Interpretation ID: nht71-2.39

DATE: 05/04/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 12, 1971, regarding the March 10, 1971, amendment to Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection.

The following are answers to your questions:

1. Question:

Standard to be effective as of August 15, 1973, through August 14, 1975, second option (S4.1.2.2) --- How many dummies should be used for frontal crash? Is the use of dummies necessary for roar and front seats or for front seat only?

Answer:

S4.1.2.2 (b) and (c) specify that the frontal barrier crash requirements of S5.1 shall be met for each front designated seating position. Thus, a dummy must be placed in each front designated seating position for these tests.

2. Question:

Same standard (S4.1.2) --- For a two seater car, what options for passive seat belts for both occupants should be taken? (First or Second option or one of these)

Answer:

A passive belt system may be used to meet the requirements of either the first or the second option under S4.1.2. If the passive belt system is intended to get the second option, however, it must employ a Type 1 seat belt assembly either as a part of the passive belt or as a separate component. This Type 1 belt must be separately usable, and must in addition meet the requirements of S7.1 and S7.2 and have a seat belt warning system.

The risk that the presence of a latch in the system may cause occupants to leave the belt unfastened while the vehicle is in motion is of concern to the NHTSA. At the same time, it is evident that some method of release is necessary for passive belt systems as well as for other passive restraints. We are therefore considering additional rulemaking on the subject of passive belts.

3. Question:

In regard to the Volkswagen Mini bus, which is the category of this automobile? (Multipurpose Passenger or Passenger)

Answer: It in a multipurpose passenger vehicle.

4. Question:

I understand that the convertible type automobile has partial exemption before August 15, 1973. What exception would be taken after that date? Also, through rumor, I have heard that this automobile will be included in the Multipurpose Passenger Car category. Is the correct?

Answer:

Because the multipurpose passenger vehicle may be manufactured in convertible form, the standard refers to convertibles under the multipurpose passenger vehicle requirements. A clear distinction is intended between such convertible multipurpose passenger vehicles, which are regulated by S4.2, and convertible passenger cars, which are regulated by S4.1. There is no plan to treat a convertible passenger car as a multipurpose passenger vehicle.

Convertible passenger cars are not distinguished from other passenger cars other than to exempt them from shoulder belt requirements in the January 1, 1972, to August 14, 1973, time period. They must thereafter meet the passive system requirements applicable to passenger cars, with no special exceptions.(Illegible Word) the multipurpose passenger vehicle category, convertibles are given the option of meeting lesser passive requirements than other multipurpose passenger vehicles (S4.2.2 and S4.2.3).

Please advise us if further clarification is needed.