ID: nht72-1.34

DATE: 03/29/72

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

TO: Toyo Kogyo Detroit Office

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 16, 1972, in which you ask whether the definition of "unloaded vehicle weight" is the same as that for "'curb weight' plus optional parts," and whether the definition of "gross vehicle weight" is the same as that for "maximum loaded vehicle weight."

The two sets of definitions are expressed in substantially different terms. The new terms, "unloaded vehicle weight" and "gross vehicle weight rating" are more general than the older ones. The newer terms also eliminate some ambiguities in the definitions based on "curb weight," such as just what is (Illegible Word) by "standard equipment," and whether other vehicle fluids besides fuel, oil, and coolant should be included. Further, GVWR is a rating, not necessarily identical to any scale weight although some constraints have been placed on it in our Certification regulations (@ 567.4(g)(3)).

Thus, although the two sets of definitions are somewhat similar in their application, they are different enough that each must be interpreted and used in its own terms.

ID: nht72-1.35

DATE: 03/23/72

FROM: HARTMAN FOR DOUGLAS W. TOMS -- NHTSA

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of February 18, 1972, dealt with three aspects of Standard 215 that continue to be of concern to Chrysler and with one feature of Standard 210 that you regard as inappropriate.

Your first problem with Standard 215 is the requirement for corner impacts at heights below 20 inches. Our response to the objections raised by Chrysler and others when this requirement was made a part of the standard was to grant an additional two years for compliance. We did this in the expectation that the additional time would permit the manufacturers to make the necessary changes within their normal tooling cycle.

The agency considered the corner impact requirement to be justified, and it is not now persuaded to the contrary. We would be willing, however, to review any additional information you can provide on the subject of the costs and the benefits of the improved corners.

Your second concern has also been expressed at several points in the rule-making process. In response to comments advocating the use of resilient materials in the bumper itself, the standard was amended to specify a broader impact ridge, rather than to specify the resiliency of material with which contact would be permitted. The agency has not considered the styling effects of the pendulum requirement to be sufficient to justify amending the standard to permit cosmetic additions of the type you describe. Of course you are free to submit additional information to support the need for such an amendment.

The photometric requirements from Standard 108 that are proposed for incorporation in Standard 215 have been the subject of several comments under Notice 10 in Dockets 1-9 and 1-10. The issue has not been resolved by issuance of a final rule and we will therefore consider your remarks as an addition to Chrysler's comments on Notice 10.

In the area of seat belt anchorages, the question of whether to use dynamic or static test methods was resolved in October 1970 by specifying a static test with a 10-second holding period. It was thought that this was the surest means of testing the basic strength of the metal and that it therefore carried out the original intent of the standard. Although it may be that the resulting anchorages are able to withstand barrier crashes at speeds considerably higher than 30 mph, we do not consider this to be sufficient cause for relaxing the anchorage requirement. If you have information concerning the force levels at which accidents are survivable, and the relation of these levels to anchorage strength, we would be glad to receive this information.

ID: nht72-1.36

DATE: 09/05/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Toyo Kogyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 8, 1972, on the subject of the location of the anchorages for passive belt systems. We understand from your letter that you are considering using a door-mounted anchorage for your system, but we are uncertain as to the nature of your difficulties with Standard No. 210.

The standard does not prohibit door-mounted anchorages. If an anchorage can be placed on the door so that it directs the belt across the occupant at the angle specified in the standard, and if it also meets the strength requirements, then it would be considered to conform to the standard. It may be that the anchorage you are considering fails to provide the correct belt angle.

At this time there is no exemption provided for passive belts from the belt angle requirements of Standard No. 210. If you wish to petition for rulemaking to amend the requirements for passive belts, you should accompany your petition with full information concerning the system and the advantages of the proposed anchorage locations

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.