Interpretation ID: nht69-2.16

DATE: 09/30/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Honorable John A. Blatnik

COPYEE: FHWA LEGAL 26-30; CONG. LIA.; MR. HITCKCOCK; OFF ACCIDENT AVOIDANCE, MVSPS

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of September 9, 1969, in reference to the motor vehicle safety items discussed in Mr. Frank L. Van Alstine's letter of July 2, 1969, to Mr. H. M. Jacklin, Jr., Acting Director of our Motor Vehicle Safety Performance Service. I am enclosing a copy of our reply to Mr. Van Alstine's letter.

As we indicated in our reply, Federal Motor Vehicle Safety Standard No. 107, "Reflecting Surfaces - Passenger Cars, Multipurpose Passenger Vehicles, Trucks and Buses," affects only original installation; it does not apply to replacement windshield wiper arms, such as those referred to in Mr. Van Alstine's letter.

Federal Standard No. 210 specifies strength and general location requirements for lap and shoulder belt anchorages in passenger cars. Even though vehicles such as Mr. Van Alstine's 1969 Plymouth Valiant must meet this standard, some degree of discomfort may be experienced with certain(Illegible Word) positions and/or certain occupant sizes. As our reply stated, we are not aware of any significant injuries resulting from the present belt anchorage locations.

Based on the information supplied by Mr. Van Alstine, it does not appear that the two situations described represent violations of Federal Motor Vehicle Safety Standards.

It is most helpful to our efforts to improve highway safety when concerned citizens such as Mr. Van Alstine take the time to bring their safety experiences to our attention and that of their elected representatives.

Enclosure