Interpretation ID: 1984-1.35

TYPE: INTERPRETATION-NHTSA

DATE: 04/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: H. Nakaya -- Office Manager, Mazda (North America), Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. Nakaya Office Manager Mazda (North America), Inc. 24402 Sinacola Court Farmington Hills, MI 48018

This responds to your letter of February 20, 1984, asking three questions concerning the compliance test procedures of Standard No. 219 that would be used in testing a truck with a forward tilt cabin. The answers to your questions are discussed below.

You first asked whether in doing the compliance test, "may the test sample consist of just the cabin with the production seating system installed?" In conducting Standard No. 210 compliance tests, the agency conducts the test on a fully assembled vehicle (i.e., cabin and chassis/frame).

You then asked whether the tilt cabin rear latch bracketry could be reinforced during the testing. The answer is no; the agency tests the vehicle as manufactured.

Finally, you asked "should the tilt cabin latch bracketry and mechanism be considered within the scope" of the Standard No. 210 compliance testing. The answer is no. The purpose of the standard is to measure the performance of the seat belt anchorages. A failure of the tilt cab latch would not constitute a failure of Standard No. 210. I must note, however, that a failure of a tilt cab latch under the loading experienced during a Standard No. 210 compliance test could raise the question of whether the latch contains a defect related to motor vehicle safety. I urge you to design the latch in such a manner that it will withstand the loads generated during a crash.

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

Sincerely, Original Signed by Frank Berndt, Chief Counsel

February 20, 1984

Mr. Frank Berndt Chief Counsel National Highway Traffic and Safety Administration 400 7th S.W. Washington, DC 20590

re: Interpretation of Compliance Testing Criteria - Safety Standard 210 - Seat Belt Assembly Anchorages

Dear Mr. Berndt:

Mazda, after reviewing our test procedures used to verify compliance with Standard 210, has a number of questions relating to truck vehicles equipped with a forward tilt cabin:

1. When a forward tilt cabin equipped truck is to be tested for seat belt assembly anchorage performance, may the test sample consist of just the cabin with the production seating system installed?

2. If just the cabin is required, would it be possible to reinforce the tilt cabin rear latch bracketry? If the chassis/frame is required, would such reinforcement be allowed?

3. When performing Standard 210 compliance testing, should the tilt cabin latch bracketry and mechanisms be considered within the scope of their Standard 210 compliance varification testing?

Please respond to these questions and discuss any issues relevant to the accurate interpretation of Standard 210 testing procedures and criteria at your earliest convenience.

Thank you, Sincerely, Original signed by H. Nakaya