ID: nht93-6.15

DATE: August 16, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Ron Marion -- Sales Engineer, Thomas Built Buses, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7/2/93 from Ron Marion to Marvin Shaw (OCC 8838)

TEXT:

This responds to your inquiry about the applicability of Standard No. 131, School Bus Pedestrian Safety Devices, to school buses you wish to sell to a customer in the United States Virgin Islands. You stated that these buses will be built as right hand drive vehicles with the entrance door located on the left side, since vehicles are driven on the left side of the road in this jurisdiction. You asked whether you can install, on the right side of the bus, the stop signal arm that is required by FMVSS 131. The answer is yes.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1381, "Safety Act") requires new school buses sold in this country and in the U.S. Virgin Islands to comply with all applicable Federal school bus safety standards. (See, 15 U.S.C. S 1391(8) for reference to the Virgin Islands.) Standard No. 131 requires school buses to be equipped with a stop signal arm "on the left side of the bus." (S5.4) The purpose of this standard is "to reduce deaths and injuries by minimizing the likelihood of vehicles passing a stopped school bus and striking pedestrians in the vicinity of the school bus." (S2)

When NHTSA specified that the stop arm must be placed on "the left side of the bus," the agency meant the driver's side. Comments to the notice of proposed rulemaking (NPRM) and preamble of NHTSA's final rule all assumed that the left side of the bus meant the driver's side. (56 FR 20363, 20367). For example, while endorsing the proposed requirement for the stop arm, several commenters stated that an arm is needed near the driver's window. Moreover, S5.4.1(b) states that, for locating the arm, "the top edge of the stop signal arm is parallel to and not more than 6 inches from a horizontal plane tangent to the lower edge of the frame of the passenger window immediately behind the driver's window." (Emphasis added).

This provision indicates that the agency assumed that the "left" side is the driver's side. Further, a stop arm would not be needed on the non-traffic side of the vehicle.

Since the left side is not the driver's side for the school buses in question, the agency's general assumption was incorrect. In light of your letter, we will issue a technical amendment of Standard 131 so that S5.4 will require the stop signal arm on the DRIVER'S side of the bus. Until the amendment is issued, we will not take enforcement action regarding a manufacturer's locating a right hand drive school bus with a stop signal arm on the bus's driver's side.

I hope this information is helpful. If you have any questions about NHTSA's safety standards, please feel free to contact Marvin Shaw at this address or by telephone at (202) 366-2992.

ID: nht75-6.15

DATE: 10/29/75

FROM: AUTHOR UNAVAILABLE; John G. Haviland; NHTSA

TO: Laird E. Johnston -- General Motors Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Free Sliding Latch With Tension Relieving Feature

Laird E. Johnston ASE - Engineering Staff

The following comments are in reference to your question concerning whether existing safety standards allow a shoulder belt tension relieving feature on a single loop three point belt system having a free sliding (non-cinching) latch.

GM Legal Staff has been consulted concerning interpretation of the present wording in MVSS 203, Section S7.1.1 (Attachment 1) and proposed amendment Docket 74-32 Notice 1 (Attachment 2). Legal Staff and ASE agree that:

a) The current MVSS 203 does not clearly prohibit the use of a free-sliding latch plate with a shoulder belt tension relieving device but the NHTSA interprets MVSS 208 as prohibiting such a system (see Attachment 3), and

b) A proposed amendment to MVSS 208 Docket 74-32 Notice 1, does clearly limit the use of comfort devices to the upper portion of the seat belt assembly - the lap belt portion must remain individually adjustable (i.e. introducing slack into the shoulder belt should not affect the lap portion of the assembly).

In our response to Docket 74-32 Notice 1 (Attachment 4), General Motors agreed that devices to relieve tension should not be used on systems permitting inadvertent misadjustment.

ASE also has reservations about the impact performance of such a system both for adult occupants and when used in conjunction with child seats. Although limited sled tests of one such system resulted in no submarining with up to three inches of slack in the lap belt, there is no assurance that occupants would wear these systems correctly or that all similar belt configurations would perform in this manner. Additionally, GM only recommends the use of the child seat in 1968-1975 domestic made vehicles. All of these vehicles have a lap belt that permits lap belt tension independent of the shoulder belt. Present thoughts are that a separate lap belt tension holding clip will have to be supplied with the child seat if GM were to recommend its usage with a free-sliding latch single loop system.

One compromise you may wish to consider is the use of a friction device on the free sliding latch that would allow free belt transfer from the lap belt to the shoulder but hold minimal lap belt tension, possibly five to ten pounds. This should satisfy the NHTSA but would still pose some problem with improper child seat usage. Another solution, which you are aware of, is providing low shoulder belt tension thus reducing the need for a tension relieving device. A one-way cinching latch is the ideal solution to the performance and compliance questions.

If we can be of any further assistance, please let us know.

(original signed by) John G. Haviland Collision Protection/Restraints Automotive Safety Engineering JGH/rk

Attachments (4)

cc: G. F. Ball E. E. Conner T. G. Wingblad

ID: nht95-6.1

TYPE: INTERPRETATION-NHTSA

DATE: August 4, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jim Burgess -- Engineering Manager, Independent Mobility Systems, Inc.

TITLE: NONE

ATTACHMT: ATTACHED TO 5/18/95 LETTER FROM JIM BURGESS TO WALTER MYERS (OCC 10931)

TEXT: Dear Mr. Burgess:

This responds to your letter of May 18, 1995 to this office and your telephone conversations with Walter Myers of my staff on June 14 and 27, 1995, concerning an exclusion in Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door locks and door retention components. The standard excludes from its requirements doors equipped with wheelchair lifts and either a visual or audible alarm system.

You state that your company converts minivans into wheelchair accessible vehicles by lowering the floor and adding a wheelchair ramp to the right rear side sliding door area, with an audible and/or visual alarm. The issue you raise is whether FMVSS No. 206's exclusion of wheelchair-equipped doors also excludes a ramp-equipped door. The answer is no.

FMVSS No. 206 requires that side doors leading directly into a compartment containing one or more seating positions must conform to the standard. However, paragraph S4 of the standard states:

Side doors equipped with wheelchair lifts and which are linked to an alarm system consisting of either a flashing visual signal located in the driver's compartment or an alarm audible to the driver which is activated when the door is open, need not conform to this standard.

FMVSS No. 206 was amended to add the wheelchair lift exception by final rule dated March 27, 1985 (50 FR 12029, copy enclosed). The agency's rationale was that when not in use, wheelchair lifts are stowed in a vertical position parallel to and in close proximity to the interior surface of the vehicle door, thus providing a barrier to occupant ejection if the door opened while the vehicle was in motion or in the event of a crash. The alarm requirement was intended to alert the driver to a door that was open on a vehicle that was in motion.

While the information you provided us showed that your wheelchair ramp is also stowed in a vertical position parallel to and in close proximity to the door and that you install audible and/or visual alarms for the driver, wheelchair lifts and wheelchair ramps are distinctly different components. Although they serve the same purpose and are similarly configured when in the stowed position, this agency cannot by interpretation say that "lift" includes "ramp." In order to amend the standard to exclude wheelchair ramps as well as lifts, rulemaking action would be required. You may petition this agency to do rulemaking, under 49 CFR Part 552 (copy enclosed). This agency will entertain your petition and decide whether a rulemaking proceeding is appropriate.

I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Mr. Myers at this address or at (202) 366-2992.

ID: nht92-4.44

DATE: August 7, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA; Signature by Kenneth N. Weinstein

TO: Eugene Welker

TITLE: None

ATTACHMT: Attached to letter dated 6/22/82 (should be 6/22/92) from Eugene J. Welker to Jackson Rice (OCC 7434)

TEXT:

This responds to your letter about a mirror system designed to improve a driver's view of areas behind a motor vehicle. You explained that a 35" vertical post would be bolted near a vehicle's rear bumper. This would result in a mirror being located a few inches above the top rear window stop light and facing forward at a 45 degree angle. You asked whether such a device would be legal. The following discussion and the enclosed information sheet, "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment," explain your responsibility under NHTSA's regulation.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not approve, endorse, or certify motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act ("Safety Act"), the manufacturer is responsible for certifying that its vehicles or equipment comply with applicable Federal motor vehicle safety standards. The Safety Act requires that these safety standards establish minimum levels of performance for vehicles or equipment. Once the performance level has been established, vehicle or equipment manufacturers are free to choose any means they wish to achieve the required level of performance.

NHTSA has exercised its authority to establish performance requirements for new vehicles in Standard No. 111, Rearview Mirrors (49 CFR S571.111, copy enclosed). Standard No. 111 establishes performance and location requirements for rearview mirrors installed in any new vehicle. This means that the vehicle manufacturer must certify that each vehicle it manufactures complies with the specified requirements. Standard No. 111 requires that passenger cars be equipped with an inside rearview mirror and a driver's side outside rearview mirror that provide the field-of-view specified in S5.1.1. A passenger's side outside rearview mirror is required in situations where the inside rearview mirror does not provide the specified field-of-view. Additional requirements for other vehicle types are set forth in S6, S7, and S8.

No provision in the Standard specifies requirements for a mirror that attaches to the vehicle's rear bumper. Accordingly, a mirror like yours would not be prohibited from being installed on any vehicle by the current requirements in Standard No. 111. Accordingly such a mirror would be permitted, but only as a supplement to the required mirrors. In installing the mirror, one must take care to avoid obscuring the vehicle's lighting devices, including the center highmounted stop lamps (CHMSL).

Please be aware that NHTSA does not regulate vehicles while they are in use. The American Association of Motor Vehicle Administrators, 4600 Washington Blvd, Arlington, VA 22203 may be able to advise you about the laws of the individual States related to the use of equipment such as your own.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: nht92-6.4

DATE: June 17, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Steven Rovtar -- General Manager, Blazer International Corp.

TITLE: None

ATTACHMT: Attached to letter dated 5/28/92 from Steven Rovtar to Paul J. Rice (OCC 7353)

TEXT:

This responds to your letter of May 28, 1992, asking for "a written ruling" that the product you described "meets current SAE/DOT guidelines."

The product is intended for the vehicle towing trailer market. Currently, lamps on towed vehicles are activated by splicing into the wiring harness of the towing vehicle. Your product eliminates the need for this type of hard wiring. This product "utilizes photodetectors to read the output of the towing vehicle's stop and turn signal lamps, and in turn activate the lamps of the towed vehicle." Photodetectors are embedded in suction cups which are attached to the towing vehicle's stop and turn signal lamps. The device is plugged into the cigarette lighter receptacle of the towing vehicle, and the harness of the towed vehicle is plugged into the device. When the stop lamp or turn signals of the towing vehicle are activated, the photodetectors read the light emitted, and the towed vehicle's lamps are activated via the completed circuit.

For purposes of this discussion we shall assume that the device is intended for aftermarket distribution. Further, from your description, it appears to be the type of device that is simple enough to be installed by the vehicle owner. The product itself is not directly regulated by Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment, because it is not replacement equipment intended to replace original equipment. Its installation on a vehicle in use by the vehicle's owner is outside the prohibition contained in the National Traffic and Motor Vehicle Safety Act. That prohibition forbids "manufacturers, distributors, dealers, and motor vehicle repair businesses" from "rendering inoperative, in whole or in part," mandated safety equipment such as stop lamps and turn signal lamps.

Were the device installed by a person in these categories we would be concerned that the addition of the suction cups would partially obscure the original equipment stop and turn signal lamps and, thus, render them "partially inoperative" within the meaning of the prohibition. That concern is not lessened by the fact that the device may be installed by a person not covered by the prohibition, such as the owner of the towing vehicle. However, as a practical matter, we realize that the safety impact may be minimal since the presence of the trailer will obscure the lamps on the towing vehicle to which the suction cups are applied.

We cannot advise you on whether the product meets SAE requirements. The legality of the use of equipment that is not regulated by NHTSA is determinable under the laws of States where the towing-towed vehicle combinations are operated. We are unable to advise you on these laws, and suggest that you write the American Association of Motor Vehicle Administrators, 4600 Washington

Boulevard, Arlington, Va. 22203, for an opinion.

ID: nht91-6.15

DATE: October 7, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Jon Nisper -- K.B. Lighting, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 8-23-91 from Jon Nisper to Jerry Medelin (OCC 6403)

TEXT:

This responds to your FAX of August 23, 1991, to Jere Medlin of this agency. You have enclosed a drawing of a combination headlamp/turn signal lamp assembly that depicts two possible positions ("Case l," "Case 2") for the inboard wall. With respect to each, you have asked "where should the 100mm separation be measured for turn signal headlamp position?"

Let me begin by noting that there is no requirement in Standard No. 108 that front turn signal lamps be separated from headlamps by at least 100mm. However, if there is less than a 100mm separation of those lamps, S5.3.1.7 of Standard No. 108 provides that the multiplier applied to obtain the required minimum luminous intensities for the lamps shall be 2.5. NHTSA determines the distance of the separation pursuant to the provisions of paragraph 5.1.5.4.2 of SAE Standard J588 NOV84, "Turn Signal Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width." That paragraph provides the following means of measuring spacing:

"Spacing for a front turn signal lamp which primarily employs a reflector (for example, one of parabolic section) in conjunction with a lens to meet photometric requirements, shall be measured from the geomeric centroid of the front turn signal functional lighted area to the lighted edge of the low beam headlamp or any additional lamp used to supplement or used in lieu of the lower beam, such as an auxiliary low beam or fog lamp."

We would apply this as follows. You stated in your letter that the inboard walls in your proposed headlamp/turn signal assembly serve no functional purpose. We interpret this as meaning that neither the inboard wall in Case 1 or Case 2 shown in your drawing would be used optically in the headlamp. Under this assumption, and the assumption that no direct light from the bulb filament illuminates the outer edges of the headlamp lens nearest the turn signal, the lighted edge of the headlamp reflector would end where the relevant inboard wall meets the reflector. Pursuant to SAE Standard J588 NOV 84, one would then take a vertical plane that is parallel to the axis of the headlamp bulb, and project it from the end of the lighted edge of the reflector (i.e., where the respective inboard wall meets the reflector) onto the lens. You have already drawn this as a line in the drawing enclosed with your FAX. Next, take the axis of the turn signal bulb and project it onto the lens (this line also exists in your enclosed drawing). To determine the separation, one would then measure the distance between the projected points on each lens. Should the headlamp lens area between the turn signal and the projected vertical wall line onto the headlamp lens be lighted, either on purpose or inadvertently, then the actual lighted edge of the headlamp would be used for measurement purposes.

ID: nht74-5.47

DATE: 04/22/74

FROM: AUTHOR UNAVAILABLE; James B. Gregory; NHTSA

TO: American Safety Equipment Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 3, 1973, petitioning for amendments to paragraphs S4.9 and S5.3.1 of Motor Vehicle Safety Standard No. 213 which would allow the use of a buckle release mechanism design that requires, before release, some foreshortening of the belt system to reduce the load on the release mechanism. This design cannot meet the existing requirements of S4.9 of Standard No. 213 with the device under load. We wrote to you on August 20, 1973, and on December 17, 1973, requesting additional data. We have not received a response from you to either letter.

We have decided that your petition should be denied. Our objection to the design you wish to employ is that it cannot be released when the belt restraint system is under load. The NHTSA believes, and has adopted its position in Standard No. 213, that a fundamental safety requirement for any occupant restraint release mechanism is the ability to release when it is under a load imposed by the weight of the occupant. In many vehicle crashes restraint systems may be loaded in this fashion when occupants must be removed.

We do not disagree with your argument that mechanisms which release under load may more readily be released by children when release is undesirable. We believe the greater safety problem, however, is presented by designs which are difficult to operate because they require a prior unloading of the release mechanism. These systems may not be able to be released, even by adults, in crash situations. Data we have received indicates substantial difficulty in the ability of adults to release a child from a child seat in situations (total darkness) simulating emergencies. The study in question has been conducted by the National Swedish Road and Traffic Research Institute and is on file in Docket No. 2-15.

Moreover, we believe buckle release mechanisms should be operable by older child occupants, particularly in situations such as in upside-down configurations where a load is imposed on the mechanism. This purpose is met by the existing requirements of the standard but would not be met were we to grant your petition.

In your petition you argue that even a lower release force does not necessarily mean that the occupant will be able to escape easily from the restraint system. While this may be true, as no requirements are specified in Standard No. 213 regarding ease of belt removal, it is not a justification for increasing the difficulty of operating the buckle release mechanism.

SINCERELY

August 3, 1973

Administrator National Highway Traffic Safety Administration Subject: Petition for Rule Making

Reference: MVSS213, S4.9 and S5.3.1

American Safety Equipment Corporation is a major developer and manufacturer of safety belt restraint systems for automobile manufacturers. American Safety personnel have a great deal of experience designing aircraft and automotive restraint systems, particularly hardware such as buckles, retractors and associated items. The Company has been active since 1966 in the business of designing and producing restraint harnesses and complete seating systems for children in the 20 to 40 pound size range. The Company has been working on development of a new child safety seat since 1970 basing the basic design criteria on dynamic performance under simulated crash testing, while also observing the current static testing regulation. Final testing of prototype models has been completed on the design considered optimum for performance, economy and simplicity of use.

This petition is submitted in accordance with the procedure described in Subpart B Section 553.31. This proposal is to add a performance requirement and test procedure for an occupant harness release mechanism not currently considered by the Child Seating Systems regulation. The mechanism is not of a nature normally classified or described as a "buckle", but for purposes of MVSS213, is being considered a release mechanism.

The proposed additions and revisions to MVSS213 are shown underlined:

S4.9 (b) Release when a force of not more than 20 pounds is applied when tested in accordance with S5.3 expect for systems described by S4.9 (c).

2 (c) Release when a force of not more than 10 pounds is applied when the release mechanism requires foreshortening of the webbing restraint components to activate and is tested in accordance with S5.3.1 (d).

S5.3.1 For forward-facing child seating systems where foreshortening of the webbing restraint components is not required by the release mechanism -

(a) -- unchanged --

(b) -- unchanged --

(c) -- unchanged --

When foreshortening of the webbing restraint components is required to actuate the release mechanism -

(d) Test the system with a 1,000-pound force as specified in S5.1, remove the force completely and then release the mechanism in a manner typical of that employed in actual use.

Photographs are enclosed showing the release mechanism actuation under normal and simulated emergency conditions and a typical testing set-up to determine release force. The application of force to release the occupant harness must simultaneously pull down on the abdominal pad and the shoulder straps thereto attached and upwards under the metal latch. This is very simply described as a "pinching" action of the thumb and first and/or second finger. The shoulder straps are thereby foreshortened and the occupant will be forced rearward (unless lifted or pushed) toward the back surface of the child seat. The hand not activating the release mechanism can be used to move the child's torso away from contact with the restraint straps. The actuation of the release mechanism with the belts in a slackened condition is an easy one-hand operation with a low force requirement.

The performance criteria on which our restraint release mechanism design is based are as follows:

1. The mechanism must be capable of restraining the occupant when the system undergoes dynamic forces of an auto crash without distortion of any kind which could result in a jammed or difficult-to-release condition.

2. Child must not be able to easily release himself.

3. The mechanism must be extremely easy to understand from the standpoint of an adult learning how to actuate. Similarity to current production adult safety belt hardware assures the shortest possible learning time by an adult.

3 These criteria were formulated after studying field experience of consumers and consulting with experienced people in various phases of the child and adult restraint business. This experience indicated to us that -

1. A common possible problem with many child seat harness buckle release mechanisms is that the release mechanisms could be easily actuated by the child occupant. The child is protected only while sitting in the seat with the harness secured.

2. Emergency removal of a child occupant from a wrecked automobile should be accomplished within a minimum time. Emergency removal always involves supporting at least a portion of the child's weight while releasing the harness mechanism. After an accident the child's weight is forced against the restraining straps if the car has overturned or if the car seat back is exerting pressure on the child and/or child's seating system.

3. Restraint harness buckles which have a low release force (even under occupant's weight load) may not completely detach all components of the harness system from the occupant. Such components as shoulder and/or lap belts may remain wholly or partially attached to the buckle and could interfere with the removal of the occupant from the seating system.

Much subjective information from consumers was also evaluated by us to finalize the release mechanism design since it is considered one of the key components of the overall child seating system. Real-world data is scarce on crash performance of child restraint systems, but accident experience is reasonably hypothesized from experience with children and emergency post-crash situations. It is considered reasonable by us that release mechanisms which actuate under the test procedures now in effect are likely to be released wholly or partially be a child prior to a crash. Protection in low speed, as well as high speed crashes, is important and a securely fastened harness is mandatory for protection. Driver distraction by unrestrained children can also cause accidents which is minimized by a release mechanism not easily operable by the child. Supporting the child's weight or otherwise relieving pressure of the child's body from the harness webbing during emergency removal is consistent with a majority of conceivable accident conditions and always would be a requirement with the impact-shield type restraints (no harness) where the occupant would be expected to be wrapped around the impact shield after a crash. Self-removal from a harness restraint under emergency conditions by a child in the 20 to 40 pound age group

4 is not reasonable unless the child is taught expressly for this purpose. In such a case, training in body articulation and hardware manipulation is probably difficult for the proposed release mechanism.

American Safety is planning procurement of the necessary tooling for manufacturing the child seat design incorporating the proposed release mechanism. The proposed child restraint release mechanism and release procedure is nearly identical to the release of the detachable shoulder harness pin-connector in production for adult restraints in certain cars for three years. The pin and plastic grommet used on the child restraint mechanism proposed are parts produced for several different 1973 model cars. The Company requests the addition of the proposed requirements to MVSS213 to permit it to manufacture and sell the child restraint product.

Gordon M. Bradford Vice President, Corporate Development

enclosures

(Graphics omitted)

PHOTOGRAPH NO. 1

Restraint release mechanism -- This general view shows the similarity to the established pin and connector design now in production for shoulder belts on adult restraints. The two straps above the release mechanism are adjustable upper torso restraints. The release mechanism is affixed to the abdominal pad and the adjustable crotch strap is sewn permanently to the release mechanism connector.

PHOTOGRAPH NO. 2

Release mechanism activation -- The initial step in activating the release is as shown. The thumb depresses the abdominal pad and foreshortens the upper torso restraints. The index finger or middle finger holds up the connector while the pin is forced downward.

PHOTOGRAPH NO. 3

Release mechanism activation -- The completion of the releasing operation shows the pin and grommet now moved downward into the enlarged opening of the connector where it is completely separated from the crotch strap and connector. A slight forward pull with the finger finishes the release. The connector is then dropped and the abdominal pad with upper torso straps attached is swung upward over the occupant's head for removal when the seat is situated in a normal horizontal attitude.

PHOTOGRAPH NO. 4

Release force requirements -- A possible form of measurement device which operates the release mechanism in a manner typical of that employed in actual use is shown. This test would be performed after the child seating system had been subjected to a static load of 1,000 lbs in accordance with MVSS213, S5.1. Following this the release force test would be done in accordance with the proposed procedure S5.3.1(d).

PHOTOGRAPH NO. 5

The position illustrated simulates a nose-down car attitude. The child's full weight is resting on the harness. The adult is about to release the harness.

PHOTOGRAPH NO. 6

The adult has pushed upward with her left hand on the abdominal pad. This slackens the crotch strap allowing normal operation of the buckle with her right hand. The load required to release the buckle in this way is no greater than normal.

PHOTOGRAPH NO. 7

The buckle has opened and the adult has begun to lower the child. The abdominal pad has slid naturally from her left to her right hand. Her left hand continues to support the abdomen.

PHOTOGRAPH NO. 8

The adult's right hand continues to guide the abdominal pad while the left hand continues to support the abdomen. The crotch strap is completely clear of the child.

PHOTOGRAPH NO. 9

The child is out of the harness and is now on what would be either the car's dash or front seat back, depending on where the child seat was installed in the vehicle. The harness is clear of the child. No force greater than the child's weight was exerted. There were no "practice" runs after instructions on how to correctly release the child were given to the Mother.

ID: aiam4565

"Dear Mr. Ditlow: This responds to your most recent letter to m concerning retrofitting of cars originally equipped with rear seat lap belts with rear seat lap/shoulder belts. In my November 1, 1988 letter to you, I explained that we have sought the voluntary cooperation of manufacturers to make retrofit kits available for those customers who desire them and that the vehicle manufacturers have responded positively to our efforts. I also explained that the fact that retofit kits are not available for all model lines produced by each manufacturer does not suggest some failure on the part of the vehicle manufacturers or of our policy to encourage the manufacturers to make such retrofit kits available. In a November 7, 1988 letter, you asserted that my November 1 letter 'reflects such callous disregard and ignorance of the facts as to defy belief that you are doing little more than covering up for a GM policy that will kill rear seat passengers.' You stated that you would welcome a 'substantive response' to this letter. I am happy to be able to give you such a response. Let me begin by emphasizing that the lap belts in the rear seat of most vehicles on the road today are effective in reducing the risk of death and injury in a crash. Based on our analysis of a number of crash data files, we estimate that rear seat lap belts saved about 100 lives and prevented over 1500 serious injuries in 1987 alone. These figures would have been substantially higher if more rear seat occupants used their lap belts. In fact, if everyone had worn their rear seat lap belts each time they rode in a vehicle, those belts would have saved about 660 lives and prevented more than 10,000 serious injuries in 1987 alone. These facts illustrate that the fastest and most effective way to save the greatest number of lives and prevent the greatest number of injuries is to convince the public to use the safety belts, including the rear seat lap belts, that are in their vehicles every time they ride in those vehicles. Because of these facts, I do not accept your assertion that GM's policy of not providing rear seat lap/shoulder belt retrofit kits for a few of their past models will 'kill people.' To the extent that reckless assertions like this tell the public that they should not wear their rear seat lap belts, it is unfortunate that you have chosen to divert attention away from the overriding issue of convincing the public to use their safety belts, and instead chosen to mislead the public about the quality of their safety belts. Even though lap belts have been proven to be effective in reducing the risk of death and injury in a crash, we agree that properly designed lap and shoulder belts have the potential to offer even greater crash protection than lap belts alone. For this reason, we have proposed to require that all new passenger cars sold in the United States be equipped with rear seat lap and shoulder belts beginning in the 1990 model year. Additionally, we have actively sought the car manufacturers' cooperation in providing retrofit kits to interested consumers. As you may know, every domestic manufacturer and many foreign manufacturers now offer retrofit kits for many of their vehicle models. You objected to General Motors' (GM) statement in its Information Bulletin that retrofit kits are not offered for its 1978-88 Oldsmobile Cutlass, Buick Regal, Chevrolet Monte Carlo, or Pontiac Grand Prix, 'because GM safety engineers have concluded that in these cars, a rear seat lap/shoulder belt combination would not enhance the safety offered by the lap belt alone.' You asserted that since Leonard Evans, a GM employee, has concluded that lap/shoulder belts are significantly more effective than lap belts and since the National Highway Traffic Safety Administration (NHTSA) is proposing to require rear seat lap/shoulder belts, there is no 'possible scientific basis' for GM's conclusion. NHTSA's proposal reflects our tentative conclusion that rear seat lap/shoulder belts that are designed and installed at the factory have the potential to offer even greater crash protection than lap belts alone for vehicles in general. However, any particular vehicle model's floor pan design, seat stiffness, and seat design (as it relates to occupant posture) can affect the possibility of an occupant submarining under a lap/shoulder belt system in a crash. During the design and production of the vehicle, the vehicle manufacturer can take these factors into account to minimize the likelihood of such submarining and its associated consequences. However, this is emphatically not true for vehicles that were not originally engineered and designed to use rear seat lap/shoulder belts as original equipment. With respect to these vehicles, the effectiveness of a retrofitted rear seat lap and shoulder safety belt system may well depend on the belt system's compatability with the vehicle and the installation of the belt system. The suitability of a particular vehicle for retrofitting is therefore a complex question. It is our view that the judgment as to whether a retrofit lap/shoulder belt system should be installed in a particular vehicle is best made by a vehicle manufacturer, which is most familiar with the detailed seat and structural design and crash performance of the car. I hope this information is helpful. Please let me know if you have any further questions or would like some additional information on this subject. Sincerely, Erika Z. Jones Chief Counsel";

ID: aiam4240

Dear Senator Stevens: Thank you for your letter on behalf of your constituent, Ms. Bridge Ernst, regarding our regulations for safety belts on school buses. Your letter has been referred to my office for reply, since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety.; In her letter to you, Ms. Ernst enclosed materials issued by th National Coalition for Seat Belts on School Buses which explained why the Coalition believes safety belts should be required by Federal law on all school buses. You asked us to discuss the main counter-arguments against such a requirement, and asked also whether any Federal legislation has been introduced recently to increase the safety requirement on school buses. I am pleased to respond.; I would like to begin with some background information on our schoo bus regulations. The National Traffic and Motor Vehicle Safety Act of 1966 authorizes NHTSA to issue motor vehicle safety standards for new motor vehicles, including school buses. Pursuant to that authority, NHTSA issued a comprehensive set of motor vehicle safety standards to improve school bus safety. Our school bus safety standards apply to various aspects of vehicle performance, including school bus windows and windshields, emergency exits, fuel systems and passenger seating and crash protection.; The safety belt issue your constituent raises involves the safet standard we issued for school bus passenger crash protection, Federal Motor Vehicle Safety Standard No. 222. Standard No. 222 requires that large school buses provide passenger crash protection through a concept called 'compartmentalization.' Compartmentalization requires that the interior of the school bus be improved with protective seat backs, additional seat padding, and better seat spacing and performance. These interior features are intended to keep occupants in their seating area during an accident. They ensure that a system of crash protection is provided to passengers independent of their actions to use safety belts. Standard No. 222 requires safety belts for passengers in smaller school buses since belts are needed on those vehicles to provide adequate crash protection.; The information from the Coalition that Ms. Ernst enclosed in he letter to you states that safety belts are needed on all school buses to protect children and keep them within their seating compartment in the event of a collision or rollover. We believe that effective passenger crash protection and containment is already provided by compartmentalization and that it would be inappropriate to issue a Federal mandate for safety belts on all school buses. While the effects of compartmentalization are expected to be greater in crashes involving front or rear impacts, the standard also has potential in side impacts and rollovers by minimizing the 'hostility' of the crash environment and by limiting the range of movement of an occupant in those two types of crashes.; For your information, I have enclosed a DOT report, 'Seat Belts i School Buses' (June 1985), which provides a thorough discussion of the safety belt issues raised by your constituent. As explained in the report, school buses in this country have compiled an excellent safety record. In addition to meeting compartmentalization requirements, large school buses incorporate more safety by virtue of their greater mass, higher seating height and high visibility to other motorists. Thus, the need for safety belts to mitigate against injuries and fatalities is not the same as that for other vehicles, such as passenger cars. Because the safety record of large school buses is very good, we must conclude that a Federal requirement for the installation of safety belts is not justified at this time.; The Coalition's material enclosed by Ms. Ernst included a statemen indicating that NHTSA 'supports local district seat belt programs.' NHTSA permits the voluntary installation of safety belts for passengers on large school buses if the purchaser wishes to have belts installed. We believe that such a decision should be made by individual schools and school districts that have made a reasoned assessment of their particular pupil transportation needs. However, because there are many effective ways to improve pupil transportation safety, such as improving driver training and school bus maintenance programs, it would be inappropriate for us to endorse local district programs for safety belts on school buses. Therefore, for purposes of clarification, we neither support nor discourage school districts' decisions to install safety belts on their large school buses.; You asked about any Federal legislation that had been recentl introduced to increase the safety of school buses. The Administration has not proposed any legislation affecting school buses. However, two bills were introduced in the 99th Congress concerning school buses. H.R. 3129 contained a provision calling for a school bus safety study to determine the measures most effective in protecting the safety of school children. H.R. 749 proposed incentive grants to the States encouraging the adoption and enforcement of laws requiring the use of safety belts in school buses. Neither H.R. 3129 nor H.R. 749 was enacted.; In addition, NHTSA has issued a notice of proposed rulemaking to amen Standard No. 222 by setting performance requirements for safety belts voluntarily installed in large school buses. If adopted, this rule would require safety belts voluntarily installed on new large school buses to meet Federal safety belt standards for strength and proper installation.; We are evaluating the comments submitted on our proposal and a fina decision on the rulemaking action is expected in the near future.; I hope this information is helpful. Please contact my office if we ca be of further assistance.; Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam5363

"Dear Mr. Fabrycky: This responds to your letter about an aftermarke product you wish to manufacture. The product is a child safety seat buckle shield, which is intended to prevent a child from opening the buckle on a child restraint system. You state that your device would cover the buckle and prevent the child from gaining access to the pushbutton of a child seat buckle. To depress the pushbutton, the device requires that a latch be actuated and the cover pivoted away from the buckle. You indicated that the device requires 'manual dexterity to exert the forces in many directions simultaneously.' Although we understand your concern that young children not be able to easily unbuckle a child safety seat, we have reservations about devices that interfere with the unbuckling of the seats. I hope the following discussion explains those reservations and answers the questions in your letter about the effect of our regulations on your product. Our agency has the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Safety Standard No. 213, 'Child Restraint Systems,' which applies to all new child restraint systems sold in this country. However, Standard 213 does not apply to aftermarket items for child restraint systems, such as your buckle shield. Hence, you are not required to certify that this product complies with Standard 213 before selling the product. Additionally, you are not required to get 'approval' from this agency before selling the buckle shield. NHTSA has no authority to 'approve' motor vehicles or motor vehicle equipment, nor do we endorse any commercial product. Instead, the National Traffic and Motor Vehicle Safety Act establishes a 'self- certification' process under which each manufacturer is responsible for certifying that its products meet our safety standards. The agency periodically tests vehicles and equipment items for compliance with the standards, and also investigates alleged safety-related defects. Although we do not have any standards that directly apply to your product, there are several statutory provisions that could affect it. Manufacturers of motor vehicle equipment such as your buckle shield are subject to the requirements in sections 151-159 of the Safety Act concerning the recall of products with defects related to motor vehicle safety. The agency does not determine the existence of safety defects except in the context of a defect proceeding, and thus is unable to say whether your product might or might not contain such a defect. However, the agency is concerned that people be able to easily and quickly operate a child safety seat buckle in an emergency. As the agency said in a rule on the force level necessary to operate child restraint buckles: The agency's safety concerns over child restraint buckle force release and size stem from the need for convenient buckling and unbuckling of a child and, in emergencies, to quickly remove the child from the restraint. This latter situation can occur in instances of post-crash fires, immersions, etc. A restraint that is difficult to disengage, due to the need for excessive buckle pressure or difficulty in operating the release mechanism because of a very small release button, can unnecessarily endanger the child in the restraint and the adult attempting to release the child. (50 FR 33722, August 21, 1985) It appears that your product could significantly increase the difficulty of using the buckle release and thus hinder a person attempting to release the belt in an emergency. In addition, use of your product could be affected by section 108(a)(2)(A) of the Safety Act. That section prohibits commercial businesses from knowingly tampering with devices or elements of design installed in an item of motor vehicle equipment, such as a child safety seat, in compliance with the Federal motor vehicle safety standards. In determining the effect of a buckle shield on a child seat's compliance with Standard 213, NHTSA would evaluate the performance of the seat with the buckle shield installed. Standard 213 specifies several elements of design with which a child restraint system is unlikely to comply if your buckle shield were installed. Section S5.4.3.5 of Standard 213 requires the pushbutton release for any buckle on a child restraint to have a minimum area for applying the release force. Since your device will completely cover the buckle when installed, the buckle shield would cause the child restraint to no longer comply with this requirement. That section also requires the buckle to release when a specified maximum force is applied. Your device will not allow the buckle to release when the force is applied because it will cover the buckle and require force to be applied 'in many directions simultaneously.' Your device would thus cause the child restraint to no longer comply with that requirement. Therefore, commercial establishments cannot legally install your device on customers' child safety seats. In addition, section S5.7 of Standard 213 requires each material used in a child restraint system to comply with the flammability resistance requirements of Standard 302, 'Flammability of Interior Materials.' If your buckle shield does not comply with the requirements of Standard 302, commercial establishments cannot legally install your device. The prohibition of section 108(a)(2)(A) does not apply to individual vehicle owners who may install or remove any items on child restraint systems regardless of the effect on compliance with Standard 213. However, our policy is to encourage child restraint owners not to tamper with or otherwise degrade the safety of their child restraints. I hope this information is helpful. If you have any further questions, please contact Ms. Deirdre Fujita of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel";