ID: nht78-2.6

DATE: 08/23/78

FROM: AUTHOR UNAVAILABLE; F. Berndt for J. J. Levin, Jr.; NHTSA

TO: U. S. Suzuki Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 10, 1978, asking for an interpretation of Motor Vehicle Safety Standard No. 108. You have asked "whether an aftermarket Class A reflex reflector can be installed in addition to the original Equipment Class A reflex reflector, that is, an existing part of the motorcycle's rear combination lamp assembly." You have stated that "both reflectors would be installed vertically on the motorcycles vertical centerline," and have commented that you understand "that two reflectors may be installed horizontally about the vertical centerline, but it is unclear to us whether they may both be installed one on top of the other, vertically, as this is not addressed in FMVSS #108."

You have misunderstood Standard No. 108. Table IV clearly states with respect to location of rear reflex reflectors on motorcycles that "if two are used on the rear, they shall be symmetrically disposed about the vertical centerline." This requirement precludes the use of two rear reflectors mounted above each other vertically on the vehicle's centerline if your fender extension is sold as an accessory on a motorcycle at the time of its first purchase for purposes other than resale.

Generally, however, Federal standards do not cover vehicles after their first purchase and an owner may modify his vehicle in any manner he chooses consistent with local law. Modification by dealers, distributors, and repair businesses are prohibited only if they "render inoperative" any device or element of design installed on a motor vehicle in accordance with a Federal safety standard. Although aftermarket installation of the fender with reflector by a dealer after a vehicle's sale would not be consistent with the reflector location requirements of Standard No. 108, we cannot say that it would "render inoperative" the reflector installed as original equipment. We therefore have no objection to you offering this component as an aftermarket accessory to be added after a vehicle's initial sale.

SINCERELY,

U.S. SUZUKI Motor Corporation

August 10, 1978

Joseph J. Levin, Esquire Chief Counsel National Highway Traffic Safety Administration

Re: Request for interpretation

Dear Mr. Levin,

The U.S. Suzuki Motor Corporation is considering the addition of a rear fender extension to its Suzuki aftermarket accessory line for one of its large motorcycles. The accessory fender extension in question has as a component a Class A reflex reflector. The motorcycle's existing Class A reflex reflector is part of the rear combination lamp assembly.

The problem we are encountering is with interpreting FMVSS #108, Table IV, Location of Required Equipment, as to whether an aftermarket Class A reflex reflector can be installed in addition to the original Equipment Class A reflex reflector, that is, an existing part of the motorcycles' rear combination lamp assembly.

Both reflectors would be installed vertically on the motorcycles vertical centerline. We understand that two reflectors may be installed horizontally about the vertical centerline, but it is unclear to us whether they may both be installed one on top of the other, vertically, as this is not addressed in FMVSS #108.

For demonstration purposes we are enclosing photographs that show one of our current motorcycles in its original state (#1) and two that show the aftermarket fender extension mounted on the motorcycle (#2, #3). We would appreciate your reply as to whether or not Suzuki can offer this fender extension with reflex reflector as an aftermarket accessory, and that if aftermarket installation of it would be permitted.

Thank you for your assistance in this matter.

F. Michael Petler Assistant Manager Safety & Legislation Dept.

ENCLS.

CURRENT MODEL MOTORCYCLE WITHOUT AND WITH ACCESSORY FENDER EXTENSION

Photograph #1 Motorcycle rear fender in original state "OEM"

Photograph #2 Motorcycle rear fender with accessory fender extension installed

Photograph #3 Motorcycle rear fender with accessory fender extension installed.

(Graphics omitted)

ID: nht78-2.7

DATE: 10/31/78

FROM: AUTHOR UNAVAILABLE; S. P. Wood for J. J. Levin, Jr.; NHTSA

TO: Subaru of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 12, 1978, with respect to Subaru's intention to offer "a retracting center auxiliary lamp" on one of its models. You have asked us to comment on the lamp's nomenclature, switching, and compliance problems.

The lamp in question is not an item of lighting equipment required by Federal Motor Vehicle Safety Standard No. 108 and may be added as standard equipment provided it does not impair the effectiveness of equipment that the standard does require. Whether this device would cause impairment we cannot say since you have told us nothing of its candle-power output or its color. If it is operable by a separate on/off switch it could be viewed as impairing the effectiveness of the headlights by causing the operator to use it and rely on it at a time when the headlamps should be in use. We have no opinion on what you should call the lamp.

Even if permissible and not prohibited under Federal lighting requirements we believe that you should be aware of possible problems at the State level. An auxiliary driving light similar to the one you describe (though positioned closer to the right headlamps) was offered as optional equipment on 1969 Dodge cars, named the "Super Lite", and intended to be used in conjunction with low beam headlights to increase the strength of the headlamp system without producing the glare effects associated with high beams. The States of New Hampshire, New York, and Vermont prohibited the lamp primarily because its bluish color was judged close to that of the color reserved for use on emergency vehicles (see Chrysler Corp. v. Rhodes, 294 F. Supp. 665 (1968) and Chrysler Corp. v. Tofany, 419 F.2d 499 (1969)). We therefore suggest that Subaru review its plans with State officials.

SINCERELY,

SUBARU OF AMERICA, Inc.

September 12, 1978

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

Re: FMVSS 108

Dear Mr. Levin:

Subaru of America plans to offer as standard on our MPV, BRAT model, a retracting center auxiliary lamp. We request your office's comments to the following questions.

1. Can we call the center lamp an auxiliary driving lamp?

2. Can we use a single on/off switch for this lamp? Or must it be switched to be used only with bright beam headlamps?

3. What are the compliance problems, if any?

Paul Utans Assoc. Vice President Product Compliance

(Graphics omitted)

ID: nht78-2.8

DATE: 06/19/78

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

TO: Highway Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 1, 1978, to Mr. Vinson of this office asking whether marker lamps on your new "bevel designed front Van Trailer" comply with Federal Motor Vehicle Safety Standard No. 108. Specifically, instead of providing two amber clearance lamps, on the trailer front and two amber side marker lamps at the trailer's leading edge, you would install a combination clearance-side marker lamp at 45 degrees on the beveled leading edge of the trailer.

Paragraph S4.4.1 of Standard No. 108 permits a side marker lamp to be combined with a clearance lamp "if the requirements for each lamp . . . are met . . . ." This means that the combination lamp in position on the vehicle must meet the requirements of SAE Standard J592e, Clearance, Side Marker, and Identification Lamps, July 1972. This standard addresses specific photometric requirements for combination clearance and side marker lamps and I enclose a copy for your information.

SINCERELY,

March 1, 1978

National Highway Traffic Safety Administration

Attn: Taylor Binson Chief Consul

Dear Sir:

We would like to have a ruling on location of marker lights on our new bevel designed front Van Trailer. At present we use four (4) amber lights; two (2) on front and two (2) on side at front. Would it be permissible to use two (2) amber lights on the 45 degree front bevel corner and eliminate two (2) lights?

Enclosed is a sketch showing front of trailer marked per above.

HIGHWAY MANUFACTURING COMPANY A Division of MOTAC, INC.

LaVerne L. Kruckenberg -- Engineer

(Graphics omitted)

ID: nht78-2.9

DATE: 06/30/78

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

TO: Christy Electronics, Inc.

COPYEE: AMER. ASSOC. OF MOTOR VEHICLE ADMINISTRATORS

TITLE: FMVSS INTERPRETATION

TEXT: Our regional office in White Plains has forwarded your letter of May 29, 1978, for reply.

You have requested "approval" of your vehicle lighting system which flashes the stop lamps at a rate three times per second when the brake pedal is depressed.

We do not "approve" lighting devices but we do provide interpretations whether such devices are permissible under Federal lighting requirements. As an item of original vehicle equipment your device would appear to be prohibited by paragraph S4.6 of Federal Motor Vehicle Safety Standard No. 108. This paragraph requires that all lamps be steady - burning in operation except for turn signal lamps, hazard warning, signal lamps, and school bus warning lamps, and it also allows headlamps and side marker lamps to be flashed for signalling purposes.

As an aftermarket device, however, it would be subject to regulation by the individual States. We are forwarding a copy of your letter to the American Association of Motor Vehicle Administrators for an opinion on this point.

We appreciate your interest in safety.

Sincerely,

U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

June 8, 1978

Frank B. Caristia Christy Electronics, Inc.

Dear Mr. Caristia:

We are forwarding your letter of May 31, 1978 to the National Highway Traffic Safety Administration's Office of Crash Avoidance in Washington D.C. for their review and action.

Irving Rodness Motor Vehicle Program Specialist

CHRISTY ELECTRONICS, INC.

May 29, 1978

National Highway Traffic Safety Administration

Gentlemen:

We hereby request approval of our new product, for vehicular use, with function as described below:

1. When the brake pedal is depressed the stop lights will flash three times, at a rate of approximately three flashes per second, and then remain lit as long as the brake pedal is held depressed.

2. When the brake pedal is released, the stop lights go off and the circuit resets, ready to flash the stop lights when the brake pedal is again depressed.

This rapid flashing of the stop lights is intended as a means of "waking up" the driver of the vehicle behind you when making stops on highways.

In case of product failure, a by-pass switch can be thrown to restore the vehicles original stop light circuitry.

Please note that many drivers pump their brakes to cause the stop lights to flash, risking an accident because of increased stopping distance.

Frank B. Caristia President

ID: nht78-3.1

DATE: 04/27/78

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

TO: Bureau of Transportation - L.A., CA

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 10, 1978, question whether Standard No. 121, Air Brake Systems, applies to a device that automatically applies to vehicle's service brakes when a sensing bumper mounted at the rear of the vehicle is tripped by contact with an object during a backing maneuver. For purposes of your question, I assume that the vehicle, whether new or used, has been certified to comply with Standard No. 121 prior to installation of the device.

The answer to your question is no. Paragraph S3 (Applicability) of Standard No. 121 states that the standard applies to trucks, buses, and trailers equipped with air brake systems (with some specified exceptions). The standard therefore applies only to vehicles, and does not apply to motor vehicle equipment such as the braking actuator you describe. The vehicle must, of course, conform to Standard No. 121 following installation of the device, if the installation occurs prior to the first purchase in good faith for purposes other than resale.

After the first retail sale, $ S 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (the Act) (15 U.S.C. $ S 1397(a)(2)(A)) prohibits, with one exception, manufacturers, distributors, dealers, and repair businesses from knowingly rendering inoperative devices or elements of design installed in satisfaction on a safety standard such as Standard No. 121.

ID: nht78-3.10

DATE: 09/22/78

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

TO: Mercedes-Benz of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent question whether Mercedes may use a dynamic test to evaluate seat structure integrity instead of the static test specified in the testing procedures of Safety Standard No. 207.

The answer to your question is yes. A manufacturer is permitted to use whatever test procedures or methods of evaluation he chooses to assure its vehicles are in compliance with Federal motor vehicle safety standards. The legal requirement under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391, et seq.) is that the manufacturer exercise due care to determine that his vehicles will be in compliance with all applicable standards when tested by the agency in accordance with the test procedures specified in those standards.

Therefore, you may use a dynamic test method to determine the integrity of your vehicle seats if this constitutes the exercise of due care to assure the seats meet the performance requirements specified in Standard No. 207. Of course, it cannot be determined whether a manufacturer in fact exercised due care in advance of the actual events leading to the certification of compliance. Likewise, the agency will not approve a manufacturer's method of testing in advance of certification.

Please contact me if you have any further questions.

SINCERELY,

MERCEDES - BENZ OF NORTH AMERICA, INC.

July 3, 1978

National Highway Traffic Safety Administration

Attention: Office of Chief Counsel

Subject: Request for Interpretation; FMVSS 207

Dear Madam or Sir,

Federal Motor Vehicle Safety Standard No. 207 specifies in Section S5. Test Procedures, loading techniques to evaluate seat structure integrity. All figures in this standard depict draw bars or other force controlling devices typical of static testing procedures.

Mercedes-Benz of North America believes that such a description of these tests restricts a manufacturer from using alternative test procedures. It is also believed that dynamic testing techniques are more realistic and within the intent of this standard when they produce forces equal to or exceeding those specified in this standard. We would appreciate receiving your confirmation of this opinion at your earliest convenience to enable the use of a dynamic test as an alternative to the current technique specified.

HEINZ W. GERTH

ID: nht78-3.11

DATE: 10/06/78

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

TO: Southwest Research Institute

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your June 27, 1978, letter concerning the requirements of Safety Standard No. 207 as they would apply to pedestal seat assemblies for use in van vehicles. You ask whether your test methodology is consistent with the requirements of the standard and whether the pedestal base is considered part of the seat assembly.

As you know, the agency does not approve a manufacturer's test methods. A manufacturer must exercise due care to ascertain that his product is in compliance with all applicable motor vehicle safety standards and regulations. While your test methods appear to be reasonable, the agency will test seats in the vehicle rather than on a surrogate test frame. You must exercise due care to assure that your simulated test is a true determination whether the seats would comply with the standard when tested as provided in that standard. (The vehicle manufacturer is, of course, responsible for compliance with Standard 207.)

Regarding your second question, the pedestal base would be considered part of the seat assembly for purposes of Standard 207. This means that the agency would test the entire assembly by applying a force of 20 times the combined weight of the seat and the pedestal, contrary to your simulated test procedure of using only the weight of the seat frame and adjuster, without the pedestal base attached.

Finally, the force requirements of Safety Standard No. 210, Seat Belt Assembly Anchorages, (5,000 pounds) are applied simultaneously with the force requirements in Standard No. 207, if the anchorages are connected to the vehicle seat, to the pedestal, or to the pedestal base.

Please contact this office if you have any further questions, and please excuse the delay in this response.

SINCERELY,

SOUTHWEST RESEARCH INSTITUTE

DEPARTMENT OF STRUCTURAL SYSTEMS AND FIRE TECHNOLOGY

June 27, 1978

National Highway Traffic Safety Administration Office of Chief Counsel

Attention: Chief Counsel

Subject: Interpretation of FMVSS 207/210 Load Application to Van Seating Assemblies Gentlemen:

SwRI is currently performing qualification testing of van seating systems for commercial seat assembly manufacturers. The purpose of these tests has been to provide test data which demonstrates that the seat assembly appears to qualify to the requirements of FMVSS 207. These seat assemblies consist of a seat frame, seat adjuster tracks (if applicable), and pedestal base. Since this entire assembly is manufactured as a separate component for sale to van manufacturers, SwRI performs the tests and reports the results with the understanding that the portion of the assembly above the pedestal base does/does not appear to qualify to the load/time profile requirements of the Standard. In addition, SwRI insures that the test conditions which are not consistent with the requirements of FMVSS 207 are delineated, which are:

1. The assembly is tested on a rigid test frame (not in a vehicle).

2. SwRI utilizes available fasteners to secure the pedestal base to the test fixture (since OEM fasteners are not available).

3. Satisfactory test results are reported which indicate that only the seat structure and fasteners attaching the seat frame to the adjuster track and pedestal base appear to qualify to the requirements of FMVSS 207.

4. The fore/aft CG loads are calculated based on the seat frame and adjuster weight without the pedestal base attached.

SwRI would like an interpretation to determine if this methodology is consistent with the requirements of FMVSS 207.

SwRI has recently received a "barrel" van seat assembly which is constructed as illustrated in the attached sketch. This assembly has seat belt anchorage holes in the gussetted plate. The seat frame is attached to the gussetted plate which is secured to the pedestal base. SwRI would like an interpretation on the correct load application to this assembly by responding to the following:

* Is the load applied as required in FMVSS 207 -- i.e. Forward CG load = 20 x seat assembly weight + 2500 lbs. for each anchorage?

or

* Is the FMVSS 210 load (5000 lbs.) applied separately?

It appears the key question with these seat assemblies is, "Is the pedestal base considered a part of the seat assembly as it applies to the FMVSS 207 requirements?"

Your prompt response to this request will be appreciated as SwRI has a sponsor awaiting test results.

Charles J. Kerr Research Engineer

cc: VINCE QUARLES SEAT STRUCTURE TUBING

FIBERBOARD

PEDESTAL BASE

PEDESTAL ANCHORAGE POINTS

GUSSETTED PLATE

SEAT BELT ANCHORAGE POINTS

"BARREL" VAN SEAT ASSEMBLY

(Graphics omitted)

ID: nht78-3.12

DATE: 07/20/78

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: Hon. John Glenn -- U.S. Senate

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 7, 1978, pertaining to your constituent's, Mrs. Carl A. Koch, concerns regarding motor vehicle seat backs that do not permanently lock.

Federal Motor Vehicle Safety Standard No. 207, Seating Systems, copy enclosed, requires that hinged or folding occupant seat or occupant seat back shall be equipped with a self-locking device for restraining the hinged or folding seat or seat back and a control for releasing that restraining device. The industry is currently installing two types of seat back latches, a manual conventional type of latch and a new inertial locking device. The standard requires that the locks withstand a load 20 times the weight of the hinged portion of the seat and is not required to withstand the load of an occupant striking the seat back. Rear occupants are expected to be restrained by the rear seat belts, however, seat backs in locked position, because of some padding, do provide some protection for unrestrained occupants.

The seat back latch referred to by your constituent is an inertial seat back latch which is neither required nor prohibited by the standard. The industry, in an effort to facilitate rapid egress from a motor vehicle in emergency situations, such as a fuel fire, have introduced inertial seat back latches. The seat back latch will lock when the low forces of a panic breaking situation occurs or a high impact force occurs, releasing itself automatically when the inertial forces drop to a predetermined force, normally approximately .5g, allowing rapid occupant egress.

We believe there can be positive post-crash escape advantages for the inertial type seat back latches, however, it would appear from Mrs. Koch's experience that it may be warranted to initiate an investigation of the type of inertial latches installed in the 1978 Ford Granada. Accordingly, I am forwarding a copy of your letter to our Office of Defects Investigation for their action to determine if and what corrective action may be warranted.

I hope this information is helpful to you in responding to Mrs. Koch's inquiry. If I can be of further assistance, please let me know.

SINCERELY,

Michael M. Finkelstein Acting Associte Administrator for Rulemaking

June 2, 1978

Dear Senator Glenn,

I have no idea who to write to about what I consider a major problem and since your name and address was listed in the paper and I voted for you I am asking you to get my complaint to the right person.

I recently purchased a 1978 Ford Granada, two door car. No one told me that the seats now do not lock permanently in place and must be released. A small truck with no stop lights on back caused me to brake real fast and my eight year old was sitting on the end of the back seat and the seat acted as a slide when it fell forward and propelled my daughter right up into the windshield. I took it to the service department and have even written Ford Motor Company and they tell me that they cannot lock this seat for me as Ralph Nader has made them put in this kind of seat. They further told me that until I have an accident and maybe kill one of my little ones by having them fly out the windshield they have no way of proving wether my seats actually lock on rapid decellaration. There could be a malfunction and they have no way of checking it out. I can't believe that if you could fly in outer space there isn't something that could be done to give you a choice of wether we want our seats locked while we are driving or wether we prefer them to be movable. If no one is in the car and you stop fast the seat flies forward. It is a distraction and safety hazard. When a child is old enough to open a seat belt it is impossible to keep him in them if he wants to be able to see out the side or front window. I bought a two door car because I have eight children from twenty six to six and I want them confined while I am driving where if anything happens they will receive the least injury possible. With locked seats and no doors to open or windows to open the child is farely safe and I have never had a scare like the incedent that I related at the beginning of my letter.

I am sorry but I think Ralph Nader has made a big goof and who ever in government that is responsible for helping him make this change in automobiles better take a second look and do some more testing. I feel the manufacturer should also be required to have some way of testing to make sure that if I have an accident that these seats are going to lock as we are told they will. I have taken this car out in the country and slowed rapidly, stopped fast and done everything short of hitting a brick wall and these seats will not lock.

Thank you for getting my complaints to the right person,

Dolores A. Koch (Mrs. Carl)

ID: nht78-3.13

DATE: 02/13/78

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Emil M. Mrak

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 12, 1977, to Secretary of Transportation, Mr. Brock Adams, concerning the seat belts in your automobile.

Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, requires that the distance between the lap-shoulder belt intersection and the vertical centerline of a 50th percentile (164 pounds, 5 feet 8 inches) adult male occupant must be at least six inches when the seat is in its rearmost position. The purpose of this requirement is to reduce the risk of the occupant "submarining" out from under the belt and to reduce the possibility of the shoulder belt pulling the lap belt up onto the abdomen where it could cause serious injury in a crash.

The possibility of submarining increases as the intersection of the lap-shoulder belt is moved toward the occupant's center-line and/or as seat cushion rigidity is reduced. In other words, the closer the intersection of the lap-shoulder belt is to the centerline of the occupant, and the softer the seat, the more the danger of "submarining" in a crash. The standard does not limit the maximum distance from the occupant's centerline to the lap-shoulder belt intersection because of varying degrees of seat rigidity and installation configurations. Thus, contrary to what you may have been told, manufacturers who provide belt systems with distances greater than six inches do so by choice and not because they are required to do so by Federal standards.

Thank you for informing us of your problem.

SINCERELY,

December 12, 1977

The Honorable Brockman Adams The Secretary of Transportation

Dear Mr. Adams:

Sometime ago I wrote the Ford Company complaining about the inaccessibility of the short portion of the seat belt to a person who is up in years. I pointed out that because of the extreme difficulty of hitching these up, more and more people are failing to use seat belts. Furthermore, the twisting and squirming required could very well result in backbone injuries to elderly people.

I was astounded to receive a letter from the Ford Company indicating that the Federal Standards required such a belt. This is hard for me to believe. In any event, I would appreciate knowing if what they told me is the truth, and if it is, then, the truth, I would strongly recommend that this requirement be revised. If it is not a requirement, then I think the Ford Company should be told to take the blame off the Department of Transportation.

If Congressional help is needed to make such a change, I would be glad to pursue it.

I am enclosing copies of my letter to Mr. Wilson of the Ford Company and also his reply, which as indicated above, astonished me.

Emil M. Mrak

ENCLS.

December 12, 1977

A. S. Wilson Ford Parts and Service Division Ford Motor Company

Dear Mr. Wilson:

I am enclosing a copy of a letter I have written to the Secretary of Transportation, Brockman Adams, which is self-explanatory.

I feel so strongly in this matter that I would go to certain of my friends in Congress, if need be, and as much as I dislike most of the things that Nader does, I would even be willing to go to him.

Emil M. Mrak

ENC.

Ford Parts and Service Division Ford Motor Company

November 23, 1977

Emil M. Mrak

Dear Mr. Mrak:

We are sorry to learn of the problem you are experiencing using the seat belts in your Cougar Brougham. As you probably know, the Ford Motor Company has been an active proponent of the use of seat belt systems for many years. Ford does not have complete freedom, however, in selecting the design of the seat belt system since the Federal government does impose requirements that seat belt systems must meet. An explanation of certain of these requirements may be helpful in giving you a better understanding of why present seat belt systems are different than those you may have been accustomed to using.

For all passenger vehicles built after January 1, 1972, Federal safety standards require the installation of a three-point seat belt system; that is, a combination lap belt and shoulder harness. The Federal standard also requires that the intersection or attaching point of the shoulder harness to the lap belt be at least six inches from the centerline of an average size adult male. In the opinion of the Federal authorities, this intersection point offers the best protection to occupants using the shoulder harness. In order for Ford to satisfy this requirement, it is necessary to limit the length of the buckle portion of the lap belt.

It is clear from your letter that shortening the buckle portion of the lap belt has created a problem for some people. We regret the inconvenience but hope that it will not deter you from continuing to use the seat belt system when operating your vehicle.

We appreciate the interest you have shown in this matter and thank you for giving us the opportunity to respond to your questions.

A. S. Wilson Owner Relations

November 10, 1977

A. S. Wilson Ford Parts and Service Division Ford Motor Company

Dear Mr. Wilson:

In May I wrote to you concerning problems with my seat belts in the new Cougar Brougham we had just purchased. You replied on May 17 indicating that I should return to the selling dealer with the complaint.

First of all, I thought I made it clear in my letter that I was not complaining. I was asking for an improvement. In any event, I had the dealer refer to Ford Technical Service Bulletin 100, Article 1290, as indicated in your letter, and this advice was completely useless, and the dealer, as far as I'm concerned, was helpless.

The real problem with the seat belt is that the part attached to the seat is so short that a person of my age finds it literally impossible, or at least very difficult, to squirm around and get it attached.

I am taking the liberty of writing this second letter to you because I have read that fewer and fewer people are using seat belts. I am certain it is because of the fact that it is so difficult to use them. In order to use the belt I must squirm and fuss and work and finally I get it attached. Some day I may well injure a spinal disk.

I think this is a problem for the Ford engineers. When I wrote to you I was asking for an extension so it would be easier to attach them, but I did not get an iota of help from you.

I feel that if anyone not using the belt because of this difficulty should get into an accident and be injured, that person would have a case for suit against the Ford Company because of the inadequacy of the belt hook-ups.

I have felt like writing to the Transportation Department and also to Senator Eagleton, but since I am a stockholder in Ford, I thought I had better wait until I get another reply from you.

Emil M. Mrak

cc: BRUCE WILLIAMS

ID: nht78-3.14

DATE: 04/13/78

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

TO: P. Arquin

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking what loading conditions are applicable for purposes of measuring the wheelbase of passenger cars, under the new phased-in passive requirements of Standard No. 208, Occupant Crash Protection. Apparently, the wheelbase of one of Peugeot's vehicles having an independent rear suspension varies as a function of the vehicle loading.

The phased-in passive requirements of Standard No. 208 were based on a determination of the lead time necessary to engineer passive restraints into each size class of automobile. Wheelbase was chosen as a measure to delineate the phasing requirements because it is directly related to vehicle size and because it is a well-defined quantity that does not vary significantly within a given car line.

For purposes of measuring wheelbase, the vehicle is loaded according to the general test conditions of Standard No. 208. These test specifications, including loading, are meant to approximate the likely condition of the vehicle under normal driving circumstances. Since a vehicle having a variable wheelbase will generally carry the same weight as the average automobile of its size, it is appropriate that the wheelbase on such a vehicle be determined under the loading conditions specified under Standard No. 208. Therefore, Peugeot should measure the wheelbase of its vehicle under the loading conditions specified in paragraph S8.1.1(a) of the standard.

SINCERELY,

U.S. TECHNICAL RESEARCH COMPANY

February 8th, 1978

Joseph J. Levin Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

Re.: Wheelbase Cutoff Points for FMVSS-208 Application

Dear Mr. Levin:

Certain automobiles with independent rear suspensions have a wheelbase which varies as a function of the vehicle loading. In order to determine the effective date of FMVSS-208 for one of our vehicles, it is necessary for us to know under which loading conditions the wheelbase should be measured. "Curb Weight" as defined in CFR 49, Chapter V, Subchapter A, Part 571, Subpart A, R 571-2 and "Unloaded Vehicle Weight" as defined in 36 F.R. 2511 (Feb. 5, 1971) have been suggested by your staff as the most probable possibilities

We would appreciate receiving a prompt official clarification on this matter.

P. Arquin Government and Engineering Liaison