGING

Trailer supply line air pressure enters the SR-4 valve at the trailer supply port, actuates the control piston, opens the spring brake inlet/exhaust valve and flows into the cavity under the pressure protection piston. When the air builds to a pressure of aproximately 55 psi, the pressure protection inlet valve opens and the air pressure flows past Check Valve "A" and into the rear service reservoir and PR-3 Pressure Protection Valve and then past Check Valve "B" and through the open spring brake inlet/exhaust valve and into the spring brake units. Air pressure is prevented from passing into the front service reservoir by Check Valve "C". When the pressure in the PR-3 valve reaches approximately 60 si the PR-3 inlet valve opens and the air pressure flows past the PR-3 check valve and into the front service reservoir. Both reservoirs and all the spring brake units can now be charged to full system pressure and parking brakes will be released.

NORMAL OPERATION

Service Brakes

Trailer service brakes are controlled by application and release of pressure in the trailer service line connected to the control port of the relay valve. Air pressure consumed from the front reservoir is replenished from the rear reservoir and the trailer supply line via the open PR-3 Pressure Protection Valve. The combined volume of front and rear reservoirs is at least 8 times the volume of all the service chambers at maximum travel.

Since the rear reservoir is in communication with the front reservoir via the open PR-3 Pressure Protection Valve during normal operation (system supply pressure in excess of 60 psi) that total service reservoir volume of the system is in compliance with the requirements of S5.2.1.2.

Parking Brakes

Trailer parking brakes are controlled by application and release of air pressure in the trailer supply line. Loss of supply line pressure due to trailer breakaway, leakage or operation of tractor valving causes the pressure protection valve to close and deactuates the control piston, which closes the spring brake inlet/exhaust valve and vents the air pressure in the spring brake units via the SR-4 exhaust port; thereby causing application of all trailer parking brakes. Reapplication of air pressure in the tractor supply line reactuates the control piston, opens the spring brake inlet/exhaust valve and pressurizes the spring brake units with the air pressure contained in both reservoirs; thereby releasing all trailer parking brakes.

SERVICE FAILURES

Failure of Rear Reservoir System

With a failure in the rear reservoir full air pressure is retained in front reservoir due to the check valve in the PR-3 Pressure Protection Valve and Check Valve "B". Pressure in trailer supply line is maintained at approximately 55 psi due to closing of the pressure protection inlet valve. The reduced trailer supply line pressure actuates the low pressure warning on the tractor alerting the driver to a system failure. The trailer parking brakes do not automatically apply because the trailer supply pressure keeps the control piston actuated and front reservoir pressure is maintained in the spring brake units. In this failure mode, trailer braking is provided by service brake applications on both axles using the air pressure retained in the front reservoir, or by a manual parking brake application on both axles, releaseable by the air pressure retained in the front reservoir.

Failure of Front Reservoir System

With a failure in the front reservoir, approximately 55 psi air pressure is retained in rear reservoir due to closing of the PR-3 Pressure Protection Valve and Check Valve 'C'. Pressure in trailer supply line is maintained at approximately 55 psi due to closing of the pressure protection inlet valve. The reduced trailer supply line pressure actuates the low pressure warning on the tractor alerting the driver of a system failure. The trailer parking brakes do not automatically apply because the trailer supply pressure keeps the control piston actuated and full pressure is maintained in the spring brake units. In this failure mode, trailer braking is provided by a manual parking brake application on both axles, releaseable by the air pressure retained in the rear reservoir. Air pressure in rear reservoir is rechargeable to approximately 60 psi from the trailer supply line pressure.

With respect to the foregoing service failures in the front and rear reservoir systems, the failure modes depict system functions after the reservoirs have been pressurized to 90 psi air pressure and the respective reservoir pressure has been vented to atmosphere to simulate an extreme failure in a service brake system.

In summary, the Bendix Two Reservoir Tandem Axle Trailer Brake System, with its four wheel non-automatic "back-up" braking on tandem axle trailers under conditions of a trailer service system failure, complies with the noted reservoir requirements of FMVSS 121 and provides the safety, performance and economy of cost and space objectives necessary for acceptance by the industry.

Bendix hereby respectfully requests from the NHTSA written confirmation similar to that issued to the Wagner Electric Corporation that the Bendix System complies with the requirements of Sections S5.2.1.1 and S5.2.1.2 of FMVSS 121. We would be pleased to discuss this system in more detail at your convenience.

Very truly yours,

R. W. Hildebrandt Group Director-Engineering

RWH:ep

Attachments

ID: nht79-2.28

DATE: 09/11/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Dixson, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Clay Lansdown Chief Engineer H. D. Instrument Division Dixson, Inc. P. O. Box 1949 Grand Junction, Colorado 81501

Dear Mr. Lansdown:

This is in response to your letter of August 8, 1979, asking whether construction, mining and agricultural machinery must comply with the requirements of Federal Motor Vehicle Safety Standard No. 127. In order for a vehicle to fall within the ambit of Standard 127 or any other safety standard it must be a motor vehicle. Section 103(3) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.) defines a motor vehicle as

any vehicle drawn or driven by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.

Thus, a motor vehicle is a vehicle which the manufacturer expects will use the public highways as part of its intended function.

There are two exceptions to the above rule that permit certain vehicles to use the highways without being considered motor vehicles. Agricultural equipment that is strictly used in farm fields and only incidentally uses the roads adjacent to those fields has been excepted from the definition of motor vehicle. However, not all agricultural equipment is excepted from the definition of motor vehicle. A piece of agricultural equipment, like any other vehicle, that uses the public streets and roads not adjacent to the fields on a necessary and recurring basis would be considered to be a motor vehicle and must meet the requirements of Standard 127 and the other safety standards.

The agency has further excepted certain vehicles from the definition of motor vehicle despite frequent highway use. Some maintenance and construction equipment whose maximum speed does not exceed 20 miles per hour and whose abnormal configuration distinquishes them from the traffic flow are not considered motor vehicles.

I suggest that you contact the manufacturers to whom you are selling your equipment. It is their responsibility initially for determining whether use on the public highways is part of the vehicles' intended function. The enclosed information sheet should be helpful in making that determination.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

August 7, 1979

National Highway Traffic Administration United States Department of Transportation Docket No. 76-06 Speedometer-Odometers 400 Seventh Street S. W. Washington, D. C. 20590

Dear Sir,

Our product line includes electronic speedometer-odometers. A significant portion of the units we manufacture are sold to manufacturers of construction, mining, and agricultural machinery. I am not sure if S3 of Standard 127 defines vehicles of the type listed above. These vehicles do on occasion, travel on highways, and in some cases are used to repair and build highways. The speedometers in these vehicles rarely, if ever, have markings above 40 MPH I wish to know if these vehicles are defined by S3 of Standard 127 in order to determine if the speedometers are required to meet S4.1.1 and S4.1.3 of Standard 127.

Sincerely,

DIXSON, INC.

Clay Lansdown Chief Engineer aH. D. Instrument Division

CL/ms

ID: nht79-2.29

DATE: 11/08/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Veeder-Root Company

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Alan L. Sinder Manager Vehicle Products Group Veeder-Root Company Hartford, Connecticut 06102

Dear Mr. Sinder:

This is in response to your letter of August 21, 1979, asking whether Federal Motor Vehicle Safety Standard No. 127, Speed-ometers and Odometers, applies to your product, the Veeder-Root 7-Day Tachograph, and whether the odometer provisions of the standard would apply if your product were installed in vehicles with gross vehicle weight ratings (GVWR) of less than 16,000 pounds. You also asked whether a tachograph installed in a school bus as a replacement for the speedometer and marked with speeds from 0 to 50 mph on both the dial and on the inside chart would comply with Safety Standard 127.

Section 4.1.1 of Safety Standard 127 requires that "each motor vehicle shall have a speedometer that meets the requirements . . ." of the standard. Section 4.2.1 requires that "each motor vehicle with a gross vehicle weight rating of 16,000 pounds or less shall have an odometer that meets the requirements . . ." of the standard. Therefore a tachograph installed in lieu of the speedometer and odometer in a new vehicle with a gross vehicle weight rating of 16,000 pounds or less must meet both the speedometer and the odometer requirements of Safety Standard 127. If the new vehicle in which the tachograph were installed had a gross vehicle weight rating greater than 16,000 pounds the speedometer requirements of Safety Standard 127 would apply but the odometer requirements would not.

If the tachograph were installed in a new vehicle as a supplement to an existing speedometer and odometer which meet the requirements of Safety Standard 127, the provisions of Safety Standard No. 127 would not apply to the tachograph.

Section 4.1.4 of Safety Standard 127 provides that:

No speedometer shall have graduations or numerical values for speeds greater than 140 km/h and 85 mph and shall not otherwise indicate such speeds.

Although this section specifies the maximum speed indication which may appear on the dial of a speedometer, it does not prohibit the use of a lower maximum speed indication. Section 4.1.5 of the standard provides that "each speedometer shall include the numeral '55' in the mph scale." However, this provision assumes that the speedmmeter dial will have calibrations for speeds in excess of 55 mph. If the speedometer dial will not include calibrations for speeds of 55 mph and above, then there is no requirement that the numeral 55 be included in the mph scale. This follows from the rationale on which Safety Standard 127 is based, which is to reduce the temptation for drivers to test the top speeds of their vehicles and to induce greater compliance with the national maximum speed limit of 55 mph.

I hope that you will find this response helpful and have not been greatly inconvenienced by our delay in sending it to you.

Sincerely,

Frank Berndt Chief Counsel

August 21, 1979

Ms. Kathleen DeMeter Office of Legal Counsel National Highway Traffic Safety Administration Room 5219 400 7th Street, So. West Washington, D. C. 20591

Dear Ms. DeMeter:

Mr. Kevin Cavey of the Office of Crash Avoidance suggested that I write you seeking a legal opinion concerning the coverage of FMVSS-127 in regards to Tachographs.

The enclosed literature describes our products. The Tachograph sometimes is used by itself and sometimes in conjunction with the existing speedometer. I would like to know if 127 is applicable to these products and whether the odometer sections of 127 would apply if these units were installed on vehicles of less than 16,000 pounds GVW.

We are currently working with a School Bus Authority whose installations specify a unit whose dial face shows from 0 to 50 MPH. It is probable that this unit would replace the current speedometer. Must the Tachograph face show from 0 to 85 MPH with 55 highlighted or can this School District specification stand as written ( 0 to 50 MPH on a dial and 0 to 50 on the inside chart)? The specifications also call for road speed - electro mechanical engine - governors permanently set at 45 MPH maximum.

I would appreciate your response as soon as possible as the specification for this School District requirements are in the process of being finalized.

Please do not hesitate to call me if you have any questions.

Very truly yours,

VEEDER-ROOT COMPANY

Alan L. Sinder Manager Vehicle Products Group

ALS/gsb

Enclosure

ID: nht79-2.3

DATE: 08/30/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Freedman Seating Company

TITLE: FMVSS INTERPRETATION

ATTACHMT: Attached to 8/16/88 letter to Glenn L. Duncan from Erika Z. Jones (Redbook A32; Std. 207); Letter dated 4/28/77 to Gordon P. Cress from Frank A. Berndt (Std. 210); Letter dated 2/1/88 to Erika Z. Jones from Glenn L. Duncan; Letter dated 11/16/97 to Erika Z. Jones from Glenn L. Dunn (OCC 1278)

TEXT: This responds to your recent letter asking how much deflection or deformation of seat belt anchorages is allowed under the requirements of Safety Standard No. 210, for anchorages that are attached to or are a part of revolving pedestal seats. You mention cases in which seat bases deflect so much that the seat touches the floor before the forces required by the standard are attained.

As noted in your letter, paragraph S4.2.3 of Safety Standard No. 210 specifies that permanent deformation or rupture of a seat belt anchorage or its surrounding area is not considered to be a failure, if the required force is sustained for the specified time. Likewise, the agency has stated in the past that the force requirements of Safety Standard No. 207, Seating Systems, allow some deformation of the seats during the force test, provided structural integrity of the seats is maintained.

Although Safety Standard No. 210 would allow some deformation of the seat base for anchorages that are part of pedestal seats, the structural integrity of the seats would have to be maintained during the force test. Further, you should note that Safety Standard No. 207 requires the forces for testing seats and the forces required by Safety Standard No. 210 to be applied simultaneously for seats that have belt assemblies attached to them. Thus, the pedestal seats discussed in your letter would have to maintain their structural integrity when subjected to the combined forces required by both standards. The agency Would not consider pedestal seats to be in compliance with these requirements, if the seats are displaced to an extent that the agency determines occupant safety is threatened.

I hope this letter has clarified the agency's position regarding the force requirements of both Safety Standard No. 210 and Safety Standard No. 207.

SINCERELY,

FREEDMAN SEATING COMPANY

June 22, 1979

Office of Vehicle Safety Standards National Highway Traffic Safety Administration

Dear Sirs: This letter is a request for clarification of Federal Motor Vehicle Safety Standard No. 210.

As a seat manufacturer and supplier for the Recreational Vehicle Industry, we have developed products which are intended for use in a variety of vehicles, and therefore must certify their compliance with Motor Vehicle Safety Standards when installed in these vehicles. It has become common practice for seating companies as ourselves to test certain "seating systems" on laboratory test equipment, rather than in each vehicle, and certify that the "seating system" complies with applicable Motor Vehicle Safety Standards when installed properly. In the case of revolving seat pedestals which are designed to be "seat belt anchorages" (by definition, the provision for transferring seat belt assembly loads to the vehicle structure) this laboratory testing raises certain questions relative to interpretation of MVSS No. 210. Per MVSS 210, "permanent deformation or rupture of a seat belt anchorage or its surrounding area is not considered to be a failure, if the required force is sustained for the specified time." Since no limitations are set for seat belt anchorage deflection, many seat manufacturers have ignored this aspect totally, and tested seat bases (seat belt anchorages) to force requirements only. In some cases, the seat bases deflect so much that the front edge of the seat is touching the floor before the required force is eventually attained. (See enclosed photographs.) While it would appear obvious that these bases are not in compliance with MVSS 210 for driver application, since the seat back would have impacted the steering wheel prior to the required force being attained, (the steering column is sustaining part of the force) the bases appear to be in compliance with MVSS 210 when installed at a location in a vehicle where there is nothing to obstruct free movement of the seat.

Our request at this time is that the Department of Transportation supply us with its interpretation of MVSS 210 to the extent that it would consider seat bases of this type in compliance or not in compliance with the standard.

Secondly, with respect to the intent of the safety standards, it would appear that future consideration should be given to setting deflection limitations in Motor Vehicle Safety Standards 207 and 210. If the "seating system" or "seat belt anchorage" is able to sustain required forces only after the occupant has impacted the steering wheel or windshield, it appears that we have met a safety standard without providing the intended safety.

Your prompt attention to this matter will be appreciated.

Robert J. Wahls Chief Engineer

ENC.

Kenco Builds Stress Machine

A new stress test machine for van and motorhome seat bases has been designed and built by Kenco Engineering, Middlebury, Indiana, to meet the specifications required by the Department of Transportation (D.O.T.). The machine operates hydraulically and can exert 8,000 pounds of pull. The seat base pictured above has sustained 6,750 pounds, well over the D.O.T. requirement of 5,000 pounds for 10 seconds. Kenco will use the machine for testing seat bases, tire carriers and other products which undergo stress in use.

(Graphics omitted)

(Graphics omitted)

ID: nht79-2.30

DATE: 09/12/79

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

TO: United States Testing Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

SEP 12 1979

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

Dear Mr. Pepe:

This responds to your recent letter concerning the requirements applicable to automatic seat belts under Safety Standard No. 208, Occupant Crash Protection. Specifically, you ask for confirmation that all automatic belts must comply with the adjustment specifications of paragraph S7.1 of the standard.

Your understanding is correct. Automatic seat belts must meet the adjustment requirements of pargaraph S7.1, and those parts of Safety Standard No. 209 incorporated by reference, whether or not they are required to meet the frontal crash protection requirements of paragraph S5.1 of the standard. Automatic belts that are installed to meet the frontal crash protection requirements are excepted from the other parts of Safety Standard No. 209 by paragraph S4.5.3.4 of Safety Standard No. 208. Please contact Hugh Oates of my office if you have any further questions (202-426-2992).

Sincerely,

Frank Berndt Chief Counsel

July 23, 1979

Mr. Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street Washington, D.C. 20590 Reference: Your letter dated July 17, 1978 to Mr. George C. Nield, President, Automobile Importers of America - NOA-30.

Dear Mr. Levin:

I have this date, received a copy of your letter, referenced above, concerning the testing of passive seat belt assemblies to FMVSS No. 208 or 209 requirements. I feel that your letter may need some clarification or I need some further interpretation.

The question posed was pertaining to para. S4.5.3.4 of FMVSS No. 208. Your answer to that question was yes, that seat belt passive systems are exempt from FMVSS No. 209 testing with the exception of those that are not required to meet the perpendicular frontal crash protection requirements.

My interpretation of the Standard is that the aforementioned paragraph replaces only the assembly performance requirements of FMVSS No. 209, which is a Static Test, with the Dynamic test requirements of FMVSS No. 208.

Paragraph S4.5.3.3 of FMVSS No. 208 states that the passive belt assembly must meet the requirements of FMVSS No. 209 for retractor performance (para. S7.1 Adjustment). Therefore, all passive belt systems whether or not they are installed to meet the frontal crash protection requirements must conform to paragraph S7.1 (S4.5.3.3) of FMVSS No. 208. If my interpretation is not correct, then a retractor which will encounter more usage in a passive belt system, does not have to be tested for endurance per FMVSS No. 209 (i.e. resistance to environments, cycling and retraction force); but an active belt system which sees far less use, must meet those same 209 tests.

In view of testing programs presently in progress for several manufacturers an early reply would be greatly appreciated.

Very truly yours,

Frank Pepe Assistant Vice President Engineering Division

FP:mg

ID: nht79-2.31

DATE: 09/11/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Jack Brooks - H. O. R.

TITLE: FMVSS INTERPRETATION

TEXT:

SEP 11 1979

NOA-30

Honorable Jack Brooks House of Representatives Washington, D.C. 20515

Dear Mr. Brooks:

This responds to your note we received on August 29 enclosing correspondence from one of your constituents, Mr. Don Bush. Mr. Bush requests information concerning passive seat belts on a 1977 Volkswagen Rabbit. Apparently, he was told by the Society of Automotive Engineers that there are currently no standards for this type of restraint system.

The information given Mr. Bush by the Society of Automotive Engineers was incorrect. The National Highway Traffic Safety Administration issues safety standards and regulations governing the manufacture of new motor vehicles and motor vehicle equipment. Safety Standard No. 208, Occupant Crash Protection, specifies requirements for restraint systems in passenger cars and other vehicles (49 CFR 571.208). For 1977-model passenger cars manufacturers had three options: (1) total passive protection (protection by means that require no action by vehicle occupants); (2) head-on passive protection; (3) the installation of combination lap and shoulder belts for front, outboard seating positions and lap belts for center and rear seating positions.

Volkswagen apparently certified its 1977-model deluxe Rabbit under the second option of the standard. This option requires the vehicle to meet specified injury criteria in a perpendicular barrier crash test, and to either meet lateral and rollover criteria in dynamic impact tests by automatic means or to install lap belts at front, outboard seating positions. Volkswagen used a single, diagonal passive belt to comply with the automatic frontal crash protection requirement of the second option. Additionally, paragraph S4.5.3 of Safety Standard No. 208 allows a passive belt to be used in lieu of any other belt required by any option of the standard. Therefore, Volkswagen's single, diagonal passive belt also qualifies as a lap belt for purposes of complying with the lateral and rollover requirements of the second option.

I am enclosing a copy of Safety Standard No. 208 for Mr. Bush's information. Please have him contact Hugh Oates of my office if he has any questions after reviewing the standard (202-426-2992). Mr. Bush might also note that General Motors voluntarily installed an active lap belt in its Chevettes that have passive shoulder belts (these vehicles were introduced in the spring of this year). Active lap belts in these vehicles are not required by the standard, however.

Sincerely,

Frank Berndt Chief Counsel

2 Enclosures Constituent's Letter Standard No. 208

March 28, 1979

The Honorable Jack Brooks United States Representative District 9, State of Texas 2419 Rayburn Building Washington, DC 20515

Re: 1977 Volkswagon Rabbit passive shoulder belt restraint system

Dear Mr. Brooks:

I represent a young man who received serious head injuries in a traffic collision in which he was driving the vehicle in question. During the collision, our client was thrown against the door, the door flew open and our client was thrown out of the vehicle. We are of the opinion that the injuries were caused due to a defectively manufactured or designed passive restraint seat belt system.

We are in the process of gathering information so we can evaluate whether or not a law suit is appropriate. Today we contacted the Society of Automotive Engineers. The young man we spoke with told us that there are currently no standards for this type of passive restraint system. He did advise that there is at least one piece of legislation in Congress which deals with establishing such standards.

I would appreciate any help you could provide in the way of identifying, providing copies of or providing the names and addresses of someone who can advise me of the status of this legislation. I would also appreciate you referring me to any other individual or agency there in Washington who might be able to provide me with pertinent information.

Thanking you for your help in this matter, I am

Very truly yours,

Don Bush

DB/pw

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

ID: nht79-2.33

DATE: 12/07/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Ward Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

DEC 7 1979

Mr. E. M. Ryan Ward Industries, Inc. P.O. Box 849 Highway 65 South Conway, Arkansas 72032

Dear Mr. Ryan:

This responds to your October 8, 1979, letter asking whether your new bus design will comply with Standard No. 217, Bus Window Retention and Release. The window exit that you plan to install in the bus would slide open rather than push out and would be operated by a squeeze-type force application that is parallel to the horizontal centerline of the bus.

Standard No. 217 requires buses to be equipped with emergency exits that comply with a variety of requirements. In the case of window exits, the force application for opening them depends upon the location of the release mechanism. For example, the required force application in the high force access region, according to the standard (S5.3.2), is straight and perpendicular to the exit surface.

In applying the above requirement to your vehicle, it appears that your bus would not comply with the standard. From the pictures that you enclosed with your letter, it appears that your release mechanism falls in the high force access region. If so, the force application for opening the exit is in the incorrect direction as specified by the standard. Further, your bus would use window exits that slide open rather than push out. Although, sliding emergency exits are not prohibited by the standard, they must comply with all of the standard's requirements. Also, they must be capable of complying when the non-exit half of the window is either open or closed. The agency prefers the use of push-out emergency exits, because they are less likely to "bind up" during a side impact than sliding emergency exits.

The standard was written in its present form to provide uniformity of emergency exits in buses. A uniform exit system can help prevent confusion during accidents and facilitate emergency exit of vehicles. The vehicle that you plan to build would be unlike other buses now in operation with respect to emergency exits. The NHTSA does not think that this would be desirable or in the interest of safety.

Sincerely,

Frank Berndt Chief Counsel

October 8, 1979

Office of Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Admn. 400 Seventh Street, S.W. Washington, D.C. 20590

Ref: FMVSS 217 "Bus Window Retention and Release" Paragraph S5.3 and S5.4

Dear Sir:

Ward Industries proposes to incorporate in a new bus design an emergency exit described as a horizontal sliding type. The window consists of two sliding sections, one of which opens large enough to admit unobstructed passage of an ellipsoid as required and described in Paragraph S5.4.1.

The sliding section of this window slides fore and aft and parallel to the longitudinal center line of the bus. The window is not hinged at the top and does not swing out or "push out." It appears that the suggested type of emergency exit would comply with the requirements of FMVSS 217, Paragraph S5.4.1. Will this type of action be acceptable?

The latching mechanism consists of a single latch which holds the sliding section in position. (See enclosed photos.) The release mechanism requires for release a squeeze type application to open. The force application for release is aft and parallel to the horizontal centerline of the bus. Will this type of release mechanism be acceptable?

We would appreciate very much an early reply. Thank you in advance for your consideration.

Sincerely,

E. M. Ryan, Specifications Engineering Mgr.

EMR/ws

Enclosures

ID: nht79-2.34

DATE: 02/02/79

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: United Bus Sales, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

FEB 2 1979

NOA-30

Mr. Melvin Ives President United Bus Sales, Inc. 6700 S. Garfield Avenue Bell Gardens, California 90201

Dear Mr. Ives:

This responds to your November 6, 1978, letter asking for an interpretation of the warning buzzer requirement of Standard No. 217, Bus Window Retention and Release.

The standard requires a warning buzzer to sound when an emergency door release mechanism is not in the closed position and the vehicle's ignition is on. From conversations with you and our Office of Vehicle Safety Compliance, we have determined that your rear emergency door uses a warning buzzer that sounds when the door release mechanism is not in the closed position unless someone continues to exert pressure to hold the door closed. The National Highway Traffic Safety Administration considers such a warning device to be in compliance with the standard. The purpose of the warning alarm is to warn passengers and the driver when a door is accidentally left in the open condition while the vehicle ignition is in the on position. Your device appears to meet the intent of the standard.

We have discussed this issue with Mr. Jerry Alexander of the California Highway Patrol, and he has indicated that he will accept our determination. We are sending him a copy of this letter for his information.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel cc: Mr. Jerry Alexander P.O. Box 11730 Fresno, California 93775

November 6, 1978

National Highway Traffic Safety Administration 400 West 7th Street Southwest Washington, D.C. 20590

Attention: Chief Counsel

Gentlemen:

It has been suggested by the Commercial Vehicle Section of the Highway Patrol, State of California, that we ask you for a legal interpertation of Federal Standard, Part 571; S-217, Section S5.3.3 (C) pertaining to the position of the release mechanism and the sounding of the warning buzzer.

Specifically:

"When the release mechanism is not in the closed position, and the vehicle ignition is in the "on" position, a continuous warning sound shall be audible--------."

It is our feeling that our van-type school buses comply. It would, however, be most helpful if we could have an interpretation of the above quoted section for clarification. Mr. George Shifflett, your Compliance Specialist, has visited our plant and is familiar with the details of our units and our request and has been most helpful to us.

Sincerely,

UNITED BUS SALES, INC.

Melvin Ives President

MV/daw

cc: Zemaitis, Joseph Shifflett, George Campoy, Cliff Canova, Andy 02/02/79

ID: nht79-2.35

DATE: 09/12/79

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

TO: Sheller-Globe Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

SEP 12 1979

NOA-30

Mr. R. M. Premo, Director Vehicle Safety Activities Sheller-Globe Corporation 3555 St. Johns Road Lima, Ohio 45804

Dear Mr. Premo:

This responds to your August 27, 1979, letter asking how the agency tests a floor joint for compliance with Standard No. 221, School Bus Body Joint Strength. You enclosed a sketch and sample floor joint with your letter and asked in which direction the forces would be applied for test purposes. You suggested that the forces be applied in a perpendicular direction to the floor.

The floor joint that you manufacture is welded in three locations. One weld is located on top of the floor surface and joins the two panels together. The agency concludes that this joint should be tested by applying force in a direction that is parallel to the floor surface, not perpendicular to it. This is the procedure that is specified in section S6 of the standard for testing joints that are constructed in a manner similar to the floor joint in your vehicle.

Sincerely,

Frank Berndt Chief Counsel

August 27, 1979

Office of the Chief Counsel U. S. Department of Transportation 400 7th Street, S.W. Washington, D. C. 20590

Attention: Mr. Roger Tilton

Dear Mr. Tilton:

The purpose of this letter is to obtain an interpretation of the testing procedure that will be used to check the underbody joints shown in proposal number 2.

It is our interpretation of FMVSS 221 that both joints, floor panel to crossmember and floor panel to floor panel, would be tested in the direction of the arrows shown on the enclosed proposal.

An early reply will be appreciated.

Very truly yours,

R. M. Premo, Director Vehicle Safety Activities

RMP:cr Enclosure