ID: nht94-1.93

TYPE: Interpretation-NHTSA

DATE: March 23, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Richard A. Zander -- AlliedSignal Automotive Proving Grounds (New Carlisle, IN)

TITLE: None

ATTACHMT: Attached to letter dated 5/19/93 from Richard A. Zander to NHTSA Office of Chief Council

TEXT:

This responds to your letter asking about the fade and recovery requirements of Federal Motor Vehicle Safety Standard No. 105, Hydraulic Brake Systems. I apologize for the delay in our response. You noted that the standard requires vehicles with a GVWR of 10,000 pounds or less to be capable of making a specified number of fade stops "at a deceleration not lower than 15 fpsps for each stop." You stated that you are aware of a number of different understandings within the industry of the quoted phrase, and requested an interpretation as to whether vehicles must be capable of maintaining an average deceleration of at least 15 fpsps or a minimum deceleration of at least 15 fpsps. As discussed below, vehicles must be capable of maintaining a minimum dec eleration of at least 15 fpsps.

By way of background information, the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S 1381, et seq.) authorizes the National Highway Safety Administration (NHTSA) to issue safety standards applicable to new motor vehicles and items of motor ve hicle equipment. NHTSA does not, however, approve motor vehicles or motor vehicle equipment. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all appli cable safety standards.

Manufacturers must have some independent basis for their certification that a product complies with all applicable safety standards. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations. Whatever the basis for certification, however, the manufacturer must certify that the product complies with a standard as it is written, i.e., that the vehicle will pass all applicable requirements if it is tested exactly according to the standard's test conditions and other specifications.

Standard No. 105's fade and recovery test requirements are set forth in S5.1.4. These requirements must be met under the conditions prescribed in S6, when tested according to the procedures set forth in S7. See S5.1. The purpose of the fade and recover y test requirements is to help ensure that brakes retain adequate stopping capacity during and after exposure to conditions caused by prolonged or severe use, such as long, downhill driving.

The standard specifies two fade and recovery tests for vehicles with a GVWR of 10,000 pounds or less. Each of the fade and recovery tests consists of three parts: (1) baseline check stops, (2) fade stops, and (3) recovery stops. The requirements for t he fade stops are set forth in S5.1.4.2(a), which states that:

Each vehicle with a GVWR of 10,000 lbs or less shall be capable of making 5 fade stops (10 fade stops on the second test) from 60 mph at a deceleration not lower than 15 fpsps for each stop, followed by 5 fade stops at the maximum dec eleration attainable from 5 to 15 fpsps."

As noted, S5.1.4.2(a) must be read in conjunction with S7.11.2.1, which sets forth the procedure for conducting the fade stops. It reads, in relevant part, as follows:

Make 5 stops from 60 mph at 15 fpsps followed by 5 stops at the maximum attainable deceleration between 5 and 15 fpsps for each stop. ... Attain the REQUIRED DECELERATION within 1 second and, AS A MINIMUM, MAINTAIN IT for the remaind er of the stopping time. Control force readings may be terminated when the vehicle speed falls to 5 mph. (Emphasis added.)

The words "required deceleration" in S7.11.2.1 refer to 15 fpsps. (That value is set forth both in S5.1.4.2(a) and the first sentence of S7.11.2.1.) Thus, in conducting fade stops, within one second of beginning a stop, a deceleration of 15 fpsps must be attained. S7.11.2.1 then specifies that, "as a minimum," the required deceleration (15 fpsps) must be maintained for the remainder of the stopping time. (The word "it" in the highlighted sentence refers back to the phrase "required deceleration.") Thus, after a deceleration of 15 fpsps is attained (within one second of beginning the stop), the deceleration cannot drop below 15 fpsps even momentarily.

You stated that you are aware of the following three understandings within the industry concerning the meaning of this requirement:

1. The average deceleration for the stop must be greater than 15 fpsps. The average deceleration is calculated one second after the stop begins to a vehicle speed of 5 mph.

2. After 1 second the deceleration can not drop below 15 fpsps even for an instant. If the deceleration drops below 15 fpsps at any time it is considered a failure even if the average deceleration is greater than 15 fpsps.

3. The average deceleration for the stop must be greater than 15 fpsps and the deceleration must be greater than 15 fpsps for at least 75% of the stop excluding the first second of the stop.

Of the three understandings, the first and third are inconsistent with the plain wording of S7.11.2.1 which specifies that, after the required 15 fpsps deceleration is attained (within one second of beginning the stop), it must, as a MINIMUM, be maintain ed for the remainder of the stopping time. The first and third understandings would, among other things, replace S7.11.2.1's specification that the 15 fpsps deceleration be maintained as a "minimum" with one that it be maintained as an "average."

The second understanding is largely correct. It is correct to state that, in conducting a fade stop, after a 15 fpsps deceleration is attained (within one second of beginning the stop), the deceleration cannot drop below 15 fpsps even

for an instant. However, if the deceleration did drop below 15 fpsps, that would not necessarily indicate a "failure" but might simply be an invalid test. As you note in your letter, a deceleration might fall below 15 fpsps because the driver did not co mpensate for in-stop fade. However, if a vehicle was unable to pass Standard No. 105's fade stop test requirements at the specified deceleration rates, it would not comply with the standard, notwithstanding the fact that it might be able to pass the req uirements at slightly lower deceleration rates.

You stated in your letter that the second understanding appears to not consider the intent of the fade procedure, the intent being that a vehicle must be capable of making multiple high deceleration stops in a short period of time without drastic changes in effectiveness. As discussed above, the purpose of the fade and recovery test requirements is to help ensure that brakes retain adequate stopping capacity during and after exposure to conditions caused by prolonged or severe use, such as long, downhi ll driving. If a vehicle was unable to pass Standard No. 105's fade stop test requirements at the specified deceleration rates, it would indicate inadequate stopping capability during conditions caused by prolonged or severe use, such as long, downhill driving.

You also stated that in the Laboratory Test Procedure for Standard No. 105, published by NHTSA's Office of Vehicle Safety Compliance (OVSC), the data sheet for the fade stops requests the following information for the deceleration: "Average Sust Decel." You stated that it therefore appears that NHTSA's interpretation of the phrase "at a deceleration not lower than 15 fpsps for each stop" is "the average sustained deceleration."

It is incorrect to interpret the OVSC Laboratory Test Procedures as limiting the requirements of the Federal motor vehicle safety standards. I call your attention to the following note which is set forth at the beginning of the Laboratory Test Procedure :

The OVSC Laboratory Test Procedures, prepared for use by independent laboratories under contract to conduct compliance tests for the OVSC, are not intended to limit the requirements of the applicable FMVSS(s). In some cases, the OVSC Laboratory Test Procedures do not include all of the various FMVSS minimum performance requirements. Sometimes, recognizing applicable test tolerances, the Test Procedures specify test conditions which are les s severe than the minimum requirements of the standards themselves. Therefore, compliance of a vehicle or item of motor vehicle equipment is not necessarily guaranteed if the manufacturer limits certification tests to those described in t he OVSC Laboratory Test Procedures.

I am enclosing a copy of the most recent version of the Laboratory Test Procedure for Standard No. 105, in response to your request. I hope this information is helpful. If you have any further questions, please feel free to contact David Elias of my st aff at this address or by telephone at (202) 366- 2992.

ID: nht94-1.94

TYPE: Interpretation-NHTSA

DATE: March 24, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Gary D. March -- Director, Illinois Dept. of Transportation, Division of Traffic Safety (Springfield, IL)

TITLE: None

ATTACHMT: Attached to letter dated 2/14/94 from Gary D. March to John Womack (OCC 9667)

TEXT:

This responds to your letter of February 14, 1994, requesting an explanation of the compliance date for vehicles manufactured in two or more stages of a recent final rule amending Standard No. 217, Bus Emergency Exits and Window Retention and Release (57 FR 49413; November 2, 1992).

The effective date for the November 2 final rule is May 2, 1994. Only vehicles manufactured on or after the effective date of an applicable requirement in a Federal motor vehicle safety standard must comply with that requirement. If a vehicle is manufa ctured in two or more stages, the final stage manufacturer is required to certify that the vehicle complies with "the standards in effect on the date of manufacture of the incomplete vehicle, the date of final completion, or a date between those two date s." (49 CFR Part S568.6). The choice of a date is the manufacturers.

I hope you find this information helpful. If you have any other questions, please contact Walter Myers of my staff at this address or by phone at (202) 366-2992.

ID: nht94-1.95

TYPE: Interpretation-NHTSA

DATE: March 24, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Bob Carver -- Product Engineering, Wayne Wheeled Vehicles (Marysville, OH)

TITLE: None

ATTACHMT: Attached to letter dated 1/8/94 from Bob Carver to John Womack (OCC 9544)

TEXT:

This responds to your letter of January 8, 1994, asking two questions concerning a recent amendment to Standard No. 217, Bus Emergency Exits and Window Retention and Release (57 FR 49413; November 2, 1992). Your questions and the response to each follow .

1. There's some confusion here in our engineering department regarding the interpretation of the "Daylight Opening" and "Unobstructed Opening" as it applies to the new side emergency door specification in FMVSS 217. Page 2 shows the allowable obstructi on and the context in which "Daylight Opening" and "Unobstructed Opening" are used. Page 3 shows some measurements of our seats placed according to the "30 cm minimum" shown on page 2. Page 4 shows four different interpretations of the "Unobstructed Op ening" area. Depending on the interpretation, between 9 and 15 people may be accommodated by a side emergency door. My question is this: of the four possibilities shown, which definition of the "Unobstructed Opening" area is correct? Mr. Hott indicat ed definition 4.

The term "daylight opening" is defined in the Final Rule as "the maximum unobstructed opening of an emergency exit when viewed from a direction perpendicular to the plane of the opening." An obstruction in this context would include any obstacle or obje ct that would block, obscure, or interfere with, in any way, access to that exit when opened. In determining the "maximum unobstructed opening of an emergency exit," we would subtract, from the total area of the opening, the area of any portions of the opening that cannot be used for exit purposes as a result of the obstruction. The area measurements would be taken when viewed from a direction perpendicular to the plane of the opening.

Your question specifically concerns how the "maximum unobstructed opening" of a side door is measured when the opening is partially obstructed by a seat. In the case of the illustrated door exit, occupants would use the exit by movement along the floor. This would be considered in determining the extent of an obstruction. None of the four examples you enclosed with your letter correctly illustrates the area that would be credited for the illustrated exit. The following regions would not be credited for this exit: (1) the area visually obstructed by the seat; (2) your region A 2, an area bounded by a horizontal line tangent to the top of the seat back, a vertical line tangent to the rearmost portion of the top of the seat, the upper edge of the doo r opening, and the edge of the door forward of the seat; (3) your region A 5, an area bounded by the seat back, a horizontal line tangent to the top of the seat back, and the edge of the door forward of the seat; and (4) your region A 8, an area bounded by the seat leg, the floor, the lower edge of the seat bottom, and the edge of the door forward of the seat. Because the seat would make the last three regions unusable as exit space for a person traveling along the floor of the bus towards the exit, th ey would not be credited for that exit.

You should be aware that the agency published a notice of proposed rulemaking to amend Standard No. 217 on December 1, 1993 (58 FR 63321). The notice proposed two alternate means for determining the maximum amount of area that will be credited for all t ypes of emergency exits on school buses. The agency is currently reviewing the comments received in response to this notice. I am enclosing a copy of this notice.

2. Here is an excerpt from FMVSS 217 S5.5.3(a):

"Each school bus ....shall have the designation "Emergency Door" or "Emergency Exit" as appropriate, .... For emergency exit doors, the designation shall be located at the top of, or directly above, the emergency exit door on both the inside and outside surfaces of the bus.... For emergency window exits, the designation shall be located at the top of, or directly above, or at the bottom of the emergency window exit on both the inside and outside surfaces of the bu s."

I've seen a two-sided sticker used by other bus manufacturers. It is applied on the inside surface of a window and the same image "Emergency Door" or "Emergency Exit" can be read from both inside and outside the bus. Is it permissible for us to use thi s sort of decal, assuming it meets all other (i.e., FMVSS 302)?

The answer to your question is yes. The agency addressed this issue in an October 2, 1978, letter to Mr. E.M. Ryan of Ward Industries, Inc. I am enclosing a copy of this letter.

I hope you find this information helpful. If you have any other questions, please contact Walter Myers of my staff at this address or by phone at (202) 366-2992.

ID: nht94-1.96

TYPE: Interpretation-NHTSA

DATE: March 24, 1994

FROM: Marvin A. Leach -- Regional Program Manager, Region VIII, NHTSA

TO: Robert Hellmuth -- Office of Vehicle Safety Compliance, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/14/94 from John Womack to Robert L. Montgomery (A42; Std. 108; VSA Sec 108(a)(2)(A))

TEXT:

3/24/94 LETTER FROM REGION VIII MANAGER MARVIN A. LEACH TO ROBERT HELLMUTH:

Dear Mr. Hellmuth:

Please find enclosed a request for information related to the conspicuity rule, from a local business in Denver. Since they are requesting an opinion, it is beyond the scope of our office to assist. They have forwarded considerable detail and I hope yo u will be able to be of assistance.

We have had a number of requests for information on the rule, and in most instances sending a copy has sufficed.

I know your assistance will be appreciated.

Sincerely,

Marvin A. Leach, D.Ed.

3/24/94 LETTER FROM REGION VIII MANAGER MARVIN LEACH TO ROBERT MONTGOMERY:

Dear Mr. Montgomery:

It will not be possible to answer your "conspicuity" question from our office here in Denver. I have forwarded your letter and pictures to the Office of Vehicle Safety Compliance in Washington, and asked them to respond to your request.

I hope this will provide the information your need and thank you for your interest in highway safety.

Sincerely,

Marvin A. Leach, D.Ed.

3/9/94 LETTER FROM ROBERT MONTGOMERY TO MIKE BAKER:Mr. Mike Baker, State Director Federal Highway Administration Department of Transportation 555 Zang St

Lakewood, CO 80228

REF: 49 CFR Part 571 - Federal Motor Vehicle Safety Standards; Lamps, Reflective Devices and Associated Equipment

Dear Mr. Baker:

I am enclosing two photos. Photo number one depicts the conspicuity stripes as they come from the manufacturer. They are mounted on the Doors at a height of 56 inches which is approximately 6 inches higher than the 1.25 meters (50 inches) dictated. As you can see, it is necessary to offset the rear red and orange logo striping so that the stripes no longer make an even continuous line around the trailer.

Photo number two depicts the rear of an identical trailer where the reflectorized material was installed between and in line with the taillight assemblies. This installation is 46 inches which is 4 inches less than the 1.25 meters (50 inches) dictated. The material DOES NOT extend form the extreme edges of the trailer as in photo number one.

S5.6.1.4.1 allows for "as close as practical" to both height and width.

We would, of course, prefer to equip the rear of our trailers as depicted in photo number two: 1) To avoid the need to offset our red and orange reflectorized striping and 2) to bring the conspicuity striping down more to eye level and in line with the r ear lamps.

The diagram provided in the register does show the reflectorized striping from edge-to-edge but the artist failed to consider the bumper bar area and the light assemblies that are actually on a van and which basically interferes with proper height and wi dth placement on most trailers.

Would it be possible to obtain a written interpretation as to the legality of compliance with the regulation as to the installation of the reflectorized striping shown in photo number two, in a prompt and timely manner.

Thank you. Sincerely,

Robert L. Montgomery, Safety Manager Leprino Transportation Division

ATTACHMENT:

58414 Federal Register / Vol. 57, No. 238 / Thursday, 12-10-92 / Rules and Regulations. (Text omitted.)

ID: nht94-1.97

TYPE: Interpretation-NHTSA

DATE: March 25, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Thomas D. Turner -- Manager, Engineering Services, Blue Bird Body Company

TITLE: None

ATTACHMT: Attached to letter dated 11/15/93 from Thomas D. Turner to John Womack

TEXT:

This responds to your letter of November 15, 1993, in which you requested an interpretation of the final rule issued by this agency on January 15, 1993, 58 FR 4586, which amended Federal Motor Vehicle Safety Standard (FMVSS) No. 222, School Bus Passenger Seating and Crash Protection to include requirements for wheelchair securement devices and occupant restraint systems.

You referred to the second sentence in S5.4.3.2 of the standard which provides in pertinent part: "When more than one wheelchair occupant restraint shares a common anchorage, the anchorage shall be capable of withstanding a force of 13,344 Newtons multi plied by the number of occupant restraints sharing that anchorage." You stated that you believe that this language is intended to address the situation where restraints from two different wheelchair occupant restraint systems share a common anchorage, a nd is not intended to address the situation "where the lower end of an upper torso restraint joins the pelvic restraint and goes to one of the rear floor anchorages of a single occupant's restraint system." You stated that if the latter, the floor ancho rage would be required to withstand a force of 13,344 Newtons each for the upper torso restraint and the pelvic restraint; and if the wheelchair was also secured to that floor anchorage, the anchorage would be required to withstand 3 x 13,344 Newtons.

Your letter included two figures illustrating typical wheelchair securement and occupant restraint system designs. In Figure 1, the upper torso restraint is attached to the lap belt at the buckle, and the lap belt is attached to the vehicle at the same anchorage as the rear anchorage for the wheelchair securement device. In Figure 2, the upper torso restraint is also attached to the lap belt; however, the lap belt is attached to the rear wheelchair securement device instead of the wheelchair securemen t anchorage. You asked for verification that the required load for the rear anchorages for both designs is 2 x 13,344 Newtons rather than 3 x 13,344 Newtons.

You are correct that the load for the rear anchorages for both these designs would be 26,688 Newtons (2 x 13,344 Newtons). The relevant section to determine this load is S5.4.3.2(e) which states:

When a wheelchair securement device and an occupant restraint share a common anchorage, including occupant restraint designs that attach the occupant restraint to the securement device or the wheelchair, the loads specified by S5.4.1. 3 (13,344 Newtons) and S5.4.3.2 (13,344 Newtons) shall be applied simultaneously...

The term "wheelchair occupant restraint" includes both the pelvic and upper torso restraints (see S5.4.4). In your designs, each rear floor anchorage would be required by S5.4.3.2(e) to withstand a combined force of 26,688 Newtons, which includes the lo ad specified for the wheelchair occupant restraint and the load specified for the wheelchair securement device.

The second sentence of S5.4.3.2, which you quoted in your letter, addresses the situation where the wheelchair occupant restraints for more than one wheelchair, e.g. two wheelchairs, are secured to the same floor anchorage. This requirement parallels a r equirement in S5.4.1.3 which addresses the situation where the wheelchair securement devices for more than one wheelchair are secured to the same floor anchorage. Thus, for example, if either of your designs were installed in a bus such that the right r ear anchorage was shared with another identical wheelchair securement and occupant restraint system (functioning as the left rear anchorage for the second system), that floor anchorage must be capable of withstanding a force of 13,344 Newtons for each oc cupant restraint system and 13,344 Newtons for each wheelchair securement system, for a total force of 4 x 13,344 Newtons, such force to be applied simultaneously as required by S5.4.3.2(e).

I hope you find this information helpful. If you have any other questions, please contact Walter Myers of my staff at this address or by phone at (202) 366-2992.

ID: nht94-1.98

TYPE: Interpretation-NHTSA

DATE: March 25, 1994

FROM: Roger W. Bruett -- Chief; Signed by Carol I. Morton -- Administrative Assistant, Equipment and Standards Review Unit, Washington State Patrol

TO: Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/14/94 from John Womack to Carol I. Morton (A42; Std. 108)

TEXT:

It has come to our attention, new headlamps are being installed on BMWs, 750 models. These lamps are called XENON and are "Hella SSB 352 (lower beam) and Hella SSB 328 (upper beam) with replaceable bulb headlamp with glass lens and plastic reflector.

This office received a complaint from a BMW Dealership indicating an owner of one of these vehicles is being continually stopped by law enforcement because of these headlamps. The reason for concern from the officers, is the intensity of the light beam from these lamps is much whiter and appears to be stronger.

We would like to know if these headlamps are legal for use on motor vehicles. A report was sent to us stating they meet all the requirements of the FMVSS 108. This report was generated by ETL Testing Laboratory in New York.

I would appreciate your response on this subject as soon as possible.

ID: nht94-1.99

TYPE: Interpretation-NHTSA

DATE: March 25, 1994

FROM: Tilman Spingler -- Robert Bosch GMBH

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: FMVSS 108, S4.Definitions, Integral Beam Headlamp Request for Interpretation

ATTACHMT: Attached to letter dated 5/5/94 from John Womack to Tilman Spingler (A42; Std. 108)

TEXT:

In this paragraph an integral beam headlamp is defined to be an indivisible optical assembly of lightsource, reflector and lens. In the case of High Intensity Discharge Headlamps where the lightsource is comprised of a bulb and associated electronic mod ules, it may in some cases not be feasible to integrate the ignition module and the control module in the headlamp housing because of space limitations. In the letter to TOYOTA of March 1991 these modules were permitted to be separately located, but per manently attached by cable at the time of assembly. When the ignition module is installed inside and the control module outside the headlamp housing they will be connected by a 4-core cable in one design. Are there requirements for this cable concerning indivisibility and integration, for example, may it be of the following? - soft cable, resistant to abrasion? - hard cable, resistant to cutting and abrasion? - armored cable? Maximum voltage on 2 cores will be 130 V AC in the on-mode of the headlamp, on the 2 other cores 400 V AC for 700 msec during ignition of the light source. These voltages are much lower than voltages on ignition cables for motor vehicle engines.

ID: nht94-2.1

TYPE: Interpretation-NHTSA

DATE: March 28, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Thomas D. Turner -- Manager, Engineering Services, Blue Bird Body Company

TITLE: None

ATTACHMT: Attached to letter dated 2/21/94 from Thomas D. Turner to John Womack (OCC 9719)

TEXT:

This responds to your letter of February 21, 1994, requesting further clarification of the requirements of S5.5.3(c) of Standard No. 217, Bus Emergency Exits and Window Retention and Release (as amended at 57 FR 49413; November 2, 1992). Section S5.5.3( c) states that "(e)ach opening for a required emergency exit shall be outlined around its outside perimeter with a minimum 3 centimeters wide retroreflective tape." *1 Your letter referenced our July 7, 1993 letter to you in which we stated that S5.5.3 (c) permits interruptions in the tape necessary to accommodate curved surfaces and functional components. You requested confirmation "that retro-reflective tape around the perimeter of the rear of a school bus can be used to satisfy the requirements of S5.5.3(c)."

I cannot interpret the requirements of S5.5.3(c) as you request, since for many, if not most, designs the nearest possible location will be closer than the perimeter of the bus. While we appreciate your concerns about durability if numerous cuts or notc hes are made to accommodate rivets, our July 7 letter stated that manufacturers have the option of placing the retroreflective tape immediately adjacent to the rivets, rather than over the rivets. As an example, from the illustrations you enclosed, it a ppears that it may be possible to apply retroreflective tape outside the rivets adjacent to the lower portions of the door. Thus, that would be the nearest possible location, rather than the perimeter of the bus itself. I note, however, that the illust rations do not provide sufficient detail of all obstructions for us to determine the nearest possible location for each design.

I also note that your letter stated in support of your request that all school buses are required to have a rear emergency exit. While this is true, the type of emergency exit will vary and retroreflective tape at the perimeter of the exit would allow r escuers to immediately know the precise location of the exit. Moreover, retroreflective tape at the perimeter would enable rescuers to immediately know which type of exit is in this location. This information could be vitally important. Because push-ou t windows are not required to have a means of releasing the exit from outside the bus (S5.3.3.2), this information would allow rescuers to quickly determine that they should move to the sides of the bus to locate an exit they can open.

Your letter asked the agency to treat it as a petition for rulemaking if we did not interpret the standard as you requested. You will be notified of our decision to grant or deny your petition.

I hope you find this information helpful. If you have any other questions, please contact us at this address or by phone at (202) 366-2992.

*1 The July 7, 1993 letter also stated that the agency planned to issue a correction notice of the November 2, 1992 rule that would specify a minimum size of 2.5 cm for the tape. This notice has not yet been published. Until the correction is issued, NHTSA will not take enforcement measures regarding tape size against a manufacturer who uses 1 inch wide retroreflective tape.

ID: nht94-2.10

TYPE: Interpretation-NHTSA

DATE: April 1, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: William D. McIntosh -- Quality Assurance Manager, Perstorp Components (Ontario, Canada)

TITLE: None

ATTACHMT: Attached to letter dated 6/9/93 from William D. McIntosh to Chief Council, NHTSA (via John Messera)

TEXT:

This responds to your inquiry about whether Standard No. 302, Flammability of Interior Materials (49 CFR S 571.302), applies to your product. You state that you manufacture a "composite assembly acoustical abatement product" that is installed against ve hicle sheet metal and is then covered by carpet, trim, or the instrument panel. You had further questions about testing your product and certifying its compliance if the Standard applies to it. I apologize for the delay in responding.

By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the national Traffic and Motor Vehicle Safety Act (The "Safety Act") establishes a "self- certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety st andards. Since Standard No. 302 is a vehicle standard, the manufacturer of the vehicle, and not the manufacturer of the individual component, is responsible for certifying compliance with Standard No. 302. The agency periodically tests new vehicles and items of equipment for compliance with the standards.

Under the Safety Act's authority, NHTSA has issued Standard No. 302 which specifies burn resistance requirements for materials used in the occupant compartment of new motor vehicles. Section S4.1 lists the components in vehicle occupant compartments tha t the vehicle manufacturer must certify as complying with the flammability resistance requirements of paragraph S4.3. The components listed include seat cushions, seat backs, seat belts headlining, convertible tops, arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, and any other interior materials, including padding and crash deployed elements, tha t are designed to absorb energy on contact by occupants in the event of a crash. Among the listed items that might be applicable to your acoustical abatement product are floor coverings and engine compartment covers. That is, the standard would apply to your product if the acoustical abatement material is a part of one of the covered items and is within 1/2" of the occupant compartment.

You indicate in your letter that you are uncertain whether to test your product to Standard No. 302 as a composite with other materials. S4.2.2 of Standard No. 302 states, "Any material that adheres to other material(s) at every point of contact shall m eet the requirements of S4.3 when tested as a composite...." You indicate in your letter that your product has multiple layers that always

adhere to each other. Accordingly, assuming your product is subject to Standard No. 302, the agency would test your product as a composite material, in accordance with S4.2.2.

Please note that there are other NHTSA requirements that could affect the manufacture and sale of your product. A motor vehicle or equipment manufacturer incorporating your product in its vehicles or equipment would be subject to sections 151-159 of the Safety Act to ensure that its vehicles or equipment do not contain any safety related defect. If the manufacturer or NHTSA determines that a safety related defect exists, the manufacturer would be responsible for notifying purchasers of the defective v ehicle or equipment and remedying the problem free of charge.

In addition, section 108(a)(2)(A) of the Safety Act states: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative...any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable motor vehicle safety standard..." Under this section, the entities mentioned above are required to ensure that the addition of your product would not adversely affect the compliance of any component or element of design on a vehicle with an applicable Federal safety standard. With respect to Standard No. 302, the addition of your product must not reduce the vehicle's overall flammability resistance.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202)366-2992.

ID: nht94-2.100

TYPE: INTERPRETATION-NHTSA

DATE: April 25, 1994

FROM: Gerald Plante -- Manager, Product Compliance, Saab Cars USA, Inc.

TO: Barbara Gray -- Office of Market Incentives, NHTSA

TITLE: NONE

ATTACHMT: Attached to letter dated 8/9/94 from Barry Felrice to Gerald Plante

TEXT: Dear Ms. Gray:

Saab has made some updates to our anti-theft alarm systems in our 1995 model year Saab 900 models. I am sorry I missed your return call. I was hoping we could have had some discussion about NHTSA's current evaluation guidelines on the telephone before submitting written materials. As a way of introduction, I have taken David Raney's place as Saab's Manager of Product Compliance.

Saab views the changes in 1995 components and designs with our anti-theft systems as de minimis ones that would enhance the anti-theft effectiveness of the 1994 alarm. To the extent permitted in 49 CFR Part 543.9, Saab is requesting permission to modify our existing exemption on the Saab 900.

The enclosed material is primarily updates of the material provided to NHTSA on March 25, 1993. Briefly, the changes involve the following:

1. Remote control added. 2. Arming/disarming of alarm/immobilizer functions from remote control only. 3. Remote control operation of the central locking system added. 4. Immobilizer function expanded by adding fuel pump and ignition disengagement to the existing starter motor disengagement.

We would very much appreciate your review of this material to confirm that NHTSA agrees with Saab on the above points. Please feel free to contact me at (404) 279-6377.

Given the definition of "carline" in Part 541.4(b), all 1995 Saab cars labelled as 900 models belong to one carline: Saab 900.

The basis of our petition for exemption is the specification of an effective anti-theft system on all Saab 900 models as standard equipment. In addition, this carline will be specified with an anti-theft radio system, which will further reduce the incidence of auto theft involving Saab cars.

Carline Description

1995 Saab 900 Carline: Body Style Model Designation Engine Variant 2-door hatchback 900 Turbo 4 cyl., 16-valve 4-door hatchback 900 6 cyl., 24-valve 2-door hatchback 900 6 cyl., 24-valve 4-door hatchback 900 4 cyl., 16-valve 2-door hatchback 900 4 cyl., 16-valve 2-door convertible 900 Turbo 4 cyl., 16-valve 2-door convertible 900 Turbo 6 cyl., 24-valve 2-door convertible 900 4 cyl., 16-valve

Anti-Theft System Description-MY 1995 Saab 900

The system consists primarily of the following components and functions:

Components

Audible signal device Electronic control module Remote control (2) Lock assembly protective covers Door-mounted switches (4) Hood-mounted switch Hatch/trunk lid-mounted switch Light-emitting diode (LED-system status indicator light) Glass breakage sensor Anti-Theft system window warning label (2) Three circuit disengagement relay (starter motor, fuel pump, and ignition)

Functions

Central door/lock/unlock from driver and front passenger door locks Dead-bolt locking of all doors and hatch/trunk lid from driver's door lock Starter motor, fuel pump, and ignition disengagement with alarm activation Horn sounding with alarm activation. Turn signal indicator flashing with alarm activation Arm/disarm from remote control Hatch/trunk lid lock/unlock and temporary disarming of the alarm from the remote control

Attachment I contains a wiring diagram depicting the Saab 900 anti-theft system circuitry and electric/electronic components. Attachment II depicts the location of the above-listed components. The vehicle depicted is the Saab 900 four-door hatchback. The two-door hatchback and convertible is identical to the four-door version, with the exception of the added rear passenger doors. Locking features for the rear passenger doors are identical to the front passenger locking features. The two-door convertible differs from the two-door hatchback only in that it has a conventional trunk, which is isolated from the passenger compartment by the rear seatbacks.

Functional Description

From the driver's, or front passenger's door lock, using the ignitiiion key or the remote control, the operator may activate or deactivate the central locking system by turning the key 45 degrees clockwise or counter-clockwise, respectively. In the locked position, all doors, including the hatch/trunk lid, are electro-mechanically locked. It is not possible to lock the doors while they are open (The lock plunger will not depress while the door is open); doors can only be locked from outside when the door is closed by using the ignition key in the door lock or the remote control.

From the dirver's door lock only, if the key is turned an additional 45 degrees in the same direction and withdrawn from this position, the dead-bolt is activated. This means that the door handles and lock devices are disengaged in the locked position, forcing an intruder to crawl through a broken window in order to enter the vehicle. The operator can not activate or deactivate the dead-bolt feature from the remote control.

From the left button on the remote control only, the alarm and immobilization features are armed. In armed condition, the vehicle doors, hatch/trunk, hood and windows are protected by the alarm system. If an attempt is made to enter the vehicle, an audible signal device (105-118 decibels) will sound for 30 seconds and the turn signals will flash for 300 seconds. If the alarm is disarmed within 30 to 300 second period, the horn is interrupted and the turn signal indicators cease flashing. If another trigger signal occurs (e.g., trunk) during this 30 or 300 second period, each function resets for another 30 or 300 second period, from the moment of retriggering.

At the same time, the starter motor, the fuel-pump and the ignition systems are automatically disabled for 30 minutes. If a renewed attempt is made to enter the vehicle, all systems will again react as described above. The anti-theft alarm can be disarmed idefinitely from the left button on the remote control, or temporarily from the hatch/trunk lid, using the right button on the remote control. In the latter case, the alarm rearms automatically ten seconds after the hatch/trunk lid is again closed.

In addition to the active systems described above, several passive anti-theft features further deter vehicle entry and theft. All door lock mechanisms are covered, and recessed inside the door, making it extremely difficult to unlock a door using an instrument slid down between the window and outer door skin. Furthermore, because the latch mechanism is located in the door, rather than in the B-pillar, it is much more difficult to unlatch the door using an instrument slid in between the door and B-or C-pillar. Also, the interior door lock plungers are of a design that is impossible to snag with a wire inserted between the weatherstip and window glass.

Functional Description continued

The Saab 900 ignition key and keylock, which is used to activate and deactivate the anti-theft system, are of a design unique to Saab, and are virtually impossible to "pick". The ignition key is also difficult to duplicate on the open market as a special blank, special key outlining equipment, and access to Saab key codes are required. Key blanks and codes are protected within the Saab corporate and dealer network.

The radio is designed to be extremely difficult to remove without the use of a special extraction tool. Once disconnected from a power-source, the radio will not function again unless a unit-specific, four-digit access code is keyed in. The radio facia is also an uncommon size, making it impractical to install in a different model vehicle.

A dash-mounted LED is used to indicate the various states of the alarm as follows:

1. Arming: The LED is lit for ten seconds.

2. Disarming: The LED is lit for one second.

System triggered during arming procedure: The LED Blinks at half-second intervals for 10 secons.

4. System triggering input cancelled during arming procedure: The LED stops blinking, and remains lit for 10 seconds.

5. Disarming from hatch/trunk lid: The LED is lit for 10 seconds after unlocking the hatch/trunk lid, and again for 10 seconds after closing it.

6. Glass breakage sensor override switch (M95) activated (ignition on): Teh LED is off.

7. Glass breakage sensor override switch (M95) pressed continuously (ignition off): The LED blinks at half-second intervals for 10 seconds.

8. Glass breakage sensor, override switch (M95) activated (ignition off): The LED blinks at half-second intervals for 10 seconds.

9. Disarmed system: The LED is off.

10. Armed system: The LED blinks at 2 second intervals until the system is disarmed.

11. Activated system: The LED blinks at 2 second intervals until the system is disarmed.

12. Self-armed three circuit disengagement: The LED blinks at 2 second intervals until the system is disarmed.

The system is protected against false activation from such common occurrences a shaiking or knockng, sound wave vibration, air turbulence, and temperature or light changes. In addition, the anti-theft system is equipped with a self-diagnostic system, which initiates a 10 second self-check function each time the system is armed. If a failure is detected, a fault code is stored, and the LED will blink for 10 seconds after arming the alarm (rather than remaining steadily lit for 10 seconds) as long as the code is left in the memory. Other system functions remain undisturbed. Diagnostic communication with the electronic control moduel can be initiated through the use of a special Saab Electronic diagnostic scanning tool when the alarm is unarmed.

Saab Automobile 900 MY95 Alarm Immobilizer Parts list:

900

INDEX PART NAME SAAB PART NUMBER:

%Q1. Horn assembly 44 93 443 2. El. unit anti-theft system 45 88 182 3. Window warning label 95 68 049 4. Theft security lock/unlock switch 43 27 292 5. C-lock/security lock motor driver side 43 26 773 6. C-lock/security lock motor passenger 43 26 781 side 7. C-lock/security lock motors right read 43 26 799 doors 8. Door switch driver and passenger door 44 08 423 9. Door switch rear doors 44 08 423 10. Hatch/trunk lid switch 44 08 423 11. Hood switch 43 23 259 12. Glass breakage sensor/lamp 45 50 869 Convertible (black) 45 50 851 13. Central lock unit 40 90 991 14. L.E.D. 40 90 991 15 Remote control 45 50 075

GP/abh Enclosures