ID: 11-000699 Signature Products Group Seat Cushion 214 Interpretation Letter

ID: 16660-1.pja

Ms. Jeanne Isbill
TarasPort Trailers, Inc.
P.O. Box 327
Sweetwater, TN 37874

Dear Ms. Isbill:

This responds to your letter requesting an interpretation of whether two trailers your company manufactures would be excluded from the National Highway Traffic Safety Administration's (NHTSA's) rear impact protection (underride guard) regulations. You enclosed photographs of two flatbed trailers with rear extenders that slide out as much as 36 inches from the rear of the chassis. In the case of one trailer, the extension is full width, meaning that the extension forms a continuous plane from one side of the trailer to the other. On the other trailer, the extensions are only on the sides, like the small shelves that slide out from office desks on either side of the chair. Although no dimensions are given, it appears from the photographs that the extenders are more than 560 mm above the ground, near the top of the trailer tires. You ask if these trailers are special purpose vehicles and, if so, whether their bumpers need to be labeled stating that they are excluded. As explained below, these trailers are not excluded special purpose vehicles, and a compliant underride guard would need to be provided.

Federal Motor Vehicle Safety Standard No. 224, Rear impact protection, requires most trailers and semitrailers weighing over 10,000 pounds to be fitted at the rear with a rear impact (underride) guard meeting the requirements of Standard No. 223, Rear impact guards (49 CFR 571.223 and 571.224, published on January 24, 1996 at 61 FR 2004). However, certain kinds of vehicles are excluded. The only excluded category that is relevant for the purposes of this letter is that of "special purpose vehicles."

A special purpose vehicle is defined in S4 of FMVSS No. 224 as "a trailer or semitrailer having work-performing equipment that, while the vehicle is in transit, resides in or moves through the area that could be occupied by the horizontal member of the rear underride guard, as defined by S5.1.1 through S5.1.3."⁽¹⁾ S5.1.2 states that "[t]he vertical distance between the bottom edge of the horizontal member of the guard and the ground shall not exceed 560 mm at any point across the full width of the member. . . ." We can see no part of your trailer that, while the vehicle is in transit, would reside in or pass through an area described in S5.1.2.

In addition, to be a special purpose vehicle the guard area would have to be occupied or passed through by work-performing equipment. NHTSA interprets the words "work-performing" to mean that the equipment must actively perform its function, and that the function must involve exerting force or moving something else. There is no work-performing equipment at the rear of your trailers. Therefore, these vehicle do not meet the definition of a special purpose vehicle. No other exclusion applies to them, so the vehicle would have to be equipped with an underride guard meeting the requirements of 49 CFR 571.223 in order to be certified. The guard would have to be labeled as specified in S5.3 of Standard No. 223.

When deciding how to mount the guard, please keep in mind that a vehicle would have to meet the requirements of the rule in every configuration in which it can be operated on the road. Standard No. 224 does not specify the position the rear extenders would have to be in when the agency determines compliance. When a standard does not specify a particular test condition, we begin with a presumption that the requirements must be met in every test condition in which the vehicle can be operated. See, for example, NHTSA's October 2, 1990 letter to Mr. S. Kadoya of Mazda. Starting from this presumption, we look to the language of the standard and its purposes for guidance to decide whether some limitation on the test condition should be implied. We see no language that would imply a limitation. As to the purposes, with the trailer configured in the flatbed mode with its rear end at a height above 560 mm, a colliding vehicle would likely underride the trailer rear extenders. This safety concern is one that the agency considered extensively in the January 24, 1996 final rule (see 61 FR 2016-18), and it is this kind of situation the regulation was intended to prevent. Therefore, NHTSA could determine whether the vehicle complied with the rear extenders in any position they could be placed in transit.

S5.1.3 of Standard No. 224 states that the horizontal member of the guard must be as close as practicable to the rear extremity of the vehicle, but in no case farther than 305 mm from the rear extremity of the trailer. Your trailer's rear extremity with the extenders out would be the rearmost surface on the extenders themselves. To comply with S5.1.3, the rear face of the horizontal member of the guard would need to be no farther forward than 305 mm from the extenders, when the extenders are in any position in which they can be placed when in transit.

We cannot provide a specific opinions on how your trailer might be redesigned to accommodate a guard. We note, however, that the standard specifies only the guard's horizontal member position, and therefore there is a great deal of flexibility in how you attach the guard to the trailer, so long as the strength and energy absorption requirements are met. There is no requirement that the guard be suspended from the bed area. A guard attached to the extenders would move in and out with them, thus complying with the S5.1.3 no matter what position the extenders are in. However, we emphasize that it is you, as the vehicle manufacturer, who is responsible for the vehicle's compliance with the standard.

If you expect to encounter unusual difficulty redesigning your trailers, the agency would consider a petition for temporary exemption from Standard No. 224. Under one of our regulations (49 CFR Part 555), vehicle manufacturers may apply for a temporary exemption from the Federal motor vehicle safety standards. Under Sec. 555.6(a), a manufacturer whose yearly production is not more than 10,000 units may ask for an exemption of up to three years on the basis that compliance would cause it substantial economic hardship and that it has attempted in good faith to comply with the standard from which it has asked to be excused. We have enclosed a copy of Part 555 for your information. We have also enclosed a copy of our regulations relating to the protection of confidential business information. Most of the trailer manufacturers submitting petitions for temporary exemption have requested that their financial information remain confidential.

Please note Part 555 requires the agency to publish a notice in the Federal Register seeking public comment on each exemption petition before a decision can be made on such a request, and then publish a second notice either granting or denying the petition. This process normally takes three to four months from the date of submission.

If you have any further questions, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
John Womack
Acting Chief Counsel
Enclosures: Parts 512, 555
ref:224
d.5/22/98

1. Note that this definition, as quoted, reflects an amendment made in response to petitions for reconsideration of the final rule. See 63 F.R. 3654 (January 26, 1998).

ID: 571-209-fire truck seat belt assemblies-Christopher Palabrica-16-000817

ID: aiam2636

Dear Mr. Beach: This responds to your June 23 and July 8, 1977, letters asking severa questions about the effect of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, on the construction of school buses with gross vehicle weight ratings (GVWR) below 10,000 pounds.; You first ask whether there are any seat performance requirements fo the rearmost seat after April 1978. The rear seat has been exempted from the forward and rearward performance requirements of the standard. This exemption was possible since there are no passengers seated behind the rear seat who could impact with it in a crash situation. Therefore, the rear seat may be positioned against the rear panel if it does not protrude into the emergency exit zone.; In a second question, you ask whether the head protection zon requirements (S5.3), as well as the requirements of S5.1.2, S5.1.3, S5.1.4, and S5.1.5, are applicable to buses with GVWRs of 10,000 pounds or less since these buses are required to have seat belts. The answer to your question is yes. Section S5(b) of the standard states that all of the above sections are applicable to buses with GVWRs of 10,000 pounds or less.; In connection with your question concerning the head protection zon requirements, you submitted sketches of the sidewall and roof structure of one of your buses. In that sketch you depict a 50th percentile adult and show the proximity of that adult with the sidewall-roof structure. You question whether a portion of the bus structure above the window is part of the roof structure subject to the head protection zone requirements. The NHTSA has determined that the portion of the interior skin that is depicted by the diagonal line connecting the horizontal roof line to the vertically contoured line representing the sidewall is part of the roof structure and must comply with the requirements of the standard for head protection.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: nht89-2.46

TYPE: INTERPRETATION-NHTSA

DATE: 07/27/89

FROM: STEPHEN P. WOOD -- NHTSA

TO: MARTIN M. GINSBURG -- PROLINE DESIGNS

TITLE: NONE

ATTACHMT: LETTER DATED 05/08/88 FROM MARTIN M. GINSBURG TO ERIKA JONES -- NHTSA; OCC 2027; LETTER DATED 11/24/88 FROM MARTIN M. GINSBURG TO ERIKA Z. JONES -- NHTSA

TEXT: Dear Mr. Ginsburg:

This responds to your letters asking whether Federal Motor Vehicle Safety Standard (FMVSS) No. 302, Flammability of Interior Materials (49 CFR @ 571.302), applies to the "interior window coverings" that you manufacture for "pick up truck shells." In your letters, you briefly explain that the "shell," which is sold as an aftermarket product, "is placed directly over the bed of a truck." The answer to your question is no, Standard No. 302 does not apply to your product. I regret the delay in responding t o your letter.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not grant approval of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the m anufacturer to ensure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on our understanding of the facts provided in your letter.

There are two factors which lead us to conclude that Standard No. 302 does not apply to your window coverings. First, you manufacture an aftermarket item of equipment -- i.e., an accessory or addition to a motor vehicle sold to owners of used vehicles. Standard No. 302 regulates the flammability resistance of curtains and shades in new completed vehicles only.

Second, even if the shell and its window coverings were installed on a new vehicle prior to the vehicle's first sale to a consumer, Standard No. 302 applies only to components in the "occupant compartment air space" (S4), which the agency has indicated i s the area in which persons are likely to use to ride. Assuming that we are correct in believing that people do not typically ride in the enclosed bed of the truck, we conclude that the area enclosed by the shell would not be an occupant compartment. Th is accords with the agency's February 15, 1983 letter to Mr. Nakaya in which NHTSA stated that, with regard to vans, the space to

the rear of the rearmost seat was not part of the occupant compartment. Accordingly, since the window coverings in question are not located in the occupant compartment, we conclude that they are not subject to Standard No. 302.

Nevertheless, there are two matters that you ought to consider when manufacturing your window coverings. First is the possibility of liability under State and common law if the coverings were to catch fire in a situation where a window covering meeting Standard No. 302's flammability resistance requirements would not have caught fire, or if the coverings burn much more rapidly than coverings meeting those requirements.

Second is the possibility of a finding of a safety-related defect in your products. While Standard No. 302 does not directly apply to your product, you should be aware that the window coverings you manufacture are considered to be items of motor vehicle equipment. As the manufacturer of motor vehicle equipment, you are thereby subject to the provisions set forth in sections 151-159 of the Vehicle Safety Act concerning the recall and remedy of equipment with defects relating to motor vehicle safety. I f you or this agency determined that your product had a defect relating to motor vehicle safety, you would have to notify all known purchasers of the defect and either repair your product so that the defect is removed, or replace the window coverings wit h an identical or reasonably equivalent product that does not contain a defect.

Your letter did not indicate whether you also manufacture the truck shell to which you refer. If you are the shell manufacturer, and if your product contains glazing material, Standard No. 205 (49 CFR @ 571.205, Glazing Materials) directly applies to yo ur product. Standard No. 205 is an equipment standard which sets performance requirements for glazing materials used in new and used motor vehicles and glazing materials sold as items of motor vehicle equipment, including glazing used in truck shells. The standard establishes both performance requirements, including those regulating the light transmittance and abrasion resistance of glazing, and labeling requirements applicable to the glazing used in your product.

We note also that, since your description of the "shell" was very brief, we were not certain whether the term "shell" as you use it includes what our regulations refer to as a "slide-in camper." Under Standard No. 126, Truck-Camper Loading (49 CFR @ 571. 126), a "slide-in camper" is a structure having a roof, floor, and sides, designed for the purpose of providing shelter for persons and to be mounted on and removed from the cargo area of a truck by the user. (See, also, 49 CFR @ 575.103 for NHTSA's con sumer information requirements for trucks that are capable of accommodating slide-in campers.) In light of the possibility that the structures to which you refer are slide-in campers, and that you might be the manufacturer of the campers, we would like t o mention our regulations that apply to slide-in campers.

Briefly, each slide-in camper must meet Standard No. 205 for any glazing materials used in the camper. In addition, Standard No. 126 requires each slide-in camper to be permanently labeled with information including its maximum loaded weight. This stan dard also requires each camper to be furnished with an owner's manual that includes information on total camper weight, proper matching of a truck and slide-in camper, appropriate methods of camper loading, and how to determine the camper's center of gra vity (cg) and where the cg should be placed in the truck cargo area. All campers must also be certified in accordance with section 114 of the Vehicle Safety Act as conforming to all applicable Federal motor vehicle safety standards. Each camper manufac turer must submit certain information concerning its company pursuant to Part 566 of our regulations, Manufacturer Identification. However, Standard No. 302 does not apply to slide-in campers, even if the slide-in camper is installed on a new pickup tru ck.

Finally, we must decline your request that we review "California Health and Safety Code Standard No. 19" to inform you whether window coverings that meet the California standard can meet Standard No. 302. NHTSA determines whether a vehicle or item of mo tor vehicle equipment complies with an applicable safety standard by purchasing vehicles and equipment and testing them under strict conditions according to the procedures specified in the standards. Thus, we determine whether a product subject to our s tandards complies with those standards by assessing the actual performance of the product in our tests. Since your window coverings are not subject to Standard No. 302, they will not be part of our compliance testing. Further, even if the coverings were subject to Standard No. 302, we have already noted that it is the responsibility of the manufacturer of the motor vehicle or motor vehicle equipment -- and not NHTSA -- to ensure that its vehicles or equipment comply with applicable FMVSS's.

I have enclosed copies of all of the safety standards and regulations mentioned above, and an information sheet explaining how you can obtain copies of NHTSA regulations for your future reference. I hope this information is helpful.

Sincerely,

Enclosures

ID: aiam2744

Dear Mr. Mrak: This is in reply to your letter of December 12, 1977, to Secretary o Transportation, Mr. Brock Adams, concerning the seat belts in your automobile.; Federal Motor Vehicle Safety Standard No. 208, Occupant Cras Protection, requires that the distance between the lap-shoulder belt intersection and the vertical center line of a 50th percentile (164 pounds, 5 feet 8 inches) adult male occupant must be at lease six inches when the seat is in its rearmost position. The purposes of this requirement is to reduce the risk of the occupant 'submarining' out from under the belt and to reduce the possibility of the shoulder belt pulling the lap belt up onto the abdomen where it could cause serious injury in a crash.; The possibility of submarining increases as the intersection of th lap-shoulder belt is moved toward the occupant's centerline and/or as seat cushion rigidity is reduced. In other words, the closer the intersection of the lap-shoulder belt is to the centerline of the occupant, and the softer the seat, the more the danger of 'submarining' in a crash. The standard does not limit the maximum distance from the occupant's centerline to the lap- shoulder belt intersection because of varying degrees of seat rigidity and installation configurations. Thus, contrary to what you may have been told, manufacturers who provide belt systems with distances greater than six inches do so by choice and not because they are required to do so by Federal standards.; Thank you for informing us of your problem. Sincerely, Elwood T. Driver, Acting Associate Administrator fo Rulemaking;

ID: aiam3635

Dear Mr. Tashima: This responds to your recent letter asking whether various vehicl seating designs being considered by your company would qualify as auxiliary seating positions and not be subject to the Federal motor vehicle safety standards. These seats would be installed in extended-cab pick-up trucks behind the driver's and front passenger's seats and would include storage space beneath the seating accommodation.; A seating accommodation is subject to the vehicle safety standard (e.g., Standards Nos. 207, 208) if it qualifies as a 'designated seating position'. That term is defined in 49 CFR 571.3 as:; >>>'any plan view location capable of accommodating a person at leas as large as a 5th percentile adult female, if the overall seat configuration and design is such that the position is likely to be used as a seating position while the vehicle is in motion, except for auxiliary seating accommodations such as temporary or folding jump seats....'<<<; In our opinion, most of the seat designs included in your illustration would be considered to be designated seating positions. We would not consider the seats to be 'auxiliary seating accommodations' since, as you stated in meeting with us, they would be present as a cushioned seat a majority of the time, i.e., without having to fold the seats down or move them around as is necessary with a temporary jump seat. The fact that the seats are not 'auxiliary' is further evidenced to a certain extent by the fact that the cab of the pick-up trucks would be extended to accommodate the seats so that four persons could ride inside the vehicle. You do not suggest that the cab would be extended for the primary purpose of providing the small amount of storage space that would be beneath these seats.; In your illustrations, seat designs A, B, C, F, G, and H have a overall seat configuration such that the position is likely to be used as a seating position while the vehicle is in motion. Your designs D and E may be somewhat less likely to be used as seats since design D does not have a cushion (just a board) and design E does not have a seat back. If these two designs were combined, i.e., no seat back and no seat cushion, the agency would consider the positions to be auxiliary seating positions. It is possible that either design D or E alone might also be considered to be an auxiliary seating position, depending on the agency's assessment of the seat together with the total passenger compartment design. I would like to emphasize, however, that it is the responsibility of the manufacturer to determine whether or not its vehicles are in compliance with all applicable safety standards and to certify that compliance. Therefore, your company would have to make its own determination concerning whether any of these designs would qualify as designated seating positions. The agency can only offer its opinion based on the information supplied in your letter. The agency would make its own final determination only during an enforcement investigation involving a certified vehicle.; You also asked the following general questions regarding all of th designs illustrated in your letter: are seat belts required, is seat size a factor in determining whether a seat is auxiliary, and is there a distinction in the determinations if a bench seat is used instead of two separate cushions? As mentioned earlier, seat belts are required if a particular accommodation is determined to be a designated seating position. Seat size is a factor in determining whether a particular position is a designated seating position to the extent that the definition of that term specifies, as a threshold, a space capable of accommodating at least a 5th percentile adult female (your letter notes that all your designs are capable of accommodating a 5th percentile adult female). Whether or not a particular position is designed as a bench seat or as separate cushions is generally irrelevant to the determination of whether the seat qualifies as a designated seating position.; I hope this has been responsive to your inquiry. Please contact Hug Oates of my staff if you have any further questions (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel

ID: nht80-3.44

DATE: 08/29/80

FROM: FRANK BERNDT -- CHIEF COUNSEL, NHTSA; SIGNATURE BY STEPHEN P. WOOD

TO: Aston Martin Lagonda (1975) Limited

TITLE: FMVSS INTERPRETATION

TEXT: I have in hand your letter of July 31, 1980, and regret to inform you that the vehicle identification number (VIN) scheme which you propose is apparently not in compliance with U.S. Federal Motor Vehicle Safety Standard No. 115.

S4.5.2 and Table 1 of Standard No. 115 provide that the following information shall be decipherable from the five characters comprising the second section of the VIN for passenger cars: Line, Series, Body Type, Engine Type, Restraint System Type. A review of your Engineering Instructions and the accompanying drawings do not provide information concerning either the engine type or the restraint system type. Likewise, it is not clear whether your model designation is more appropriately characterized as line and/or series.

If the information omitted remains constant throughout a particular model, it will only be necessary for you to so state when deciphering your model code. For example, the following would be permissible:

Position 5 and 6: "V8" means V8 Volante model LHD, seat belt manual restraint system, V-8 engine with a displacement of 5.3 liters/326 cubic inches, a compression ratio of 8.3 and a net brake horsepower of .

We would also call to your attention that gross vehicle weight class is not required to be encoded in the VIN, although you are free to do so if you so choose.

Amongst the material furnished to the agency were drawings indicating the location of your confidential chassis identification number. As these are not required to be forwarded to the agency, I have taken the liberty of destroying them.

SINCERELY,

ENCLS.

ASTON MARTIN LAGONDA (1975) LIMITED

Frederic Schwartz Officer of the Chief Counsel, N.T.S.A.,

JULY 31, 1980

Dear Mr. Schwartz,

Vehicle Identification Numbering (17 characters)

Please find enclosed details upon which the Aston Martin Lagonda (1975) Ltd.

company has based its vehicle identification number (VIN) system, to be introduced with our 1981 model year cars.

The following documents have been enclosed to help clarify and explain the construction of the VIN system in detail:

(a) Construction drawings B97-16204/5/6 apply to Aston Martin V8 Saloon, Volante and Vantage (LHD) models respectively, B97-16224 applies to the Lagonda (LHD) (not currently certified in USA).

(b) Engineering Instruction number 205 gives a detailed explanation of the VIN construction. Engineering Instructions are sent to various departments within the Aston Martin organization and act as a reference and guide upon which work is carried out.

(c) Drawings A97-16226 and A97-16544 show the VIN plate designs and locations on the vehicle. The VIN is also stamped on the chassis member in characters with a minimum height of 7 mm (0.28 inches), Figures 1 and 2 in Engineering Instruction 205 show the location.

We have not sent details of our VIN system to anyone else, therefore we would appreciate your forwarding this letter and its contents to the relevant U.S. department, or advising accordingly.

KINDEST REGARDS,

R. Goldsmith Certification Engineer Safety and Emissions Department

ENGINEERING INSTRUCTION no. 205

Vehicle Identification Number (VIN) Systems

1. INTRODUCTION

AML will soon be operating two distinct Vehicle Identification Number (VIN) systems, one system applying to cars sold to U.S.A. and Canada and the other system applying to cars sold elsewhere in the world.

2. U.S.A. AND CANADA VIN SYSTEM (NHTSA)

1981 and subsequent model year cars sold to U.S.A. and Canada are required to have a 17 (seventeen) character vehicle identification number assigned. This means a series of arabic numbers and roman letters assigned to each motor vehicle for identification purposes and shall be sans sarif type face with a minimum height of 4 mm.

The VIN shall appear clearly and indelibly (i.e. stamped) on:

(a) the vehicle certification label (i.e. the brass plate, part number A97-13074, fixed to left hand 'B' post), and

(b) the VIN label part number A97-16226 and fixed in the same manner and position as the superceded label, part number 071-50-0160, on the dashboard.

2.1 VIN Content and Structure The VIN content and structure is as follows:

STRUCTURE

RACTER POSITION

1)

2) Assigned by BSI

3)

4) Gross vehicle weight class. 'C' = 4001 to 5000 lbf 'D' = 5001 to 6000 lbf

5)

6) Model

7 Not used

8 Model variant

9 Check digit (see R.G.'s memo for detailed explanation)

10 Model Year. 'A' = 1980

11 Plant of manufacture. 'T' = Tickfords

12 Driving position. 'T' = (Illegible Words) A = 1 J = 1 T = 3 B = 2 K = 2 U = 4 C = 3 L = 3 V = 5 D = 4 M = 4 W = 6 E = 5 N = 5 X = 7 F = 6 P = 7 Y = 8 G = 7 R = 9 Z = 9 H = 8 S = 2

VIN: S C F C V 8 0 S A Assigned value: 2 3 6 3 5 8 0 2 0 1 Weight factor: 8 7 6 5 4 3 2 10 0 9 Product: 16 21 36 15 20 24 0 20 0 9

2.1.1 World Manufacturers Identifier (WMI) Section

The WMI section is located in character positions 1 to 3 inclusive and is assigned by B.S.I. The code for all our models is SCF.

2.1.2 Vehicle Description Section (VDS)

The VDS is located in character positions 4 to 8 and is assigned by the manufacturer within the constraints laid down in the USA Federal Register, volume 44, number 57.

2.1.3 Vehicle Indicator Section (VIS)

The VIS is located in character positions 10 to 17 inclusive and is also assigned by the manufacturer within the constraints in the Federal Register.

2.1.4 The Check Digit

The check digit shall be determined and included in the VIN for each car sold to North America and Canada. It is determined by carrying out a mathematical computation that utilises each of the VIN characters according to the following formula:

(a) Each alphabetic character is assigned a numeric value according to the following table:

(b) The assigned value for each character is then multiplied by a weight factor that is dependent on VIN character position, see worked example below.

(c) The products are then added together and the sum divided by 11.

(d) The check digit is the remainder of the division, when this is 10 the check digit is X; when zero the check digit remains zero.

Worked example

VS Saloon (LHD) with assumed chassis number 12456 VIN: T L 1 2 4 5 6 Assigned value: 3 3 1 2 4 5 6 Weight factor: 8 7 6 5 4 3 2 Product: 24 21 6 10 16 15 12

Sum of products = 265, divide by 11 = 24 1/11

*Thus the check digit = 1 (to be inserted in ninth character of VIN)

2.1.4.1 Check Digit - Simplification

Because many of the VIN characters are common to each model the check digit

The scheme works thus:

(a) The Intermediate Check Digit remains constant for each model variant.

(b) Having allocated the sequential chassis number, multiply each digit by its weight factor and add these products to find the sum.

(c) Referring to Table 1(a), line-up the appropriate Sum and read across to the next column for the Sequential Number Check Digit (SCD).

(d) Next, refer to Table 1(b), and in the first column line-up the Sequential Number Check Digit, then line-up the Intermediate Check Digit; the point where the column and rows intercept is the corresponding VIN Check Digit.

(e) A worked example of the simplified Check Digit determination is shown below.

V8 SALOON APPROX. LHD

VIN Prefix Sequential Chassis No.

SCFCV80S ATL12678

4 3 2

Sum = 61 = 24+21+16

Sequential No. Check Digit = 6 [From Table 1(a)]

Intermediate Check Digit = 2

VIN Check Digit = 8 (Illegible Words)

(f) A summary of the Intermediate Check Digits for our model range is listed below: Model Driving Intermediate Instruction Drawing position Check Digit Number V8 Saloon Left HD 2 B97-16204 " Right HD 0 B97-16211 V8 Volante Left HD 5 B97-16205 " Right HD 3 B97-16212 V8 Vantage Left HD - B97-16206 " Right HD 8 B97-16213 Lagonda Left HD 4 B97-16224 " Right HD 2 B97-16225

* APPLICABLE (Illegible Words) VIZ (Illegible Words)

3. VIN SYSTEM - BEST OF THE WORLD (i.e. not applicable to USA or Canada)

The vehicle identification number (VIN) section on the brass plate, part numbers A97-15564/5 applicable to the Lagonda and V8 models respectively, will be completed by AML using the current sequential chassis numbering system. The plates will be embossed using stamps with a character of 4 mm minimum height. There will be no gaps or marks between the characters. The number will be finished with a dash, again without a gap, similar to the start of the number as shown in drawing A97-15564/5.

The chassis numbering (VIN) system is as follows:

(a) Lagonda : -LOOR13XXX-

(b) V8 Saloon : -V8SOR12XXX-

(c) V8 Volante : -V8COR15XXX- and (d) V8 Vantage : -V8VOR12XXX-

3.1 Lagonda VIN Structure Lagonda VIN Structure CHARACTER POSITION 1 -L Model 2 0 Not yet designated 3 0 Not yet designated, but J to be used for cars sold to Japan 4 R R = Right hand drive; L = Left hand drive 5 1) Chassis number model variant prefix 6 3) 7 X) 8 X) Sequential chassis number 9 X-

3.2 V8 VIN Structure V8 VIN STRUCTURE CHARACTER POSITION 1 -V) Model 2 8) 3 S,C or V Variant, i.e. S = Saloon; C = Convertible & V = Vantage 4 0 Not yet designated, but 'J' to be used for care sold to Japan 5 R or L R = Right hand drive; L = Left hand drive 6 I) Chassis number model variant prefix 7 2 or 5) 8 X) 9 X) Sequential chassis number 10 X-

3.3 Location of VIN Chassis Stamping

Bearing in mind the points outlined in 3. above, the VIN will also be stamped in the RHS of the chassis in the locations indicated in Figures 1 and 2 applicable to the Lagonda and V8 models respectively. The character heights shall be a minimum 7 mm high, and the number shall be legible when the car is completed and ready for sale, i.e. not covered by underseal.

APPROVED BY: S. COUGHLIN

PREPARED BY: A. GOLDSMITH

SAFETY & EMISSIONS: J. D. ORCHARD

Table 1

(a) Sequential No. Check Digit (SCD) Sum SCD Sum SCD Sum SCD 1 1 36 3 71 5 2 2 37 4 72 5 3 3 38 5 73 7 4 4 39 6 74 8 5 5 40 7 75 9 6 6 41 8 76 10 7 7 42 9 77 0 8 8 43 10 78 1 9 9 44 0 79 2 10 10 45 1 80 3 11 0 46 2 81 4 12 1 47 3 13 2 48 4 14 3 49 5 15 4 50 6 16 5 51 7 17 6 52 8 18 7 53 9 19 8 54 10 20 9 55 0 21 10 56 1 22 0 57 2 23 1 58 3 24 2 59 4 25 3 60 5 26 4 61 6 27 5 62 7 28 6 63 8 29 7 64 9 30 8 65 10 31 9 66 0 32 10 67 1 33 0 68 2 34 1 69 3 35 2 70 4

(b) VIN Check Digit

Intermediate Check Digit (Illegible Table)

ID: nht76-5.13

DATE: 04/27/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Blue Bird Body Company's March 22, 1976, request for interpretation of the provision of Standard No. 217, Emergency Exits, that requires unobstructed passage of a described parallelepiped through the opening provided by an open rear emergency door in the case of a school bus with a gross vehicle weight rating of more than 10,000 pounds (S5.4.2(a)). The dimensions of the parallelepiped are 45 inches by 24 inches by 12 inches, and it is oriented so that the 45-inch dimension is vertical, the 24-inch dimension is parallel to the opening, and the lower surface is in contact with the bus floor.

You point out that "unobstructed passage" through the opening could be considered to occur when the rearmost surface of the parallelpiped coincides with a vertical transverse plane that intersects the outer surface of the bus body at either the top or the bottom of the opening, or intersects the inner surface of the bus body at either the top or the bottom of the opening.

The NHTSA considers unobstructed passage of the parallelepiped to occur when its rearmost surface coincides with the vertical transverse plane that intersects the outer surface of the bus body at the bottom of the opening in question. Thus, your intention to assure compliance by measuring unobstructed passage at the point when the rearmost surface is flush with the bus body outer surface appears justified. The agency does not consider the bus body outer surface to include rub rails or trim materials for purposes of this measurement.

YOURS TRULY,

BLUE BIRD BODY COMPANY

March 22, 1976

Richard B. Dyson Assistant Chief Counsel National Highway Traffic Safety Administration

SUBJECT: FMVSS 217, PARAGRAPH S5.4.2a, EFFECTIVE OCTOBER 26, 1976

This paragraph specifies a rectangular parallelepiped 45 inches high, 24 inches wide, and 12 inches deep. We need an interpretation as to the reference point from which the 12" dimension should be measured. The four alternatives are:

1. From outside body at floor level.

2. From inside body at floor level.

3. From outside body at top of parallelepiped.

4. From inside body at top of parallelepiped.

As you can see from the enclosed photograph, the measuring point can make several inches difference depending on where it is located.

Because time is so important to us in complying with this standard and several others, we have made a decision to proceed based on measuring the 12" at the floor level with the rear surface of the parallelepiped flush with the outside surface of the body as shown in the enclosed photos. If this interpretation is not valid, please call us immediately. We shall look forward to your early written confirmation of this interpretation.

Thanks for your attention to this matter.

W. G. Milby Staff Engineer

(Graphics omitted)

ID: aiam0614

Dear Mr. Maty: Thank you for your letter of February 16, 1972, to Secretary Joh Volpe, concerning the length of seat belts in a 1972 Cadillac automobile.; Federal Motor Vehicle Safety Standard No. 208 Occupant Cras Protection, copy enclosed, specifies requirements for occupant restraint systems. Effective January 1, 1972, car manufacturers are required to provide Type 2 belt assemblies (lap-shoulder belts) at the front outboard seating positions and lap belts at other positions. The Type 2 belt assemblies may have either integral or detachable shoulder belts, but the distance between the intersection of the lap- shoulder belt and the vertical centerline of a 50th-percentile adult male occupant must be at least six inches when the seat is in its rearmost position. The purpose of this requirement is to reduce the possibility of the shoulder belt pulling the lap belt up onto the occupant's abdomen where it could cause serious injury in a crash.; We have examined several 1972 model cars and have found that som manufacturers have chosen belt designs that provide distances of ten inches or more between the lap-shoulder belt intersection and the centerline of the occupant. The standard does not prohibit distances greater than six inches, but it is obvious that the greater this distance, the closer the inboard end of the belt is to the seat and the more difficult it is to buckle the belt. I am happy to inform you that we have already initiated rule making action to amend Standard No. 208 that would prohibit such excessive distances.; Under the requirements of the National Motor Vehicle and Traffic Safet Act, copy enclosed, it is a violation of the law to sell a vehicle that does not conform to an applicable standard. Although the Act does not prevent the purchaser of a vehicle from altering or removing a safety device, after he has completed the purchase, we strongly advise him against such action. A dealer who performs such services after he has sold the vehicle does not violate the law, but he does his customer a disservice.; In regard to the belts in the Cadillac you sold to Mr. and Mrs. T Albert McCulley, we do not have the authority to grant or deny you permission to lengthen the inboard end of the belt. We can only suggest that perhaps you could lengthen the belt only to the extent that is necessary to provide a distance of not less than six inches between the intersection of the lap-shoulder belt and the centerline of a 50th-percentile adult male occupant measured in accordance with paragraph S7.1.2 of Standard No. 208.; Thank you for your interest in motor vehicle safety. If we can be o further assistance, please do not hesitate to contact us.; Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs;