ID: nht74-2.21

DATE: 08/12/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: B. F. Goodrich Aerospace and Defense Products

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your June 4 and June 20, 1974, letters asking if a parking brake system which locks mechanically after the brake is applied by any emergency air supply acting through the service air brake chamber would comply with Standard No. 121, Air brake systems. The parking brake provisions require in part:

S5.6.3 Application and holding. The parking brake shall be applied by an energy source that is not affected by loss of air pressure or brake fluid pressure in the service brake system. Once applied, the parking brakes shall be held in the applied position solely by mechanical means.

The arrangement described would not meet this requirement because the energy source to apply the brakes (the emergency air supply) would be affected by loss of air pressure in the service brake system. For example, any failure in the service brake piston diaphragm would cause a loss of air pressure that would in turn "affect" the energy source that applies the parking brakes. The brake chamber housing assembly is an element which is not considered to be part of the service brake system for this requirement.

I would like to point out that the provisions of Standard No. 121 do not apply to trailers manufactured before January 1, 1975.

Your truly,

ATTACH.

June 4, 1974

CHIEF COUNCIL -- U. S. Department of Transportation National Highway Traffic Safety Administration

Dear Sirs:

The following inquiry is submitted to you with regards to telephone conversations with Mr. S. F. Williams on Friday afternoon, May 31, 1974, and Monday morning June 3, 1974.

Will MVSS 121 permit actuation of a mechanically locking parking and/or emergency brake, using air that is applied to the service brake diaphragm?

The air is supplied, of course, from an isolated emergency source.

Yours truly, B. F. GOODRICH ENGINEERED SYSTEMS COMPANY A Division of The B. F. Goodrich Company;

A. J. Burt -- Sales Engineer

CC: S. F. Williams, D.O.T.; R. D. Buehler, B. F. Goodrich, Washington D. C.; C. R. Collins, B. F. Goodrich, Springfield, Virginia

B. F. Goodrich Aerospace and Defense Products

June 20, 1974

S. F. WILLIAMS -- U. S. Department of Transportation, National Highway Traffic Safety Administration

Dear Sid:

Relative to our phone conversation this afternoon, attached is a copy of all the technical information we have concerning the Park-Lock brake.

The Park-Lock people that we talked to in February of this year were Mr. Joe D'Angelo and Mr. Paul Mantle.

I should note that my inquiry to the Chief Council dated June 4, 1974 and copied to you, is meant to be interpreted as a generalized question concerning the use of a service brake diaphragm. The "mechanically locking parking and/or emergency brake" was not meant to refer specifically to the "Park Lock" device, but any general device which would require actuation by emergency air applied to a service brake diaphragm, and then mechanically locking once the actuation stroke is completed.

Yours truly,

A. J. Burt -- Sales Engineer, Highway Products

CC: R. D. Buehler -- B. F. Goodrich, Washington, D.C.; C. R. Collins -- B. F. Goodrich, Springfield, Virginia

Park-Lock

(Illegible Word) PARK LOCK?

Park Lock is an Automatic Brake Holding Device that holds your brakes, once applied . . . A New Friend to the Trucks.

WHAT DOES PARK LOCK DO?

Park Lock prevents trailer roll offs; climinates wheel chocking; prevents release of brakes when service system air pressure is below safe operating level.

HOW IS PARK LOCK APPLIED?

In emergency conditions, such as loss of air, the Relay Emergency Valve applies your brakes. . . As the air leaks off, Park Lock gently applies, automatically, and holds your brakes by mechanical means.

HOW IS PARK LOCK RELEASED?

There are two ways to release Park Lock.

1. With the application of air, Park Lock releases automatically.

2. By mechanical means. No special wrench is required. Pliers, screw-driver or coin can be used.

IS PARK LOCK SAFE?

Park Lock is a true safety device. Any child can dismantle it without danger (no explosion hazard).

DOES PARK LOCK WORK ON EQUIPMENT PRESENTLY IN USE?

(Units in service prior to S-121 and September 1, 1974)

Park Lock can be installed on all trailers, new and used. The Relay Emergency Value and air tank, currently on all trailers, applies your brakes. Park Lock holds your brakes mechanically, thus preventing trailer roll-offs.

IS PARK LOCK DURABLE?

The Park Lock casting is made of especially treated aluminum, for long, tough wear. Park Lock has four movable parts that include a special brake rod. Park Lock is mounted on your present brake chamber and plumbed into the Relay Emergency Value. Installation is easy and simple. The Park Lock weighs about two pounds.

PARK LOCK AND S-121 (After September 1, 1974)

Park Lock passes all requirements under S-121, pertaining to both parking brakes and emergency brakes for your trailers. It is used in conjunction with a Relay Emergency Value and air tank (same tank used under S-121 to release the spring brake).

Park Lock works in conjunction with your New Anti-Skid Braking System and allows you to come to a complete anti-skid stop. This is accomplished by plumbing the air (emergency mode) back through the anti-skid computer valve.

Park Lock can be released from the tractor cab by the same method used to release the spring brake. As required by S-121, Park Lock has a manual release that can be released from the unit.

HOW DOES PARK LOCK SAVE YOU MONEY?

Park Lock eliminates trailer roll-off accidents. This will reduce insurance claims. . . thus reduce insurance premiums.

Park Lock virtually eliminates replacement costs. There are few moving parts.

The sole function of Park Lock is to hold your brakes, once applied; therefore there is virtually no wear on the units.

Park Lock requires very little maintenance, which eliminates down time.

Park Lock eliminates wheel-chocking and need for expensive chocks, chains, and locks.

Park Lock protects your landing gears. No more damage to the landing gear caused by hooking the tractor to the trailer, running fork lifts into the trailer while loading, etc.

(Illegible Words) FIND OUT MORE ABOUT PARK LOCK?

For more information about Park Lock write or call

PARK LOCK, INC. 8240 C Moberly Dallas, Texas 75272 (214) 381-2237

(Illegible Text)

(Graphics omitted)

INVENTORS

Woller Case William F. Benefield to and communicating with said first bore, the said brake actuating red having a series of rack teeth transversely thereof and operatively extending through said first bore and connected at one end to said power element and connected at its opposite end through a linkage to said brake crank and a spring biased pawl rod in said second bore and a salenoid coil connected into the electrical system of said vehicle and embracing said pawl rod whereby, which said salenoid coil is energized, the pawl rod is operated to (Illegible Word) the rack teeth on said brake actuating rod and restrain the same in position to set the brakes.

2. In a brake getting mechanism, as described in claim 1, the said spring actually biasing the pawl rod in retracted position to (Illegible Words) said pawl rod being extended to engage said brake actuating rod by said solenoid against the tension of said spring.

3. In a device as described in claim 1, and a collar on said pawl rod for adjusting the tension of said compression spring.

(Illegible Line)

UNITED STATES PATENTS

(Illegible Table)

GEORGE E. A. HALVOSA, Primary Examiner

UR Ct. XR 74-503; 192-3; 188-163

ID: 1969truck

Mr. John Dunn
1392 Webb Rd. Apt. 28
Lakewood, OH 44107

Dear Mr. Dunn:

This is in response to your recent inquiry regarding requirements for seat belts in light trucks. Specifically, you ask if Federal regulations required 1969 model year pickup trucks to be equipped with seat belts. The answer to your question is no.

Some background information about our agency may be helpful. The National Highway Traffic Safety Administration (NHTSA) is authorized under Title 49, Chapter 301 of the U.S. Code to issue Federal motor vehicle safety standards that set performance requirements for new motor vehicles and new items of motor vehicle equipment. Federal law prohibits the manufacture or sale of any new motor vehicle or new item of motor vehicle equipment which does not conform to all applicable Federal motor vehicle safety standards.

One of the standards that NHTSA has issued is Standard No. 208, Occupant Crash Protection (49 CFR 571.208), which specifies occupant protection requirements based on vehicle type and seating position within the vehicle. The requirements for trucks with a GVWR of 10,000 pounds or less, which have since been amended, originally required that trucks in this weight category manufactured on or after July 1, 1971, must be equipped either with an automatic occupant protection system or a Type 1 (lap) or Type II (lap and shoulder) seat belt at each designated seating position. As your 1969 model year truck was built before January 1, 1972, it was not required to have seat belts at any seating position.

I hope that this is responsive to your inquiry. If you have any questions, please contact Otto Matheke of my staff at 202-366-5253.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:208
d.10/21/99

ID: nht91-7.2

DATE: November 7, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Marc M. Baldwin -- Parker, McCay & Criscuolo

TITLE: None

ATTACHMT: Attached to letter dated 9-25-91 from Marc M. Baldwin to NHTSA

TEXT:

This responds to your September 25, 1991, letter in which you asked "the specific date when 2-point seatbelts were outlawed." Lap, or 2-point, belts have never been outlawed by this agency. Rather, 3-point, or lap/shoulder belts have been required at certain seating positions in certain vehicles. Lap belts are still permitted as the only occupant restraint at a seating position in all vehicles at some seating positions. Such seating positions include all seating positions that are not outboard seating positions and all seating positions that are not forward-facing. Your letter mentioned that you are specifically interested in this information for pending litigation regarding a 1984 passenger car convertible. Passenger car convertibles manufactured in 1984 were permitted to have lap belts installed at all seating positions. The following discussion should clarify NHTSA regulations regarding safety belts.

S4.1.2 of Standard No. 208 gives vehicle manufacturers a choice of three options for providing occupant crash protection in passenger cars. Option 1, set forth in S4.1.2.1, requires vehicle manufacturers to provide automatic protection at the front outboard seating positions, lap or lap/shoulder safety belts at all other seating positions, and either meet the lateral crash protection and rollover requirements by means of automatic protection systems or have manual safety belts at the front outboard seating positions such that those positions comply with the occupant protection requirements when occupants are protected by both the safety belts and the automatic protection. Option 2, set forth in S4.1.2.2, requires vehicle manufacturers to provide a lap or lap/shoulder safety belt at every seating position, have automatic protection for the front outboard seats, and have a warning system for the safety belts provided. Option 3, set forth in S4.1.2.3, requires the manufacturer to install lap or lap/shoulder safety belts at every seating position and to have a warning system for those belts.

Beginning on September 1, 1986, manufacturers were required to begin phasing-in the installation of automatic restraint systems, such as automatic belts and airbag systems, in their passenger cars. For example, S4.1.3.1 of Standard No. 208 required manufacturers to certify that at Bleast ten percent of their passenger cars manufactured on or after September 1, 1986, and before September 1, 1987, complied with S4.1.2.1. S4.1.3.2 required 25 percent of passenger cars manufactured on or after September 1, 1987, and before September 1, 1988, to comply with S4.1.2.1, and S4.1.3.3 required 40 percent of passenger cars manufactured on or after September 1, 1988, and before September 1, 1989, to comply with S4.1.2.1.

However, the agency temporarily excluded convertibles from the automatic restraint requirement during the phase-in period. This exclusion meant that convertibles did not have to be counted in the total passenger car production to determine the percentage of total passenger car production equipped with automatic restraints. Instead of automatic restraints, convertibles manufactured prior to September 1, 1989, were allowed to have either a manual lap or lap/shoulder belt at each seating position. All passenger cars, including convertibles, manufactured on or after September 1, 1989, must be certified as complying with S4.1.2.1.

There are also currently requirements for lap/shoulder belts in some rear seating positions in convertibles. Again, however, these requirements would not have applied to the 1984 convertible involved in your litigation. For your information, S4.1.4 of Standard No. 208 includes additional requirements for forward-facing rear outboard seating positions in passenger cars. All passenger cars, except convertibles, manufactured on or after December 11, 1989, were required to have lap/shoulder belts at these seating positions. All convertibles manufactured on or after September 1, 1991, are required to have lap/shoulder belts at these positions.

I hope this information is helpful. If you have any more questions about this issue, feel free to contact Mary Versailles of my office at this address or by telephone at (202) 366-2999.

ID: nht78-3.37

DATE: 07/19/78

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Mr. Robert Hoppe

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your letter of May 3, 1978, in which you request a determination as to whether the three-wheeled motor vehicle which you are designing is a "motorcycle" or an automobile ("passenger car") for purposes of complying with federal motor vehicle safety standards.

The vehicle falls within the definition of "motorcycle" set forth in regulations under the National Traffic and Motor Vehicle Safety Act of 1966:

"Motorcycle" means a motor vehicle with motive power having a seat or saddle for the use of the rider and designed to travel on not more than three wheeles in contact with the ground. (49 CFR Part 571.3(b))

Accordingly, the vehicle would have to meet the requirements of safety standards applicable to motorcycles. I have enclosed an information sheet explaining where you can obtain federal standards and regulations.

I want to point out that in April 1974, this agency proposed a revision of the above definition of "motorcycle" under which this term would be limited to two-wheeled motor vehicles and to three-wheeled motor vehicles with handlebars and no passenger enclosures. I have enclosed a copy of this proposal. However, in view of the time that has elapsed since the proposal was issued, the agency has decided not to issue a final rule on this subject without providing another opportunity to comment.

SINCERELY,

Office of Chief Counsel Nat'l Highway Traffic Safety Admin.

May 3, 1978

Gentlemen:

Enclosed is a drawing of a small vehicle I am presently designing. Would you please give me a determination as to whether it is a motorcycle or an automobile? I realize that if I only build a single car I won't have any trouble making it street legal, however if I want to produce it in quantity it will have to comply with the various safety laws. Obviously having definite knowledge of which safety laws I will have to comply with is basic to the design.

It is a three wheel vehicle. The single wheel in the rear is driven by the engine, the two front wheels steer. It will hold a single occupant who will sit in an automobile type seat and will steer with a normal steering wheel. Entry/exit is by a single gull wing type door on the left side. The windshield will be safety glass, provided with windshield wiper and defroster. Two headlights, tail lights, brake lights and turn signals will be included in the design. The frame will be welded box tubing with independent front suspension using motorcycle spring over shock absorbers. The wheels and tires will be standard 4.00 x 18 motorcycle. The fully enclosed body will be fiberglass. It will have a rear mounted motorcycle engine and standard swing arm. The engine will be a water cooled "V"-twin of 500 C.C. displacement and uses an enclosed shaft drive to the rear wheel.

My purpose is to produce an extremely economical commuter vehicle which will get one man and his briefcase back and forth to work as comfortably and as swiftly (55 mph) as a modern car while getting 100 miles per gallon of gas. I believe there will be an urgent need for such a vehicle in the near future.

A swift determination and any other information you can give me will be greatly appreciated.

SINCERELY,

Robert Hoppe

(Graphics omitted)

ID: nht76-4.39

DATE: 11/10/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Solar Control Products

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your September 22, 1976, letter regarding the use of "Solar Control Reflective Films" in motor vehicles. You asked several questions concerning the applicability of Federal requirements to the manufacture and sale of your "Scotchtint" protective film.

I am enclosing a copy of a letter to Mr. Mark T. Lerche from this agency that discussed the applicability of Federal requirements to his company's "Madico" solar protective film. The discussion in that letter is equally applicable to "Scotchtint" protective film and should answer your questions. The main point to be noted is that these protective films that are attached to glass are not "glazing" themselves and, therefore, the requirements of Federal Safety Standard No. 205 are not applicable to the manufacture of the film. It is the responsibility of the manufacturer, dealer, or vehicle repair business that applies the film to ensure that glazing remains in compliance with the standard. Of course, if your company applies the film to any glazing you would fall in this same category.

It is laudable that your company is interested in ensuring that its film is not used in a manner that would be detrimental to the safety of the motoring public. Although it is not your responsibility to do so, a safety warning to your consumers that "Scotchtint" should not be placed on vehicle glazing in "areas requisite for driving visibility," would be helpful.

We appreciate your interest in motor vehicle safety.

SINCERELY,

Industrial Tape Division

September 22, 1976

Frank Berndt Acting Chief Council National Highway Traffic Safety Administration

Subject: Usage of Solar Control Reflective Films in Vehicles

Our organization is presently manufacturing sun control films under the brand name "SCOTCHTINT".

When originally invented and taken to the marketplace the products were designed and intended for application to existing window glass for the purpose of reducing the transmission of heat, glare and ultraviolet light.

Following the introduction of the original product concept, additional product variations have been developed in response to specific customer/market demand with the result that today there is a family of products marketed.

An assortment of technical and promotional literature on our products is enclosed for your reference.

In the marketing of our products we have taken the position that the application of "SCOTCHTINT" Brand Films to automobiles is not recommended and our dealer applicator training and consumer do-it-yourself literature stipulate this fact. However, the demand for a sun control film has been increasing, particularly for recreational vehicles. We are also aware that other manufacturers of reflective films are implementing aggressive programs to sell their products in the automotive/recreational van market areas. All of this activity causes us to re-evaluate our own position.

We have been soliciting information and assistance from various sources and take this opportunity to review with you our understanding and ask for your verification and/or clarification:

1) It is our understanding that if we actively promote the sale of sun control films to vehicle manufacturers, then we must determine whether the products being offered are in compliance with Section 108 of the National Traffic and Motor Vehicle Safety Act of 1966. This would apply to visible light transmittance, abrasion resistance, etc.

2) If the products are marketed to automotive refinish shops, the same conditions would apply as to selling to the automotive manufacturers in that an automotive refinish shop may only use products that are in compliance with the act cited above.

3) Insofar as the after-market is concerned, i.e. selling directly to the consumer for self-application, the above act does not apply.

To elaborate on points 1 and 2 we further understand that compliance must be determined by the manufacturer and should compliance be challenged or questioned by the Office of Standard Enforcement, then they would have the product evaluated by an independent agency or laboratory. Should it be found that the manufacturer is not in compliance they would be cited accordingly and appropriate fines would be levied.

Should we promote the sale of reflective films for the after-market, we should do so with the stipulation that the film should not be applied to the windshield or front side windows of any vehicle, be it automobile or recreational van. However, application is permissible, and legal under Federal law, on rear side windows and on the rear window so long as the vehicle has an outside rear view mirror.

We visualize a fairly good sales potential in recreational vehicles, such as trailers and self-contained units, if we restrict application to rear side windows and rear windows. We know that a need exists for our product and that our products will make a contribution not only in passenger comfort, but also in the area of energy conservation, i.e. air conditioning equipment will function more efficiently and reduce fuel consumption.

We want to approach this market in an ethical manner, and therefore, respectfully request your guidance.

Your prompt response to this letter and your cooperation will be sincerely appreciated.

M. P. McNiff, Global Market Planning Manager Solar Control Products

dc: D. ALLEN G. A. BERGER; J. R. BERG; T. J. SCHEUERMAN

ID: aiam3854

Dear Mr. Kawano: This letter replies to your request for an interpretation of FMVSS No 202, *Head Restraints*. Your first question concerns the measurement of the lateral width of a head restraint with a 'Volvo-type configuration.' The drawing attached to your letter appears to depict an adjustable head restraint with a rectangular shape and a hollow center. Paragraph S4(b) of Standard No. 202 requires measurements, according to S4(b)(1) and (2), to be made when the head restraint is 'adjusted to its fully extended design position.' The lateral width of the head restraint of an individual or bucket seat may be measured either 2.5 inches below the top of the restraint or 25 inches above the seating reference point. These are the only two locations at which this measurement may be made. The lateral width may not be measured at part B on your drawing, because B is not the correct location at which to make this measurement. A copy of this drawing is enclosed for your convenience.; Your letter and drawing indicate a concern that, if the lateral widt is measured 2.5 inches below the top of the restraint, the hollow space between the two sides of the rectangular head restraint may not be included in measuring the total width. Using the information you have supplied, we believe that the lateral width of this type of head restraint, measured either 2.5 inches below the top of the restaint or 25 inches above the seating reference point, would include the hollow space, if the hollow space occurs at either location. The lateral width would also include, of course, the widths of both sides of this restraint, marked A1 and A2 in your drawing. This lateral width may or may not equal the width, B, located at the top of the restraint in your drawing.; Your second question regarding the correct demonstration procedure t test compliance with Standard No. 202 is answered by the language of paragraph S5.2 of the standard. This paragraph states that, if the head restraint conforms to S4(b), compliance is demonstrated in accordance with S5.2 with the head restraint in its fully extended design position. The dynamic testing procedure would not be required, unless your head restraint conforms to paragraph S4(a). The manufacturer has the option of designing a head restraint which meets the performance requirements of either paragraph S4(a) or paragraph S4(b).; Sincerely, Frank Berndt, Chief Counsel

ID: nht74-5.47

DATE: 04/22/74

FROM: AUTHOR UNAVAILABLE; James B. Gregory; NHTSA

TO: American Safety Equipment Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 3, 1973, petitioning for amendments to paragraphs S4.9 and S5.3.1 of Motor Vehicle Safety Standard No. 213 which would allow the use of a buckle release mechanism design that requires, before release, some foreshortening of the belt system to reduce the load on the release mechanism. This design cannot meet the existing requirements of S4.9 of Standard No. 213 with the device under load. We wrote to you on August 20, 1973, and on December 17, 1973, requesting additional data. We have not received a response from you to either letter.

We have decided that your petition should be denied. Our objection to the design you wish to employ is that it cannot be released when the belt restraint system is under load. The NHTSA believes, and has adopted its position in Standard No. 213, that a fundamental safety requirement for any occupant restraint release mechanism is the ability to release when it is under a load imposed by the weight of the occupant. In many vehicle crashes restraint systems may be loaded in this fashion when occupants must be removed.

We do not disagree with your argument that mechanisms which release under load may more readily be released by children when release is undesirable. We believe the greater safety problem, however, is presented by designs which are difficult to operate because they require a prior unloading of the release mechanism. These systems may not be able to be released, even by adults, in crash situations. Data we have received indicates substantial difficulty in the ability of adults to release a child from a child seat in situations (total darkness) simulating emergencies. The study in question has been conducted by the National Swedish Road and Traffic Research Institute and is on file in Docket No. 2-15.

Moreover, we believe buckle release mechanisms should be operable by older child occupants, particularly in situations such as in upside-down configurations where a load is imposed on the mechanism. This purpose is met by the existing requirements of the standard but would not be met were we to grant your petition.

In your petition you argue that even a lower release force does not necessarily mean that the occupant will be able to escape easily from the restraint system. While this may be true, as no requirements are specified in Standard No. 213 regarding ease of belt removal, it is not a justification for increasing the difficulty of operating the buckle release mechanism.

SINCERELY

August 3, 1973

Administrator National Highway Traffic Safety Administration Subject: Petition for Rule Making

Reference: MVSS213, S4.9 and S5.3.1

American Safety Equipment Corporation is a major developer and manufacturer of safety belt restraint systems for automobile manufacturers. American Safety personnel have a great deal of experience designing aircraft and automotive restraint systems, particularly hardware such as buckles, retractors and associated items. The Company has been active since 1966 in the business of designing and producing restraint harnesses and complete seating systems for children in the 20 to 40 pound size range. The Company has been working on development of a new child safety seat since 1970 basing the basic design criteria on dynamic performance under simulated crash testing, while also observing the current static testing regulation. Final testing of prototype models has been completed on the design considered optimum for performance, economy and simplicity of use.

This petition is submitted in accordance with the procedure described in Subpart B Section 553.31. This proposal is to add a performance requirement and test procedure for an occupant harness release mechanism not currently considered by the Child Seating Systems regulation. The mechanism is not of a nature normally classified or described as a "buckle", but for purposes of MVSS213, is being considered a release mechanism.

The proposed additions and revisions to MVSS213 are shown underlined:

S4.9 (b) Release when a force of not more than 20 pounds is applied when tested in accordance with S5.3 expect for systems described by S4.9 (c).

2 (c) Release when a force of not more than 10 pounds is applied when the release mechanism requires foreshortening of the webbing restraint components to activate and is tested in accordance with S5.3.1 (d).

S5.3.1 For forward-facing child seating systems where foreshortening of the webbing restraint components is not required by the release mechanism -

(a) -- unchanged --

(b) -- unchanged --

(c) -- unchanged --

When foreshortening of the webbing restraint components is required to actuate the release mechanism -

(d) Test the system with a 1,000-pound force as specified in S5.1, remove the force completely and then release the mechanism in a manner typical of that employed in actual use.

Photographs are enclosed showing the release mechanism actuation under normal and simulated emergency conditions and a typical testing set-up to determine release force. The application of force to release the occupant harness must simultaneously pull down on the abdominal pad and the shoulder straps thereto attached and upwards under the metal latch. This is very simply described as a "pinching" action of the thumb and first and/or second finger. The shoulder straps are thereby foreshortened and the occupant will be forced rearward (unless lifted or pushed) toward the back surface of the child seat. The hand not activating the release mechanism can be used to move the child's torso away from contact with the restraint straps. The actuation of the release mechanism with the belts in a slackened condition is an easy one-hand operation with a low force requirement.

The performance criteria on which our restraint release mechanism design is based are as follows:

1. The mechanism must be capable of restraining the occupant when the system undergoes dynamic forces of an auto crash without distortion of any kind which could result in a jammed or difficult-to-release condition.

2. Child must not be able to easily release himself.

3. The mechanism must be extremely easy to understand from the standpoint of an adult learning how to actuate. Similarity to current production adult safety belt hardware assures the shortest possible learning time by an adult.

3 These criteria were formulated after studying field experience of consumers and consulting with experienced people in various phases of the child and adult restraint business. This experience indicated to us that -

1. A common possible problem with many child seat harness buckle release mechanisms is that the release mechanisms could be easily actuated by the child occupant. The child is protected only while sitting in the seat with the harness secured.

2. Emergency removal of a child occupant from a wrecked automobile should be accomplished within a minimum time. Emergency removal always involves supporting at least a portion of the child's weight while releasing the harness mechanism. After an accident the child's weight is forced against the restraining straps if the car has overturned or if the car seat back is exerting pressure on the child and/or child's seating system.

3. Restraint harness buckles which have a low release force (even under occupant's weight load) may not completely detach all components of the harness system from the occupant. Such components as shoulder and/or lap belts may remain wholly or partially attached to the buckle and could interfere with the removal of the occupant from the seating system.

Much subjective information from consumers was also evaluated by us to finalize the release mechanism design since it is considered one of the key components of the overall child seating system. Real-world data is scarce on crash performance of child restraint systems, but accident experience is reasonably hypothesized from experience with children and emergency post-crash situations. It is considered reasonable by us that release mechanisms which actuate under the test procedures now in effect are likely to be released wholly or partially be a child prior to a crash. Protection in low speed, as well as high speed crashes, is important and a securely fastened harness is mandatory for protection. Driver distraction by unrestrained children can also cause accidents which is minimized by a release mechanism not easily operable by the child. Supporting the child's weight or otherwise relieving pressure of the child's body from the harness webbing during emergency removal is consistent with a majority of conceivable accident conditions and always would be a requirement with the impact-shield type restraints (no harness) where the occupant would be expected to be wrapped around the impact shield after a crash. Self-removal from a harness restraint under emergency conditions by a child in the 20 to 40 pound age group

4 is not reasonable unless the child is taught expressly for this purpose. In such a case, training in body articulation and hardware manipulation is probably difficult for the proposed release mechanism.

American Safety is planning procurement of the necessary tooling for manufacturing the child seat design incorporating the proposed release mechanism. The proposed child restraint release mechanism and release procedure is nearly identical to the release of the detachable shoulder harness pin-connector in production for adult restraints in certain cars for three years. The pin and plastic grommet used on the child restraint mechanism proposed are parts produced for several different 1973 model cars. The Company requests the addition of the proposed requirements to MVSS213 to permit it to manufacture and sell the child restraint product.

Gordon M. Bradford Vice President, Corporate Development

enclosures

(Graphics omitted)

PHOTOGRAPH NO. 1

Restraint release mechanism -- This general view shows the similarity to the established pin and connector design now in production for shoulder belts on adult restraints. The two straps above the release mechanism are adjustable upper torso restraints. The release mechanism is affixed to the abdominal pad and the adjustable crotch strap is sewn permanently to the release mechanism connector.

PHOTOGRAPH NO. 2

Release mechanism activation -- The initial step in activating the release is as shown. The thumb depresses the abdominal pad and foreshortens the upper torso restraints. The index finger or middle finger holds up the connector while the pin is forced downward.

PHOTOGRAPH NO. 3

Release mechanism activation -- The completion of the releasing operation shows the pin and grommet now moved downward into the enlarged opening of the connector where it is completely separated from the crotch strap and connector. A slight forward pull with the finger finishes the release. The connector is then dropped and the abdominal pad with upper torso straps attached is swung upward over the occupant's head for removal when the seat is situated in a normal horizontal attitude.

PHOTOGRAPH NO. 4

Release force requirements -- A possible form of measurement device which operates the release mechanism in a manner typical of that employed in actual use is shown. This test would be performed after the child seating system had been subjected to a static load of 1,000 lbs in accordance with MVSS213, S5.1. Following this the release force test would be done in accordance with the proposed procedure S5.3.1(d).

PHOTOGRAPH NO. 5

The position illustrated simulates a nose-down car attitude. The child's full weight is resting on the harness. The adult is about to release the harness.

PHOTOGRAPH NO. 6

The adult has pushed upward with her left hand on the abdominal pad. This slackens the crotch strap allowing normal operation of the buckle with her right hand. The load required to release the buckle in this way is no greater than normal.

PHOTOGRAPH NO. 7

The buckle has opened and the adult has begun to lower the child. The abdominal pad has slid naturally from her left to her right hand. Her left hand continues to support the abdomen.

PHOTOGRAPH NO. 8

The adult's right hand continues to guide the abdominal pad while the left hand continues to support the abdomen. The crotch strap is completely clear of the child.

PHOTOGRAPH NO. 9

The child is out of the harness and is now on what would be either the car's dash or front seat back, depending on where the child seat was installed in the vehicle. The harness is clear of the child. No force greater than the child's weight was exerted. There were no "practice" runs after instructions on how to correctly release the child were given to the Mother.

ID: aiam3874

Dear Mr. Berge: This responds to your December 3, 1984 letter to the National Highwa Traffic Safety Administration (NHTSA) concerning the use of Greyhound-type buses to transport school children to school-related activities. You stated that the Mandan Public School District is considering purchasing 1963 and 1965 model year Greyhound-type buses for the purposes of transporting elementary and secondary students to activity events. Your first question asked whether this would be allowed under our regulations on school buses.; To begin, I would like to explain that there are two sets o regulations, issued under different Acts of Congress, that could affect Mandan's choice of buses. The first of these, the motor vehicle safety standards issued by our agency under the National Traffic and Motor Vehicle Safety Act of 1966 (Public Law 89-563, 15 U.S.C. 1381-1426) apply to the manufacture and sale of new motor vehicles. In a 1974 amendment to the Act, Congress expressly directed us to issue standards on specific aspects of school bus safety, including emergency exits, seating systems, window and windshields, and bus structure. The standards we issued became effective April 1, 1977, and apply to each school bus manufactured on or after that date. If Mandan had planned to buy a *new* bus for use as an activity bus, the manufacturer and dealer must certify that the bus complies with the motor vehicle safety standards applicable to school buses.; Since Mandan plans to buy 1963 and 1965 model year buses, however, th Vehicle Safety Act standards do not apply. There is nothing under that Act to prevent Mandan from buying a bus that was manufactured before the effective date of the school bus safety standards for school use. There might, however, be an impediment under State law, if North Dakota has adopted the provisions of the standard on school transportation issued by our agency under the Highway Safety Act (Public Law 89- 564, 23 U.S.C. 401-408). This standard, Highway Safety Program Standard No. 17 (HSPS 17), specifies that a bus used to transport more than 16 pupils to and from school should be painted yellow, be equipped with special mirrors and warning lights, and be marked 'School Bus.' We have ruled that the States should apply these specifications to activity buses as well as to the buses used for daily transportation.; I want to stress that HSPS 17 has no direct effect on Mandan's purchas of 1963 and 1965 model year buses. HSPS 17 will affect Mandan only if North Dakota has adopted it and if North Dakota accepts our view that the specifications apply to activity buses. If North Dakota chooses to exempt activity buses from being painted, signed, and equipped as school buses, we might disagree with the wisdom of its decision but we would not insist on compliance with HSPS 17 to the extent of taking action against the State. Congress has given us discretion under the Highway Safety Act not to insist that a State comply with every requirement of the highway safety standards. While we have stressed the importance of a strong pupil transportation program, consistent with HSPS 17, we have not insisted that the States comply with every feature of the standard.; Having said this, however, I would like to restate the importance tha our agency attaches to the use of safe buses to transport children. It remains the agency's position that a yellow school bus meeting the motor vehicle safety standards is the safest means of transportation for school children. It may not be the most comfortable for long trips, since it lacks the reclining seats and restroom facilities of the Greyhound-type buses, but it has safety features that the Greyhound-type buses that you are considering lack, such as seat backs designed to cushion impacts, windows that prevent ejections, and exits that facilitate escape after crashes. In the years since buses began to be manufactured with these features, there has been a marked improvement in school bus safety. These are features that Mandan should consider before it decides to buy a Greyhound-type bus.; Your second question asked whether Mandan may charter Greyhound-typ buses from a common carrier to transport students to school-related events.; Again, Mandan would not be precluded from chartering Greyhound-typ buses if North Dakota has not adopted our view that the specifications of HSPS 17 apply to activity buses.; If you have any further questions, please do not hesitate to contac us.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam3739

Dear Mr. Fulmer: This responds to your letter asking whether an adapter you plan t manufacture for attachment to child restraint systems must be tested for compliance with Federal Motor Vehicle Safety Standard No. 213, *Child Restraint Systems* (49 CFR 751.213). The adapter you plan to manufacture snaps onto the bottom of the tube frame of child restraints, and unfolds legs and wheels to convert the car seat into a stroller. Your device does not need to comply with the requirements of Standard No. 213. However, you might wish to test it to ensure that it does not constitute a safety-related defect when attached to a child restraint and for purposes of product liability.; Section S4 of Standard No. 213 defines a child restraint system as 'an device designed for use in a motor vehicle to restrain, seat, or position children who weigh not more than 50 pounds.' The stroller adapter you plan to produce is not designed to perform any of these functions, and therefore is not a child restraint within the meaning of Standard No. 213. Because the device is not a child restraint system, it need not comply with any of the requirements of Standard No. 213.; One requirement which might be applicable to the use of your device i set forth in 15 U.S.C. 1397(a)(2)(A), which states 'No manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard...' This could be important if the attachment of your stroller adapter to a child restraint system caused the child restraint system to no longer comply with the requirements of Standard No. 213. It appears from your letter, however, that the purchaser of your device would attach it to a child restraint, and not a manufacturer or dealer. The statutory prohibition is not violated when a purchaser attaches a device to an item of motor vehicle equipment. Hence, if my understanding is correct, this would not present any difficulties for your company.; There are two possible reasons which might lead you to try to test thi adapter to learn if it affects the performance of child restraint systems to which it is attached. First, if the attachment of your adapter causes the child restraint to provide a lower level of safety, or if all or part of the adapter were to separate from the child restraint in a crash situation, the adapter might well be found to contain a defect which relates to motor vehicle safety. Sections 151-154 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1411-1414) require that when an item of motor vehicle equipment contains a safety-related defect, the manufacturer of the item must recall and repair or replace the defective equipment without charge to the purchaser.; Second, you may wish to consult an attorney for advice on potentia product liability issues which would arise from attaching your adapter to certified child restraint systems. It is possible that some testing of your adapter attached to a child restraint system in a crash situation would be helpful in the event of a product liability suit.; Should you need any further information on this subject, please do no hesitate to contact me.; Sincerely, Frank Berndt, Chief Counsel

ID: nht78-4.12

DATE: 11/20/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Volkswagen of America Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 8, 1978, concerning Federal Motor Vehicle Safety Standard No. 115, Vehicle identification number. Since the agency was considering petitions for reconsideration when your letter was received, we concluded that it would be more helpful to respond to your letter after the revised standard was issued. A copy of the amendments to the standard and a copy of a notice of proposed rulemaking to amend the standard are enclosed.

In confirmation of your meeting with Messrs. Carson, Erickson, and Schwartz, you are correct in stating that vehicle description section (VDS) informational content can change from model year, to model year even though the actual characters in the VDS remain the same. All changes in the informational content of the VDS must, of course, be submitted to the NHTSA as required in S6 of the standard.

As you point out in your letter, "dividers" which would appear at the beginning and the end of the VIN would not be considered part of the VIN and, therefore, would not be regulated by the standard. Care should be taken, however, to ensure that the dividers are neither alphabetic nor numeric characters which might be mistaken for part of the VIN.

In your meeting with NHTSA staff, you requested clarification concerning which manufacturer identifier should be used when the vehicle assembly is carried out by one company on behalf of another. In this instance, the manufacturer identifier of the company under whose authority the assembly is carried out and which maintains responsibility for the vehicle's compliance with safety standards should be used. You have also asked for a definition of the term "transfer document." A "transfer document" will vary in content from manufacturer to manufacturer, but means the document(s) given to the owner of the vehicle for use when the vehicle is being titled.

We would also call to your attention proposed changes to the standard contained in the enclosed notice of proposed rulemaking. If the proposed changes are adopted, the check digit would be placed in the fourth position of the VIN, and the first and second characters of the VDS, which immediately follow the check digit, would be alphabetic.

Sincerely,

ATTACH.

Volkswagen of America, Inc.

September 8, 1978

Joseph J. Levin, Esquire -- Chief Counsel, National Highway Traffic Safety Administration RE: VW/NHTSA Meeting on Vehicle Identification Numbers

Dear Mr. Levin:

On September 8, 1978, representatives of Volkswagen of America, Inc. and Volkswagenwerk AG met with Messrs. Carson, Erickson, Parker and Schwartz of the NHTSA to discuss FMVSS 115, the Final Rule on Vehicle Identification Numbers as published in the Federal Register of August 17, 1978.

VW explained that the vehicle identification numbering system it adopts must be compatible with the new NHTSA VIN rule, various international regulations and its own internal purposes. VW indicated that the NHTSA Final Rule had furthered compatibility by changing the position of the VIN check digit from the third to the second section.

VW presented to the NHTSA representatives its proposed concept for fulfilling the requirements of FMVSS 115 including the reporting system (see attachment). NHTSA agreed that the same five digit code within the second section could be used, even if the characteristics of the specific attributes change, for example horsepower or displacement increases from one model year to a new model year. NHTSA also observed that the key used for reporting and deciphering the attributes will consist of the WMI, the five characters of the second section and the model year.

VW described the Common Market directive requiring the use of so-called "dividers" at the beginning and end of the vehicle identification number. These "dividers" are characters which are not part of the VIN and would be in the nature of a star, asterisk or company logo. NHTSA indicated that dividers can be used for vehicles sold in the U.S. provided the VIN is distinct and the divider could not be confused as part of the VIN.

VW requested a clarification as to the meaning of "transfer documents." NHTSA informed VW that "transfer documents" were the official documents needed for titling a vehicle in accordance with state requirements.

VW described the manufacturing process involved in production of its Type 2 Camper vehicle and Scirocco. The Camper's final stage and the Scirocco are assembled by other companies. VW assumes full responsibility for both of these finished vehicles. Therefore, NHTSA agreed that VW's WMI should be used for these vehicles.

We appreciate the willingness of NHTSA to meet with us in order to clarify several aspects of the final VIN rule. It is our intent to institute VIN and reporting systems in accordance with these interpretations by NHTSA.

Sincerely,

Philip A. Hutchinson, Jr. Washington Representative

[Attachment Omitted]