Interpretation ID: nht90-1.58

TYPE: Interpretation-NHTSA

DATE: February 27, 1990

FROM: Delbert N. Pier -- Legislation and Compliance Coordinator, Hyundai America Technical Center, Inc. TO: Stephen Wood, Esq. -- Acting Chief Counsel, NHTSA

TITLE: FMVSS Number 107, Reflective Surfaces

ATTACHMT: Attached to letter dated 7-16-90 to Delbert N. Pier from Paul Jackson Rice; (A35; Greenbook Std. No. 107) TEXT:

Hyundai requests assistance with an interpretation regarding Federal Motor Vehicle Safety Standard, Number 107 (reflective surfaces).

It is Hyundai's intention to test the surface visible on the windshield wiper blade rail spring. In accordance with ASTM Designation D 523-62T, Hyundai has set up a test specimen for the specular gloss test to accomplish this, see attachment.

Because of the limited amount of area (side "B") allowable for the light source to reflect into the specular reflectance meter, Hyundai is using several rail springs gathered together. As shown in the attachment, this allows for the adequate reflective surface to accomplish the test. Hyundai believes this specimen shows sound engineering judgement and is a satisfactory way to conduct this test.

Hyundai is requesting an interpretation on this specimen as an acceptable means of conducting the test for establishing compliance with FMVSS, Number 107.

Thank you for your assistance in this matter. Should further clarification be needed, do not hesitate to contact me at the telephone number listed above.