Interpretation ID: 1983-3.17

TYPE: INTERPRETATION-NHTSA

DATE: 10/28/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Nissan Motor Co. Ltd. -- Shizuo Suzuki

TITLE: FMVSS INTERPRETATION

TEXT:

This is in response to your September 23, 1982, letter regarding the applicability of Federal Motor Vehicle, Safety Standard No. 118, Power-Operated Window Systems, to power sunroofs. The agency apparently has never previously addressed this question.

Standard 118 specifies requirements only for power-operated window and partition systems. A power sunroof would be considered neither a "window" nor a "partition" and therefore would not be subject to the standard. Our standard was intended to apply to the typical power side windows and the power tailgate window of station wagons. The reference to "partitions" in the standard was adopted as part of the July 23, 1970, final rule establishing Standard 118 and was intended to assure that power-operated interior partitions, such as might be used in a taxi or a limousine, would comply.

Although Standard 118 does not apply to power sunroofs, we strongly recommend that safety precautions along the lines of those established in that standard be incorporated in power sunroof designs. It appears possible that the types of accidents which the standard was intended to prevent could also occur as a result of the unsupervised operation of power sunroofs.

If you have any further questions to this matter, please contact us.

Sincerely,

Original Signed by Frank Berndt Cheif Counsel

Mr. Frank A. Berndt Chief Counsel National Highway Traffic Safety Administration Room 5219 Nassif Building Washington, D.C. 20590

Dear Mr. Berndt: We sincerely request information concerning the interpretation of Federal Motor Vehicle Safety Standard No. 118: "Power Operated Window Systems" (49 CFR Part 571).

Nissan's question is whether or not the requirements of MVSS 118 are applicable to a power-operated sunroof.

Thank you in advance for your prompt attention to this inquiry. We are looking forward to an expeditious reply.

Sincerely,

Shizuo Suzuki Washington Representative Safety