ID: nht72-1.37

DATE: 11/02/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 27, 1972, on the subject of the test procedures under Motor Vehicle Safety Standard No. 210, Seat Belt Anchorages.

Your question is whether the seat belt installed in the vehicle must be used for the anchorage test. The answer is no. The standard sets requirements only for anchorages, and the seat belts are merely means by which specified forces are applied to test the anchorages.

ID: nht72-1.38

DATE: 08/21/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 11, 1972, requesting confirmation of your understanding of the phrase "the nearest contact point of the belt with the hardware attaching it to the anchorage", as used in S4.3.1.3 of Motor Vehicle Safety Standard No. 210.

You indicate that the buckle in the proposed Nissan belt system is attached to the seat structure by a rigid bracket. The nearest contact point of the belt with the hardware attaching it to the anchorage appears to be correctly shown in each of the drawings attached to your letter. The installation shown in the upper drawing is, as you suggest, the only one of the four that would meet the location requirements of S4.3.1.3.

ID: nht72-1.39

DATE: 03/23/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of March 3, 1972, you asked for our interpretation of how a rigid bracket installed on the B-pillar to guide the shoulder belt would be treated under Standard 210.

Although the bracket in question does not perform all the functions of the anchorage, in that it would sustain only a fraction of the total force imposed on the anchorage in an accident, it performs a significant anchorage function by controlling the angle at which the shoulder belt crosses the occupant's chest. It is therefore considered a part of the anchorage and must fall within the acceptable range for upper torso anchorage locations specified in Standard 210.

If you have information to indicate that the acceptable zone could be extended forward of its present position without lessening the effectiveness of the shoulder belt, we would be most interested in obtaining it for review.

ID: nht72-1.4

DATE: 12/19/72

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Oppenheimeir & Co.

TITLE: FMVSS INTERPRETATION

TEXT: [Illegible Page].

ID: nht72-1.40

DATE: 08/16/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of July 25 and 28, 1972, on the subject of the positioning of seat backs for the purposes of testing under Standards No. 208 and 210.

The "nominal design riding position" specified in Standard 208 and formerly employed in Standard 210 is the position considered by the manufacturer as that most likely to be used by vehicle occupants. In our compliance tests, we ask the manufacturer of each vehicle to be tested to advise us of the correct position.

The term "most upright position" used in Standard 210 was adopted in part to avoid the need to go to the manufacturers for advice each time we tested a vehicle's seats. Under S4.3.2 of the standard, the seat back is adjusted to the position which places the seating surface most nearly in a vertical position.

There have, however, been difficulties with the use of the "most upright position", in cases where that position is not the same as the position used by the manufacturer to establish the seating reference point. Because S4.3.2 also calls for the positioning of the SAE J826 mannikin on the seating reference point, there is a possibility that the manikin cannot be correctly positioned. This does not appear to be a serious discrepancy, but it is one that should be resolved, and we intend to do so by appropriate amendment in the Federal Register.

ID: nht72-1.41

DATE: 07/11/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 21, 1972, in which you requested our interpretation of the phrase in S4.3.1.3 of Motor Vehicle Safety Standard No. 210 which states that the angle of the belt is to be measured from the seating reference point to the "nearest contact point of the belt with the hardware attaching it to the anchorage".

The language in question was adopted in response to petitions for reconsideration of the amended rule as published in 1970 (35 F. R. 15298, 35 F. R. 18116). Several petitioners had stated that measuring the angle from the seating reference point to the anchorage, as the standard then specified, would not accurately reflect the true angle of the belt because of the intervention of rigid attachment hardware between the anchorage and the webbing. The section was therefore amended to refe to the point at which the belt touched such attachment hardware.

In the diagram which you provide of a seat belt system in which the buckle is attached to the seat by means of a rigid bracket, we would consider the buckle itself to be a part of the attaching hardware. The contact point would therefore lie on the interface between the tongue and the (Illegible Word) at the point nearest the seating reference point.

It does not appear from Figures 2 and 3 of your letter that any of the designated angles correspond exactly to the angle that should be measured under S4.3.1.3. In both figures the angle would be determined by the line between the reference point and the nearest point to it on the forward end of the buckle.

Please advise us if you have further questions on this point.

ID: nht72-1.42

DATE: 02/29/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mr. Richard F. Hirsch

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 29, 1972, on the subject of test procedures under Standards 207 and 210.

Your questions deal with the general and frequently asked question of whether a manufacturer may devise his own test procedures to determine compliance with a standard. Our answer is that he is free to use whatever method he thinks appropriate to test his product, so long as his method reliably predicts the performance of the product when tested according to the procedures set out in the standard.

In answer to your first question, therefore, if testing of seats in a mock up accurately indicates their performance in a vehicle, then mock up testing might be an appropriate test method. Our laboratories will be testing the seats in the vehicle. If a failure occurs, a manufacturer must show that he exercised due care in the development and production of the seat. To do this it will be necessary to show, among other things, that the development tests you conducted were, in fact, equivalent to the test procedures of the standard.

The same comment is appropriate in response to your second question. If you apply force through the seatbelt that approximates the combined forces of the belt anchorage test and seat anchorage test, you should take care to be sure that the test is, in fact, equivalent to a test in which the anchorages are tested simultaneouly in the manner specified in Standards 207 and 210.

Your third question is whether the test must be conducted with seatbelts and body locks, and if so, whether this would not be a redundant test of the seatbelt that is already required to conform to Standard 209. Although the response given to your first two questions is also appropriate for the third, there are practical reasons for using the vehicle's belts in the test. If the belt breaks, for example, it may be that your client would want to re-examine the sufficiency of the belt. Under Standard 208, the vehicle manufacturer is required to install a belt that conforms to Standard 209. If the belt fails in our testing under Standard 209, the vehicle manufacturer will have to show that he exercised due care in determining that the belt conformed to the standard. Using the belt in testing for Standard 210 is one way of detecting potentially serious belt problems.

ID: nht72-1.43

DATE: 06/01/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Hamilton Cosco, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 4, 1972, posing certain questions concerning paragraph S4.10 of Motor Vehicle Safety Standard No. 213, "Child Seating Systems." You ask "what criteria are to be used to determine whether an area is a contactable area under S4.10."

The components that would be considered contactable by the head under S4.10.1, or by the torso under S4.10.2, are any components which a child within the weight and height range for which the seat is recommended might contact in a 30 m.p.h. barrier crash, as represented by the test procedure specified in S5.1 and S5.2.

You also ask for clarification of the meaning of "rigid side" as that phrase is used in S4.10.3. As we indicated to you in our letter of February 23, 1972, manufacturers should rely on generally available definitions of "rigid" in determining whether or not components are within the term. The reference to "side" includes components placed both to the right and left, and forward of and behind the child occupant. Consequently, both an arm rest and a head rest (either separate from the back of a child seat or part of a one piece back of a child seat) could fall within the exemption of S4.10.3. The reference to "back or side" in the proposed amendment to S4.10 published September 23, 1970 (35 F.R. 14786), is intended purely as a clarification of the existing language; the main thrust of the proposed revision would be, as stated in its preamble, to eliminate the exemption in the head-contact area.

With reference to the status of the September 23 proposal, a final rule based on this notice is still under consideration and we cannot presently provide an indication as to when it may become effective.

ID: nht72-1.44

DATE: 10/16/72

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: Mr. Heinrich von Wimmersperg, Development Engineer

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 2, 1972, concerning the Ford "Tot-Guard" and your child restraint patents.

The consumer complaints that we have received on the Ford Tot-Guard have been complaints focussing on the fit of the device for minimum recommended size children. The comments relate both to the case with which small children may climb out of the device and slide under it, as well as to the vision restriction problem for the small child.

The Tot-Guard has proven to perform well in 30 mph frontal impacts with the three-year-old child dummy in our research programs, but can be improved in lateral protection capability and in performance with the 50-pound child dummy.

We have just completed a research program to develop new concepts in child restraints and will very shortly be making these designs available for any manufacturer who chooses to produce one of these advanced design restraints.

A copy of your letter will be placed in the public docket along with plans for the restraints developed on our child restraint development contract.

We are interested in reviewing and placing in the public docket copies of your designs for the infant car bed, which you mention, in hopes of stimulating the production of a crashworthy design for such a device.

We appreciate your letter and are looking forward to hearing from you in the near future.

SINCERELY,

HEINRICH VON WIMMERSPERG DEVELOPMENT ENGINEER

OCTOBER 2, 1972

Douglas W. Toms Director National Highway Traffic Safety Administration

An article by John Thorner in the WASHINGTON POST on 20 July 1972, relative to the Consumers Union's report on children's car safety restraint systems, quoted you as stating that your agency, the National Highway Traffic Safety Administration, had found that children did not like the FORD "TOT-GUARD" and that therefore it would be difficult to get parents to use this restraint system.

As the owner of the basic patent used in the "TOT-GUARD", (Patent #3,232,665), I am naturally interested in your comments.

It is my impression that you are referring to the fact that the "TOT-GUARD" does have an extended front piece, covered by FORD's patent #3,424,497, which does interfere somewhat with the child's ability to see forward and may thus cause some children to object to being placed in the seat.

However from all dynamic tests about which I have heard, the FORD "TOT-GUARD" does provide maximum safety for children weighing up to 50 pounds in simulated crash conditions.

An editorial in the WASHINGTON POST of 6 July 1972, copy of which I am enclosing, did pose the question: "If some manufacturers can meet safety testing, why can't all of them?"

It is with this thought in mind that I would like to call your attention to the fact that FORD has a NON-EXCLUSIVE license on my patent and that I would be willing to license other manufacturers to avail themselves of its features on terms generally equivalent to the FORD agreement, involving a very nominal royalty.

I do feel that the small royalty should not deter them from using my patent to make their devices safer.

I have already noted that some attempts have been made to copy my system, but the endeavor to avoid infringement of my patent has not resulted in making their devices as safe as they would be if they had used my patent.

I realize that the NHTSA is not in a position to act as a "sales agent" for my patent but, in the mutual interest of promoting safety for children riding in cars, I do think it would be perfectly proper for you to at least call attention of manufacturers of child car restraint systems to the fact that my basic patent is available on a non-exclusive basis to any manufacturer for a very nominal royalty.

For your ready reference, I am enclosing a copy of U.S. Patent #3,232,665 issued on 1 February 1966.

I am presently in the process of developing a new version of a children's seat based on my Patent #3,232,665, for children up to 50 pounds weight, having no restricted frontal vision, conveniently adaptable to different sizes of children and collapsible for easy storage and transportation.

Recently a patent was allowed to me which probably will be issued in January 1973. This is for a Safety Seat for Infants (old enough to be seated).

Further, I have just filed a Patent Application for a CAR BED for infants too young to be seated. It is based on a completely new principle, which provides maximum possible protection, equally safe for short trips or for longer traveling.

These three developments thus cover the complete range from the newborn baby to the 50 pound child.

Having had over 30 years background in the development of automotic firearms, covered by over 60 patents, I have, since 1955, been interested in the difficult problem of decelerating fast moving vehicle occupants in crashes without injury, a problem very similar to the problems to be solved in the design of ornaments. This work has resulted in my obtaining patents for an Automotive Safety Belt and for a shock absorbing Sun Vison, automatically covering the impact area of the windshield.

I would be happy to give you additional information regarding any of the above-mentioned matters if you are interested.

I know that you primary interest is in promoting, SAFETY for all people riding in cars and airplanes. It is my sincere belief that I have contributed something to this cause, and I got particular satisfaction from seeing a display of photos on the fifth Floor of the NASSIF Building in Washington showing a little girl sitting in a "TOT-GUARD" and also the car in which she was riding when it was rolled over in a side-impact collision, without injuring the girl. I presume you have seen this display. If not, I am enclosing a copy of the display.

I look forward to hearing from you.

Heinrich von Wimmersperg

[Enclosures Omitted]

1) Copy of U.S. Patent #3,232,665

ID: nht72-1.45

DATE: 03/10/72

FROM: JAMES E. WILSON FOR CHARLES H. HARTMAN--NHTSA

TO: Rose Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 1, 1972, concerning the National Highway Traffic Safety Administration (NHTSA) pamphlet, "What to Buy in Child Restraint Systems."

While you approve generally of the pamphlet, you state that you consider certain statements in it to be incorrect. Particularly, you disagree with two statements appearing on the page of the pamphlet discussing child harnesses. Those statements were: "Give preference to those which attach under the seat back, not over it."; and, "Give preference to those which either attach directly to the vehicle floor, or to the vehicle seat belt, not to the seat back." We do not agree that either of these statements is incorrect.

The NHTSA position is that child harnesses that attach over or directly to the vehicle seat back increase the chance of seat back failure, a hazard which you recognize in your letter. Our dynamic test data have shown that affixing a child harness in either of these ways can cause the inertial load of the child to be applied to the seat back excessively deforming or failing the seat back, thereby allowing excesive occupant excursion and increasing the chance of injury to the child. In short, these configurations increase rather than, as you seem to argue, decrease the chance of seat back failure.

With regard to the statements concerning compressive forces being applied to the child during a crash, while we agree in principle that such forces are undersirable, it is not clear from your letter how their application is prevented by having the child harness attach over the top of the vehicle seat. In any event, it is preferable, in our view, for some force to be applied to the child's torso, as long as it is evenly distributed, than to have the child flung into hostile surfaces within the vehicle.

We also do not agree with the statement on page 2 of your letter that harnesses can safely be attached to a vehicle seat back, as the seat back is ". . . in turn securely attached to the car floor." Our experience has been quite the opposite; vehicle seat backs are merely attached to the seat frame and are quite susceptible to collapse in crash situations.

Finally, we do believe the pamphlet, in its recommendation that a child should not stand on the front seat of the vehicle when the harness is attached, is consistent with the design of your harness in that both seek to reduce the danger of whiplash injury,

I hope this clarifies our position for you.

SINCERELY,

rose manufacturing co.

February 1, 1972

Douglas W. Toms Administrator National Highway Traffic Safety Administration U.S. Department of Transportation

Dear Mr. Toms:

Please permit us to congratulate you on the excellent pamphlet, entitled "What to buy in Child Restraint Systems".

Also, however, please permit us to question some statements in this pamphlet which we consider to be, in effect, erroneous and dangerous.

We refer to the next-to-the-last page regarding child restraint harnesses. The first drawing on this page illustrates a restraint harness essentially similar to the one we manufacture, and market under the "Sears" and other trade names. Your first statement in red ink states: "Give preference to those which attach under the seat back, not over it". We submit that any such harness which is attached solely under the seat back, and not also over it, is subject to two vicious hazards. First, it would in case of a crash permit the seat back to move forward to crush the child against the seat cushion. This might result from the folding forward of a hinged seat back or the breaking loose of a fixed one.

The second hazard is more prevalent and just as vicious. An adult lap belt is normally attached under the seat back, and is safe when thus attached. In a crash it puts the impact loading on the hips and pelvic region--the strongest parts of the body with no vital organs to be affected. This is positively not true of any belt or harness which places any restraint on the shoulders or upper torso. All adult 3-point belts are required to have the upper torso restraint attached at some point above the shoulder. Some such safety should also be required in the child harness. It must not be permitted to apply any compressive pressure to the shoulders and downward along the spine, in case of a crash.

Your second statement in red reads: "Give preference to those which either attach directly to the vehicle floor, or to the vehicle seat belt, not to the seat back". This, again provides the same two hazards, the crushing, forward-moving seat back, and the linear forces compressing the spine.

We wish to emphasize that these two hazards are definitely and completely eliminated in the belt which we make, and which is partially indicated in your drawing, but without explanation or comment.

Our harness is not attached directly to the car floor. It is attached directly to the seat back, which in turn is securely attached to the car floor. This holds the seat back securely in its place in a crash, and it also eliminates the linear spinal pressure. The child harness is free to slide up and down along the anchor strap which extends vertically at the front of the seat back. This provides two important safety features. First, it assures that the impact force will always be restrained from a point horizontal to the position of the body at the instant of impact, whether this position is standing, sitting or lying down. Not only will this restraining force be applied directly linear to the impact force but the construction and attachments of our harness assures that such restraint force will be applied to the front of the child and never at the side or rear which might cause neck or spinal injury.

The other, and very important safety feature of our harness is the complete and instantaneous freedom of movement of the child. A child of 2 or 3 years cannot be forcibly restricted to a single sitting position during a long ride without venement and justifiable protest, and consequent distraction of the driver's attention.

This brings us to the last of your statements on that page, viz. "Caution: Parents are warned not to allow a child to stand on the front seat of the vehicle when utilizing a harness restraint, or this may happen". The accompanying drawing indicates a typical whiplash injury situation. To eliminate this hazard, and still provide the maximum safe freedom of movement, our harness includes a positive but adult-adjustible stop on the vertical anchorage strap, and our instructions include a positive warning to keep this stop adjusted to a point which will not permit the child to stand in any seat, front or rear, under any conditions which permits his head to extend to a point higher than the top of the seat back.

We very strongly feel that, in your sincere efforts to educate the public and save the lives of children, you should see to it that these erroneous implications are promptly corrected and that such corrections be given as wide publicity as the original pamphlet.

We shall be awaiting your reply with interest.

C. W. Rose Chairman of the Board