ID: nht76-2.19

DATE: 11/22/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Crown Coach Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 7, 1976, in which you ask several questions concerning Standard No. 217 Bus Window Retention and Release, and Standard No. 222, School Bus Passenger Seating and Crash Protection.

Your first question asks whether a California regulation requiring 20-inch minimum seat spacing in school buses would be preempted by the requirement for 20-inch maximum seat spacing in Standard No. 222.

The National Traffic and Motor Vehicle Safety Act (the Act) provides in section 103(d) that any state or local law or regulation on an aspect of motor vehicle performance covered by a Federal standard must be identical to that Federal standard. Although the NHTSA requirement is phrased in terms of maximum spacing while the California standard concerns minimum spacing, the aspect of performance in question is seat spacing. Therefore, it is the NHTSA's opinion that a California standard on seat spacing regulates the same aspect of performance and to the degree it is not identical to the Federal standard, it would be preempted.

Your second question asks whether the seating reference point, as specified in relation to the "H" Point used in SAE Standard J826b, varies with the size of different individuals. The seating reference point, as defined by the NHTSA in Part 571.3 allows the manufacturer some discretion in selecting a point that approximates the position of the pivot center of the human torso and the thigh. While the NHTSA definition does refer to the SAE procedures for "H" point location that includes the specific measurements you cite, the manufacturer retains discretion to vary this point slightly as long as he can show that the point selected continues to simulate the position of the pivot center of the human torso and the thigh of the passengers for whom the seat is designed.

Finally, you note in your letter that compliance with the seat spacing required in Standard No. 222 might entail relocation of the side emergency exit, because Standard No. 217 requires that "[a] vertical transverse plane tangent to the rearmost point of a seat back shall pass through the forward edge of a side emergency door." The seat spacing requirement arguably could occasion the realignment of the side emergency door, but this does not have to be the case. The manufacturer is free to adjust seat spacing to be properly aligned with the emergency exit. The NHTSA's intent in this requirement is to provide an emergency exit opening extending at least 2 feet rearward of a vertical transverse plane tangent to the rearmost point of a seat back. The agency would not prohibit the use of doors wider than 2 feet as long as a minimum 2-foot opening is provided rearward of the reference plane and the latch mechanism is operated by a device located within the required 2-foot opening.

SINCERELY, Crown COACH CORPORATION

October 7, 1976

National Highway Traffic Safety Administration Motor Vehicle Programs Office of Chief Council

SUBJECT: Federal Standard 222-School Bus Seating and Crash Protection

We are presently trying to establish a seating floor plan to conform to your standards. So far, we know of only one manufacturer that may produce a seat meeting your requirements, namely American Seating Company.

The point in question is the establishment of some manufacturing tolerance between seats. Standard 222 states the maximum spacing from the seats, Seating Reference Point (SAE "H" Point), is 20 inches. This distance is equal to the minimum California standard of 25 inches from seat back to the back of the seat in front. This would leave no manufacturing tolerance. We know that Federal Standards take precedence, but the State could put a limitation on minimum spacing. American Seating has told us that they are using 20 inches +/- 1/2 inch. as a target. They will also have a tolerance on the thickness of their seat, which would affect seat spacing.

Another question on the "H" Point as specified in SAE Standard J826 - the distance up from the seat to the "H" Point is 3.84 Inches and from the "H" Point to the seat back is 5.28 Inches. Would not these dimensions change with respect to different percentile figures?

The location of the seats and tolerances create another problem which cannot be solved until something has been firmed up; that is, the location of the side emergency exit.

Standard 217, Docket No. 75-3, Notice 4, states "A vertical transverse plane tanget to the rearmost point of a seat back shall pass through the forward edge of a side emergency door." This means the door has to float with the seat locations. Also suppose the door is larger in size than the Standard states, this would penalize the manufacturer of the bus body, having to redesign side walls to accept different door and window locations.

We have been in contact with Mr. Tim Hoyt of your Docket Writer Section, who has been very helpful, but cannot answer our specific questions, and recommends we contact your Department for clarification of the Standard and specific answers to our problems.

If you need any clarification on our questions please phone and we will try to explain more fully.

Ray Hartman Vice President-Engineering

ID: nht92-8.37

DATE: March 2, 1992

FROM: Nathan W. Randall

TO: Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/21/92 from Paul J. Rice to Nathan W. Randall (A39; Part 571)

TEXT:

I am planning to start a business assembling classic automobile replicas for individual collectors. My intention is to construct approximately four-to-eight vehicles annually. Each vehicle will be constructed around a new, previously unused, NASCAR-style tubular-steel spaceframe chassis. This chassis features a safety engineered cockpit surrounded by designed crush zones to absorb impact energy, heavy steel inner door frames, roll bar, and a safety fuel cell located to minimize the possibility of rupture.

Each vehicle will utilize a new and previously unused body, and new unused components for braking, steering, suspension, cooling, fuel delivery, etc. In compliance with EPA emission requirements for rebuilt vehicles, these vehicles will incorporate previously used engine/transmission/drive axle/gearing combinations from previously certified configurations.

These vehicles will be fully compliant with EPA regulations for rebuilt automobiles and the Colorado State Motor Vehicle code.

My situation appears to be analogous to that of the Porsche replica builder in the "copy" interpretation letter (see attachment) provided by the NHTSA Compliance Office. As I understand the "copy" interpretation letter, your agency would tend to view my automobile as "used", even though its body and chassis are previously unused, because its running gear is not new. Also, due to the safety design incorporated into the vehicle, plus the low level of production, you would not consider my vehicles to contribute to any overall degradation of traffic safety.

I understand that I will be viewed as a "manufacturer" of used motor vehicles and will be responsible for notification and remedy of any safety related defects occurring in my product.

Please review the above facts and tell me if I have correctly applied the "copy" interpretation letter to my situation.

If I can answer any further questions you may have, please call me at (719) 593-5533.

Attachment

This is in reply to your letter of March 30, 1980, asking about the applicability of Federal regulations to the Porsche replica which you plan to build.

You have explained that the vehicle will be constructed from new parts except for the front suspension and axles, engines, and transmissions which will be taken from Volkswagens of the mid-1960's. Your present intention is to construct a total of 200 vehicles on an annual basis of 24 units.

As Mr. Vinson discussed with you on the telephone, you will be a "manufacturer" of motor vehicles because you are the assembler of the machine. The regulation of vehicles assembled from both old and new parts is a complex subject. Because such vehicles appear to comprise an infinitesimal portion of motor vehicle production, we have not developed a comprehensive set of regulations specifically designed for them. Each case is treated individually on the basis of the facts as we understand them. For example, the combination of a new body and the chassis of a vehicle previously in use has been considered a "used" vehicle to which Federal motor vehicle safety standards (which cover only new vehicles and equipment) do not apply. Similarly, the agency has again that even where a new frame is involved, if the vehicle is to be assembled by the ultimate owner who has a choice of new or used components (such as suspension, engine, radiator and tires and wheels) compliance appeared impossible and common sense required that it be treated as "used."

We have taken a more formal position in situations that are somewhat analogous: combining new and used components in refabricating trucks (glider kits) and in trailer manufacturer, fact situations covered by Title 49 Code of Federal Regulations 571.7(c) and 7(f). Where a new cab is installed, the resultant vehicle will be considered "used" if the engine, transmission, and drive axles (as a minimum) are not new and at least two of these components were taken from the same vehicle. Similarly, a reconditioned trailer is "used" if, at a minimum, the running gear assembly (axles, wheels, braking and suspension) is not new, and (1) was taken from an existing trailer whose identity is continued in the reassembled vehicle with respect to its Vehicle Identification Number and (2) that is owned or leased by the user of the reassembled vehicles.

You will see from the above that the agency tends to view as "used" a motor vehicle whose running gear is not new even though its body and chassis may be previously unused. We therefore would consider your vehicle as one that is "used." The list of safety related designs you intend to incorporate in your vehicle, plus the low level of production, indicates that it should not contribute to any overall degradation of traffic safety. As a "manufacturer" of a motor vehicle, however, new or used, you would be responsible for notification and remedy of any safety related defects occurring in your product.

There is one final possibility. If your vehicle is intended primarily for competition purposes with special features such that it cannot be licensed for on-road use, it would no longer be a "motor vehicle subject to our jurisdiction.

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

Sincerely,

Frank Berndt Chief Counsel

ID: nht90-1.78

TYPE: INTERPRETATION-NHTSA

DATE: 03/20/90

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TO: T. CHIKADA -- MANAGER, AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPT., STANLEY ELECTRIC CO., LTD.

TITLE: DECORATIVE SUPPLEMENTAL LIGHTING DEVICES NOT SPECIFIED BY STANDARD 108 (MOTORCYCLES)

ATTACHMT: LETTER DATED 2-21-89 TO ERIKA Z. JONES, NHTSA, FROM T. CHIKADA, STANLEY ELECTRIC CO., LTD. ATTACHED; [OCC-3190]

TEXT: This is in reply to your letter with respect to two types of decorative lighting devices intended for installation "on the rear face, and at the top of optional motorcycle rear trunks respectively." I regret the delay in responding.

Type A and Type B would be installed on the same motorcycle. Type A would be installed at the top of the trunk. It consists of an elongated device, illuminated by LEDs when the taillamp is on. Type B is installed on the motorcycle itself. It is a rec tangular device, illuminated by an incandescent bulb, which is mounted on the vertical centerline and is flanked by the tail and stop lamps. The distance between the center of the light sources on the two devices is 290mm. (approximately 11 1/2 inches) . Both devices emit red light, and their maximum intensity is less than the minimum intensity of the taillamp.

You have asked whether it is permitted to equip a motorcycle with the Type A and Type B accessory lamps. If the answer is affirmative, you have asked whether an LED could be used as the light source for Type B. You have also asked whether the maximum i ntensity of each device separately should be less than the minimum intensity of the tail lamp, or whether the combined maximum intensity of both devices should be less than the minimum intensity of the tail lamp.

Paragraph S5.1.3 of Federal Motor Vehicle Safety Standard No. 108 (formerly S4.1.3) permits the installation of these lamps if they do not impair the effectiveness of the lighting equipment required by the

standard. In this instance, the question to be asked is whether the devices, activated with the taillamps, impair the effectiveness of the taillamps, or the stop lamps. The devices are, in effect, supplemental taillamps, and as such, arguably do not ap pear to impair the effectiveness of the taillamps required by the standard no matter what their intensity is.

The diagram of Type B indicates that the stop lamps and taillamps are in the same compartment, presumably incorporating a dual filament bulb. Although the stop lamps when activated are brighter than the taillamps, their proximity to the supplemental dev ices Type A and Type B, each of which are emitting a red light, leads to the possibility that the stop signal would not be as effective as it would be were there no other red lights in the vicinity, and hence impaired within the meaning of S5.1.3. A sto p signal must be instantly perceived so that a following driver may determine appropriate action to take. However, we note that this configuration is similar to other stop/taillamp configurations on many vehicles in use on the highways. This would indic ate that such configurations do not result in impairment. Thus, the answer to your first question is that both Types of devices are permitted under the standard.

Your second question is whether LEDs are acceptable light sources for Type B. Since there is no restriction on light sources for a lighting device not required by Standard No. 108, you may use the LEDs as light sources.

Your third question is whether the maximum intensity of Type A and Type B, separately, should be less than the minimum intensity of the taillamp. Even though Type A and Type B are optional devices, in the configuration depicted where Type B is immediate ly flanked on both sides by a taillamp, the appearance of the three lamps would be that of a multicompartment lamp, even though they may actually be separate. To help assure that impairment of either the taillamp or stop lamp does not occur, the intensi ty of Type B should be identical with that of the taillamps. Otherwise, observers may assume that Type B (which you intend to have an intensity less than a taillamp) is actually the taillamp, and the actual taillamps (which you intend to have an intensi ty greater than Type B) might appear to be stop lamps that are continually on. This would be deemed impairment since there would be three intensity levels, increasing the possibility of confusion of the intent of the lamps.

As for Type A, its vertical separation decreases the possibility for confusion. If the light sources are LEDs, the color would be a different shade of red that the stop and taillamps. Thus, the intensity is less important. However, it functions as an a uxiliary taillamp and should be within the same intensity range as the original equipment taillamps. Finally, you asked whether the combined maximum intensity of both devices would be less than the minimum intensity of the taillamps. Again, this

would create three levels of intensity, and could cause confusion in understanding the intent of the lamps. As noted above, the individual intensities should be similar to the intensity of the taillamps.

I hope that this answers your questions.

ID: 86-2.23

TYPE: INTERPRETATION-NHTSA

DATE: 04/18/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Carol Dingledy

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter to Steve Kratzke of my staff, asking several questions about the effects of an amendment to the buckle force requirements in Standard No. 213, Child Restraint Systems (49 CFR @ 571.213). Buckles used on child restraints manufactured on or after February 16, 1986, must release with a minimum of 9 pounds force and a maximum of 14 pounds force. Buckles used on child restraints manufactured between January 1, 1981, and February 15, 1986, were required to release with a minimum of 12 pounds applied force and a maximum of 20 pounds applied force. Buckles used on child restraints manufactured before January 1, 1981, were required to release with a maximum of 20 pounds applied force. You asked with which buckle release force requirements replacement buckles provided by your company should comply. Assuming that the replacement buckles are to be installed by you or dealers, distributors, or repair businesses, the answer is that the buckles may, at your option, comply with either the release force requirements applicable to child restraint buckles as of the date of manufacture of the child restraint or with the current buckle release force requirements.

Standard No. 213, like all of our safety standards applicable to items of motor vehicle equipment, does not apply to the equipment after its first purchase in good faith for purposes other than resale. This general rule is, however, limited by the provisions of section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)), which specifies: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative . . . any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . ." Please note that these prohibitions do not apply to the child restraint owner rendering inoperative some element of design installed on his or her child restraint. Hence, replacement buckles that are sold to and installed by child restraint owners are not required to comply with the provisions of Standard No. 213.

However, if you as a manufacturer, or any dealers, distributors, or repair businesses were to remove complying buckles from a child restraint and replace them with buckles that did not comply with Standard No. 213, this would violate section 108(a)(2)(A). This result arises because buckles with the specified release force levels were installed on an item of motor vehicle equipment (the child restraint system) in compliance with an applicable Federal motor vehicle safety standard (Standard No. 213). Section 109 of the Safety Act (15 U.S.C. 1398) specifies that each violation of section 108(a)(2)(A) subjects the violator to a potential $ 1,000 civil penalty.

Assuming that you or your dealers and distributors will be installing the replacement buckles, section 108(a)(2)(A) gives you an option of which release force requirements the replacement buckles must meet. In connection with several other standards that have been amended, the National Highway Traffic Safety Administration has stated its opinion that a manufacturer, distributor, dealer, or repair business does not knowingly render inoperative an element of design by replacing components installed in satisfaction of a safety standard with other components used in newer items of the same type in satisfaction of the same standard, even if the newer version of the standard imposes less stringent performance requirements. See, for example, the enclosed opinion issued when Standard No. 121, Air Brake Systems, was amended; 42 FR 26279, May 23, 1977. In this context, this opinion means that child restraint manufacturers may install replacement buckles that either:

1. comply with the requirements of Standard No. 213 as of the date the child restraint was manufactured; or

2. comply with the current requirements of Standard No. 213.

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

Sincerely,

Enclosure

ATTACH.

COSCO INC.

OCC 0062

Steve Kratsky -- NHTSA, Office of Chief Counsel

January 16, 1986

Dear Mr. Kratsky,

I am interested in receiving clarification about the FMVSS 213 amendment for reduction of pressure required to operate buckles on child restraints. This amendment, effective February 16, 1986, will require child restraints to have buckles with a release pressure of not less than 9 or more that 14 pounds, instead of the original 12 pounds minimum.

My questions regarding the provision of replacement buckles for child restraints are as follows:

1. Which type buckle will need to be provided for child restraints manufactured prior to January 1, 1981?

2. Must we provide 12 pound minimum pressure buckles for child restraints manufactured between January 1, 1981 and February 16, 1986 so they will continue to be in compliance with the FMVSS 213 standard in effect at time of manufacture?

3. Must we provide buckles meeting the amendment requirements for child restraints manufactured between January 1, 1981 and February 16, 1986 so they will be in compliance with the current FMVSS 213 standard as amended?

Thank you for your assistance.

Sincerely,

Carol Dingledy -- Communications Supervisor

ID: 22044

Mr. Matthias Friedrich
Managing Director
Van Riesen GmbH+CoKG
IndustriestraBe 10
D-32130 Enger
Denmark





Dear Mr. Friedrich:

This is in response to your letter asking whether the buckle release on your child restraint system meets the area requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 213, "Child Restraint Systems." The answer is no.

S5.4.3.5(c) of Standard No. 213 requires any buckle in a child restraint system to "[m]eet the requirements of S4.3(d)(2) of FMVSS No. 209 ( 571.209), except that the minimum surface area for child restraint buckles designed for push button application shall be 0.6 square inch." You state that your buckle release design would meet this requirement if we add the "press" area (0.39 square inch) of the release button to the bottom area (0.23 square inch) of the release button.

We do not consider your buckle release to be designed for push button application because a sliding action activates the buckle release. In fact, it is apparent from your letter that you concur that the buckle release is not of a push button type. You state in your letter: "The button is not a push-button as described in the FMVSS-standard, [sic] it is as [sic] slide action release button . . . ." Since your buckle release is not designed for push button application, the 0.6 square inch minimum surface area requirement in S5.4.3.5(c) does not apply.

S4.3(d)(2) of Standard No. 209 reads:

A buckle designed for pushbutton application of buckle release force shall have a minimum of 452 mm with a minimum linear dimension of 10 mm for applying the release force, or a buckle designed for lever application of buckle release force shall permit the insertion of a cylinder 10 mm in diameter and 38 mm in length to at least the midpoint of the cylinder along the cylinder's entire length in the actuation portion of the buckle release. A buckle having other design for release shall have adequate access for two or more fingers to actuate release.

(Emphasis added.)

Because your buckle release is designed for slide application rather than push button or lever application, your buckle release falls under the "other design for release" category. Under the last sentence of S4.3(d)(2), it must have adequate access for two or more fingers to actuate release. None of our staff working on this response was able to place two fingers into your slide action release button to actuate release, and you do not claim otherwise. Thus, we do not agree that your buckle release meets the requirement of S4.3(d)(2).

If you have any further questions, please feel free to contact Mr. Dion Casey of this office at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel

ref:213#209
d.2/6/01

ID: nht79-4.29

DATE: 08/15/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Nissan Motor Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of July 3, 1979, asking several questions concerning the definition of "designated seating position" (49 CFR 571.3), as that term was recently amended (44 FR 23229, April 19, 1979).

In your first question, you ask for confirmation that any bench or split-bench seat with less than 50 inches of hip room may never be required to have three or more than three designated seating positions, notwithstanding the capability of accomodating a person at least as large as fifth percentile adult female. Your assumption is incorrect. As noted in the (Illegible Word) to the recent amendment, the 50-inch specification does not mean that some vehicle seats with less than 50 inches of hip room should not also have more than two designated seating positions, if the vehicle and seat design is such that three positions would likely be used (44 FR 23232). The specification is nerely the amount of space the agency will consider as conclusive evidence that there should be at least three designated seating positions. The 50-inch caveat was included in the definition to simplify determinations of proper seating capacity by both manufacturers and the agency.

Your second question involves technical aspects of the amended definition of "designated seating position". The definition specifies that "hip room" is to be measured in accordance with SAE J1100(a). That standard defines "hip room" as,

"the minimum dimension measured laterally between the trimmed surfaces on the 'x' plane through the (Illegible Word) front Vithin 1.0 in. (25mm) below and 3.0 in. (76mm) above the SqRP-front and 3.0 in. (76mm) force and aft of the SqRP-front." (Area A in your diagrams.)

Your question includes diagrams and asks whether various portions of vehicle seats or other components would be considered "trimmed surfaces" within SAE Standard J1100(a).

Specifically, you ask whether slightly soft surfaces such as arm rests, seat back contours or other raised portions of the seat cushion would be considered "trimmed surfaces", for purposes of determining the minimum hip room dimension. The answer to your question is yes. The agency would probably consider all of the surfaces illustrated in your letter "trimmed surfaces" and, strictly speaking, within the meaning of the SAE procedure. This interpretation must be qualified, however. The procedure specifies that "hip room" is the minimum dimension "between trimmed surfaces". If a particular bench seat has distinct sections, the total dimension must be determined by adding the minimum dimensions of each section. For example, your Figure 5 illustrates a bench seat that includes a slightly raised center surface on the tunnel (in the center of the seat over the driveshaft). The lowest portion of Area A as defined in SAE J1100(a) would strike the side of this elevated center section, even though the top portion of Area A would be above the elevation. In such case, there would be three distinct portions of the seat (the driver's seat, the passenger seat, and the center seat position) that should be measured separately and then added together to get the total dimension. Otherwise, only the portion of the seat on the driver's side of the center elevation would be measured under the strict wording of the SAE procedure--an absurd result.

Regarding these questions about the measurement procedure, I must make several candid remarks. The agency will not allow manufacturers to avoid the obvious intent of the definition of "designated seating position" by finding loopholes in the measurement procedure. Further, as noted above, even if the hip room as measured in accordance with SAE J1100(a) is less than 50 inches, a manufacturer may still be required to designate three seating positions. If the measured dimension is less than 50 inches only because of slight elevations or contours on the outside seat cushion, a manufacturer must designate at least three positions if these elevation or contours are not real impediments to three persons occupying the seat.

Determinations of designated seating capacity under the amended definition should not cause manufacturers any real problems. If a manufacturer truly only intends to market a particular bench or split-bench seat for two occupants, he can and should make this obvious by the seat design, regardless of whether the total seat dimension is more than 50 inches or less than 50 inches. One simple way to do this is to install a permanent arm rest or console in the center portion of the seat.

I hope this response has clarified our position and will alleviate any problems you might have in making future determinations of proper designated seating capacity.

SINCERELY,

NISSAN MOTOR CO., LTD.

ENGINEERING OFFICE OF NORTH AMERICA

July 3, 1979

Frank A. Berndt Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Berndt:

I am writing this letter to you to ask you for your interpretation concerning the 49 CFR Part 571, "Designated Seating Position," final rule in the April 19, 1979 Federal Register, Vol. 44, No. 77. Your earliest reply to the attached questions would be greatly appreciated.

Thank you for your cooperation in this matter. Hisakauz Murakami Staff Safety

cc: RALPH HITCHOCK; GUY HUNTER

Question 2.1 (a) General

Generally speaking, would the so-called trimmed surfaces within Area A in SAE J1100(a) include the slightly soft surface (for example, seat cushion surface, seat back surface and arm rest surface) which changes its form somewhat when an occupant is sitting?

Question 2.1 (b)

If your answer is "no" in Question 2.1 (a), please show me the detailed definitions of the trimmed surfaces (for example, body panel).

Question 2.2

Surface of the Arm-Rest

Would the surface of the arm rest be considered the trimmed surfaces within the Area A when the hip-room will be measured?

Arm Rest

Figure 2

(Graphics omitted)

Question 2.3

Surface of the Seat-Back

Would the surface of the seat-back on the wheel-house portion be considered the trimmed surfaces within Area A?

Portion of the seat-back

Figure 3

(Graphics omitted)

Question 2.4

Surface of the Outside Seat-Cushion Side

Would the surface of the outside seat-cushion side be considered the trimmed surfaces within Area A?

Outside seat-cushion side

Figure 4 Question 2.5

Surface of the Inside Seat-Cushion Side

Would the surface of the inside cushion side on the tunnel be considered the trimmed surfaces within Area A?

Inside seat-cushion side

Figure 5

(Graphics omitted)

NISSAN MOTOR CO. LTD. ENGINEERING OFFICE OF NORTH AMERICA

May 10, 1979

Guy Hunter Crashworthiness Division Office of Vehicle Safety Standards NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Dear Mr. Hunter:

During my May 4th visit to your office, I requested your interpretation concerning the measurement procedure of the "Hip Room" with regard to SAE J 1100a, which was adopted in the 49 CFR Part 571, "Designated Seating Position". The final rule was issued in the April 19, 1979 Federal Register, Vol. 44, No. 77.

At that time, you suggested that I submit my questions, along with a letter, to your office for response.

I would, therefore, like to take this time to submit my questions to you and ask for your interpretation.

Thank you for your fine cooperation with regard to this particular matter. We look forward to hearing your interpretations in the near future.

Should any questions arise, please feel free to contact me at (201) 871-3555.

NISSAN MOTOR CO., LTD.

Hisakazu Murakami Staff, Safety

Q-1 The "X" plane through the SgRP

SAE J 1100a states the following as the definitions of the Three-Dimensional Reference System and the Hip-room:

ZERO "Y" PLANE - (Centerline body zero plane) is a vertical plane which passes through the longitudinal centerline of the vehicle.

ZERO "X" PLANE - Vertical body zero plane is a plane normal to the "Y" plane.

ZERO "Z" PLANE - Horizontal body zero plane is a plane normal to the "X" and "Y" planes.

W5-HIP ROOM-FRONT - The minimum dimension measured laterally between the trimmed surfaces on the "X" plane through the SgRP-front within 1.0 in (25 mm) below and 3.0 in (76 mm) above the SgRP-front and 3.0 in (76 mm) fore and aft of the SgRP-front.

W6-HIP ROOM-SECOND - Measured in the same matter as W5

The above-mentioned definitions are identical to those in SAE J 182a as shown in Fig. 1.

It is my understanding that the "X" plane through the SgRP (I think we should call this "X" plane the "Y-Z" plane through the SgRP, mathematically speaking) in W5 or W6 of SAE J 1100a is the one as shown in Fig. 2. Is my understanding correct?

Q-2 The measurement procedure of "Hip-room

Assuming that your answer to Q-1 is "yes", it would then be my understanding that there can be two (2) different ways of interpreting the measurement of W5 (or W6) as shown below.

(a) The case of emphasizing "the "X" plane through the SgRP"

In this case, W5 will be defined as follows, and the words of "and 3.0 in (76mm) fore and aft of the SgRP-front"will not be significant as shown in Fig. 3.

W5-HIP-ROOM - The minimum dimension measured laterally between the trimmed surfaces on the "X" plane through the SgRP-front within 1.0 in (25mm) below and 3.0 in (76mm) above the SgRP-front.

(b) The case of emphasizing "within 1.0 in . . . . aft of the SgRP-front"

In this case, W5 will be defined as follows, and the words of "through the SgRP-front" will not be significant as shown in Fig. 4.

W5-HIP-ROOM - The minimum dimension measured laterally between the trimmed surfaces on the "X" plane within 1.0 in (25mm) below and 3.0 in (76mm) above the SgRP-front and 3.0 in (76mm) fore and aft of the SgRP-front.

Which is correct, (a) or (b)?

FIG. 1

(Graphics omitted) FIG. 2

"X" plane through the SgRP

FIG. 3

FIG. 4 (Graphics omitted)

ID: 1984-2.15

TYPE: INTERPRETATION-NHTSA

DATE: 07/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Wesbar Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. C. I. Nielsen III Vice President - Marketing Wesbar Corporation Box 577 West Bend, Wisconsin 53095

Dear Mr. Nielsen:

This is in reply to your letter of May 16, 1984, to Mr. Vinson of this office seeking an interpretation of Motor Vehicle Safety Standard No. 108. You wish to know whether the minimum effective projected luminous lens area for stop lamps and turn signal lamps on trailers whose overall width is 80 inches or greater is 8 square inches or 12 square inches. You cite an apparent conflict between paragraph S4.1.1.6 and SAE Standard J586d, and paragraph S4.1.1.7 and SAE Standard J588f. You have asked for an interpretation so that Wesbar may properly design a "combination tail lamp."

First, we will confirm the advice provided by "D.O.T. staff people" that the latest SAE revisions, J586d and J588f, have not been adopted.

You do not state the intended use of your proposed lamp, so we will assume that it will be sold to trailer manufacturers as original equipment, and to the aftermarket as replacement equipment. As original equipment, it must comply with the requirements specified in Table I of Standard No. 108, SAE J586c for stop lamps and SAE J588e for turn signal lamps. Paragraph 3.2 of each standard specifies a minimum effective projected luminous lens area of 8 square inches.

Paragraphs S4.1.1.6 and S4.1.1.7 become relevant, however, if Wesbar intends the lamp as replacement equipment on trailers manufactured before September 1, 1978, and after January 1, 1972 (turn signal lamps) and January 1, 1973 ( stop lamps). Under paragraphs S4.1.1.6 and S4.1.1.7 replacement stop and turn signal lamps for trailers manufactured within the 1972-1978 time frame may meet either J586b or J586c, and either J588d or J588e. We note that neither J586b nor paragraph S4.1.1.6 establish a minimum luminous lens area for stop lamps. However, a manufacturer who chooses to comply with paragraph S4.1.1.7 rather than J588e would have to provide the minimum specified luminous lens area of 12 square inches for turn signal lamps of trailers whose overall width was 80 inches or more, the requirement specified in J588d for Class A turn signal lamps. We view this interpretation as one of historical interest than current relevance.

In summary, if Wesbar designs its lamp to the 8-inch requirement, it would appear to meet specifications for application either as original or replacement equipment.

Sincerely,

Frank Berndt Chief Counsel

May 16, 1984

Department of Transportation 400 - 7th Street SW Washington, D.C. 20590

Attention: Mr. Taylor Vincent, Legal Counsel

Dear Mr. Vincent:

Re: Request for D.O.T. 108 Interpretation

Wesbar is a lamp manufacturer currently designing a new submersible boat trailer lamp, which we would like to introduce this fall at the national trade show. The reason we are writing you at this time is that we find we have a need for a written interpretation clarifying a section of Federal Motor Vehicle Safety Standard No. 108 regarding the lamps used on trailers over 80 inches wide.

The need for the interpretation arrives from several sources, which include the latest SAE Engineering Handbook, several D.O.T. staff, and the marketplace. The area needing clarification is the number of square inches actually needed (of effective projected luminous area) for a STOP LAMP (D.O.T.-108, S4.1.1.6 vs. SAE J586d) and a TURN LAMP (D.O.T.-108, S4.1.1.7 vs SAE J588f). The current SAE Handbook calls out 8 square inches of "effective projected luminous lens" area as the minimum for either a turn or stop lamp used on a trailer 80 inches or more in width. We followed this up by questioning several D.O.T. staff people. They stated the latest SAE standards revisions had not been adopted by D.O.T. and therefore the 12 square inch requirement (of effective projected luminous lens area) must still be met when the light is used on trailers 80 inches or more in width. This was consistent until one staff member learned of Peterson Manufacturing's (Anderson Marine Division) #450 series "8-in-one", which is promoted for use on over 80 inch wide trailers, that has only 8 square inches of lens -- then we were told 8 square inches would be sufficient.

As you are probably well aware, the U.S. marketplace is more price competitive and quality conscious than ever before. Therefore, while we, as a lamp manufacturer, sincerely wish to meet every letter of the law, we also need to be as up-to-date and cost competitive as possible, and this is why we have been directed to you. Is the old standard still current or is a new generation of tail lights, such as Peterson's #450 series submersible tail light, now acceptable to meet the standard?

Thank you in advance for your time and consideration in reviewing this matter. It is important that we receive your written interpretation as soon as possible for it will have great impact on the design and cost of our new proposed combination tail light, as well as keep us "on schedule" for its introduction.

Sincerely,

WESBAR CORPORATION

C. I. Nielsen III Vice President - Marketing

CIN:mk

ID: 10-001800drn_risner

ID: nht93-4.42

DATE: June 23, 1993

FROM: Gail Lindsey -- Hillsborough County Public Schools, Risk Management & Safety Department, Tampa, Florida

TO: Ron Engles -- Safety Counter Measure Division

TITLE: None

ATTACHMT: Attached to letter dated 8/5/93 (est) from John Womack (signature by Kenneth N. Weinstein) to Gail Lindsey (A41; Part 571.3)

TEXT:

This correspondence is a reply to our recent phone conversation concerning the transporting of school children to and from special events in any vehicle other than school buses.

In the past, it has been School Board policy to disallow the use of mini-vans on such events. I am requesting any information on the crash safety standards of such vehicles, or any recommendations that your office may give so that we can make a safe and fair determination on this current policy.

Any assistance you can give will be greatly appreciated.

ID: nht91-6.3

DATE: September 18, 1991

FROM: Al Lipinski -- President, Mini-Max

TO: Hall, Jackson, Rice -- NATSA (NHTSA), Chief Counsel

TITLE: None

ATTACHMT: Attached to letter dated 10-23-91 from Paul Jackson Rice to Al Lipinski (A38; Std. 108; Part 567)

TEXT:

I talked with Steve Kratzke on September 18, 1991 regarding the Dynamic Testing requirements for alterers of certified vehicles.

We are a small conversion company of walk in van type light trucks located in Escanaba, MI. Our projected production for 1992 is 75 vehicles. We do not alter anything forward of the B pillar of a certified vehicle, thus the crash protection system installed by the original manufacturer is not disturbed. We afix an additional label stating the vehicle alterations conform to all applicable FMVSS.

I would appreciate a letter stating what the dynamic testing requirements are for an alterer of a certified vehicle for my files in case this question arises in the future.