ID: 86-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 02/04/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Benjamin R. Jackson

TITLE: FMVSS INTERPRETATION

TEXT:

February 4, 1986 Mr. Benjamin R. Jackson Executive Director Automobile Importers Compliance Association 1607 New Hampshire Avenue, N.W. Washington, D.C. 20009 Dear Mr. Jackson: This responds to your letter requesting an interpretation of 49 CFR Part 541, Federal Motor Vehicle Theft Prevention Standard. Specifically, you on vehicles subject to the theft prevention standard to have the required markings entirely within the target area specified for the part by the original manufacturer of the vehicle. You stated that it was possible that target areas specified by the original manufacturer might be suitable for marking by means of labels, but not suitable for marking by means of inscription. If this situation were to occur, you asked if Part 541 could be interpreted to permit manufacturers that must mark by means of inscription to place those markings outside the target area designated by the original manufacturer. Part 541 cannot be so interpreted. In the case of inscribed markings, 541(d)(2)(iii) specifies that the required markings shall be "placed entirely within the target area specified by the original manufacturer for that part." This requirement applies to all markings inscribed for the purposes of Part 541, whether done by an original manufacturer or a direct importer. The policy bases underlying this requirement were explained at length in the preamble to the final rule establishing Part 541. See 50 FR 43166, at 43172, October 24, 1985. First, it is important that all parts be marked in the same target area so that investigators will know exactly where to look on a part for the required marking. The investigator would be alerted to possible suspicious activity if the marking were outside the target area. Second, the different target areas for original equipment and replacement parts marking are intended to ensure that there will be an adequate separation between the areas where the different types of parts will be marked. This will ensure that a thief cannot obliterate an original equipment part marking and affix a counterfeit replacement part marking directly over the area where the original equipment part marking was located. Both of these purposes would be undercut if original manufacturers and direct importers were allowed to designate different target areas for marking vehicles in the same line, Accordingly, Part 541 explicitly requires only one target area for the required marking on each part of a covered line. We do not believe that your concern about inscribing markings on curved surfaces in well-founded. The agency knows of a number of means of inscribing numbers on curved surfaces that would permit direct importers to mark those surfaces within the $15 cost limit set forth in section 604(a)(2) of the Cost Savings Act. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.22

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Robert J. Crail

TITLE: FMVSS INTERPRETATION

TEXT:

February 6, 1986 Mr. Robert J. Crail Theurer, Inc. Route 1, Box 300 Helenwood, Tennessee 37755 Dear Mr. Crail: This responds to your letter of August 20, 1985, requesting an interpretation of Standard No. 121, Air Brake Systems (49 CFR 571.121). You asked whether an extendible intermodel container chassis which adjusts to haul containers which vary in length between 40 feet and 48 feet is a "heavy hauler trailer" as defined in Section S4 of Standard No. 121. Specifically, you would like to know whether the extendible container chassis described above must comply with Sections S5.2.1.2 and S5.3, and whether you or your customer may utilize the options available in Section S5.6 for parking brake systems and in Section S5.8 for emergency brake systems. By way of background information, this agency does not give approvals of motor vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to ensure that its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter. The extendible container chassis trailers which you describe have brake lines which are designed to extend with the vehicle frame. According to Section S4 of Standard No. 121, a trailer whose "brake lines are designed to adapt to separation or extension of the vehicle frame...." is, by definition, a heavy hauler trailer. Thus, your extendible chassis trailer would be considered a heavy hauler trailer within the definition of S4. Section S5.2.1.2 of Standard No. 121 provides that trailers with air brakes are generally required to have total service reservoir volume which is "at least eight time the combined volume of all service brake chambers at maximum travel of the pistons or diaphragms." This general rule is limited by the last sentence of S5.2.1.2 which provides, "However, the reservoir on a heavy hauler trailer ... need not meet this requirement." Section S5.3 sets forth road test requirements, compliance with which must be certified for all trucks, buses and trailers. Generally, all trailers are required to be certified as complying with the timing requirements of S5.3.3 and S5.3.4. This general rule is limited by the last sentence of S5.3, which specifies, "However, a heavy hauler trailer ... need not meet the requirements of S5.3." Thus, heavy hauler trailers are expressly excepted from all of the requirements of S5.3. Finally, you asked whether the trailer you manufacture may take advantage of the options available in Section S5.6 for the parking brake system and in Section S5.8 for the emergency brake system. Both Sections S5.6 and S5.8 specifically give manufacturers of heavy hauler trailers the choice of complying with the requirements of those sections... "or at the option of the manufacturer, the requirements of sec. 393.43 of this title." Title 49 CFR section 393.43 sets forth requirements for breakaway and emergency brakes. An extendible container chassis which comes within the S4 definition of heavy hauler trailer may comply with the section 393.43 requirements or the parking emergency brake requirements or the parking and emergency brake requirements of Standard No. 121 Sections S5.6 and S5.8, respectively. If you have any further questions, please let me know. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.23

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. D. Black

TITLE: FMVSS INTERPRETATION

TEXT:

February 6, 1986 Mr. D. Black Director, U.S. Engineering Alfa Romeo, Inc. 250 Sylvan Avenue Englewood Cliffs, NJ 07632 Dear Mr. Black: This responds to your letter to Mr. Barry Felrice, our Associate Administrator for Rulemaking, requesting an interpretation of Part 541, Federal Motor Vehicle Theft Prevention Standard. You stated that you plan to begin production of a 1987 carline in March 1986. This particular carline has been selected as one that will be subject to the requirements of Part 541. However, Part 541 does not become effective until April 24, 1986. You stated your belief that the introduction of the 1987 carline before the effective date of Part 541 means that none of the 1987 vehicles would be required to comply. Your belief is essentially correct. As you noted, the effective date for Part 541 is April 24, 1986. This effective date means that Part 541 applies to all selected carlines beginning with the 1987 model year. However, the legislative history for Title VI of the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 2021 et seq.), which Title requires that Part 541 be promulgated, expressly states: "The theft prevention standard cannot apply to a car in the middle of the model year." H. R. Rep. No. 1087, 98th Cong., 2d Sess. at 11 (1984). For the purposes of Title VI of the Cost Savings Act, NHTSA believes that the model year for a carline begins on the day on which a vehicle in that carline is introduced into commerce in the United States, the start of production does not constitute an introduction into commerce in the United States when the first vehicle is imported into the customs territory of the United States. Assuming that one of the 1987 vehicles in this carline is imported, and thus introduced into commerce, before April 24, 1986 (the effective date for Part 541), the 1987 model year for that carline would have begun prior to the effective date of the theft prevention standard. Obviously, the requirements of any standard do not apply before the effective date. Given the clear expression of Congressional intent that this theft prevention standard cannot apply to a carline in the middle of its model year, NHTSA concludes that a 1987 model year version of a carline introduced into commerce before the effective date of the theft prevention standard during the 1987 model year. It would, of course, be subject to the requirements during the 1988 model year. If you have any further questions or need more information on this subject, please do not hesitate to contact me. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.24

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Hans W. Metzger

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Hans W. Metzger Scottsdale, AZ 85253

Thank you for your letter of October 14, 1985, asking several questions about Standard No. 208, Occupant Crash Protection. I hope that the following discussion answers your questions. You first asked for a clarification of S4.1.3.1.2. That section provides that a manufacturer must equip a specific amount of its vehicles manufactured on or after September 1, 1986, and before September 1, 1987, with automatic restraints. The amount must not be less than 10 percent of the average annual production of passenger cars manufactured for sale in the United States during the period September 1, 1983, to August 31, 1986 (the base period). You explained that your client did not produce any vehicles for the U.S. during one year of the base period (September 1, 1983 -September 1, 1984). For the other two years of the base period, your client produced a limited number of vehicles for sale in the U.S. You asked whether in calculating the average yearly production for the base period, it is correct for your client to use zero for the production for the production between September 1, 1983 and August 31, 1984, and the actual production figures for two subsequent years. The three year base period addresses a situation where a manufacturer has produced vehicles for sale in the U.S. in each of those years. The purpose of averaging the production is to ensure that the calculation of the percentage of a manufacturer's passenger cars that must comply with the automatic restraint requirements is based on a production figure which is representative of the manufacturer's typical production. In the case of a manufacturer who has produced vehicles for two of those years, it would defeat the purpose of the rule to allow the manufacturer to lower artificially the number of vehicles which must comply with the automatic restraint requirement by counting its production as zero for one of the base years. Thus, in a situation where a manufacturer has only two years of production, the manufacturer should calculate its base period average based on the number of vehicles produced during those two years. To provide manufacturer's with additional flexibility is calculating the number of passenger cars which must be equipped with automatic restraints, NHTSA proposed, on April 12, 1985 (50 FR 14509), an amendment to Standard No. 208 which would give manufacturers the option of using either a three year average or the actual production for the model year in question. We expect to issue shortly a final rule on this subject. You also asked for another clarification of S4.1.3.1.2. You asked if the required number of vehicles can be produced anytime between september 1, 1986 and August 31, 1987. S4.1.3.1.2 does not require that the automatic restraints be installed at any specific time during that period. Thus, you are correct that the installation of automatic restraints does not have to be evenly distributed throughout that 12 month interval. I hope this information is of assistance to you. If your have any further questions, please let me know. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.25

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Leon E. Panetta

TITLE: FMVSS INTERPRETATION

TEXT:

This responds to your request that we review the concerns expressed by one of your constituents, Mr. Joseph Loschiavo, about certain van seats. According to Mr. Loschiavo, the Monterey County Van Program for senior citizens uses vans with seats that are very low and close together, making it difficult for persons to get up out of the seats. He suggested that either the seats be raised about eight inches or that special seats be provided for persons who have problems with the present seats.

The National Highway Traffic Safety Administration (NHTSA) issues motor vehicle safety standards. Federal Motor Vehicle Safety Standard No. 207, Seating Systems, establishes requirements to minimize the possibility of seat failure during vehicle collisions. However, NHTSA does not have any standards concerning the height or spacing of van seats.

The Monterey County Van Program has several options in obtaining vans with appropriate seating. In purchasing new vans, the program may either select from among the variety of vans offered by the major vehicle manufacturers, or go to one of a number of companies that customize vans to purchasers' specifications. A number of companies also modify used vehicles.

We note that new vans, including vans which are modified prior to first sale, are required to be certified to comply with applicable Federal motor vehicle safety standards. The specific certification requirements are set forth at 49 CFR Part 567, Certification. If a used vehicle is modified by a business such as a garage, the business is not required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative the compliance of the vehicle with any safety standard. This is required by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. Thus, if a business replaced a van's existing seats with higher seats, it would need to make sure that it was not rendering inoperative the vehicle's compliance with Standard No. 207 or any other Federal motor vehicle safety standard.

I hope this information is helpful.

Sincerely,

Erika Jones Chief Counsel

TO: Mr. Joseph A. LaSala Office of Congressional Affairs Department of Transportation 400 Seventh Street, S.W., Room 10506 Washington, D.C. 20590

ENCLOSURES FROM:

Mr. Joseph Loschiavo

RE: Would you please review the attached and provide me with a written report addressing the concerns this constituent has expressed?

Thank you for your assistance.

I would appreciate your attention to the attached correspondence. Please direct your reply to the address below.

Thank you very much for your attention to this matter.

Sincerely,

LEON E. PANETTA Member of Congress

Please respond to:

380 Alvarado Street Monterey, California 93940 (408)649-3555

Attention: Ken Christopher; (408) 429-1976

ID: 86-1.26

TYPE: INTERPRETATION-NHTSA

DATE: 02/07/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Lewis Quetel

TITLE: FMVSS INTERPRETATION

TEXT:

February 7, 1986 Mr. Lewis Quetel PMI Inc. 1391 Wright Blvd. Schaumburg, IL 60193 Dear Mr. Quetel: This is in response to your telephone call on October 22, 1985, to Robert Nelson of this agency asking how our regulations would affect a product you intend to sell. The product, which you call a "Kumfi-Klip" safety belt comfort device, consists of a plastic device which attached to the upper torso belt anchorage. A belt user can then pull the webbing through the open wedge to introduce slack into the shoulder portion of the belt. As background information, let me explain that the agency does not have the authority to approve or endorse items of motor vehicle equipment, such as your device. We do have the authority to issue Federal Motor Vehicle Safety Standards that set performance requirements for motor vehicles and items of motor vehicle equipment. Manufacturers of vehicles or equipment covered by our standards must certify that their product complies with all of the applicable standards. Your particular aftermarket product is not covered by any of our safety belt or other standards. However, as a manufacturer of an item of motor vehicle equipment, you do have certain responsibilities concerning possible safety-related defects you do have certain responsibilities concerning possible safety-related defects you or the agency discover in your product. Those responsibilities are set out in sections 152-160 of the National Traffic and Motor Vehicle Safety Act. I have enclosed an information sheet on our defect and other regulations for your review. The agency is concerned that a belted occupant could inadvertently use your product to introduce excessive slack in the upper torso belt and thereby reduce the effectiveness of the belt. The instructions you provide with the "Kumfi-Klip" do warn users not to introduce excessive slack, but the instructions provide no information to guide a user on what is an excessive amount of slack. We encourage you to provide more detailed guidance. If you have any further questions, please let me know. Sincerely, Original Signed By Erika Z. Jones Chief Counsel Enclosure

ID: 86-1.27

TYPE: INTERPRETATION-NHTSA

DATE: 02/10/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: M. Iwase -- Manager, Technical Administration Dept., Koito Mfg. Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. M. Iwase Manager, Technical Administration Dept. Koito Mfg. Co. Ltd. Shizuoka Works 500 Kitawaki Shimizu-shi, Shizuoka-ken JAPAN

This is in reply to your letter of August 30, 1985, to Jere Medlin, Office of Rulemaking, asking for an interpretation of the recent amendment to Motor Vehicle Safety Standard No. 108 allowing motorcycles to be equipped with modulating headlamp systems.

In your first question, you asked for confirmation of your understanding of the modulation cycle and maximum power. We confirm that your interpretation is correct. Please note that the value of A on the modulation cycle of your diagram may be equal to or less than the value of D. However, the requirement relates to C/D rather than C/A, and it is the value of C/D that must be at least 0.17.

With reference to the electrical wiring diagram that you provided, you have asked whether the voltage drop maximum of 0.45 volt in S4.6.1(g) applies to condition (a) (when the modulator switch is "on") or condition (b) (when the modulator switch is "off"). The maximum voltage drop applies to both conditions (a) and (b), i.e., when the modulator is operating and when the headlamp is on. Paragraph S4.6.1(g) states "When tested in accordance with the test profile shown in Figure 9, the voltage drop across the modulator when the lamp is on at all test conditions ....shall not be greater than .45 volt." This not only includes the period of time when the modulator is operating, but also the period when the headlamp is on without the modulator. Paragraph S4.6.1(e) requires that both the upper and lower beams remain operable in the event of a modulator failure, and thus the agency views headlamp operation without modulator as one of the test conditions included in the term "test conditions" in S4.6.1(g). We would like to comment further that when the modulator is turned on, during the test profile of Figure 9, it should be activated when the headlamp is on, since most manufacturers of motorcycles wire their vehicles so that the headlamp is on when the ignition switch is on.

Your next question concerns the acceptability of three types of modulator switch systems which you have diagrammed. All your designs appear consistent with the requirements of Standard No. 108. The modulator must be capable of being switched out of the circuit if it fails, in which case upper and lower beams could be used im a steady-burning mode. This does not necessarily mean another switch, other than the Hi-low beam switch, however.

In response to your final question, you may write Herbert Thrower, Jr., President, Dotech Inc., P.O. Box 3322, Charlotte, N.C. 28210.

Sincerely,

Erika Z. Jones Chief Counsel

SUBJECT: ACTION: Request for Interpretation of Motorcycle Modulating Headlamp Requirements (FMVSS No. 108) by Koito

FROM: Barry Felrice Associate Administrator for Rulemaking

TO: Jeffrey Miller Chief Counsel

Rulemaking received the attached request for an engineering interpretation of the intent of certain requirements for motorcycle headlamp modulators.

Herein is the engineering interpretation of the requirements in question. Please prepare the official response to Koito based on this information.

In response to question 1:

1. Yes, 0.21 < y < 0.30 sec., as suggested by koito, is correct.

2. Yes, x/y = 50 to 70%, as suggested by Koito, is correct.

3. The value of A may be equal to or less than the value of D. However, the requirement relates to C/D rather than C/A. It is the value of C/O that must be at least 0.17.

In response to question 2:

The intent of the requirement in S4.6.1 is to assure that less than 0.45 volts is lost as a result of the addition to a headlamp circuit for the purpose of modulating the headlamp. The 0.45 volts is for night operation condition of the headlamp (i.e. condition "b" in Koito's letter).

In response to question 3.

We do not approve designs, but offer the following comments on the intent of the rule. The modulator should be capable of being switched out of the circuit if it fails, in which case upper and lower beams could be used in a steady burning mode. This does not necessarily mean another switch, other than the Hi-low beam switch, however. All your designs appear to be consistent with the requirements of the standard, however some appear more desirable, based on number of switches, case of use, etc., than others.

In response to your request for the address of Dotech, a modulator manufacturer, the following information is furnished:

Mr. Herbert Thrower, Jr.. President Dotech Inc. P.O. Box 3322 306 Clanton Road Charlotte, N.C. 28210 Tel. No. (704) 523-6727

Attachment

ID: 86-1.28

TYPE: INTERPRETATION-NHTSA

DATE: 02/10/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Timothy Pawl, P.E. -- President, Pawl Inventioneering Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Timothy Pawl P.E. President Pawl Inventioneering Corporation P.O. Box 5425 West Bloomfield, Michigan 48033

This is in response to your letter of November 29 ,1985, to the former Chief Counsel of this agency Jeffrey R. Miller, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

Your letter is vague as to the precise function of your "safety related" lighting device, and whether you wish to offer it as original equipment or equipment intended for installation after the sale of a vehicle to its first purchaser for purposes other than resale. If the latter, then its legality is determinable solely under the laws of each State in which it will be used.

If you intend it as original equipment, on a vehicle at the time of its initial sale, then its legality would be determinable under Standard No. 108. As a general rule, section S4.1.3 prohibits the installation of any device that would impair the effectiveness of lighting equipment required by the standard. You have informed us that your device, which consists of "amber LED's" in the "rear package tray," is inoperative during application of the service brakes; thus, it does not appear that it would impair the effectiveness of the center high-mounted stop lamp.

You have also stated that it is located "in relative proximity" to the center stop lamp but is not combined with it, and you have asked if this meets the intent of S4.4.1 regarding equipment combinations. This section forbids the combination of the center stop lamp with any other lamp or reflective device. Since your device is physically separate from the center lamp, S4.4.1 would not appear to prohibit your device.

You have also stated that when viewed from the rear, "the pattern of illuminated LED's may change, possibly giving the illusion of flashing," and you ask for a definition of "flashing" as described in section S4.6(c). This section has been renumbered S4.5.11, and subsection (c) permits an exception to the general rule that lamps in use must be steady-burning, permitting headlamps and side marker lamps to "flash" for signalling purposes. The definition of flash is that contained in S3, a cycle of activation and deactivation by automatic means, and this definition does not specify frequency or other characteristics. To us, the important question is whether your device complies with section S4.5.11(e) which requires all lamps (other than those specifically excepted) to be steady-burning in use. A lamp that changes patterns may not flash, but it cannot be viewed as steady-burning either.

Finally, you state that "section S4.3 states that no function other than red reflex reflectors shall be combined with CHMSL or rear turn signal lamps" and ask whether amber or any other color "may be used in proximity" since it is not used in combination. We believe you must be referring to section S4.4.1 which states that "no clearance lamp may be combined optically with any taillamp or identification lamp, and no high-mounted stop lamp shall be combined with any other lamp or reflective device." As we do not know the intended functions of your LED device, I can offer only general comments. Although red is the required color for all rear lighting devices except backup and license plate lamps, amber is permitted as an optional color for rear turn signals: furthermore, amber is generally accepted as indicating the need for caution. Thus, amber is not a lens color whose presence on rear lighting devices would per se impair effectiveness. The use of other colors for lighting devices on the rear of vehicles could lead to confusion, and be viewed as impairing the effectiveness of required lighting equipment.

Sincerely,

Erika Z. Jones

Chief Counsel

November 29, 1985

Jeffrey R. Miller Chief Council U.S. Department of Transportation 400 7th Street S.W. Washington,D.C. 20590

RE: Request for Interpretation of FMVSS 108

Dear Mr. Miller;

We have under development a new device of a safety related nature for automobiles. Before proceeding further on the development, we are hereby requesting an interpretation of Federal Motor Vehicle Safety Standard 108. Our device mounts in the rear package tray area of the automobile. We are therefore concerned about the specific sections pertaining to the operation and restrictions thereof for the Center High Mounted Stoplamp (CHMSL).

As a means of definition of the areas of concern, I will list the specific operating characteristic of our device and then the section from the Standard for which we device an interpretation.

1. Our device has amber colored LED's, during the application of the service brakes, these LED's are disabled ,allowing a vehicle following to observe only the CHMSL. Hence, although in relative proximity (near the target area of the CHMSL) it is not combined with the CHMSL. Does this operation meet the intent of S4.4.1 concerning equipment combinations.

2. When a vehicle containing our device is viewed from the rear by a following vehicle, the pattern of illuminated LED'a may change, possibly giving the illusion or flashing. We therefore need a definition of flashing as described in section S4.6(c), frequency, length of time between periods of "steady-burning" operation, etc.

3. As previously mentioned the device contains amber LED's, section S4.3 states that no function other than red reflex reflectors shall be combined with CHMSL or rear turn signal lamps.... since it is not used in combination per our question (1) may amber be used in proximity. If not amber, are there any other colors that may be acceptable.

We would appreciate your attention to this matter and await your response. If necessary we may be reached by phone at (313) 682-2007.

Sincerely,

E. Timothy Pawl, P.E. President

ID: 86-1.29

TYPE: INTERPRETATION-NHTSA

DATE: 02/10/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

February 10, 1986 Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan Dear Mr. Chikada: This is in reply to your letter of November 13, 1985, to the former Chief Counsel of this agency, Jeffrey R. Miller, with respect to the ratio of the candlepower between the taillamp, stop lamp, and turn signal lamp (Federal Motor Vehicle Safety Standard No. 108). You have enclosed a hypothetical two-compartment lamp design which could be manufactured in three variations of stop, turn signal, and taillamp combinations (layout 1, layout 2, and layout 3). Standard No. 108 incorporates by reference various SAE standards which prescribe candlepower ratios for multiple compartment lamps (J585e Taillamps; J586c Stop Lamps; J588e Turn Signal Lamps). You ask how you can apply the ratio of the candlepower between the lamps. The requirements to which you refer are contained in Note 4 to Table 1 of each of the referenced SAE standards, which in turn cite paragraph 3.1 of each standard. The first sentence of Note 4 establishes the ratio when one function is combined with another (that is to say, optically combined within a single compartment). The second sentence of Note 4 provides, however, that if a multiple compartment lamp is used and the distance between the optical axis for both functions is within the dimensions specified in paragraph 3.1, the ratio is computed with all the compartments lighted. The third sentence of Note 4 states that if these dimensions are exceeded the ratio is computed for only those compartments where the functions are optically combined. In layout 1 the turn signal lamp is not combined with the tail/stop lamp and you have asked for confirmation that only the ratio between the tail lamp and stop lamp must be considered. That is correct. The dimension specified in paragraph 3.1 of each of the SAE standards is a maximum of 22 inches between filament centers in two-compartment lamps. Your layout 2 combines the tail lamp and turn signal lamp in one compartment, and the tail lamp and stop lamp in the second, whereas in layout 3 the first compartment contains one lamp, the tail lamp, and in the second compartment, the tail lamp, stop lamp, and turn signal lamp are present. You ask for confirmation that only the ratios of the lamps in the individual compartments shall be considered. Your hypothetical lamp design does not depict the distance between filament centers of each function, but if they exceed 22 inches then you are correct with respect to layouts 2 and 3. If the distance is less than 22 inches, then the ratio is computed with both compartments lighted. I hope that this answers your questions.

Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.3

TYPE: INTERPRETATION-NHTSA

DATE: 01/02/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Ms. Patricia Hill

TITLE: FMVSS INTERPRETATION

TEXT:

Ms Patricia Hill 2150 Hacker Road Howell, Michigan 48843

Thank you for your letter of September 19, 1985, asking about the effect of our regulations on a safety belt design you have seen. You explained that the design uses "a rigid member to support a webbing guide near the shoulder of a front seat occupant. This rigid member was rigidly attached to the roof of the vehicle." You asked several questions about this design, which are answered below.

You first asked whether the rigid member would be considered a seat belt anchorage, a piece of attachment hardware or a common component for the purposes of our standards. We cannot provide a definitive answer without having further details about and preferably a drawing of the structure. Based on the information you have provided, it appears that the rigid member would be an anchorage.

Standard No. 210, Seat Belt Assembly Anchorages, defines an "anchorage" as a device that transfers safety belt assembly load to the vehicle structure. Since the rigid member is attached to the roof at one end and to a safety belt webbing guide at the other, it appears to be intended to transfer loads to the vehicle structure. Thus, it would have to meet the strength and location requirements of the standard.

You also asked if one or both ends of the rigid member are required to meet the upper torso restraint location requirements of S4.3.2 of Standard No. 210. If, as discussed above, the rigid member is intended to transfer loads, then it would have to meet the location requirement of S4.3.2. That section states that the "anchorage for the upper end of the upper torso restraint shall be located within the acceptable range" shown in Figure 1 of the standard. The purpose of the requirement is to specify the angle at which the shoulder belt crosses the occupant's chest. Thus, the portion of the anchorage that controls the angle of the shoulder belt must be within the zone specified in Figure 1.

I hope this information is of assistance to you. If you have further questions, please let me know.

Sincerely, Erika Z. Jones Chief Counsel

2150 Hacket Road Howell, Michigan 48843 September 19, 1985

Mr. Jeffrey R. Miller Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, SW Washington, D.C. 20590

Dear Mr. Miller:

This requests an interpretation of the requirements of FMVSS Nos. 209, Seat Belt Assemblies and 210, Seat Belt Assembly Anchorages.

Recently a proposed Type 2 continuous loop seat belt installation was inspected that used a rigid member to support a webbing guide near the shoulder of a front seat occupant. This rigid member was rigidly attached to the roof of the vehicle.

I am aware two previous requests for interpretation (Ford and Toyota) have been made that have some measures of similarity to the present issue. However, both the Ford and Toyota cases differed significantly from the subject seat belt assembly; webbing was used vice a rigid member to locate a webbing guide near the shoulder of a front seat occupant.

Following are my specific requests for interpretation.

1. Is the above described rigid member a seat belt anchorage, a piece of attachment hardware, or possibly a common component?

2. Are one or both ends of the rigid member required to meet the upper torso restraint location requirements of FMVSS No. 210, Section 4.3.2? Sincerely, Patricia Hill