ID: nht89-1.92

TYPE: INTERPRETATION-NHTSA

DATE: 05/22/89

FROM: H. HASEGAWA -- AUTOMOTIVE LIGHTING ENGINEERING CONTROL SECT. STANLEY ELECTRIC CO LTD

TO: RICHARD L. VAN IDERSTINE -- SAFETY STANDARDS ENGINEER U.S. DOT, NHTSA OFFICE OF VEHICLE SAFETY STANDARDS

TITLE: REVISION OF FMVSS NO. 108 (DOCKET NO. 85-15 NOTICE 8)

ATTACHMT: ATTACHED TO LETTER DATED 06/19/89 FROM STEPHEN P. WOOD -- NHTSA TO HASEGAWA; REDBOOK A33 [3]; STANDARD 108; DOCKET 85-15 NOTICE 8

TEXT: Dear Mr. Van Iderstine,

We appreciate very much for your kind cooperation during our stay in the U.S. for SAE Lighting Commity Meeting.

We have two questions on Revision of FMVSS No. 108 (Docket No. 85-15 Notice 8) which was finally issued on Federal Register of May 9, 1989.

- Question -

1. Please advice us the effective date of the requirement of S7.7.5.1 a). We suppose that S7.7.5.1 will be applied to the all headlamp with external aiming system (including replaceable bulb type headlamp).

However, this requirement was not applied for replaceable bulb type headlamp by previous FMVSS No. 108.

Therefore, we think that addition of new requirement need longer interval of effectiveness.

2. The requirement of S7.7.5.1 b) used quote SAE J580b "Sealed Beam Headlamp Assembly" by previous FMVSS No. 108 and the expression is little bit different from new S7.7.5.1 b).

Please advice us that the requirement of "0.1 in. max." will be determined, either during the test or after the test?

We would like to have your advice by facsimile.

Our facsimile number is 03-792-0007 (JAPAN).

Sincerely yours,

ID: nht89-2.67

TYPE: Interpretation-NHTSA

DATE: August 10, 1989

FROM: William Shapiro -- Manager, Regulations and Compliance, Volvo Cars of North America

TO: Stephen P. Wood -- Acting Chief Counsel, NHTSA

TITLE: Re Request for Interpretation FMVSS 213 - Child Restraint Systems

ATTACHMT: Attached to drawing of child booster cushion (graphics omitted); Also attached to letter dated 9-14-90 from P.J. Rice to W. Shapiro (A36; Std. 213)

TEXT:

Volvo has designed and developed a "built-in" child booster cushion for use in a future model vehicle. It will be integrated into the center rear seat arm rest such that the arm rest will split in half to form the booster cushion. The child using this "built-in" booster cushion will utilize the center rear 3-point seat belt for their restraint.

Because the agency has stated in the preamble to the final rule, that sets forth the requirements for "built-in" child seats, that "...S5.4.3.3 allows child restraint systems other than a 5-point harness...", Volvo believes that a "built-in" booster cush ion that utilizes the adult 3-point center rear seat belt and is designed with due care to meet all the requirements of FMVSS 213, as they apply to "built-in" child seats, is in compliance with FMVSS 213. Volvo believes that by meeting all the labeling, instruction and performance requirements set forth by FMVSS 213 - Child Restraint Systems, this "built-in" booster cushion can be marketed in the U.S. We ask that the agency confirm this as soon as possible.

Some illustrative sketches are attached. If you need any additional information, or would like to see the seat, please feel free to contact me.

Drawings of child booster cushion are attached (graphics omitted).

ID: ES02-002690

Bruce Vokoun
3745 Pioneers Blvd.
Lincoln, NE 68506

Dear Mr. Vokoun

This responds to your correspondence directed to Senator Nelson and forwarded to the U.S. Department of Transportation regarding the obtainment for you of a waiver of DOT's regulations so that you may obtain a non-breakable windshield. I apologize for the delay in our response. As explained below, the agency has determined that an exemption for your windshield from the requirements of the National Highway Traffic Safety Administration's (NHTSA) Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing materials (49 CFR 571.205) is permissible in this situation.

By way of background, the NHTSA administers a statute requiring that motor vehicles manufactured for sale in the United States or imported into the United States be manufactured so as to reduce the likelihood of motor vehicle crashes and of deaths and injuries when crashes do occur. That statute is the National Traffic and Motor Vehicle Safety Act of 1966 ("Vehicle Safety Act") (49 U.S.C. 30101, et seq.).

One of the agency's most important functions under the Act is to issue and enforce FMVSSs. These standards specify safety performance requirements for motor vehicle and/or items of motor vehicle equipment. Manufacturers of motor vehicles must certify compliance with all applicable safety standards and permanently apply a label to each vehicle stating that the vehicle complies with all applicable FMVSSs.

FMVSS No. 205 establishes performance and marking requirements for all glazing installed in motor vehicles. The standards incorporates by reference the requirements of Standard ANS Z-26, "Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways," of the American National Standard Institute. Standard ANS Z-26 requires that glazing materials for windshields must pass a specified group of test requirements designed to address safety concerns related to both visibility and occupant protection in the event that the windshield breaks. Under Federal law, dealers and motor vehicle repair businesses normally are prohibited from deactivating components that have been installed to comply with such safety standards.

On February 27, 2001, NHTSA published a final rule setting forth a limited exemption from the make inoperative prohibition for businesses or individuals who modify vehicles for persons with disabilities (66 Federal Register 12638; Docket No. NHTSA-01-8667). The exception, codified at 49 CFR Part 595, was limited to modifications made after the first retail sale of the vehicle. Accordingly, it does not apply to vehicle manufacturers or alterers. Vehicle modifiers, i.e., businesses that modify a vehicle after first retail sale, may not modify a vehicle in such a way as to negate the vehicle's compliance with any applicable FMVSSs for which there is no exemption, although the modifier is not required to certify compliance with all applicable standards.

While portions of several FMVSSs are included in the Part 595 exemption, FMVSS No. 205 is not. This is because NHTSA is generally unaware of circumstances where there would be a need to install glazing materials that do not meet the standard. NHTSA does, on occasion, issue letters of non-enforcement to address vehicle modifications that are not covered by the Part 595 exemption. In accordance with our policy of case-by-case consideration of specific situations, and in view of your son's medical condition, NHTSA will not enforce this provision against any dealer or repair business that installs a non-breakable windshield in your vehicle.

You should show this letter to your dealer or repair business when you take your vehicle to have the windshield replaced. If the dealer or repair business wishes to verify the authenticity of this letter, they may call the telephone number below.

Because of the safety benefits provided by glazing that complies with FMVSS No. 205, we strongly urge you to have the original windshield reinstalled in your vehicle prior to selling your vehicle. In addition, it is imperative that you use your safety belt at all times.

If you have any questions, pleas call Nancy Bell of my staff, who may be reached at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:205
d.4/18/03

ID: 003788_noggin_nest

Ms. Liz Franqui
The Boppy Company
560 Golden Ridge Rd., Suite 150
Golden, CO 80401

Dear Ms. Franqui:

This responds to your letter about a product you market called the Noggin Nest. According to your letter, the Noggin Nest is placed behind a babys head "to prevent Flat Head Syndrome." You currently market the product for use in a stroller, car seat [sic], bouncer or swing and would like to market the product for use in motor vehicle child restraint systems. You ask what regulations apply to the Noggin Nest and whether the product can be used in a child restraint without hindering the restraints performance in a crash.

By way of background, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards for new motor vehicles and new items of motor vehicle equipment. Section 30102(a)(7) of our statute (40 U.S.C. Chapter 301; "the Safety Act") defines the term "motor vehicle equipment," in pertinent part, as:

(A) any system, part, or component of a motor vehicle as originally manufactured; (B) [or] any similar part or component manufactured or sold for replacement or improvement of a system, part, or component, or as any accessory or addition to a motor vehicle. [Emphasis added.]

NHTSA has two criteria in determining whether a device is an "accessory." The first criterion is whether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. The second is whether the product is purchased or otherwise acquired, and principally used, by ordinary users of motor vehicles. We believe that the Noggin Nest would meet both of these criteria when you start marketing it for use in child restraint systems. A substantial portion of the expected use of the product would be with respect to use with child restraints. The product would be purchased and principally used by ordinary users of motor vehicles.

NHTSA does not approve or certify any vehicles or items of equipment. Instead, Congress has established a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

There currently are no Federal motor vehicle safety standards (FMVSSs) that directly apply to the Noggin Nest. Our standard for "child restraint systems," FMVSS No. 213, applies to "any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 65 pounds or less." The standard does not apply to accessory items, such as a pad that is used with a child restraint system.

While no FMVSS applies to the Noggin Nest, as a manufacturer of motor vehicle equipment, you are subject to the requirements of 49 U.S.C. 30118-30121 concerning the recall and remedy of products with safety-related defects. I have enclosed an information sheet that briefly describes those and other manufacturer responsibilities. In the event you or NHTSA determines that your product contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge.

In addition, while it is unlikely that the Noggin Nest would be installed by a motor vehicle manufacturer, distributor, dealer or repair business, 49 U.S.C. 30122 prohibits those businesses from installing the device if the installation "makes inoperative" compliance with any safety standard. Our FMVSSs require specific levels of performance for materials used in the occupant compartment of motor vehicles.

You state in your letter that you want to ensure that the Noggin Nest would not affect compliance with FMVSS No. 213 or otherwise interfere with the performance of the child restraint system and ask for guidance in this area. NHTSA is unable to ascertain whether and to what degree your product would affect the performance of a child restraint. However, we make the following observations for your information. The photographs you enclosed show that the product has slots through which the child restraints belts are routed. Depending on their design, some slots could restrict the belts' ability to perform in a crash. Further, padding inserted between the child restraint and the child passenger could compress in a crash and introduce slack into the belt system. In addition, FMVSS No. 213 specifies flammability resistance requirements for child restraints. Any person listed in 30122 who installs a Noggin Nest must not make inoperative the flammability resistance of the child restraint system.

The prohibition of 30122 does not apply to individual owners who install equipment in their own vehicles. Thus, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, NHTSA encourages vehicle owners not to degrade the safety of their vehicles or motor vehicle equipment.

State or local jurisdictions might have their own requirements for products such as the Noggin Nest. For information about those requirements, you should contact the Department of Motor Vehicles in any state in which the equipment will be sold or used.

If you have any other questions, please contact Deirdre Fujita of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:213
d.7/19/04

ID: nht80-2.23

DATE: 04/29/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Quester Juvenile Products Company

TITLE: FMVSS INTERPRETATION

TEXT:

April 29, 1980

NOA-30

J.P Koziatek, P.E. Director, Technical Services Questor Juvenile Products Company 771 N. Freedom Street Ravenna, Ohio 44266

Dear Mr. Koziatek:

This responds to your letter of January 25, 1980, requesting an interpretation of section S6.1.2.2.1(c) of Standards No. 213, Child Restraint Systems. Section S6.1.2.2.1(c) specifies that in the 20 mph test of forward facing child restraints with fixed or movable surfaces designed to restrain the child, the restraint system's belts are not to be attached "unless they are an integral part of the fixed or movable surface." You asked whether the crotch strap used in your Kantwet "One Step" Model-400 child restraint would be considered an integral part of the movable shield used on that device. After reviewing the diagrams and description contained in your letter, I conclude that the crotch strap is not an integral part of the movable surface and thus must not be connected during the 20 mph test.

Amended Standard 213 is intended to address, among other things, the problem of misuse of child restraints. The principal misuse involves the failure to attach buckles and latches. To ensure that children using child restraints are afforded protection notwithstanding such misuse, the standard specifies that the belts are to be attached to restraining shields during testing only if they are integral parts of the shields. Webster's New Collegiate Dictionary (1977) defines "integral" as meaning "formed as a unit with another part." Attachment of belts that are integral parts is permitted since they are intended to remain attached whether or not the restraint is in use and thus are not subject to the type of misuse described above.

The crotch strap used in the Kantwet "One Step" is not an integral part of the movable shield. The movable shield is a complete unit by itself. The crotch strap is a separate device that must be manually connected to the shield every time the unit is used. In contrast, the two upper torso restraints appear to be integral parts of the shield since they are designed to remain attached to an adjustment device and anchorage which are in turn permanently affixed to the shield. Nevertheless, we are concerned about the possibility that the upper torso restraint could be detached from the adjustment device. We urge that you and other manufacturers take the additional step of assuring that the belts permanently remain integral parts of the adjustment device.

If you have any further questions, please let me know.

Sincerely,

Original Signed By

Frank Berndt Chief Counsel

January 15, 1980

Mr. Frank Berndt Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION Nassif Building, Room 5219 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Berndt:

Re: FMVSS 213-80 CHILD RESTRAINT SYSTEMS REQUEST FOR INTERPRETATION KANTWET "ONE STEP" MODEL 400

This letter is written to provide NHTSA with the rationale leading to the design and development of the new Questor Juvenile Furniture Company (QJFC) child restraint system (Kantwet "One Step" Model 400) and to request NHTSA's confirmation of the manner in which this particular child restraint system is to be tested to determine its compliance with FMVSS 213-80, as published in the Federal Register on Thursday, December 13, 1979. Most important, we have set forth information substantiating the fact that the crotch strap incorporated in our new combined harness/restraint is "an integral part of the fixed or movable surface" under paragraph S6.1.2.3.1 (c) of FMVSS 213, thereby permitting the fastening of this integral strap during test configuration II.

Much has been written about the lack of use of child restraint systems, their cost, and their incorrect or incomplete installation/use. These concerns are well documented and have been expressed by the general public, concerned groups interested in promoting improved child passenger safety, and NHTSA. NHTSA has obviously deliberated long and with great effort in an attempt to develop rulemaking that would address those aspects of child restraint system design and usage that increase child passenger protection when properly designed child restraint systems are correctly installed in passenger vehicles. FMVSS 213-80, as published in the Federal Register on December 13, 1979, also attempts to protect the child passenger by requiring child restraint systems to meet certain minimum performance standards when they are improperly or incompletely installed in a passenger vehicle. While it is impossible to predict all potential incomplete or incorrect installations of child restraint systems in passenger vehicles, it has become apparent that certain omissions in child restraint system installations occur at a relatively high rate.

Tests have shown that child restraint systems installed with a top tether strap do reduce the occupant's relative head excursion, however these systems are often installed by the consumer without the top tether strap. The convenience armrest incorporated in some systems is also frequently misused in that it is placed in its lowered position with its restraining strap fastened, but the harness straps which are always part of such a system and which provide restraint for the system's occupant are often left unfastened. FMVSS 213-80 has considered these two improper installations of restraint systems and requires minimum occupant protection when the systems are tested under these improper conditions.

Devices for seating children in passenger vehicles were available to the consumer long before the advent of NHTSA and safety regulations for automobile occupants. Prior to NHTSA rulemaking in 1971, the majority of such child seating devices provided no protection for their occupants in the event of even low-speed vehicle accidents. However, since 1971, and particularly since 1974, there has been significant improvement in the crashworthiness of products available for seating children in passenger vehicles. The improvement has been such that child seats for automobile can now be truly classified as child restraints or, as some have suggested, "child protectors."

QJFC and its predecessor companies have been in the business of manufacturing and marketig child seating devices and restraint systems for more than 25 years. QJFC, perhaps more so than anyone else, has recognized the tremendous improvement in occupant protection now available to the consumer with crash-tested child restraints.

Likewise, QJFC has seen considerable shrinkage of the annual sales of child estraiit systems as their crashworthiness has improved and their cost has increased, as compared with the child seating devices formerly manufactured. QJFC has been concerned throughout this transition period that the consumer is not always interested in safety when he has a choice to make or that he is not fully cognizant of the possible consequences when a crash-tested child restraint system is, first, not purchased and, second, not used properly when purchased.

Since 1972, QJFC has designed and introduced five child restraint systems to the marketplace. Each of these systems was designed to meet crash testing criteria. As the state of the art improved and as more meaningful testing criteria were learned or published, the individual restraint systems were re-designed or discontinued, to be succeeded by designs which improved crashworthiness. Concurrently with efforts to improve the crashworthiness of restraint systems, QJFC recognized the sensitivity of the marketplace to the cost and the ease of use of child restraint systems. This led to the design of the Kantwet "Care Seat," the first restraint system marketed which provided crash protection for the occupant from birth through 43 pounds. The system was designed to (and did) meet the maximum relative head excursion of 18 inches forward of the forwardmost point of the car seat back without the use of a top tether anchor strap.

To provide a crash-tested restraint system for children from birth to 17 pounds, at the lowest possible cost. QJFC designed and marketed the Infanseat "Dyn-O-Mite" child restraint. This product, with its attractive pricing and broad distribution, has been well-received by the consumer and has served to re-emphasize the sensitivity of the marketplace to price and ease of use.

These comments are offered to indicate the awareness that QJFC has of the marketability and proper installation of child restraint systems. In addition to our own design and market experiences, we agree with the objectives NHTSA has established to improve the performance of the restraints, increase the use, and minimize their misuse.

To this end, QJFC has taken the sum total of its 25 years of marketing experience and combined this with NHTSA's objectives to design its sixth new crashworthy child restraint system since 1972. This system, the Kantwet "One Step" car seat, Model 400, is of a design that is a significant departure from previously available child restraint systems, thus incorporating features not necessarily familiar to NHTSA or the general public. Certain aspects of the design of the "One Step" will require interpretation in order to test the restraint properly against FMVSS 213-80.

The features of the Kantwet "One Step" design can best be understood by referring to various drawings in conjunction with the description that follows. The drawings are enclosed with this letter.

The system consists of three main parts: the tubular steel frame, a padded molded plastic shell, and a harness/shield restraint. These are shown in Figure 1. Combining these three main parts allows the assembly to be used as a rear-facing system for infants and as an upright forward-facing system for children who weigh more than 17 pounds but less than 43 pounds, with this mode also capable of being used in a forward-facing reclined position. Thus, a single purchase enables the consumer to provide protection for his child from birth through 42 pounds in weight.

Dynamic testing has been conducted on prototype and production mode is of the "One Step," and the tests have indicated excellent compliance with the performance requirements of FMVSS 213-80 in all three installation positions. These dynamic tests have been conducted at a simulated impact of 30 mph, and the average maximum relative head excursion achieved without the use of a top tether strap has been less than 32 inches. Head injury criteria and average chest accelerations have been well within requirements on those occasions when instrumented test dummies were used.

These favorable test results are attributable to the combination of a harness and an impact shield restraint system where in the most desirable features of a five-point harness and an impact shield have been combined. The single greatest criticism by the consumer of an impact shield-type of restraint has always been the difficulty of keeping the occupant within the system. The freedom of movement available to the occupant of an impact shield restraint allows the occupant not only to climb out of the system but also, if he remains in it, to be out of the ideal position to absorb effectively the forces imposed during an accident. A five-point harness restraint system distributes crash forces satisfactorily to the occupant; however, the webbing of such a system, with continued use, becomes entangled and crossed over itself, and it begins to "rope" or twist upon itself. This roping and twisting of the webbing thus imposes higher localized loading to the occupant in a crash; also, in many cases, the consumer fails to utilize the five-point harness when placing a child in such a system because he does not wish to take the time to untangle and straighten the webbing first.

The "One Step" restraint system integrates the webbing of the upper torso restraint with the crotch strap and impact shield in a continuous connection. This arrangement provides some unique features and advantages not heretofore available with child restraint systems. These advantages are described below and shown in the appended drawings.

1. The security of a five-point harness system is provided, thus retaining the occupant, with the further guarantee that the occupant will be properly positioned in the system in the event of an accident.

2. A large padded surface is available with the impact shield located at the lower torso area, to distribute impact forces over as large an area as possible.

3. While the impact shield is designed to distribute impact forces to the lower torso area, it is also shaped in such a manner and positioned so that its lower surface rests against the occupant's upper thigh. This placement eliminates the need for a separate lap belt assembly for restraint of the lower torso. Thus, the possibility of a lap belt assembly's roping, twisting, and cutting into the pelvic area has been completely obviated. The intrusion of lap belts into the hip joint of test dummies has frequently been observed during crash testing in spite of the use of a crotch strap on a five-point harness restraint.

4. The impact shield, in addition to serving the aforementioned functions, also simulates the buckle of a five-point harness system in that it accepts the ends of the upper torso belts and provides a means of connecting the crotch strap to itself. Thus, the impact shield serves a multiplicity of purposes, as well as providing a means of "shielding" the occupant's torso and extremities against certain metal hardware items.

Reference to Figures 1 and 2 will highlight the similarities between a conventional five-point harness restraint system and integrated "One Step" combination harness/shield restraint system. The impact shield of the "One Step" essentially replaces both the retaining buckle and the lap belt of a typical five-point harness system, as shown in Figure 2. Both the impact shield and the buckle serve the same purpose of accumulating the belts and of fastening them together.

5. The belts of the upper torso restraint are routed from the back support surface of the system to and around the impact shield so that their "lie flat" position is guaranteed. Reference to Figures 1 and 3 clearly illustrates this. When the impact shield is raised or lowered for entrance or egress of the occupant, the shield maintains this "lie flat" condition of the upper torso belts, preventing any possibility of their roping, twisting, or becoming entangled with themselves or any other belting. Figure 4 shows the impact shield being raised, with the upper torso belts being lifted simultaneously from the occupant.

6. Since the upper torso belts and the crotch strap are sewed together to form a continuous loop about the restraint's occupant, adjustment of the upper torso belts automatically brings the crotch strap to its corrent length and the impact shield to its correct position for the size of the occupant. The restraint system can thus "grow" with the occupant or adjust to the amount of clothing worn by the child since the impact shield contacts its upper thighs.

7. Reference to Figure 3 shows the location of metal adjustment hardware on the underside of the impact shield. It can be seen that all hardware is away from the occupant and does not contact him. This feature eliminates the possibility of over-heated metal components burning the occupant on hot summer days, a situation that NHTSA has requested manufacturers to correct.

8. Further reference to Figure 3 shows the buckle which fastens the entire harness/shield restraint system together under the impact shield and therefore out of reach of the occupant. This feature prevents the child from purposely or inadvertently releasing the buckle and thus defeating the restraint. NHTSA has identified the release of buckles on five-point harness systems as being a significant problem and has tried to minimize the occurrence by requiring manufacturers to have a minimum release force for their buckles. The "One Step" restraint system has thus gone "one step" beyond NHTSA's requirements and eliminated accidental buckle release entirely.

9. Adjustment of the entire restraint system is accomplished simply by pulling on the ends of the upper torso restraint belts, as shown in Figure 3. As stated previously, this action adjusts the entire system to "fit" the occupant correctly and position him in the location and posture intended to absorb impact forces best. Further, once the adjustment is made, it cannot be loosened accidentally by the occupant, not only because the adjustment means is located out of reach but also because a separate and distinct secondary action is needed to pull the belts back from their adjusted length. To loosen the restraint's adjusted length of belting, it is necessary to lift one portion of the belt-adjusting mechanism, as shown in Figure 5, before the belting can be loosened.

Two important advantages result from this feature. First, the child cannot purposely or accidentally loosen the restraint through his movements or through playing with the strap slides that are the usual method of adjusting harness belting. Thus the child is always properly positioned to absorb impact forces during an accident. Second, the restraint system need not be adjusted each time it is occupied. Once the system has been adjusted to fit the child, the same "fit" will be available the next time the restraint is used since it will retain its length of webbing until the webbing length is purposely changed through the conscious actions shown in Figure 5.

10. Figure 6 is an enlarged view of the hardware as it is located under the impact shield. This view illustrates the routing of the upper torso belting through the adjustment hardware and also shows that the hardware itself is permanently fastened to the shield, thus preventing disengagement and possible loss of hardware from the system.

The combination of the above features makes the "One Step" child restraint the most convenient system to use. When the impact shield is raised, all belting is lifted clear of the seating surface, thus presenting an unobstructed area for the occupant. Once the child is seated, there is no need to search for belting or hardware under him. When the impact shield is lowered, the upper torso belts are brought into correct position over the child's shoulders and held in correct alignment to prevent their slipping from his shoulders since the belts are "fixed" in locations at either end of the upper torso portion of the belts. When not occupied, the belts are held in proper relationship to themselves and to the system itself, which precludes their roping, entanglement, and twisting. Once placed in a vehicle, the "One Step" can remain in the car, secured by the auto's lap belt, regardless of its position either forward-facing or rearward-facing, since the lap belt is routed under the restraint system's seating surface for all the restraint's positions. (Most other rearward-facing restraint systems are designed so that the vehicle belt used to retain the system in the vehicle passes over the occupant, which means the lap belt must be detached for the child's egress, with subsequent restraint usage requiring re-connection and adjustment of the vehicle belt.) Once the "One Step" is adjusted to "fit" the child, it need not be "re-fitted" each time it is used unless the child has increased in stature or wears bulky winter clothing since the adjustment mechanism retains the length of the adjusted belts until they are consciously altered.

**INSERT FIGURES**

QJFC believes the Kantwet "One Step" Model 400 child restraint system to be the most convenient crash-tested child restraint system available for use by children from birth through 42 pounds in weight. It is believed that this restraint incorporates the best knowledge and experience QJFC has gained in over 25 years of manufacturing and marketing juvenile products plus the knowledge NHTSA has provided to manufacturers of child restraint systems regarding the crashworthiness that such systems must provide.

It is QJFC's belief that when tested according to test configuration II, installation of the "One Step" system (as described in paragraph S6.1.2.3.1 (c) of FMVSS 213, published in the Federal Register of December 13, 1979) permits fastening of the integral crotch strap of the harness/shield restraint. NHTSA confirmation of this installation procedure for conducting test configuration II is requested.

I would be pleased to visit NHTSA personally to describe and discuss the "One Step" child restraint further, should that be desired.

Yours truly,

QUESTOR JUVENILE PRODUCTS COMPANY

J. P. Koziatek, P.E. Director, Technical Services

Attachments

JPK:MG

*Insert Figure 3, 4, 5, and 6 Here

ID: nht87-2.16

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 18, 1987

FROM: MARY F. BARRAS -- SALES ASSISTANT, CONTRACT ADMINISTRATION, M.A.N. TRUCK & BUS

TO: MICHAEL W. VORIS -- BUS PROCUREMENT SUPERVISOR, METRO

TITLE: CONTRACT NO. T/F 19-84 REAR EMERGENCY WINDOW

ATTACHMT: MEMO DATED 2-23-88, TO JAY COSTA, FROM ERIKA Z. JONES, STD 271, REDBOOK A31; MEMO DATED 7-1-87, TO ERIKA Z. JONES, FROM JAY COSTA; MEMO DATED 6-25-87, CONTRACT NO. T/F 19-83 REAR EMERGENCY WINDOW

TEXT: In response to your letter of June 16, 1987 I am providing the following information in regard to converting the rear emergency window to a non-openable type window.

According to FMVSS 217, a total of 4,355 square inches is required for this bus. Please see the attached FMVSS information provided in regard to the computations used to arrive at this figure. Our bus has 19 windows, including the rear window, which totals 536 square inches per window. The bus also has 3 roof hatches which total 506.25 square inches per hatch. Therefore, the computations are listed below: 536 sq. ins. x 19 windows, including rear = 10,184 sq. ins. 506.25 sq. ins. x 3 roof hatches = 1,519 sq. ins. *11,703 sq. ins. * This total can be considered the accountable square inches on the bus in regard to safety requirements set forth by FMVSS 217. Also, 1,742 square inches (40%) of one side of the bus is unobstructed thereby, complying with this standard.

Therefore, the rear emergency window may be changed and the bus will remain within the FMVSS 217 boundries.

May we suggest that Metro directly contact the window manufacturer in regard to any modification to be made to this window so that warranty provisions do not become void. Please feel free to contact Mr. Mike Hurtekant at Excel Industries at (219) 264 -2131 in Elkhart, Indiana. ATTACHMENTS

ID: 9661

Mr. Jerry L. Steffy
Triumph Designs, Ltd.
Hinckley
Leicestershire LE10 3BS
England

Dear Mr. Steffy:

This responds to your FAXes of February 10 and 11, 1994, to Taylor Vinson of this Office.

You have informed us that in Canada you were able recently "to use ECE Reg. 20 in lieu of FMVSS 108 for a particular headlamp use." You have asked whether it is possible to do the same in the United States.

The answer depends upon whether the ECE Reg. 20 headlamp also meets FMVSS No. 108. Motor vehicles manufactured for sale in the United States must be equipped with headlamps that comply with FMVSS No. 108. This standard does not incorporate ECE Reg. 20. Therefore, importation and sale in the United States of any motor vehicle equipped with an ECE Reg. 20 headlamp that does not meet Standard No. 108 would be in violation of our law.

You have also asked whether our temporary exemption procedures, 49 CFR Part 555, would permit you to apply for an exemption for this headlamp on the grounds of "an equivalent overall level of motor vehicle safety." After one model year, you would change to a headlamp that meets FMVSS 108.

The exemption procedures are available to manufacturers of motor vehicles, but not motor vehicle equipment. Thus, the manufacturer of an ECE Reg. 20 headlamp could not apply for an exemption. The appropriate petitioner would be the manufacturer of a motor vehicle on which a Reg. 20 headlamp is installed as original equipment. We assume that Triumph Designs is associated with the manufacturer of Triumph motorcycles, and this manufacturer would be eligible to submit a petition under Part 555.

If you have any further questions, we shall be pleased to answer them.

Sincerely,

John Womack Acting Chief Counsel

ref:108#555 d:3/16/94

ID: nht80-2.17

DATE: 04/24/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: BMW of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Karl-Heinz Ziwica Manager, Safety & Emission Control Engineering BMW of North America, Inc. Montvale, New Jersey 07645

Dear Mr. Ziwica:

This responds to your letter of March 12, 1980. You asked whether, in the case of motorcycles, the appearance of the vehicle identification number (VIN) on the certification label required by 49 CFR Part 567 satisfies the requirements of S4.3 of Safety Standard No. 115 (49 CFR 571.115). The answer is yes. The Part 567 certification label meets note that, in order to satisfy Safety Standard No. 115, the VIN on the certification label must meet the style requirements of S4.3.1.

Sincerely,

Frank Berndt Chief Counsel

March 12, 1980

Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation 400 - 7th Street S.W. Washington DC 20590

RE: Request for Interpretation FMVSS 115, Vehicle Identification Number

Dear Sir

We request confirmation, that in the case of motorcycles, it would be permissible to simultaneously comply with FMVSS 115, S 4.3, and Part 567.4 (a), (b), (e) and (g)(6), which describe the method of affixing a VIN to a motorcycle in substantially the same language that is not mutually exclusive. It is our understanding that the certification label, which must bear the VIN, if applied in the form of a permanent label that cannot be removed without destruction, to the chassis of a motorcycle as close as practicable to the intersection of the steering post with the handle bars, would fulfill the requirements of both Part 567 and FMVSS 115.

Very truly yours

Karl-Heinz Ziwica, Manager Safety & Emission Control Engineering

KHZ/jps

ID: nht81-1.32

DATE: 03/10/81

FROM: STEPHEN W. MATSON -- TRADE SERVICES INC

TO: CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/25/81 FROM FRANK BERNDT -- NHTSA TO STEPHEN W. MATSON; REDBOOK A22, STANDARD 108

TEXT: Dear Sir:

This letter is to formally request your review and interpretation of Federal Motor Vehicle Safety Standard 108 as it relates to the placement of a clear lens cover in front of a motorcycle headlamp. The attached drawings demonstrate the specific concept in question.

Information contained in SAE standards referenced in Table III of FMVSS 108 indicates that a specific prohibition exists regarding a headlamp lens cover for passenger cars, multipurpose vehicles, trucks and busses. The SAE Motorcycle Headlamp Standard (SAE J584) contains no such prohibition. It is our understanding that a component configuration such as the one illustrated would not conflict with SAE referenced requirements.

Another section of FMVSS 108 which could relate to this issue is Paragraph S4.1.3 which states that "No . . . . automotive equipment shall be installed that impairs the effectiveness of lighting equipment required by this standard." If, when the secondary lens in question is in place, the photometric requirements of FMVSS 108 can be met or exceeded, the lens cover would then be compatible with the standard.

Detailed review of FMVSS 108 and the other Federal Motor Vehicle Safety Standards have revealed no other requirements germane to this issue.

Your review of our analysis will be most appreciated. We feel that the proposed concept is in keeping with the spirit as well as the letter of the law. Hopefully your review will confirm our opinion. Should you have any questions on this matter please do not hesitate to contact me.

Sincerely,

ENC

ID: nht78-3.27

DATE: 02/14/78

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

TO: Ward Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your December 14, 1977, letter asking whether the rear push out window emergency exit option in Standard No. 217, Bus Window Retention and Release, is limited to rear-engine school buses.

The National Highway Traffic Safety Administration (NHTSA) initially proposed that this option be restricted to rear-engine school buses. Comments to that rulemaking, however, persuaded the agency to permit the use of these emergency exits on all school buses regardless of the location of the engine or passenger seats. That determination was explained in the preamble to the final rule published on June 3, 1976 (41 FR 22356) (enclosed).

I trust that this fully responds to your question.

SINCERELY,

WARD Industries, Inc.

December 14, 1977

Joseph Levin, Chief Office of Chief Counsil National Highway Traffic Safety Admn.

Re: FMVSS 217

Dear Mr. Levin:

Paragraph S5.2.3.1(b) and referenced Figure 3C of FMVSS 217 permits the use, as a manufacturer's option, one emergency door on the vehicle left side and a pushout rear window (16 inches x 48 inches).

Does this standard permit the use of this rear window in other than rear engine type vehicles? We have had requests from schools to manufacture a conventional school bus equipped with the above combination of emergency exits.

Since Figure 3C of referenced FMVSS shows a rear shelf between the rear seat and the rear wall, does this prohibit the use of the rear pushout window when seats are located all the way to the rear wall?

An early response to this petition for clarification will be appreciated.

E. M. Ryan, Chief Design Engineer

cc: BUD RYAN; JAMES STRAUB