ID: 1983-2.18

TYPE: INTERPRETATION-NHTSA

DATE: 06/17/83

FROM: FRANK BERNDT -- CHIEF COUNSEL NHTSA

TO: CHUCK HOWARD -- PRESIDENT SAFETY ALERT CO INC

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER 06/05/90 ON STD 108 FROM STEPHEN P. WOOD -- NHTSA TO HIROSHI OZEKI -- MAZDA; LETTER FROM HIROSHI OZEKI -- MAZDA TO STEPHEN WOOD -- NHTSA DATED 04/10/90 ENTITLED REQUEST FOR INTERPRETATION OF 49 CFR 571.108 "LAMPS, REFLECTIVE DEVICES AND ASSOCIATED EQUIPMENT; LETTER FROM ERIKA JONES -- CHIEF COUNSEL NHTSA TO JAMES R. MITZENBERG -- FLXIBLE CORP DATED 12/08/86 ON STD 108 INTERPRETATION

TEXT: We have received your petition for rulemaking of April 25, 1983, your letter of May 6 withdrawing it, and your letter of May 5 to Mr. Vinson of my staff asking for an interpretation. All this concerns the applicability of Standard No. 108 to your 'Vehicle Deceleration Warning System.'

As we understand it, this system was originally designed to provide a flashing light through the back-up lamp system, in which yellow bulbs were used as substitutes for the white ones required by Standard No. 108. You were informally advised by agency staff that such a system would render the vehicle noncompliant with the requirement that a back-up lamp be white, and that it be steady burning in use.

You asked Mr. Vinson if there were another alternative for flashing red lights that would comply with Standard No. 108, and in your letter of the 6th, whether use of the hazard warning system was acceptable. You also inquired about retrofitting vehicles manufactured before hazard warning signals were required, so that your system would work through the rear turn signals.

In the context of Federal regulations an optional system such as yours is acceptable as original equipment, or equipment added before initial sale of the vehicle, if it does not impair the effectiveness of lighting equipment required by Standard No. 108. In our view, it is permissible to use any rear lighting system Standard No. 108 allows to flash for signalling purposes. Thus, your system could operate through the rear hazard warning system, or the rear turn signal system (red or amber) as long as the color of light or photometrics required by the standard was not changed.

As an aftermarket device intended for installation on vehicles in use, it must not render inoperative in whole or in part Federally- mandated lighting equipment. Subject to the restrictions noted above, your system would not violate this prohibition were it installed to work through the hazard warning or turn signal systems. However, since your system involves an aspect of performance not covered by Standard No. 108, each State may regulate its use as it sees fit.

Passenger cars built since January 1, 1969, have been required to have hazard warning signal systems. Use of the turn signal system of a vehicle built before that date is not prohibited under Federal regulations but is also a matter to be determined by local law.

I hope that this is responsive to your questions.

ID: 1983-2.19

TYPE: INTERPRETATION-NHTSA

DATE: 06/20/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mazda (North America) Inc. -- H. Nakaya, Manager

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. Nakaya Manager Mazda (North America) Inc. 23777 Greenfield Road - Suite 462 Southfield, MI 48075

Dear Mr. Nakaya:

This is in reply to your letter of May 24, 1983, asking whether the headlamp bezel is considered a "styling ornament or other feature" for purposes of paragraph 5.2 of SAE J580 Sealed Beam Headlamp Assembly, Aug 79 incorporated by reference in Standard No. 108.

The referenced SAE paragraph prohibits styling ornaments or other features in front of the lens when the headlamp is in use. The intent of this paragraph is to guarantee optimum light output from the headlamp by insuring that no part of the vehicle interferes with the light pattern. If a headlamp bezel is so large that it could interfere with the design light patterns of the lamp, we would consider it a "styling ornament or other feature" within the meaning of paragraph 5.2.

An oversize bezel interfering with light output would also be prohibited by paragraph S4.1.3. of Standard No. 108 which prohibits installation of motor vehicle equipment that impairs the effectiveness of lighting equipment which the standard requires.

I hope that this answers your question.

Sincerely,

Frank Berndt Chief Counsel May 24, 1983

Our Ref. No.: SDL3-016

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Berndt:

Per a recent phone conversation from a member of my staff to Mr. Taylor Vinson, we request a clarification concerning FMVSS108: Lamps, Reflective Devices, and Associated Equipment.

Our question is: Is the headlamp bezel included in "... any styling ornament or other feature..." which is explained in SAE J530 5.2.

Of course, the performance of the headlamp satisfies all requirements of FMVSS108.

We are looking forward to receiving your response as soon as possible.

Very truly yours,

H. Nakaya Manager

HN/ab

cc: Mr. Taylor Vinson

ID: 1983-2.2

TYPE: INTERPRETATION-NHTSA

DATE: 05/06/83 EST

FROM: FRANK BERNDT -- CHIEF COUNSEL, NHTSA

TO: F. MICHAEL PETLER -- HEAD, ADMINISTRATION, GOVERNMENT RELATIONS DEPARTMENT, SUZUKI MOTOR

TITLE: NOA-30

ATTACHMT: MEMO DATED 4-20-83, REQUEST FOR INTERPRETATION FMVSS NO. 210; SEAT BELT ASSEMBLY ANCHORAGES

TEXT: This responds to your recent letter requesting information concerning the requirements for seat belt anchorages in passenger cars under Safety Standard No. 210. Specifically, you ask whether only Type 1 seat belt anchorages are required in rear seating positions in passenger cars.

The answer to your question is no. Under paragraph S4.1.1 of standard 210, Type 2 seat belt anchorages (for combination lap and shoulder belts) are required as follows: at each front and rear forward-facing outboard designated seating position in passenger cars other than convertibles; and at each front forward-facing outboard designated seating position in vehicles other than passenger cars where Type 2 belts are required by Safety Standard No. 208. All other seating positions in both passenger cars and other vehicles may be equipped with anchorages for either Type 2 belts or Type 1 belts (lap belts). Safety Standard No. 208, Occupant Crash Protection, requires Type 2 belts only in front outboard designated seating positions in passenger cars, but passenger cars still must be equipped with anchorages for Type 2 belts in rear outboard designated seating positions.

As to your reference to discussion of anchorages in the agency's November 2, 1981 denial notice to Toyo Kogyo (46 FR 54391), that discussion was misleading because it did not provide complete information or distinguish adequately between passenger cars and other types of vehicles. The agency intended to refer to the type of belts required by Safety Standard No. 208, i.e., Type 2 belts in front outboard designated seating positions and Type 1 belts in front center and all rear seating positions.

I hope this has clarified any misunderstanding you may have had concerning the anchorage requirements. Please contact Hugh Oates of my staff if you have any further questions (202-426-2992).

Sincerely,

ID: 1983-2.20

TYPE: INTERPRETATION-NHTSA

DATE: 06/23/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Middletown Van Pool Association

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your note of May 27, 1983, attaching correspondence between yourself and a District Manager for Ford Motor Company. You requested that we investigate the Ford E-150 van (which you state is a 15-passenger van) to determine if the stated Gross Vehicle Weight Rating of that vehicle is accurate.

Each manufacturer of a motor vehicle is required by the agency's regulations to place a certification label on the vehicle specifying that the vehicle is in compliance with all Federal motor vehicle safety standards and regulations (issued pursuant to the National Traffic and Motor Vehicle Safety Act of 1966). This certification label must include information regarding the vehicle's Gross Vehicle Weight Rating, as specified in 49 CFR 567.4(g)(3):

"(3) "Gross Vehicle Weight Rating" or "GVWR", followed by the appropriate value in pounds, which shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity. However, for school buses the minimum occupant weight allowance shall be 120 pounds."

Thus, you are correct in your assumption that the GVWR for a 15-passenger vehicle would have to include 2,250 pounds for occupant weight. Further, if a 15-passenger vehicle has a stated GVWR of 6,200 pounds, its unloaded vehicle weight could not exceed 3,950 pounds. I cannot state whether the Ford E-150 van has an unloaded vehicle weight in excess of this figure. However, I am sending a copy of your correspondence to our Office of Enforcement so that they may review this matter.

SINCERELY,

Marriott Hotels

5/27/83

MR. FRANK (Illegible Word) CHIEF COUNSEL NHTSA

THE ATTACHED FILE I BELIEVE POINTS TO A PROBLEM FORD MOTOR CO. HAS AND THEY NEED TO TAKE CORRECTIVE ACTION ON.

THANKS FOR LOOKING INTO THIS PROBLEM.

(Illegible Words) May 21, 1983

Mr. J. R. Rose - District Manager Ford Motor Company

Dear Mr. Rose

Just a note to let you know that I received your May 17 letter which contains various specific accuations that "you (refering to the writer) apparently intensified the problem of load by actually carrying an overload". Sorry to inform you Mr. Rose, but you are totally misinformed and there is some question on the facts you put forth. Consider:

1. A Ford representative, Mr. Frank Palbo, speced out the Van in question. . . .as per the attached specification sheet. He had very simple guidelines.

(a) Want a 15 passenger Ford Van

(b) Want to carry 10 passenger in Captains Chairs

(c) Want individual reading lights for each Captains Chair.

2. Frank's note of August 17, 1981 and vehicle layout (copy attached) indicate,

(a) Seats will fit

(b) Van converter will do the job

(c) Finance Company approved the lease.

3. Consider Mr. Rose, I specified a 15 Passanger Ford Van. . . .which normally contains:

(a) Two front seats . . . . equals 2

b) Three bench seats holding three persons each . . . equals 9

(c) One rear bench seat holding four people . . . equals 4

(d) If my math holds up . . . that is 2 + 9 + 4 = 15 people

(e) If your letter is correct, I quote "10 passengers possibly totally 1500 lbs" is correct . . . then your Ford 15 passenger van carries a payload of 15 times 150lbs = 2250 pounds of payload.

(f) Since we are saving 5 passengers we should be saving . . . . 5 times 150lbs = 750 pounds.

(g) Now, we added 8 captains chairs on bases verses your 4 bench seats . . . and since our seats our top quality, we'll agree they probably weigh on a two for one bases, 50 pounds each more than seats . . . so eights seats times 50lbs. = 400 pounds.

(h) O.K. - I saved 750lbs. by carrying 5 less passengers - I added 400lbs by using Captains Chairs . . . so basic subtraction says 750 minus 400 equals 350 pounds.

(i) Now the Van converter recommended we beef-up your flooring along with insulating the floor so we added 3/4" plywood to the floor in under your luxurious carpeting. Say that added 100lbs. to the Van. Let's see, I still have 350lbs. I saved and I take away 100lbs. from that and I have 250lbs. . net savings.

(j) We also added reading lights, electrical wire, front wood console, rear tire carrier . . . must all total out to at least 50lbs . . . . so I reduce my 250pounds savings by 50 and my new net savings is 200 pounds.

(k) Now our regular riders are of hearty stock and probably average 20lbs. overweight to your 150lbs. standard . . . so 10 passengers being 201lbs. each overweight equals 200lbs . . . can you believe it . . . 200 plus and 200 minus and I come out to . . . ZERO.

Now that we've finished our basic math quiz we can get down to the heart of the problem. Ford is selling a Cargo/Passenger vehicle that can't possibly meet their stated weights . . . . once again simple math says: GVW is 6200 pounds 15 Passengers -2250 pounds NVW is 3950 pounds

There is no way that vehicle or any Ford Vehicle setting on your showroom floor, equipped with bench seats and ready accept 15 passengers can weigh less than 400 pounds.

So, by your own figures, you show that you are falsely representing your product, that you are endangering peoples lives and worst of all you don't give a damn. And to prove that statement, I'll take a Saturday and in your facility, take out the eight captains chairs and bases and let you weigh the Van. And so that everyone knows things are on the up and up, let's invite the President of Ford to be the official weighing judge. He certainly has a vested interest. And just in case you don't want to accept the challenge, rest assured I'll do it on my own, having everything (Illegible Word) so that TV Stations, Consumer Organizations, FTC, and NHTSA can all benefit from this information.

So, back to you Mr. Rose and this time please do your homework and get the facts straight before you respond. I want to know why a Ford Motor Company representative speced and sold our group a Van that could not possibly conform to what we requested.

A VERY UNHAPPY FORD VAN LEASEE:

WILLIAM E. MEITER Middletown Van Pool Association

Ford Motor Company

May 17, 1983

William E. Meiter Middletown Van Pool Association

Dear Mr. Meiter:

This is in response to your recent letter to Mr. Peck in which you relate the problems experienced with replacement of brake linings and pads on your 1982 Ford E-150 Van.

While the warranty which you received with the Ford E-150 Van covers defects in material and workmanship within the first 12 months or 12,000 miles, it does not cover replacement of normal maintenance items such as brake linings (friction material). There are several factors that may effect brake life; for example: individual driving habits, road conditions, stop and go traffic into and within Manhattan and optional equipment such as 10 captian chairs causing extra load. You apparently intensified the problem of load by actually carrying an overload which is indicated in the following: Your vehicle's GVW is - 6,200 lbs. After alterations, your vehicle's net weight registered as - 5,720 ibs. Allowing you - 480 lbs. to use as load; i.e.: passengers.

By transporting 10 passengers possibly totalling 1,500 lbs., you are overloading your vehicle by approximately 1,000 lbs.

We regret that our response could not be more favorable, but appreciate having had the opportunity to review this matter for you.

J. R. Rose District Manager New York District

MANHATTAN FORD, LINCOLN-MERCURY, INC. (Illegible Words) 555 WEST 57th STREET, NEW YORK, N.Y. 10019 (201)581-7860

PRICE BOOK DATE PAGE DATE SALESMAN: SALBO

CUSTOMER: J.C. PENNY

ADDRESS

ATTENTION: W.E. MEITER 60 WALLACE ROAD, MIDDLETOWN, N.J. 07748 PHONE: 212-957-0092. MODEL: EIEO WINDOW VAN SUPER (Illeg.) 6941.- PAYLOAD PACKAGE: #2 GVM: 6200 N/C ENGINE: 302-V8 101.- TRANSMISSION: AUTOMATIC 352.- AXLES FRONT: (TRACTION LOK) REAR RATIO: 4.75 170.- TIRES: P235 75R 15XL STD.- SPARE TIRE: P235 75R 15XL 111.- AIR CONDITION DASH [] HI CAPACITY [] 1020.- ALTERNATOR: 60 AMP INCL W/AIR. - BATTERY: HD 36.- BRAKES: POWER STD BUMPER: REAR STEP. 84.- OUT CONVENIENCE GROUP: INTER WIPERS-12" O/N MIRROR-RHVANITY MIRROR 50.- COOLING SYS EXTRA [] SUPER [] 55.- DOOR SIDE: SLIDING OR HINGED N/C FUEL TANK: AUX. TOTAL CAP. 40 GALS 112.- (Illeg.) SPEED CONTROL 135.- GLASS (Illeg.): SWING OUT REAR. 40.- GLASS TINTED [] PRIVACY [] 264.- (Illeg.): COMFORT RIDE 15.- HEATER AUX [] HI OUTPUT [] 25.- INSULATION: DELUX 362.- LIGHT (Illeg.): COURTESY SWITCHES 24- LOCK GROUP: SECURITY 51.- MIRRORS: WESTERN LOW MTG. 69.- PAINT: ONE COLOR N/C PROTECTION GROUP RADIO: AM. FM. CASSETTE (4 SPEAKERS.) 224.- SEATING: QUAD CAPTS. CHAIRS. (2 ONLY) 1100.- 550 SHOCKS: HD FRONT & REAR (Illeg.) SPRING FRONT: HD REAR: HD 62.- STABILIZER BAR: FRONT 25.- STEERING: POWER 197.- (Illeg.): OUTSIDE SWING AWAY TIRE CARRIER. 117.- (Illeg.): CIGAR LIGHTER. 17.- FREIGHT 509.- DELIVERY & PREPARATION CHARGE 75.- 1981 PRICE (Illeg.) 82 ESTIMATED INCREASE 4% 500.- 12926- BILL, THE VAN PEOPLE ON LONG ISLAND WANT X 355.00- EACH INSTALLED FOR CAPTAINS CHAIRS FIGURING ANOTHER SEVEN TX 368.00-297.50 25.00- 2.972 I STILL WANT TO SHOP THIS ITEM LIGHTS 34.35 15 TOTAL 212.45 504.00 15.286

(Illegible Words)

P.S. ALL ACCESSORIES ARE FIGURED AT COST SO ANYTHING YOU THINK YOU DON'T WANT JUST DELETE.

LENNIE (Illegible Words) - 914-638-2972 3 YR. #562 MO PLUS INSURANCE. DOWN #600 + ONE MOS. PAYMENT $ 8,500 BUY BACK

MANHATTAN FORD, LINCOLN-MERCURY, INC

8-17-81

BILL,

JUST A QUICK NOTE TO TELL YOU THE FINANCE CO. APPROVED THE LEASE.

ALSO ATTACHED IS A LAY OUT. I GOT THE SEAT PEOPLE TO DROP THEIR PRICE TO $ 297.50 AND THE READING LIGHTS INSTALLED EACH SEAT $ 34.95 EACH.

I THINK WE HAVE EVERYTHING, GIVE ME A CALL AS SOON AS POSSIBLE

Frank

THIS IS THE SEAT MOVES BACK & FORWARD & SWIVELS DOES NOT RECLINE.

MAIN CUT OFF SWITCH FOR LIGHTS INSTLD. IN DASH

8 (Illegible Word) SEATS INSTLD ON SWIVEL BASES W/SLIDE TRACKS AS SHOWN

SEAT INSTALLATION NOTE:

POSITION ALL SEATS APPROXIMATELY 4 (Illegible Word) FROM SIDE TO ALLOW FOR:

- SWIVEL OF SEATS

- STOREAGE OF BLUE CASES ON FLOOR BETWEEN SEAT AND SIDE WALL

WE WILL USE 8 OF THESE DRIVE & PASSENGER WILL BE FORD.

SPECIAL NOTE:

CENTER THIS SEAT (MOVE INTO AISLE) SO PASSENGERS CAN ENTER BEHIND SEAT AND (Illegible Words) AISLE TO THEIR SEATS

9 SINGLE AIRCRAFT LIGHT W/SEPARATE SWITCHES INSTLD OVER EACH SEAT AS SHOWN.

(Graphics omitted)

ID: 1983-2.21

TYPE: INTERPRETATION-NHTSA

DATE: 06/23/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: The BF Goodrich Company -- C.J. Johnston, Manager, Product Reliability

TITLE: FMVSR INTERPRETATION

ATTACHMT: 4/5/83 letter from Frank Berndt to Toyo Tire Corporation

TEXT:

Mr. C. J. Johnston Manager, Product Reliability The BF Goodrich Company Tire Group 500 South Main Street Akron, Ohio 44318

Dear Mr. Johnston:

This is in response to your May 12, 1983 letter regarding the tire sidewall molding requirements of the Uniform Tire Quality Grading Standards. In that letter you indicated that, acting in reliance on statements by a NHTSA employee, your company modified certain new tire molds by deleting the numerical treadwear grade from the sidewall label, but leaving the word "TREADWEAR" in place. NHTSA subsequently stated, in a letter to Toyo Tire Company, that if the sidewall molded label is modified, both the numerical grade and the word "TREADWEAR" should be deleted. You also indicated that BF Goodrich is now in the process of modifying the molds again to delete the word "TREADWEAR".

In light of your good faith reliance on agency statements and your current efforts to conform to the policy stated in our letter to Toyo Tire Company, NHTSA will take no enforcement action regarding sidewall molding requirements for tires produced through the completion of the mold modification process.

For future reference, please be aware formal interpretations of legal requirements are issued only by this office and only in writing. To obtain an interpretation upon which reliance can be placed for purposes of making business decisions, you should direct a letter of inquiry to the Chief Counsel's Office.

Sincerely,

Frank Berndt Chief Counsel

May 12, 1983 Mr. Frank Berndt, Chief Counsel

Dear Sir:

The BF Goodrich Company agrees with the NHTSA decision to suspend the treadwear grading requirement specified in 49 CFR 575.104. We agree with the NHTSA statement that "the treadwear grades are apparently not only failing to aid many consumers, but also are affirmatively misleading then in their selection of new tires."

When the suspension was announced, we had several new lines of molds ready for production. We felt that removing the numerical grade would help avoid further confusion. Our decision to leave the word "treadwear" in these molds was simply a matter of economics. The molds were already stamped and we wished to avoid the expense and delay required to remove it, especially due to the uncertainties as to litigation on this issue.

Before deleting the numerical grade, we sought clarification of the new tire labeling requirements. On February 7, 1983, a telephone discussion was held with the designated NHTSA contact regarding the acceptability of leaving the word "treadwear" but removing the numerical treadwear grade from new lines of tire molds. We were advised that this would be acceptable. This same advice was given by the agency to the Deputy Director of the Tire Division, Rubber Manufacturers Association (RMA), and it was in turn reported to other RMA members.

We learned, according to your April 5, 1983 letter to Mr. K. Inoue of the Toyo Tire Corporation, that the omission of the numerical grade now is not considered an acceptable format for the UTQG labeling on the sidewall of tires. The reason stated was that the display format could be interpreted as attributing the grade which appears after the word "traction" to both the treadwear and traction performance of the tire and thus could confuse tire purchasers.

We had a telephone discussion with a member of your staff on April 12, 1983 to review this history and inquire about appropriate action to be taken with regard to our present circumstances. This letter is the result of his suggestion that essential information covering this situation be communicated to you.

Since February, 1983, we have produced several new lines of tires with the numerical treadwear grades omitted. To date, we have produced approximately 420,000 tires from these molds. The mold branding is being revised to remove the word "treadwear." However, because of the number of molds involved, it is anticipated that the branding revision could take up to two months to complete. During that period, we could produce another 150,000 tires.

To summarize, we acted in good faith to comply with the treadwear suspension and with verbal guidance from the agency to both us and the Industry, through RMA. Accordingly, our tires no doubt will be part of a larger group of tires produced by the Industry with various branding formats during the interim period prior to implementation of the final version of the new branding format. Nevertheless, and in the meantime, we have started the action described above, consistent with your letter of April 5, 1983 to Toyo Tire Corporation.

Yours truly,

C. J. Johnston Manager, Product Reliability

Enclosure (4/5/83 letter from Frank Berndt to Toyo Tire Corporation omitted here.)

ID: 1983-2.22

TYPE: INTERPRETATION-NHTSA

DATE: 07/01/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Grumman Flxible Corporation -- Charles R. Sidner, Product Safety Engineer

TITLE: FMVSS INTERPRETATION

TEXT:

Charles R. Sidner, CPSM Product Safety Engineer Grumman Flxible Corporation 970 Pittsburgh Drive Delaware, Ohio 43015

Dear Mr. Sidner:

This responds to your March 31, 1983, letter asking about the lo-air pressure warning device that is required by Standard No. 121, Air Brake Systems. In particular you ask whether the requirement must be met with two switches, one on the primary and one on the secondary air tank, or whether one switch on the supply tank would be sufficient.

S5.l.5 of the standard states that a warning signal shall be provided to give a continuous warning of a loss of pressure in the service reservoir system below 60 p.s.i. The intent of the section clearly is to provide a warning to a driver of any instance that results in a loss of pressure in either the primary or secondary service reservoir system.

Dependinq upon the design of any individual brake system, it might be necessary for more than one switch to ensure that the driver will be alerted to such an air loss. For example, a single switch on the supply tank might be inadequate to signal a loss of pressure in the primary or secondary service reservoir system if the action of the compressor masks such loss of pressure. It is up to the manufacturer to determine whether its system is designed in a way that requires more than one switch.

Sincerely,

Frank Berndt Chief Counsel

March 31, 1983

Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Reference: (a) FMVSS No. 121, Air Brake Systems S5.l.5 Warning Signal

Dear Sirs:

Your assistance is requested with respect to an official interpretation/ clarification of reference (a) above as it relates to the installation of lo-air pressure switches on our Flxible-METRO transit coach.

In accordance with S5.l.5, as we interpret the standard, when the ignition is in the "on" or "run" position and the pressure in the service reservoir system is below 60 ps, there shall be a signal either visible....or both audible or visible.

In order to attain this signal, we have positioned a lo-air pressure switch, electrically operated at both the primary and secondary air tank (service reservoir system).

The issue for interpretation is whether the two lo-air switches on both the primary and secondary tanks are necessary to meet the requirement, or if one lo-air switch on the supply tank only to activate the warning signal is adequate to meet the requirements of S5.1.5.

We shall continue to locate a lo-air switch on both the primary and secondary tanks until we are advised otherwise.

Sincerely,

GRUMMAN FLXIBLE CORPORATION

Charles R. Sidner, CPSM Product Safety Engineer

cc: E. Kravitz J. Bolton L. Musser T. Schubach

ID: 1983-2.23

TYPE: INTERPRETATION-NHTSA

DATE: 07/01/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: MMC Services Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Masakatsu Kano Executive Vice President MMC Services Inc. 3000 Town Center, Suite 1960 Southfield, Michigan 48075

Dear Mr. Kano:

This responds to your letter of April 20, 1983, asking several questions concerning the requirements for armrests in Safety Standard No. 201, Occupant Protection in Interior Impact. That standard requires, as one optional means of compliance (S3.5.1(c)), that each armrest have at least 2 inches of coverage withing the pelvic impact area, when measured vertically in side elevation. You ask whether this 2-inch measurement may be made from the outermost points of the base of the armrest as it fits against the door inner trim, or whether the measurement must be made from the inboard portion of the armrest that would actually contact a vehicle occupant. You also ask if the standard permits an armrest surface that would contact an occupant to be tilted at a 15 degree angle from the vertical, and whether it permits that surface to have "low moles" or "shallow bezels" (i.e., minor protrusions or indentations).

With reference to the drawing included in your letter, Standard No. 201 would require the specified 2-inch measurement to be taken at the "H1" parameters, rather than the "HO". The purpose of the requirement is to ensure that there is at least 2 inches of coverage within the pelvic impact area. For this requirement to be meaningful, the covered surface must be contactable by the vehicle occupant. The vehicle occupant would not contact the base of the armrest illustrated in your drawing, regardless of its vertical length.

Paragraph S3.5.1(c) does not preclude "moles" or "bezels" in the armrest, since there are no limitations on radius of curvature. A "mole" which projected only moderately into the vehicle interior would be included in the calculation to determine compliance with the requirement for 2 inches of covered surface. If a mole projected so far into the vehicle interior that it would prevent pelvic contact with the rest of the armrest, however, only the mole would be included in the calculation.

By the same token, while a "bezel" is not precluded, it is not included in the calculation if it is so deep that it cannot be contacted.

Paragraph S3.5.1(c) does not specify any particular angle at which an armrest must be set with relation to the door inner trim. Therefore, it is permissible for the inboard surface of the armrest illustrated in your drawing to make an angle of 15 degrees from the vertical.

Finally, I would point out that paragraph S3.5.1(c) is one of three optional means of compliance for manufacturers who install armrests. A manufacturer may also satisfy the requirements of Standard No. 201 by complying with either S3.5.1(a) or S3.5.1(b), in which case it is not necessary to provide 2 inches of coverage within the pelvic impact area.

Sincerely,

Original Signed By Frank Berndt Chief Counsel

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington D.C. 20590

Subject: Interpretation of FMVSS 201: Occupant Protection In Interior Impact

Dear Mr. Berndt:

This is to ask your interpretation of FMVSS 201; S 3.5.1 (C) (armrests) which states, "Along not less than 2 continuous inches of its length, the armrest shall, when measured vertically in side elevation, provide at least 2 inches of coverage within the pelvic impact area" is not clear about the measuring method, therefore, the following is our own interpretation. (Reference to the figure of attachment);

We interpret the "at least 2 inches" length "HO" which is measured vertically in side elevation.

If your interpretation is not "HO" but "H1",

i) Is it acceptable that the lean of the armrest side- surface is 15 degrees (0=15) or less?

ii) Is it allowable that the armrest side-surface has the low mole or the shallow bezel, with the following dimensions:

-- Width of mole or bezel "W1" or "W2" is equal to or less than 0.5 inch.

-- Height of mole "D2" and depth of bezel "D1" are equal to or less than 0.2 inch, respectively.

Very truly yours,

Masakatsu Kano Executive Vice President

ID: 1983-2.24

TYPE: INTERPRETATION-NHTSA

DATE: 07/05/83

FROM: Frank Berndt, NHTSA

TO: Koji Tokunaga -- Manager of Engineering, Isuzu Motors America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Koji Tokunaga Manager of Engineering Isuzu Motors America, Inc. 21415 Civic Center Drive Southfield, Michigan 48076

Dear Mr. Tokunaga:

This responds to your letter of May 26, 1983, asking whether a continuous loop seat belt system you are considering would comply with the requirments of Safety Standard No. 208, Occupant Crash Protection.

Continuous seat belt systems are permissible under Safety Standard No. 208 if certain conditions are met. Paragraph S7.1.1 of that standard requires adjustment of the lap belt portion of Type 2 belts "by means of an emergency locking or automatic-locking retractor" and adjustment in most cases of the upper torso portion "by means of an emergency-locking retractor." The language permits some single retractor, continuous loop systems if the single retractor does "automatically adjust" the tension of the lap belt portion to prevent excessive slack. Because of the danger of submarining due to a slack lap belt, the agency has restricted the acceptability of continuous loop systems under S7.1.1.

To conform to the requirements, the buckle of the assembly must be designed by the manufacturer with a sufficiently low level of friction to qualify the lap portion as automatically adjusting. This means that when the belt is buckled by the vehicle occupant, the retractor must be capable of cinching the lap belt tightly around the occupant's pelvic area (regardless of where the buckle tongue is located along the belt webbing when the belt is fastened). The friction in the buckle tongue cannot be so high that the occupant must manually pull the belt webbing through the tongue to tighten the lap belt.

We note your statement that the one-way frictional bar included in your contemplated belt design "permits the wearer to fasten the lap belt more tightly than the tension from the ELR usually achieves." This is certainly permissible, provided the ELR does tighten the belt sufficiently for the lap belt to be considered automatically adjustable. You will have to make this determination, however. Please note that it is the manufacturer's responsibility to determine whether or not its belt design complies with the standard. The agency does not offer advance approval of any motor vehicle or piece of motor vehicle equipment. Further, the agency does not make determination of compliance of a vehicle or item of equipment prior to the manufacturer's certification of that vehicle or equipment.

I hope this clarification will be of help to you in your design plans.

Sincerely,

Original Signed By Frank Berndt Chief Counsel

Mr. Frank Berndt Chief Counsel

Subject: New Seat Belt System - Compliance with FMVSS 208. S7.1.1

Dear Mr. Berndt:

The purpose of this letter is to request your confirmation on the interpretation of the requirements of FMVSS 208 S7.1.1 in the context of our new seat belt system which we plan to use as soon as possible for the front outboard seating postions on our passenger cars.

This belt system is of a continous webbing loop type with an emergency locking retractor (ELR) installed on the lower part of the B-pillar. The belt webbing goes up from the ELR through a metal ring mounted on the upper part of the B-pillar, then downward diagonally across the occupant's upper torso, through a latch plate which couples the belt to the inboard buckle. Then sideways across the occupant's lap, and to the outboard anchor.

The new feature of this design is a one-way frictional bar incorporated in the latch plate which in effect is the junction between lap and shoulder portions of the webbing. This device permits the wearer to fasten the lap belt more tightly than the tension from the ELR usually achieves, while preventing the lap belt from loosening out as long as the belt is worn. When the belt is worn by the occupant, any slack in the lap belt is removed by his action to pull out the shoulder belt from the retractor. Even when he did not tighten the lap belt snugly, tensions on the shoulder belt caused by his normal motions during vehicle operation work to cause the slack in the lap belt to be taken up by the retractor.

A webbing tension-relieving device is not incorporated in this belt system.

We believe this design meets the intent of FMVSS 208 S7.1.1 because the one-way feature of the latch plates does no interfere with the function of the single retractor to automatically adjust the tension of the lap belt portion ot prevent excessive slack as mentioned in the interpretation letters issued by NHTSA to Renault (dated Sept. 25, 1972) General Motors (dated March 27, 1975) and to Chrysler (dated June 13, 1975).

We request your letter of confirmation regarding this interpretation of FMVSS 208 S7.1.1 in the context of the belt system design described above. Since our final tooling commitments to produce this system must be made very shortly, we would appreciate your prompt review and response.

We are looking forward to hearing from you.

Sincerely yours,

Koji Tokunaga Manager of Engineering

ID: 1983-2.25

TYPE: INTERPRETATION-NHTSA

DATE: 07/05/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Volvo of America Corporation

TITLE: FMVSS Interpretation

TEXT: William Shapiro,. P.E. Manager, Regulatory Affairs North American Car Operations Product Planning and Development Volvo of America Corporation Rockleigh, New Jersey 07647

Dear Mr. Shapiro:

This responds to your letter of May 24, 1983, requesting an interpretation concerning the retraction force requirements to Safety Standard No. 209, Seat Belt Assemblies. You are considering a Type 2 seat belt design which includes an emergency locking retractor for continuous loop webbing and an emergency locking retractor for additional webbing at the inboard buckle portion of the system. You state that this inboard webbing is extended only if the belt is used by an extremely large occupant. You ask whether the retraction force requirements of the standard allow testing with the webbing of the entire system extended 75%, i.e., even if this mean; that no webbing is extended from the inboard retractor, so that the retraction force is actually only measured from the retractor for the continuous loop portion of the belt.

Paragraph @4.3(j) of Safety Standard No. 209 specifies that an emergency locking retractor of a Type 1 or Type 2 seat belt assembly, when tested in accordance with the procedures specified in paragraph @5.2(j) shall:

(1) expert a retroactive force of at least 0.6 pound under zero accelaration when attached only to the pelvic restraint: (5) exert a retroactive force of not less than 0.2 pound and not more than 1.1 pounds under zero acceleration when attached only to in upper torso restraint;

(6) exert a retroactive force of not less than 0.2 pound and not more than 1.5 pounds under zero acceleration when attached to a strap or webbing that restrains both the upper torso and pelvis.

The test procedures of paragraph @5.2 (j) specify that these retraction forces are to be measured with the belt webbing extended from the retractor to 75% of its length.

The requirements of @4.3(j) apply to each retractor on a Type 1 or Type 2 belt system. There is no exception in the standard for a system which includes two or more retractors which exert force on the same belt webbing. Thus, both retractors on your proposed system would have to comply with the requirements of the standard independently of one another. Under the test procedure you suggest, the retraction force of the inboard retractor would not be measured. This is contrary to the explicit language of the standard. Both retractors on your proposed system would have to comply with the force requirements of paragraph @4.3(j) (6). This is true because both retractors are attached "to a strap or webbing that restrains both the upper torso and the pelvis." Therefore, the retraction force on your inboard retractor must be not less than 0. 2 pound and not greater than 1.5 pounds when the webbing on that retractor is extended to 75% of its length. The same is true for the retractor on the continuous loop portion of the system.

I hope this has clarified any misunderstanding you might have had concerning these requirements.

Sincerely,

Frank Berndt Chief Counsel

ID: 1983-2.26

TYPE: INTERPRETATION-NHTSA

DATE: 07/07/83 EST

FROM: FRANK BERNDT -- CHIEF COUNSEL, NHTSA

TO: BINICHI DOI -- NSK REPRESENTATIVE OFFICE

TITLE: NOA-30

ATTACHMT: MEMO DATED 1-31-83, SAFETY BELT RETRACTORS, TO ROBERT NELSON, FROM BINICHI DOI

TEXT: This responds to your letter asking whether a continuous loop seat belt system with a tension reliever ("window-shade device") on the upper torso section of the belt must have a one-way locking tongue.

Continuous seat belt systems are permissible under Safety Standard No. 208 if certain conditions are met. Paragraph S7.1.1 of that standard requires adjustment of the lap belt portion of Type 2 belts "by means of an emergency locking or automatic locking retractor" and adjustment in most cases of the upper torso portion "by means of an emergency-locking retractor." The language permits single retractor, continuous loop systems if the single retractor does "automatically adjust" the tension of the lap belt portion to prevent excessive slack. Because of the danger of submarining due to a slack lap belt, the agency has restricted the acceptability of continuous loop systems under S7.1.1 in two areas.

First, to conform to the requirements, the buckle of the assembly must be designed by the manufacturer with a sufficiently low level of friction to qualify the lap portion as automatically adjusting. This means that when the belt is buckled by the vehicle occupant, the retractor must be capable of cinching the lap belt tightly around the occupant's pelvic area (regardless of where the buckle tongue is located along the belt webbing when the belt is fastened). The friction in the buckle tongue cannot be so high that the occupant must manually pull the belt webbing through the tongue to tighten the lap belt. Based on our viewing of your proposed belt system (presented by your representative in a May 25th meeting), it is our opinion that your system does not have a sufficiently low level of friction that it would automatically adjust the lap belt portion. It is impossible for us to judge how this

system would perform when installed in a vehicle, however, since the angle of the buckle tongue at the time of fastening does affect its friction level. It is the manufacturer's responsibility to determine whether or not its belt design complies with the standard. The agency does not offer advance approval of any motor vehicle or piece of motor vehicle equipment. Further, the agency does not make determinations of compliance of a vehicle or item of equipment prior to the manufacturer's certification of that vehicle or equipment.

The second restriction in regard to continuous loop systems concerns the use of manual and automatic tension relieving devices on the upper torso portion of the continuous loop. In past letters of interpretation, the agency has limited the use of tension relieving devices to the upper torso section of seat belts that have an individually adjustable lap belt. A system does not have an individually adjustable lap belt if slack which is introduced into the continuous loop by a "window shade" device or "comfort clip" is directly transferred to the lap belt. Thus, in answer to your specific question, yes, a continuous loop seat belt system with a tension reliever on the upper torso portion of the belt should have a one-way locking tongue or some other method of preventing slack from returning to the lap belt. The high friction in the buckle tongue of your belt design would likely prevent the return of belt slack to the lap belt. However, as pointed out above, this high friction would also likely prevent the lap belt from adjusting automatically. Granted, these are somewhat conflicting concerns and they do present a tremendous design challenge. However, the agency believes these are necessary requirements if manufacturers include tension-relieving devices in their continuous loop systems.

I hope this clarification will be of help to you in your design plans.