Interpretation ID: 1983-1.46

TYPE: INTERPRETATION-NHTSA

DATE: 04/26/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Suzuki Motor Co. Ltd. -- Kenneth M. Bush, Staff Engineer, Government Relations Dept.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Kenneth M. Bush Staff Engineer Government Relations Department Suzuki Motor Co., Ltd. 3251 E. Imperial Highway P.O. Box 1100 Brea, California 92621

Dear Mr. Bush:

This is in reply to your letter of February 245, 1983, asking for an intepretation of Federal Motor Vehicle Safety Standard No. 123, Motorcycle Controls and Displays.

The last sentence of paragraph S5.3.1 is:

"If a motorcycle is equipped with self-proportioning or antilock braking devices utilizing a single control for front and rear brakes, the control shall be located and operable in the same manner as a rear brake control."

You have asked if your interpretation is correct that this sentence does not preclude the use of single control braking systems which do not incorporate "self-proportioning" or "antilock" braking devices. Your interpretation is correct; The sentence establishes a requirement that applies only to those self-proportioning devices with single control. It does not require a second control nor does it preclude a single control system without proportioning devices.

You have also asked that we provide clarification as to what self-proportioning means. This term includes any brake input device the actuation of which applies braking torque to both the front and rear wheels. Use of such a self-proportioning device does not preclude additional brake actuation devices. Examples include certain current model Moto Guzzi motorcycles.

As you have requested, the publicly available copies of your letter and this response shall not include your name and address. If you have any further questions, we shall try to answer them.

Sincerely,

Original Signed By Frank Berndt Chief Counsel

Mr. Frank Berndt, Esq. Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590

Dear Mr. Berndt:

Enclosed is a request for interpretation of a Federal Motor Vehicle Safety Standard. Because this request related to specific future product designs, we ask that this letter not be made publicly available with the request. For the same reason, we ask that our name and address be deleted from publicly available copies of your response.

Your consideration in this matter is greatly appreciated. Please contact me if you have any questions.

Sincerely,

SUZUKI MOTOR CO., LTD.

Kenneth M. Bush Staff Engineer Government Relations Department

This is to request clarification of some of the language contained in Federal Motor Vehicle Safety Standard No. 123, Motorcycle Controls and Displays (49 CFR 571.123). In particular, we have two questions concerning the last sentence of S5.2.1 which states "If a motorcycle is equipped with self-proportioning or antilock braking devices utilizing a single control for front and rear brakes, the control shall be located and operable in the same manner as a rear brake control.

First, we interpret this sentence not to preclude the use of single control braking systems which do not incorporate "self-proportioning" or "antilock" braking devices. Is this interpretation correct?

Second, we ask that you provide clarification as to what "self-proportioning" means as used in S5.2.1. If you could list examples of self-proportioning devices, this would be helpful.