ID: 13415.ztv

Ms. Ana S. Salcedas
308 N. Forklanding Road
Maple Shade, NJ 08052

Dear Ms. Salcedas:

This responds to the letter that you and Mr. Silva sent us on December 14, 1996. We are sending a copy of our reply to Mr. Silva at his Philadelphia address. You have asked our "assistance in ensuring that the patent [for the Auto Brake Light] meets the requirements for Code 571.108."

The patent application indicates that the Auto Brake Light is a message-sending device that can take several forms. In one application, the center highmounted stop lamp can display the message "STOP". In another form, the left hand stop lamp, the center highmounted stop lamp, and the right hand stop lamp can display, one word to a lamp, the message "SLOW DOWN NOW". We assume that the lower stop lamps could also display the message "SLOW DOWN." The application states that "[o]ptimally, the present invention may be used with retrofitted light assemblies that are attached to a vehicle after its original manufacture."

Under our basic regulatory statute, 49 U.S.C. Chapter 301, a motor vehicle must conform with all applicable Federal motor vehicle safety standards at the time it is sold and delivered to its initial purchaser. This means that, if the vehicle is modified after manufacture and before such sale, it must continue to comply with the Federal safety standards after the modifications. Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment, 49 CFR 571.108, permits the addition of supplementary lighting devices at the time of initial manufacture or before initial sale provided that they do not impair the effectiveness of lighting equipment required as original equipment by Standard No. 108.

As noted above, in one form of your invention, the center highmounted stop lamp can display the word "STOP." Figure 10 of Standard No. 108 establishes minimum candela intensity values that must be met at individual test points on the lamp, or the sum of such test points within zones. If any portion of the word "STOP" obscures the light at any individual test point so that the zone total falls below the minimum sum specified for the zone, that obscuration would create a noncompliance with Standard No. 108, and the retrofitted lamp would not be permissible. In addition, visibility of the center stoplamp signal must not be impaired by any part of the vehicle including the word "STOP" from test points 10U to 5D and from 10L to 10R, unless the lamp is designed to comply with all requirements when the obstruction is considered. If the letters can be arranged so that the lamp continues to comply, as discussed above, we do not believe that the word "STOP" would impair the effectiveness of the center stop lamp.

On the other hand, we believe that the message "SLOW DOWN" or "SLOW DOWN NOW" when placed on the lower stop lamps could create a momentary distraction, which would impair the effectiveness of the stop lamp system when used to signal that the vehicle is stopping. This aspect of your invention would not be permitted by Standard No. 108.

Once a motor vehicle is sold, 49 U.S.C. Chapter 301 prohibits manufacturers, dealers, distributors, and motor vehicle repair businesses from making inoperative any device or element of design installed in accordance with a Federal motor vehicle safety standard. We view the phrase "making inoperative" in this case as the equivalent of creating a noncompliance with Standard No. 108. This means that the persons named in the previous sentence may not retrofit a center lamp with the word "STOP" if it obscures any of the required test points. Further, it means that such persons may not retrofit vehicles with lamps spelling "SLOW DOWN NOW."

Because existing lamps are designed to meet the required test points with an unobscured lens, it is almost a certainty that lamps on vehicles in use would become noncomplying if retrofitted with letters forming words such as "STOP" and "SLOW DOWN NOW."

You will note that the prohibition discussed above does not extend to the vehicle owner who, under the statute, may create a noncompliance in his or her vehicle without violating Federal law. But a vehicle modified by its owner remains subject to the laws of the States in which it is registered and used. We are unable to advise you on State laws that may affect your device, and recommend that you contact the Department of Motor Vehicles of the States where you intend to market it.

We offer no opinion on the validity under Federal law of the other patented lighting devices discussed in the application.

If you have any questions, you may contact Taylor Vinson of this Office (202-366-5263).

Sincerely,

John Womack
Acting Chief Counsel

cc: Mr. Armenio N. Silva
     5110 Arendele Ave.
     Philadelphia, PA 19114

ref:108
d:2/25/97

ID: 1982-1.8

TYPE: INTERPRETATION-NHTSA

DATE: 02/02/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Pennsylvania Department of Transportation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of November 16, 1981, concerning differences between the Vehicle Equipment Safety Commission (VESC) Regulation on sun screening devices and applicable Federal standards. In addition, you asked about the requirements of several Federal motor vehicle safety standards and how they affect Pennsylvania vehicle inspection standards.

Your first question concerns any differences in light transmittance requirements between the Federal standard and the 70 percent light transmittance requirement set by VESC in its Regulation No. 20, Performance Requirements for Motor Vehicle Sun Screening Devices. We have issued a Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, which specifies performance and location requirements for glazing used in vehicles. The standard sets a minimum light transmittance level of 70 percent for glazing materials used in areas requisite for driving visibility, such as the windshield and front side windows.

As explained in the enclosed letter, the agency does not consider sun screening solar films to be glazing materials themselves and thus they would not have to comply with Standard No. 205. However, as the enclosed letter explains, use of such devices on motor vehicles would be prohibited in certain cases if the vehicle glazing no longer complies with the light transmittance or other requirements of the standard.

You also asked if bumper height is regulated by a Federal standard. The agency has issued, under the authority of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1901 et seq.) and the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1391 et seq.), a Part 581 Bumper Standard (49 CFR Part 581, copy enclosed) that specifies performance requirements for bumper systems. One aspect of performance regulated by the standard is the impact protection provided by the bumper at certain heights.

Section 110 of the Cost Savings Act (15 U.S.C. 1920) provides, in applicable part, that:

No State or political subdivision thereof shall have any authority to establish or enforce with respect to any passenger motor vehicle or passenger motor vehicle equipment offered for sale any bumper standard which is not identical to a Federal bumper standard.

Section 103(d) of the Vehicle Safety Act (15 U.S.C. 1392(d)) provides, in applicable part, that:

Whenever a Federal motor vehicle safety standard established under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard.

Therefore, unless the Pennsylvania regulation is identical to the Part 581 Bumper Standard, it is preempted.

Finally, you asked about Federal safety standards regulating the height of the windshield. The agency has not issued any safety standard specifying requirements for the vertical height of the windshield. Therefore, Pennsylvania's inspection standard on vertical windshield height is not preempted.

ENCLS.

COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF TRANSPORTATION BUREAU OF TRAFFIC SAFETY OPERATIONS

November 16, 1981

Frank Berndt

Dear Mr. Berndt:

The Pennsylvania Department of Transportation is presently in the process of reviewing its current inspection regulations to determine the validity of present equipment requirements or their present exclusion. If you could assist by responding to the two issues which follow, it would be greatly appreciated.

Our first concern is the validity of the VESC regulation regarding motor vehicle sun-screening (VESC Stand 20, approved July 1980), and any distinction from the National level between tinting by the original manufacturer and after market applications. Our specific concern is the 70 percent transmittance level set by VESC. Please refer to the enclosed copy of VESC 20.

The second issue in which we are interested and which, under certain circumstances is controlled by the Federal Motor Vehicle Safety Standards, is bumper and windshield heights on newly manufactured reproductions of old cars. Our present regulations specify a bumper height of 16"-20", and a vertical windshield height of no less than 12". Please see the enclosed information concerning a 1950 Porsche reproduction.

Any information you could supply on these two matters would be very helpful to this Department in determining what standards to set, so as to insure minimum compliance with any Federal requirements. If you have any additional questions, please contact me.

Kathy G. Phillips, Manager Vehicle Safety Division

ID: nht88-3.68

TYPE: INTERPRETATION-NHTSA

DATE: 10/14/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: WILLIAM E. LAWLER -- SPECIFICATIONS MANAGER INDIANA MILLS & MANUFACTURING, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 09/17/87 TO ERIKA Z. JONES FROM WILLIAM E. LAWLER, OCC - 1043

TEXT: Dear Mr. Lawler:

This responds to your letter seeking an interpretation of Standard Nos. 208, Occupant Crash Protection (49 CFR @ 571.208) and 209, Seat Belt Assemblies (49 CFR @ 571.209). I regret the delay in this response.

Specifically, you asked about a safety belt installation at the driver's seat of a vehicle with a gross vehicle weight rating in excess of 10,000 pounds. A customer of yours designed a lap/shoulder belt system with a continuous webbing feature and with a floor-mounted automatic locking retractor (ALR) for the belt system. Your company was concerned that this proposed design would not comply with the requirements of S4.3(i) and S5.2(i) of Standard No. 209, which limit the extent to which ALR's can move between locking positions and the retraction force that can be exerted by ALR's. Additionally, your letter stated that sections S4.1.2.3, S4.2.2, and S7.1 of Standard No. 208, "though dealing with lighter vehicles, seem to imply the intent of minimal u pper torso restriction."

To address these concerns, you made two modifications to the customer's proposed design. The first modification was to sew the latchplate to the webbing to convert the continuous webbing into a separate lap belt and upper torso restraint. The second mo dification was to place a manual adjusting device on the upper torso restraint. You asked for an opinion on these modifications.

The requirements for safety belts on vehicles manufactured before September 1, 1990, with a gross vehicle weight rating in excess of 10,000 pounds are set forth in section S4.3.1 of Standard No. 208 for trucks and multipurpose passenger vehicles and in s ection S4.4.1 for buses. Both of these sections require that the driver's seating position in heavy vehicles be equipped with a complete automatic protection system or with a Type 1 or Type 2 seat belt assembly that conforms to Standard No. 209. The re quirements for safety belts on heavy vehicles manufactured on or after September 1, 1990 are set forth in section S4.3.2 of Standard No. 208

for trucks and multipurpose passenger vehicles and in section S4.4.1 for buses. These heavy vehicles must either have a complete automatic protection system at the driver's seating position or be equipped with a Type 1 or Type 2 seat belt assembly t hat conforms to Standard No. 209, S7.2 of Standard No. 208, and include either an emergency locking retractor or an automatic locking retractor that satisfies some additional performance requirements.

Your customer has chosen to comply with Standard No. 208 by installing a belt system at the driver's seating position. Therefore, the vehicles in question would comply with the applicable requirements of Standard No. 208 if the belt assembly complies wi th the requirements of S4.3.1 or S4.4.1, if the vehicles are manufactured before September 1, 1990, or with the requirements of S4.3.2 or S4.4.2, if the vehicles are manufactured on or after September 1, 1990. Your letter does not provide sufficient inf ormation for us to offer any opinion on whether your customer's design or your design would comply with S4.3(i) and S5.2(i) of Standard No. 209. If both comply with all applicable requirements of Standard No. 209, either may be installed at the driver's seating position in vehicles manufactured before September 1, 1990. If both comply with all applicable requirements of Standard No. 209 and the additional requirements set forth in S4.3.2 and S4.4.2 of Standard No. 208, either may be installed at the d river's seating position in vehicles manufactured on or after September 1, 1990.

You also referred to an implied agency intent of minimal upper torso restriction by the belt assemblies in heavy vehicles. When the agency promulgates a safety standard specifying performance requirements for vehicles or items of equipment to accomplish a particular safety purpose, that safety standard sets forth all requirements with which the vehicles or equipment must comply regarding that purpose. If those requirements do not fully address or ensure the implementation of some aspect of that purpos e, then to that extent, that aspect is not part of the standard, even if NHTSA intended it to be part of the standard. Any aspect of performance that is not set forth in the requirements of the standard is, therefore, not relevant to determining whether the vehicles or equipment comply with the performance requirements that are set forth in the standard.

We certainly appreciate your efforts to design a comfortable lap/shoulder belt system for these vehicles, because more comfortable belt systems should increase belt use. Increased use, in turn, helps prevent deaths and/or serious injuries.

Sincerely,

ID: nht90-2.58

TYPE: INTERPRETATION-NHTSA

DATE: 05/30/90

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

TO: TIMOTHY A. KELLY -- PRESIDENT SALEM VENT INTERNATIONAL, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 01/29/90, FROM TIMOTHY A. KELLY TO DAVID A. GREENBURG -- NHTSA; RE SALEM BUS VENTILATOR/ESCAPE HATCH - FMVSS 217; OCC 4382; LETTER DATED 01/29/90 FROM TIMOTHY A. KELLY TO DAVID A. GREENBURG -- NHTSA; RE SALEM BUS VENTILATOR / ESCAP E HATCH - FMVSS 217

TEXT: This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 217; Bus Window Retention and Release as it applies to roof exits. You asked four specific questions which I have addressed below.

First, you asked for confirmation that the only specification in Standard No. 217 concerning the size of roof exits is the requirement that the exit be able to accommodate an ellipsoid with a major axis of 20 inches and a minor axis of 13 inches pushed h orizontally through the exit opening. Your understanding is not entirely correct. The ellipsoid requirement to which you refer, set forth in S5.4.1 of Standard No. 217, is the only provision in the standard that specifies a minimum size requirement for roof exit opening. Although there is no maximum size limit, you should be aware that S5.2 of Standard No. 217 provides that, in determining the total unobstructed openings for emergency exit provided by a bus, no emergency exit, regardless of its area shall be credited with more than 536 square inches of the total area requirement. Thus, if a roof exit is larger than 536 square inches, only 536 square inches will be counted for the exit in determining whether the bus complies with the unobstructed op enings requirement of S5.2 of Standard No. 217.

Second, you asked for confirmation that Standard No. 217 does not permit the use of escape hatches or ventilators in the roof of school buses as a substitute for any of the emergency exits required on school buses by S5.2.3 of Standard No. 217. This und erstanding is correct. Additionally, you should be aware that the agency has a longstanding position that any emergency exits, including any roof exits, installed on a school bus in addition to the emergency exits required by S5.2.3 must conform to the requirements of Standard No. 217 for emergency exits installed on buses other than school buses. See the enclosed July 6, 1979 interpretation to Robert Kurre on this issue.

Third, you asked for confirmation that Standard No. 217 permits the use of roof exits as a substitute for the rear exit door on buses other than school buses. This statement is not entirely correct. S5.2.1 of Standard No. 217 requires the use of a rear exit door on all non-school buses with a GVWR of more than 10,000 lbs., except where the configuration of the bus precludes the installation of an accessible rear exit. In that case, S5.2.1 requires the installation of a roof exit in the rear half of th e bus in lieu of the rear exit. This substitution of a roof exit for a rear exit door is allowed only where the bus design precludes the use of a rear exit (such as on rear-engine buses). It is not an option allowing the substitution of a roof exit for the rear door in any design.

Fourth, you asked whether the addition of more than one roof exit on a non-school bus would allow a manufacturer to delete any other required exits in addition to the rear door. It is possible that increasing the total exit space on the bus by adding ro of exits could enable a manufacturer to reduce the number or size of other emergency exits on the bus and still comply with the unobstructed openings requirement of S5.2. You should be aware that exit space provided by roof exits is not counted in deter mining compliance with the requirement in S5.2 that 40 percent of the total unobstructed openings be located on each side of the bus. Whether this substitution of additional roof exits could be made on any particular non-school bus would depend upon whe ther the bus complied with the exit space and location requirements of S5.2.1 (if the bus has a GVWR of more than 10,000 pounds) and the applicable requirements of S5.2.2 (if the bus has a GVWR of 10,000 pounds or less).

I hope you have found this information helpful. Please do not hesitate to contact David Greenburg of my staff at (202) 366-2992 if you have any further questions or need additional information.

Sincerely,

ENCLOSURE

ID: nht80-1.17

DATE: 02/26/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Toyota Motor Co. Ltd.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your recent request for an interpretation concerning the proper designated seating capacity for the rear seat in several Toyota vehicle models (Corolla Sedan, Corolla Coupe, Corona Sedan and Starlet). You assert that the rear seat hip room in these models ranges from 39.4 inches to 42.6 inches, and ask whether the vehicles would qualify as having only two designated seating positions.

Under the strict measurement technique specified in the amended definition of "designated seating position" (SAE J1100a), the Toyota vehicle models in question would have the hip room dimensions you state. This is due to the fact that the SAE procedure specifies that hip room is to be the minimum dimension of the seat cushion. The Toyota designs include wheel wells and contoured side paddings at the intersection of the seat back and seat cushion that establish the minimum dimension of the seat. However, these structures only extend out 4 to 5 inches (approximation) from the seat back. If the hip room of the rear seats is measured midway of the seat cushion, all of the designs have greater than 50 inches of hip room, and ostensibly should have three designated seating positions. Nevertheless, since according to the measurement technique specified in the definition these seats have substantially less than 50 inches of hip room, the agency must conclude that the rear seats could qualify as having only two designated seating positions. This opinion is accompanied with several candid remarks, however.

The effective hip room of the Toyota seat designs is much greater than the approximately 40 inches that is obtained by the technical measuring technique specified in the definition. If two outboard occupants move their hips several inches forward from the seat back in these vehicle designs, the wheel-wells and contoured side paddings are no longer impediments and there is over 50 inches of hip room, as noted above. Moreover, the design of these rear seats is such that use of the center position is "invited." There is at least 10 to 12 inches of well-padded hip room at the center portion of the seat between the inboard ends of the two seat belt assemblies installed in the seats. The manufacturer has given no indication that this space is not intended for occupancy. The agency is also concerned that this center position has no belt assembly to secure a child restraint system, particularly since the rear-center seat is statistically the safest position in a vehicle.

Frankly, with the wide center space that is available in these rear seat designs, we do not believe the manufacturer has made a sincere attempt to indicate to vehicle occupants that the seats are intended for use by only two occupants. It would be a simple matter for the manufacturer to make this obvious by use of a fixed armrest or some other impediment to use of the position. Furthermore, we believe that this message can be given to occupants without otherwise compromising the design the manufacturer wishes to achieve. If the manufacturer does not in fact wish to market the vehicles as having three-passenger rear seats, we do not understand why wide, well-padded center positions are present.

Finally, I am enclosing a copy of an earlier interpretation which discusses the measurement procedure included in the definition of "designated seating position." As that interpretation pointed out, the agency will not allow manufacturers to avoid the obvious intent of the definition by finding "loopholes" in the specified measurement procedure. If designs such as those displayed in the Toyota vehicles persist, without some clear indication that the center position is not to be used, the agency may find it necessary to amend the definition to provide that the hip room measurement is to be taken at the midpoint of the seat cushion. We hope that manufacturers will voluntarily alter designs of this type to conform to the intent of the definition, so that such an amendment is not necessary.

SINCERELY,

TOYOTA MOTOR CO., LTD.

U.S. REPRESENTATIVE OFFICE

January 17, 1980

Ralph Hitchcock Chief, Crashworthiness Division National Highway Traffic Safety Administration

Dear Mr. Hitchcock:

This is to confirm our request, made by Mr. Donald Schwentker, Attorney-at-Law, for a meeting with appropriate National Highway Traffic Safety Administration personnel on Tuesday, January 29, 1980, to seek an interpretation of the designated seating position definition as it applies to several specific Toyota vehicles, as follows:

* Corolla Sedan

* Corolla Coupe

* Corona Sedan

* Starlet ('81 Model)

As you requested, Toyota will bring all vehicles to NHTSA's office on that date.

Our Attorney will contact you by telephone to work out the arrangements.

J. Kawano General Manager

ID: 21871.ztv

Mr. Thomas C. Bliss
3M Traffic Control Materials Division
3M Center
St. Paul, MN 55144-1000





Dear Mr. Bliss:

This is in reply to your letter of June 30, 2000, asking for interpretations of S5.7, Retroreflective Sheeting, of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

Several of your customers would like "to incorporate their company logo directly into the conspicuity markings used on their vehicles." You understand that "our customer is permitted to use their logo on markings placed on the vehicle in excess of the amount required to satisfy the minimum coverage stated in the regulation," and you ask that we confirm that interpretation.

S5.7.1.4.2(a) requires that a strip of retroreflective sheeting, "originating and terminating as close to the front and rear as practicable," be applied to the side of trailers, but that "the strip need not be continuous as long as not less than half of the length of the trailer is covered. . . ." This exception is intended to accommodate different trailer configurations by allowing breaks in the conspicuity material where the features of the trailer are such that it may not be feasible to install continuous sheeting. A manufacturer must comply when half the trailer length is covered, but if it wishes to add more conspicuity material to the portion of the trailer length that is not covered, the material must comply with S5.7. We view the installation of nonconforming material on the side as subject to the prohibition in S5.1.3 that no additional reflective material or other motor vehicle equipment shall be added that impairs the effectiveness of lighting equipment required by the standard. For this reason, the appropriate question is, as you have asked in your first question, "do conspicuity markings that incorporate a logo conform to FMVSS 108?"

First, because the standard requires conspicuity markings to be either red or white, the introduction of a third color (or white on a red section and vice versa) would not conform to Standard No. 108. Thus, any logo must be red or white. Assuming the logo is red or white, the answer is similar to that which we have provided inquirers as to whether logos are acceptable on the lens of the center high-mounted stop lamp. Both the lamp and retroreflective sheeting must meet the color and photometric requirements that are specified for each. If the sheeting meets the color, photometric, and all other requirements with the logo in place, then retroreflective sheeting incorporating a logo would comply with Standard No. 108. This, of course, would permit a logo that straddles red and white segments of retroreflective sheeting as well as a logo that is contained entirely within either a red or white segment. However, because the standard requires segments of red and white, a red logo could not appear in a white segment and vice versa. A logo (or portion of a logo) in a red segment could, however, be shown in a different shade of red, and a logo (or portion) in a white segment could be shown in a different shade of white, provided that both shades of red and both shades of white complied with the red and white color specifications of SAE J578c.

Your next question is whether conspicuity markings that incorporate a logo would "qualify as conspicuity markings under FMVSS 108." S5.7 prescribes dimensions for the width of the sheeting and the length of the individual segments. As noted above, a logo could be inserted in otherwise conforming sheeting if the sheeting meets the photometric, color, and all other requirements with the logo in place.

You have also asked whether "conspicuity markings that incorporate a logo [are] taken into account when assessing conformance to FMVSS standard 108." The coefficients for retroreflection of each segment of red and white sheeting must be not less than the minimum values specified in Fig. 29 of Standard No. 108. In determining conformance with S5.7, if a logo prevented a segment of sheeting from complying with the photometric or any other requirement, we would consider that the segment failed to comply with Standard No. 108. Thus, the answer to this question is yes.

Finally, you have asked whether "a 48mm (2 inch) wide marking with a logo [which] conforms to the performance requirements necessary for DOT -C2, can . . . be considered DOT-C2 marking." The answer is no. S5.7.1.3(d) requires DOT -C2 sheeting to have a width of not less than 50mm. The sheeting in your question is 2mm too narrow to be DOT-C2, even if it meets the photometric requirements for DOT -C2 sheeting with the logo in place.

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).





Sincerely,

Frank Seales, Jr.
Chief Counsel

ref:108
d.10/6/00

ID: nht74-1.26

DATE: 05/23/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mazda; Toyo Kogyo U.S.A. Representative

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 9, 1974, requesting an interpretation of the test procedure specified in Standard No. 301 (Docket No. 73-20; Notice 2) concerning the operation of the vehicle's fuel pump during testing.

Paragraph S7.1.3 of the standard requires that electrically driven fuel pumps be in operation during the barrier crash tests if they normally operate with the activation of the vehicle's electrical system. If the pump is incapable of functioning with the independent activation of the electrical system and requires the operation of the vehicle's engine, then the pump should not be running during the barrier crash tests.

Based upon the description you provide in your letter, it appears that you should conduct your barrier crash testing without operating the fuel pump.

Yours truly,

ATTACH.

May 9, 1974

Richard B. Dyson -- Assistant Chief Counsel, U. S. Department of Transportation, National Highway Traffic Safety Administration

Dear Mr. Dyson:

Re: MVSS 301 Fuel System Integrity

In section 7.1.3 of Docket 73-20; Notice 2, we can find, "If the vehicle has an electrically driven fuel pump, that normally runs when the vehicles electrical system is activated, it is operating at the time of a barrier crash."

The underline was added to the Docket 73-20; Notice 1.

Although we feel NHTSA has granted our attached comments on February 8, 1974, hereby we confirm it again.

Our electrical fuel pump works only when the engine runs, and usually does not work when the ignition is in "on" position except that the engine works. In other words, our electrical fuel pump is connected to the engine and there's no relation directly from our electrical system in "on" position. Nevertheless, we will find that the vehicle's electrical system without fuel pump is activated, when the ignition is in "on" position and the engine is not in "running."

Our question is as follows: In the above system, we believe we may test the barrier crash without operating the electrical fuel pump. If its not so, we have to test it with another special connection between battery and fuel pump, "only on test."

Your opinion will be highly appreciated.

Always warmest,

Goro Utsanomiya -- Branch Manager, TOYO KOGYO U.S.A. REPRESENTATIVE OFFICE

cc: Mr. Williams; Mr. Makino

February 8, 1974

James B. Gregory -- Administrator, National Highway Traffic Safety Administration

Dear Dr. Gregory:

Although the comment closing date is already over, we would like to submit the following comment, because we have a new problem by further review.

It would be appreciated if you consider this comment.

Sincerely yours,

Gorou Utsunomiya -- Branch Manager,

TOYO KOGYO U.S.A. REPRESENTATIVE OFFICE

cc: R. N. Williams

enc.

DOCKET 73-20, NOTICE NO. 1

COMMENTS OF TOYO KOGYO CO., LTD. ON NOTICE OF PROPOSED RULEMAKING FUEL SYSTEM INTEGRITY PASSENGER CARS, MULTIPURPOSE PASSENGER VEHICLES TRUCKS AND BUSES (OF 10,000 GVWR OR LESS)

Comment

"S.7.1.4 - If the vehicle has an electrically driven fuel pump, it is operating at the time of a barrier crash test" should read as, "S.7.1.4 Ignition switch is at "On" position at the time of barrier crash tests."

Discussion

As you know, electrically driven fuel pumps are used on many cars. As far as we assume, this S 7.1.4 is established so as to minimize possibility of fire at the crash accident because electrical pump will keep working as long as ignition switch is at "On" position.

However, if we develop a system where the electrical fuel pump stops at the moment of impact in spite of ignition switch being in "On" position, this possibility will no longer exist.

As long as S 7.1.4 exists, we have to make the pump work by other means, such as direct connection between battery and pump, when we conduct a compliance test, and this S 7.1.4 will close the way of possibly developing a new safety device. We think that this situation is far apart from the actual one and this test is impractical.

Judging from the fact that there is no requirement, "Mechanical fuel pump is operating", we think S 7.1.4 can be changed. Needless to say, we recognize that we should minimize the possibility of a fire with electrical pumps. We would suggest S 7.1.4 should read, "Ignition switch is at "On" position.

ID: nht70-1.29

DATE: 02/04/70

FROM: D.W. TOMS -- DIR., NHTSA

TO: Motorcycle Scooter & Allied Trades Association Inc.

TITLE: FMVSR INTERPRETATION

TEXT: RE: MARKETING OF COMPETITION MOTORCYCLES

This is in response to your letter of November 19, 1969, in which you ask for an advisory opinion "as to the measures which an importer or distributor should take in order to assure compliance with regulations of the Federal Highway Administration in the marketing of motorcycles for competition use".

Specifically, you note:

"[The importation regulations appear] to require that the importer shall declare that motor vehicles imported for competition purposes will not be sold or licensed for use on the public roads. Hence there is some uncertainty whether this declaration connotes an implicit responsibility which survives sale to a purchaser not for resale".

The declaration to which you refer, 19 CFR @ 12.80(b)(2)(vii), is the declaration that the vehicle is being imported for purposes of competition and that it will not be sold or licensed for use on the public roads. If we discover that a vehicle covered by such a declaration has been sold or licensed for use on public roads, we would then have to determine whether the declaration was a false one. In making this determination we would look to those factors which show that, at the time he made the declaration, the importer knew or had reason to know that the vehicle would be put to on-road use. If, for example, prior dealings with the vehicle's purchaser had made the importer aware of the purchaser's intent to divert vehicles to markets for so-called "street legal" motorcycles, it is very likely that we would conclude that a declaration that the vehicle will not be sold or licensed for use on public roads was false at the time it was made. In these circumstances, our conclusion would not be altered by the fact that, at the time he sold the vehicle, the importer supplied the buyer with a document specifying that the vehicle was intended only for purposes of competition. In short, we would look behind the sales agreement to the realities of the transaction as the parties knew them.

Similarly, if relevant facts disclose that the importer seeks to evade his responsibilities by active promotion and sale to competition cycle purchasers of motor vehicle equipment which will make the competition machine "street local", and purchasers of competition machines are in fact buying such equipment for immediate conversion purposes, then a reasonable conclusion could be reached that a non-complying motor vehicle was being imported and offered for sale by the importer regardless of the declaration made at time of entry. In this sense there is "an implicit responsibility which survives sale to a purchaser not for resale".

You also raise the following point: "It is understood that motorcycle manufacturers and importers should not equip competition motorcycles with devices and accessories that would render them lawful for use and registration for use on public highways. It would be normal industry practice, however, to catalog accessory items and parts which could be applied to competition machines by the ultimate purchaser. Since many competition motorcycles have a 'sister' model manufactured for highway use, the sale of such items is necessary. Thus a question of the propriety of this practice is raised."

The mere cataloguing of parts equally applicable to both a competition motorcycle and a similar "sister" non-competition model does not appear to raise a question of propriety so long as other facts do not indicate that a significant number of purchases of these parts are made with the intention of conversion of competition motorcycles to street use.

Finally you note:

"Competition motorcycles are generally marketed through retail dealers in motor vehicles. Hence, the question arises as to whether this practice might continue without opposition by the Federal Highway Administrator."

You have also requested a ruling "that sale of competition motorcycles be permitted through franchised dealerships". You should clearly understand that the National Highway Safety Bureau his no desire to alter existing methods of motor vehicle marketing; it does not intend to "oppose" and it has no power to "permit" the sale of motor vehicles.

It does, however, have the power to classify a competition motorcycle as a "motor vehicle" if these vehicles are, in fact, being operated on the public roads to a significant extent, and if it believes that such a classification would reduce the toll of traffic injuries and deaths. But the mini-bike interpretation (34 F.R. 15416), referenced by you, states that marketing through retail dealers in motor vehicles is only one criterion which will be considered in any question of classification. Therefore importers and distributors of competition motorcycles which are sold through franchised dealerships are best advised in marketing these vehicles to follow the other criteria which the mini-bike interpretation sets forth.

ID: nht92-7.35

DATE: April 21, 1992

FROM: Thomas D. Turner -- Manager, Engineering Services, Blue Bird Body Company

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

COPYEE: Vernon Wright; Wisconsin Specification File

TITLE: Request for Interpretation: Reference: (1.) 49 CFR Part 571.131 Section S5.5. (2.) Wisconsin Administrative Code Trans 300.64 - Stop Signal Arm

ATTACHMT: Attached to letter dated 6/17/92 from Paul J. Rice to Thomas Turner (A39; Std. 131)

TEXT:

Blue Bird Body Company is in the process of implementing changes to conform to the new stop signal arm requirements of FMVSS 131. Reference 1 requires that, "THE STOP SIGNAL ARM SHALL BE AUTOMATICALLY EXTENDED in such a manner that it complies with S5.4.1, at a minimum WHENEVER THE RED SIGNAL LAMPS required by S5.1.4 of Standard No. 108 ARE ACTIVATED (emphasis added); except that a device may be installed that prevents the automatic extension of a stop signal arm." The standard continues with requirements for this device including the requirement that an audible signal shall sound when the device is activated.

These requirements are logical and can be implemented in conjunction with the use of the eight light warning systems currently required in 46 of the 50 states; however, when these requirements are considered in terms of a four light warning system, there are certain operational issues that need to be considered. Specifically, the state of Wisconsin requires a four light warning system and a stop signal arm on school buses and has the following requirements for stop signal arms per Reference 2; "(2) Any bus manufactured after January 1, 1978, shall have the stop signal arm controlled by the service door. The stop signal arm shall not become operational until the service door opens. The stop signal arm shall be installed in such a manner that it cannot be activated unless the alternating red lamps are in operation."

To meet these requirements, Blue Bird provides a system by which the alternating red flashing lamps are activated by a driver controlled manual switch and the stop signal arm is activated by opening the service door. In order to comply with the new FMVSS 131 standard, we are adding a warning buzzer that will sound when the alternating red flashing lights are activated but the service door has not yet been opened to activate the stop signal arm. We believe that this system meets the intent of Standard No. 131 but are concerned about compliance with the wording of the standard in terms of requiring "automatic extension" of the stop signal arm. The system described above for Wisconsin provides for manual activation of both the alternating red flashing lights and the stop signal arm and is not "automatic." However, it appears to meet the intent of the standard by having the stop arm extend when the service door is opened and the alternating red flashing lights are on, and by having a warning buzzer activated whenever the arm is not extended and the lights are on.

It is our understanding that the Wisconsin requirements are necessary so that the alternating red flashing lights can be used to warn traffic of an impending stop and the stop signal arm is used to actually stop traffic. They do not

want the stop signal arm to extend automatically when the red lights are activated. For an eight light warning system, the amber lights are used to warn traffic of an impending stop and it is proper for the alternating red flashing lights and the stop signal arm to be activated simultaneously to stop traffic. Since Federal Motor Vehicle Safety Standards require as a minimum a four light warning system and allow an eight light warning system, the requirements of Standard No. 131 must be compatible with both systems.

Based on the above information and reasoning, and with the best interests of school bus safety in mind, Blue Bird requests confirmation that the warning light and stop arm system and operation, as required by Wisconsin and described above, conforms to the requirements of Standard No. 131 section S5.5. Specifically we request written confirmation that when a four light warning system is used and is activated by a driver actuated switch, it is permissible for the stop signal arm to be activated by opening of the service door, provided that an audible signal warns the driver when the alternating red flashing lights are on but the stop signal arm has not been extended.

Blue Bird is working to resolve all system design and operational issues regarding Standard No. 131 in the very near future so that changes in production can be implemented in time to meet the September 1, 1992 effective date. Your prompt consideration and response to this request is, therefore, urgently requested.

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