ID: aiam0252

Dear Mr. Walders: This will acknowledge your letter of July 27, 1970 to the Nationa Highway Safety Bureau requesting an interpretation of Federal Motor Vehicle Safety Standard No. 110.; You are correct in your statement that no formal petition for rul making action is necessary for tire and rim combination cited within the references of S3 of Standard No. 109.; Concerning your question on 'approval equivalent rim', we offer th following. The policy of the Bureau in 1967 at the time of the promulgation of Standard No. 109 and No. 110 was to give a 'blanket' approval of all rims cited within the references. From that time on however, all *new* tire and rim combinations had to be approved by the Bureau. After the tire and rim combination was approved then it was listed within Table I, Appendix A of Standard No. 110.; Standards No. 109 and No. 110 do not have requirements for ri contours. Our standards only specify the flange letter-code and width for a particular rim resignation. Therefore, any request to change a rim dimension of an existing rim does not require a formal action by this Bureau.; Sincerely, Lawrence R. Schneider, Acting Deputy Chief Counsel

ID: aiam0251

Dear Mr. Walders: This will acknowledge your letter of July 27, 1970 to the Nationa Highway Safety Bureau requesting an interpretation of Federal Motor Vehicle Safety Standard No. 110.; You are correct in your statement that no formal petition for rul making action is necessary for tire and rim combination cited within the references of S3 of Standard No. 109.; Concerning your question on 'approval equivalent rim', we offer th following. The policy of the bureau in 1967 at the time of the promulgation of Standards No. 109 and No. 110 was to give a 'blanket' approval of all rims cited within the references. From that time on however, all *new* tire and rim combinations have to be approved by the Bureau. After the tire and rim combination was approved then it was listed within Table I, Appendix A of Standard No. 110.; Standards No. 109 and No. 110 do not have requirements for ri contours. Our Standards only specify the flange letter-code and width for a particular rim designation. Therefore, any request to change a rim dimension of an existing rim does not require a formal action by this Bureau.; Sincerely, Lawrence R. Schneider,Acting Deputy Chief Counsel

ID: 1984-1.17

TYPE: INTERPRETATION-NHTSA

DATE: 02/29/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: United States Testing Company Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Frank Pepe Assistant Vice President Engineering Services Division United States Testing Company, Inc. 1415 Park Avenue Hoboken, New Jersey 07030

Dear Mr. Pepe:

This responds to your letter concerning Safety Standard No. 209, Seat Belt Assemblies. You asked several questions about the requirements applicable to Type 2 Vehicle Sensitive Emergency Locking Retractor utilizing a tension reducer device. The particular device you are concerned about is, according to your letter, activated by the vehicle door. With the door open the mechanism operates in a high tension mode; with the door closed the mechanism is in a low tension mode.

By way of background information, this agency does not grant approvals of vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act it is the responsibility of the manufacturer to certify that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter.

Safety Standard No. 209 specifies requirements concerning minimum and maximum retraction force. Requirements are specified for both initial retraction force and retraction force after a test sequence which includes lengthy retractor cycling. See sections S4.3(j), (k) and S5.2(k).

As you know, retractors have traditionally had only one rather than two tension modes. Standard No. 209 does not prohibit a design with two tension modes. However, as written, the standard's requirements do not distinguish between tension modes.

We agree with your suggestion that both tension modes should be tested for retraction force effort as specified in the standard. However, we do not agree with your suggestion that the high tension mode should only be tested for minimum retraction force and the low tension mode for maximum retraction force. Instead, because Standard No. 209 does not distinguish between tension modes, we interpret the standard to require that all of its requirements must be met in both tension modes. For example, under section S4.3(j)(6), both tension modes must exert a retractive force within the 0.2 to 1.5 pound range. For testing purposes, of course, a single retractor could only be fully tested for one of the two modes, since testing for both modes would involve twice the amount of cycling required by the standard.

Your letter states that since the high tension mode is used only for stowing the webbing and is not in operation during normal use, you believe that only cycling tests without lock-ups should be performed in testing. While we appreciate this argument, the standard, as written, does not permit that exception. Section S5.2(k) states in relevant part:

attached to upper torso restraint shall be subjected to 45,000 additional cycles of webbing withdrawal and retraction between 50 and 100 percent extension. The locking mechanism of an emergency locking retractor shall be actuated at least 10,000 times within 50 to 100 percent extension of webbing during the 50,000 cycles....

Since the standard does not distinguish between tension modes, lock-ups should be performed in testing for both the low and high tension modes.

As already noted, the retractor in question represents a new design which was not specifically considered in drafting Standard No. 209. If the standard as written creates problems, the manufacturer may wish to consider submitting a petition for rulemaking to amend the standard to establish special test procedures.

Your letter suggests that there may be a conflict between section S7.4.2 of Standard No. 208, Occupant Crash Protection, and Standard No. 209's 0.2 pound retraction force requirement (section S4.3(j)). However, section S7.4.2 of Standard No. 208 only applies to automatic belt systems, while section S5.3(j) of Standard No. 209 only applies to active belt systems. Therefore, there can be no conflict.

Sincerely,

Frank Berndt Chief Counsel

May 12, 1983

Mr. William Smith National Highway Traffic Safety Administration 400 - 7th St., S.W. Room 5320 Washington, D.C. 20590

Dear Mr. Smith:

Some questions have been raised pertaining to the requirements relating to retraction force and lock-up distance on Type 2 Vehicle Sensitive Emergency Locking Retractors utilizing a tension reducer device (comfort type mechanism). This particular device is activated by the vehicle door; with the door open the mechanism operates in a high tension mode; with the door closed the mechanism is in a low tension mode.

The purpose of measuring retraction force is to insure that two (2) separate requirements are met.

1. Retraction force is high enough to sufficiently retract the webbing to its normal stowed position (Minimum Requirement).

2. Retraction force is not so high as to cause discomfort to the user (Maximum Requirement).

Since the referenced tension reducer is activated solely by door position, and the user has no manual control of the tension reducer operation, a question is raised pertaining to retraction force requirements.

We feel that both tension modes should be tested for retraction force effort as specified in FMVSS 209. That is; High Tension Mode -minimum retraction force requirements and Low Tension Mode - maximum retraction force requirement.

However, this raises another question on FMVSS 209 minimum requirements for retractor force for Type 2 Assemblies (0.2 lbs.). In FMVSS #208 proposed requirements for Comfort and Convenience, slack is allowed to be introduced in the webbing (S7.4.2.) provided that it is cancelled when the adjacent door is opened. This appears to be in contradiction of the 0.2 lbs. retraction force requirement of FMVSS 209 when utilizing a tension reducer type of retractor. Therefore, it seems, that since the tension reducer type of retractor is designed strictly for comfort, and not to induce slack, only 50% loss in retraction effort requirement after cycling should be pertinent.

The purpose of retractor cycling is to determine if the retractor will perform satisfactorily during repeated use and that spring tension does not change significantly as well as its ability to lock-up.

Since the high tension mode is used only for stowing the webbing and is not in operation during normal use, we feel that only cycling tests without lock-ups need be performed in accordance with FMVSS #209.

The low tension mode is the portion of the retractor that will perform during impact conditions and therefore should require standard cycling with lock-ups.

Therefore, we feel an interpretation of the adequacy of the minimum retraction force requirement pertaining to Comfort and Convenience type mechanisms is necessary. Also do both tension modes have to satisfy the Retractor Performance requirement of FMVSS #209.

We would appreciate your review of the above comments and your interpretation of same.

Very truly yours,

UNITED STATES TESTING COMPANY, INC.

Frank Pepe Assistant Vice President FP/na

ID: aiam3065

Dear Mr. Chamberlain: This responds to your letter of August 2, 1979, concerning th requirements of Safety Standard No. 208, *Occupant Crash Protection*, as applicable to vehicles sold to the U.S. Postal Service.; Under the general requirements of paragraph S4.2.2 for trucks an multipurpose passenger vehicles with GVWR's of 10,000 pound or less, Type II seat belt assemblies are required for outboard designated seating positions. That paragraph does provide optional requirements, however, for certain vehicles that are designed to be exclusively sold to the U.S. Postal Service. Under the optional requirements, these vehicles can instead meet the requirements of S4.2.1.2 which allow the use of Type I seat belts at outboard designated seating positions in convertibles, open-body type vehicles, walk-in van- type vehicles and for outboard seating positions that do not include the windshield header in the head impact area. Therefore, if the 'X-1' vehicles described in your letter are any of these vehicle types and are sold exclusively to the Postal Service, they may legally be equipped with either Type I or Type II assemblies, at the manufacturer's option.; Regarding your second question, whether or not the 'X-1' vehicle conform to Postal Service specifications is a matter of contractual agreement that must be determined by the contracting parties. The most the agency can say is that the 'X-1' vehicles would be in compliance with Safety Standard No. 208 if they qualify as one of the vehicle types discussed above.; I hope this has been responsive to your inquiry. Sincerely, Frank Berndt, Chief Counsel

ID: aiam4900

Dear Mr. Johannessen: This responds to your letter seeking a interpretation of Standard No. 209, Seat Belt Assemblies (49 CFR 571.209). More specifically, you asked about the meaning of the requirement in S4.1(b) of Standard No. 209 that '...the pelvic restraint shall be designed to remain on the pelvis under all conditions, including collision or roll-over of a motor vehicle.' I am pleased to have this opportunity to explain this provision. You explained that some have asserted that a safety belt fails to comply with S4.1(b) if it actually moves off an occupant's pelvis during a crash. To reach such a conclusion, one must ignore the words 'be designed to' and treat the requirement as though it read '...the pelvic restraint shall remain on the pelvis under all conditions, including collision or roll-over of a motor vehicle.' Such a reading is plainly incorrect, because it reads the phrase 'be designed to' out of the regulation. You explained that you believe S4.1(b) of Standard No. 209 is merely a hortatory phrase that is essentially meaningless. According to your letter, this language first appeared in a standard developed by the Society of Automotive Engineers (SAE), and was subsequently adopted verbatim in the safety belt standard issued bye the Department of Commerce and in Standard No. 209. You asserted that the SAE committee that developed this language included it as a design goal only, since the committee members 'were aware that they had no objective test procedure to confirm compliance with this design goal,' and 'were aware that the seat belt would not necessarily remain on the pelvis during the entire collision event in all of the varied collisions encountered in the field.' We cannot agree with your suggestion that S4.1(b) of Standard No. 209 is merely a hortatory design goal. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) requires each safety standard to meet certain requirements, including, among other things, that the standard be practicable, meet the need for motor vehicle safety, and be stated in objective terms. When NHTSA adopted Standard No. 209 as one of the initial Federal motor vehicle safety standards, the agency concluded that Standard No. 209, including S4.1(b), met all applicable statutory criteria. It is true that there is no compliance test procedure specifically for S4.1(b) of Standard No. 209. However, the meaning of that provision becomes clear when it is viewed in the context of the occupant protection requirements in Standard Nos. 208, Occupant Crash Protection, Standard No. 210, Seat Belt Assembly Anchorages, and the rest of Standard No. 209. Standard No. 208 requires, among other things, that vehicles be equipped with safety belts and that the lap belt portions of those belts adjust to fit persons ranging in size from a 6-year-old child to a 95th percentile adult male (See S7.1.1). Standard No. 209 requires that safety belts meet specified strength, durability, and other performance requirements. Standard No. 210 requires that the anchorage holding the safety belt in the vehicle meet stringent strength requirements, so that the belt will remain attached to the vehicle in a crash, and lap belt location requirements (S4.3.1), including a minimum lap belt mounting angle, to reduce the likelihood of occupant submarining, i.e., having the lap belt move off the pelvis. See the detailed discussion of the minimum lap belt mounting angle at 55 FR 17970, at 17974, April 30, 1990. Viewed in this context, we believe that the requirement of S4.1(b) of Standard No. 209 means that safety belts must be designed to be capable of being properly adjusted and positioned on the pelvis of occupants ranging from 6-year-old children to 95th percentile adult males. The belts must also be capable of remaining on the pelvis of such occupant during collision or roll-over. A belt system that was not capable of being positioned on the pelvis and remaining there during crashes would not comply with S4.1(b). Given this meaning and purpose, we offer the following observations. First, the fact that a lap belt moved off the occupant's pelvis during a collision would not of itself show that the lap belt failed to comply with S4.1(b) of Standard No. 209. Compliance with S4.1(b) of Standard No. 209 is determined by the design of the safety belt system, not the performance of individual safety belts while in service. Second, the actual performance of a safety belt in a vehicle (e.g., a lap belt moving off the occupant's pelvis during a crash) could indicate that the lap belt failed to comply with S4.1(b) of Standard No. 209. If the agency had information indicating that a particular belt design was not capable of being properly positioned on the pelvis or not capable of remaining on the occupant's pelvis when installed in particular vehicles in particular crash modes, the agency might well investigate whether that safety belt design complied with S4.1(b). However, NHTSA has no such information about any safety belt systems at this time. Sincerely, Paul Jackson Rice Chief Counsel;

ID: nht72-4.1

DATE: 08/31/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: General Motors Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 21, 1972, on the subject of the operation of the seat belt warning system when the vehicle is in one of the free start modes allowed by S7.4.3 and S7.4.4 of Standard No. 208.

You are correct in your understanding that S7.3.5.4 does not require the warning to operate when the ignition switch is in the "start" position if the conditions described in S7.4.3 and S7.4.4 exist. Under those conditions, the interlock system continues to act as if the operation of the belt systems had not been followed by their release. By the same logic, the warning system activation required by S7.3.5.4 is in abeyance until the ending of the free start conditions.

ID: nht72-4.8

DATE: 10/20/72

FROM: F. ARMSTRONG FOR ROBERT L. CARTER -- NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 26, 1972, to Mr. Douglas W. Toms, in reference to our restraint systems and other standards for motor vehicles which may be purchased for use by law enforcement agencies.

Our Federal motor vehicle safety standards regulate new motor vehicles up to the sale to the purchaser. Accordingly, a law enforcement agency or other purchaser is not restricted by Federal law from removing or modifying required vehicle safety equipment once delivery is taken.

In the case of restraint systems, an aircraft or racing type safety harness with double shoulder belts would probably be superior to the standard automotive safety belts. However, our testing with human volunteers and baboons has demonstrated that the air cushion provides better crash protection than either aircraft or automotive safety belt systems. Thus, while we would not have reservations about replacing the standard automotive safety belts with the aircraft or racing type harness, we would not recommend replacing an air cushion system with any type of harness system. Rather, we would recommend relocating shotguns, communications, or other equipment to a location compatible with air cushion function if at all possible. In most cases, the vehicle manufacturers should be able to provide assistance in this regard.

I appreciate your interest in our motor vehicle safety programs. We would be pleased to provide whatever advice or assistance we may be able to give in assuring that law enforcement officers are afforded the safest vehicles suitable for their planned application.

SINCERELY,

DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

September 26, 1972

File No.: 1.A2711.A997

Douglas W. Toms, Administrator National Highway Traffic Safety Administration U. S. Department of Transportation

Dear Mr. Toms:

There are few who are more concerned with highway safety than the members of the California Highway Patrol. The members of this Department spend most of their waking hours striving for the reduction of injuries and deaths on the roadways of California. Certainly Departmental policy has supported all governmental regulations aimed at the reduction of highway accidents. However, some present and proposed automotive design features hinder the effectiveness of the traffic officer in performing his duties. In fact, some regulations will actually result in a reduction of safety for the patrolman or police officer.

A restraint system which will slow an officer's exit from or entry into the car can be dangerous in some situations. Could not law enforcement agencies be allowed some leeway in the ordering of their cars? An aircraft-type quick release belt/harness arrangement would be effective yet would not create the problems of entry and exit inherent to the proposed sequential system to be introduced on 1974 model cars.

Shotguns are presently mounted in a vertical position to the right of the transmission hump and are attached to the dash. The vertical mounting provides visibility of an enforcement item, the muzzle is aimed in the safest direction, and the near center location provides accessibility to each front seat occupant. If the manufacturers supply air bags to comply with passive restraint regulation, will qualified law enforcement agencies be allowed to deactivate the system until the car is sold following its useful life? The convenient and safe installation of the shotgun and communications equipment will be most difficult in a car equipped with an armed air bag system.

It would seem that some consideration must be given to the needs of law enforcement agencies. Exemptions would not be requested just for the sake of reducing problems but rather in those few instances where a design requirement in the name of occupant safety actually increases the hazard to a police officer on duty.

The problems heretofore related are only a few of the many which face those who must use basically standard production automobiles for law enforcement adaptation. It is hoped that some action can be taken in those instances where regulations may actually make the car more dangerous and ineffective for enforcement work.

W. PUDINSKI Commissioner

ID: aiam4226

Dear Ms. Kreeger: This responds to your letters of June 27, 1986, and July 11, 1986, an your subsequent phone conversations with Stephen Oesch of my staff concerning the safety belt installation requirements for multipurpose passenger vehicles and buses. I regret the delay in our response and hope the following information is of assistance to you.; As Mr. Oesch discussed with you, Federal Motor Vehicle Safety Standar No. 208, *Occupant Crash Protection*, sets forth the safety belt installation requirements for passenger cars, trucks, multipurpose passenger vehicles and buses. The standard, a copy of which is enclosed, regulates only the installation of safety belts and does not require their use. However, the Federal Highway Administration's Office of Motor Carriers has issued a regulation (49 CFR Part 392.16) that requires safety belt use by operators of trucks and buses involved in interstate commerce. Belt use is also governed by State mandatory use laws.; S4.2.2 and S4.3 of the standard set forth the safety belt installatio requirements for new multipurpose passenger vehicles (MPV's). Our regulations (49 CFR 571.3) define an MPV as a 'motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' S4.2.2 and S4.3 of Standard No. 208 require the installation of a safety belt for each designated seating position in a MPV.; S4.4 of the standard sets forth the safety belt installatio requirements for buses. Our regulations define a bus as a 'motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons.' S4.4 of Standard No. 208 requires the installation of a safety belt at only the driver's designated seating position in a bus. The agency has set additional safety belt requirements for school buses with a gross vehicle weight rating of 10,000 pounds or less. S5(b) of Standard No. 222, School bus passenger seating and crash protection, requires the installation of a safety belt at the passenger seats in those small school buses. A copy of Standard No. 222 is enclosed.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel

ID: nht92-2.21

DATE: November 18, 1992

FROM: L. J. Sharman

TO: NHTSA, Department of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 3-23-93 from John Womack to L. J. Sharman (A40; Std. 302)

TEXT: Recently, two questions have arisen concerning the procedure to be followed when conducting the flammability test method specified in Motor Vehicle Safety Standard No. 302. Each of the questions, the writers answer and rationale are given on the attached sheets. I am writing to request an advisory opinion as to whether these answers are correct, if not what the correct interpretation should be.

Thank you for your prompt attention to this matter.

QUESTIONS CONCERNING THE FLAMMABILITY TEST PROCEDURE SPECIFIED IN MVSS-302

QUESTION 1.

MVSS-302, in Section S5.3(e), states that the timing for each specimen be started when the flame from the burning specimen reaches a point 1.5 inches from the open end of the specimen and, in Section S5.3(f), is stopped when the flame progresses to a point 1.5 inches from the clamped end of the specimen. Further, the Standard, in Section S5.2.2, states the specimen is oriented so that the surface closest to the occupant compartment air space faces downward on the test frame. The question that has been raised is whether the timing is started and stopped when the flame reaches the designated points on the surface of the specimen closest to the occupant compartment air spaces (the surface facing down during the test), or when the flame reaches the designated points on the surface of the specimen facing away from the occupant compartment air space (the surface facing up during the test).

ANSWER

Timing of the flame should start when the flame from the burning specimen reaches the 1.5 inch point on the surface facing up during the test and stopped when the flame progresses to a point 1.5 inches from the clamped end of the specimen on the surface facing up during the test.

RATIONALE

The Standard states that the bunsen burner and the specimen are positioned so that the center of the bottom edge of the open end of the specimen. While the Standard does not specify how far above the cabinet floor the specimen must be located, the bunsen burner and flame height specified above effectively define this distance. At that height, it is extremely difficult if not impossible to observe the flame front underneath the specimen. If the intent of the standard was to observe the flame front test cabinet floor or some other means of

observing the flame front. Since NHTSA did not make such requirements, the logical location points for starting and stopping the timing are on the surface facing up during the test.

QUESTION 2.

MVSS-302, in Section S5.3(f), states that the flame progression be measured to a point 1.5 inches rom the clamped end of the specimen under test. The standard does not specify actions to be taken after timing has stopped. Some laboratories put out the flame using a small amount of water from a spray bottle. The question has been raised as to whether using a small amount of water from a spray bottle to put out the flame is an acceptable procedure.

ANSWER

The use of a small amount of water from a spray bottle is believed to be acceptable.

RATIONALE

The primary concern with the use of water to put out the flame is whether the water would affect the humidity in the test chamber and, therefore, the test results. MVSS 302 states in Section S5.1.2 that prior to testing each specimen be conditioned at a temperature of 70 degrees F. and a relative humidity of 50 percent, and the test be conducted under those ambient conditions. The Standard does not specify the humidity limits within which the test must be conducted. Considering the short time the specimen is in the chamber before burning and the small amount of water used it is believed that the humidity would not be significantly affected and therefore the procedure to be both acceptable and a good safety precaution.

ID: aiam5258

"Dear Mr. Tanaka: This responds to your FAX of August 4, 1991, to Ms Delmas Johnson of this agency concerning Standard No. 208, Occupant Crash Protection. Your questions and the answers to each follows. Is it true that the belt fastening law now goes into a part of the federal law? The National Traffic and Motor Vehicle Safety Act authorizes NHTSA to issue motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. The Federal requirements do not, however, regulate the use of vehicles. While there is no Federal requirement mandating safety belt use, a recent final rule will impose penalties on states which do not have both a safety belt and a motorcycle helmet use law by 1994. Currently, all the states and territories have some type of mandatory belt use law except Kentucky, Maine, Massachusetts, New Hampshire, North Dakota, and South Dakota. Is it true that the cars with airbag do not need to perform 'Roll Over Test'? Passenger cars manufactured on or after September 1, 1989, are required to be equipped with automatic crash protection at the front outboard seating positions. 'Automatic crash protection' means that a vehicle is equipped with occupant restraints that require no action by vehicle occupants. The two types of automatic crash protection currently offered on new passenger cars are automatic safety belts (which help to assure belt use) and air bags (which supplement safety belts and offer some protection even when safety belts are not used). The performance of automatic crash protection is dynamically tested, that is, vehicles equipped with automatic crash protection systems are required to comply with certain injury criteria as measured by test dummies in a barrier crash test at speeds up to 30 mph. In addition, the automatic crash protection must either meet the lateral and rollover crash protection requirements or have a Type 1 (lap) or Type 2 (lap/shoulder) seat belt assembly. A passenger car equipped with an air bag does not have to comply with the rollover test if it has a Type 1 or Type 2 seat belt at that position. To our knowledge, all vehicles currently being manufactured are certified to the automatic crash protection requirement by installing Type 1 or Type 2 seat belt assemblies. A new Federal statutory requirement will make air bags and Type 2 seat belts mandatory in all cars and light trucks by the late 1990's. I am enclosing a copy of the recently published final rule implementing these requirements. These requirements will make the option of complying with the lateral and rollover crash protection requirements moot. I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure";