Interpretation ID: nht90-1.52

TYPE: Interpretation-NHTSA

DATE: February 21, 1990

FROM: Dipl.-Ing H. Westermann -- Hella KG Hueck & Co.

TO: Taylor Vinson -- Office of Chief Counsel., NHTSA

TITLE: Request for interpretation - CHMSL unity.

ATTACHMT: Attached to letter dated 4-25-90 To Dipl.-Ing H. Westermann and From Stephen P. Wood; (A35: Std.108); Also attached to letter dated 2-7-90 To Richard van Iderstine and From Dipl.-Ing. H. Westermann

TEXT:

Please receive enclosed our request for interpretation, which had accidentally been addressed to Mr. van Iderstine but we were informed that it is yours responsibility. A major uncertainty has arisen with respect to CHMSL unity, where the CHMSL is mounted on the trunk of a convertible (no rear window, appendix 2 of the letter). By ECE unity is defined but SAE and FMVSS 108 yield no such definition. In absence of a clear definition of unity for CHMSL, please let us know, whether the appropriate ECE definition can be applied and whether the designs as shown in the appendices form a CHMSL unity in the sense of FMVSS 108. A soon answer is very much appreciated.