ID: nht72-1.46

DATE: 06/12/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Peterson Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 24, 1972, inquiring whether Standard No. 213 requires head rests, arm rests, and shields of certain Peterson child seats to be covered with nonrecovery, or slow-recovery energy absorbing material.

Paragraph S4.10.3 of Standard No. 213 exempts the contactable area of a rigid side of a child seating system from the requirement that it be covered with deformable, nonrecovery, or slow-recovery energy absorbing material (S4.10.1 and S4.10.2), when the contactable area of the side that is higher than the system's seating surface is at least 24 square inches. We would consider head rests, arm rests, and shields of the Peterson child seats in question to be within the exemption of S4.10.3 if their contactable area above the child seating surface is 24 square inches or more.

I point out, however, that the proposal of September 23, 1970 (35 F.R. 14786) would alter this result, as the exemption would no longer extend to any components contactable by the head.

ID: nht72-1.47

DATE: 12/14/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Kettler of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: A review of correspondence we sent you on October 6, 1972, (in response to your letter of September 26, 1972, concerning child seating systems you plan to import), has revealed that one statement we made should be clarified.

In the second paragraph of our letter we stated that each "seat must be labeled or tagged with a certification that it conforms to all applicable Federal motor vehicle safety standards." Standard No. 213 (49 CFR 571.213), which applies to child seating systems, does require each child seating system to be labeled with information regarding its safe use, and we refer you to the standard for these requirements. However, with respect to certification, manufacturers are not limited to the method specified in our October 6, 1972, letter (viz., attaching a label to the seat), but may certify in other ways as well. For example, Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), on which the certification requirement is based, states that the certification may also be placed on the outside of the container in which the item is delivered.

We regret that our former letter was incomplete in this regard.

ID: nht72-1.48

DATE: 03/10/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Irvin Industries Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 23, 1972, in which you list information you wish to label on child seats you will manufacture, and ask whether the information as presented will comply with Motor Vehicle Safety Standard No. 213. You state that a label containing the model number, date of manufacture, and the company's name and place of business will be permanently affixed to the product, while a separate legend, containing other information, will be molded on the bottom of the seat in raised letters at least 3/32 inches high.

The labeling scheme you wish to use would conform to paragraph S4.1 ("Labeling") of Standard No. 213, providing, of course, the blank spaces for model number and date of manufacture are appropriately filled in. We would suggest, however, that that part of the molded legend beginning" . . . and there is a minimum of 19 inches vertical clearance between this seating . . .", to the end of that provision be simplified to be more understandable to an ordinary consumer.

WE ARE PLEASED TO BE OF ASSISTANCE.

ID: nht72-1.49

DATE: 02/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Cosco Household Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 8, 1972, requesting information pertaining to reclining type child seating systems. You describe these seats in your letter as those which allow the child to ride in a semi-recumbent posture by moving the seating surface forward while maintaining the upper back in a more or less fixed location. You state the hip of the child moves forward as a result, while the head remains in roughly the same place.

The questions you asked regarding this type of child seat are repeated below, followed by our responses.

1. Is NHTSA now testing, or does it intend to test, reclining car seats in both the upright and reclining configurations?

Paragraph S4.11.1(b) of Standard No. 213 requires that each child seating system in which the attitude of the child is adjustable meet the performance requirements of the standard when placed in each designed adjustment position. Consequently, reclining child seats must meet these requirements in both reclining and upright positions.

2. Is the allowed twelve-inch excursion to be measured from the reference point of the semi-recumbent dummy, or from the location of this point were the seat assumed to be upright?

The allowable forward movement of the dummy reference point is to be measured using the reference point of the semi-recumbent dummy, and the forward movement must not exceed 12 inches when measured from that point.

3. Does the NHTSA intend to make a specific statement on the requirements of reclining car seats . . .?

We believe the language of paragraph S4.11.1 of the standard to be sufficiently explicit regarding this requirement.

ID: nht72-1.5

DATE: 04/05/72

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

TO: U.S. Technical Research Corporation

TITLE: FMVSS INTERPRETATION

TEXT: The questions asked by your letter of March 18, 1972, have been compared with the applicable paragraphs of the Federal Motor Vehicle Safety Standard (FMVSS) No. 164 and the Society of Automotive Engineers Recommended Practice J942.

1. The purpose of paragraphs 2.11 and 4.42b of J942 is to allow the testing of both manual and automatic systems seeing the same procedures. The (Illegible Word) of 4.42b attempts to equalise the usual cleaning cycle of each type of system. It is apparent that the manual system allowed for by 4.42b is one in which a single actuation, if held long enough, would put 15 cc of fluid through the nozzle. The systems you described is not of this type, nor is it the automatic system. You must therefore comply with the intent of the test, which would be to operate your system for 8,000 washer cycles, as stated in paragraph 3.4. Each washer cycle is that which puts approximately 15 cc of fluid through the nozzle. Since your system is not the usual system implied in the standard, the three-record rule would not apply. Time limitation would be dictated by the "Mo./min" column of Table 1 of J942, i.e. two washer cycles per minute.

Therefore, the pump and central switch you described, along with the other parts of the systems, if they meet all other prescribed (Illegible Word), would comply with Federal Motor Vehicles Safety Standard No. 104.

2. An automatic pump cycling device would not be limited by the three-second rule. It would be requested to meet the "Mo./min" column of Table 1 of J942, 1.2., two washer cycles per minute.

3. Paragraph 3.1 does not specify the duration of water spray, member of water sprays, or start time of wiper action. No standard wiper blade, windshield, or mechanism is specified. These are the items which, in conjunction with the washer, must produce an effective wips/wash system.

The National Highway Traffic Safety Administration is concerned that the entire system provide good washing and wiping, and is not concerned with compliance of individual components.

4. "Repeatedly," as used in paragraphs 4.2.2a and b, means the repeated application of the control device (push button, usually) which is designed to cause the water to squirt out of the nozzles. Practically, this reproduces a driver's attempts to activate the system on a cold day, not knowing if it is frozen or plugged. Upon warming up, the systems must not have been damaged, and must still function after removal of the ice or plug. Without this safeguard, many systems would be rendered inoperative on the first cold day by an impatient driver.

5. To our knowledge, there is no reservoir size stated by Federal or State regulations.

Please ask for further information, if needed.

ID: nht72-1.50

DATE: 11/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Pride Products Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 23, 1972, requesting information on the use of sample testing for determining conformity to Motor Vehicle Safety Standard No. 213. You ask if there are sampling provisions to which manufacturers should currently be adhering.

There is no specified sampling provision for manufacturers to follow in testing their products for conformity to Standard No. 213. The National Traffic and Motor Vehicle Safety Act requires each item of motor vehicle equipment (for example, each child seat) to conform to the applicable safety standard in effect on its date of manufacture. It is the manufacturer's responsibility to decide what type of testing program is necessary to be reasonably certain that each item complies. The extent of his sampling should depend on such factors as the margin by which typical samples pass the performance requirements, the amount of variation in production that is present, and the degree to which substandard items can be detected by non-destructive techniques.

ID: nht72-1.6

DATE: 06/13/72

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

TO: FMC Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 25 inquiring about compliance of your planned motorhome with Federal Motor Vehicle Safety Standards Nos. 101 and 104.

Standard No. 101 requires certain controls to be illuminated. We interpret this to mean sufficiently illuminated that the control identification, if verbal, can be read, or if pictorial, can be understood. Therefore, illumination from any course is satisfactory as long as the basic requirement of comprehension is met.

Standard No. 104 does not describe the type of windshield wiping system that must be used to meet its requirements. It is the manufacturer's responsibility to insure, whatever system is used and whatever configuration of windshield is employed, that the wiped and washed area requirements are met.

ID: nht72-1.7

DATE: 07/27/72

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

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 20, 1972, to Mr. Toms concerning general reference material in support of the proposals contained in Docket No. 70-27. Hydraulic Brake Systems. You ask that the NHTSA place in the file "The supporting data upon which the test sequence is based as well as the data used to determine the performance values based on the sequence."

The proposed test sequence is based primarily upon the test sequence of standard No. 105, which is that of SAE Recommended Practice J937 incorporated by reference. Parking brake lightly loaded vehicle, inoperative brake power assist unit, and partial failure tests not included in J937, were placed in the sequence in the order that appeared, in the judgment of agency personnel, most likely to provide realistic and undistorted results. The sequence, of course, is subject to revision on the same basis in the forth-coming final rule. General reference material in the Docket includes data from braking tests of eighteen 1970 automobiles, NBS Technical Note 557, "The Brake Pedal Forces Capability of Adult Females," and SAE 720032, "Evaluation of the Use of Automotive Braking Systems During a 7300 Mile Cross-Country Trip."

ID: nht72-1.8

DATE: 04/11/72

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

TO: GGO Group, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 3, 1972, to Mr. Schneider asking whether your Gemini Tow Control System would come under our regulations, and whether you would be considered a brake manufacturer.

The Federal motor vehicle safety standard covering vehicle hydraulic brake systems, Standard No. 105, applies only to passenger cars (not directly to equipment manufacturers), and does not cover the hydraulic braking relationship between towing and towed vehicles. For that reason the Gemini system would not be regulated by Standard No. 105. There are no Federal standards applicable to a tow control system per se.

We would, however, view you as a "manufacturer," and the product you have described as "motor vehicle equipment," within the remaining of the National Traffic and Motor Vehicle Safety Act of 1965.

ID: nht72-1.9

DATE: 11/06/72

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

TO: Paul Utans

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of October 9, 1972, you enclosed a master brake cylinder cover ("Exhibit A"), and a reservoir label ("Exhibit B"), both produced by Alfred Teves, and asked our views as to their conformity with the lettering size and contrast requirements of paragraph S3.4.3 of Motor Vehicle Safety Standard No. 105a.

These sample items appear to conform to the lettering requirements, with the exception that the cylinder cover of Exhibit A is the same color as the raised lettering, and does not provide a contrasting background as required by the standard.