ID: aiam2963

Dear Mr. Utans:#I regret the delay in responding to your September 12 1978, letter requesting interpretation of Federal Motor Vehicle Safety Standard 101-80, *Controls and Displays*. The responses to your specific questions regarding the compliance of your prototype monitor of vehicle systems are as follows:#1. When there is no problem with the vehicle systems included in the monitor, only the outline of a car is visible. The displays for items such as oil and electrical charge would not be illuminated. You asked if the monitor in its 'no problem' model would comply with FMVSS 101-80. The answer is yes. There is no requirement that the displays be continuously illuminated.#2. On the monitor, the high beam symbol would be oriented so that it pointed upward. You asked whether this complies with the standard even though the symbol appears in Table 2 of the standard pointing to the left. The answer is yes. The requirement is section 5.2.3 that the display symbol appear preceptually (sic) upright to the driver was not intended to apply to the situation in which the symbol is used in conjunction with a car diagram of the type in your monitor. In such situations, it would be more confusing to place the symbol in the upright position than to orient the symbol so that it bears the same relationship to the diagram as the symbolized equipment does to the actual vehicle.#Sincerely, Frank Berndt, Acting Chief Counsel;

ID: aiam1328

Dear Mr. Gerth: This is in reply to your letter of September 24, 1973, concerning th conformity of an emergency feature of Mercedes-Benz's interlock system to S7.4.3 of Standard No. 208.; The feature you describe would permit the engine starting system to b operated without belt use for a period of 3 minutes after an activation knob inside the engine compartment is depressed. If the vehicle stalls, the driver would have to leave his seat, open the hood, depress the knob, close the hood, and return to his seat, at which point the interlock would be deactivated for the 3-minute period. This bypass feature would apparently supplement other convenience aspects provided pursuant to S7.4.3.; After review of the Mercedes system we have determined that it woul not result in bypassing the interlock in situations where that would not be permissible under S7.4.3 or S7.4.4. We therefore conclude that it is an allowable system and that it may be installed.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1794

Dear Mr. Riechel: This responds to Volkswagen's December 11, 1974, request for determination that a brake system indicator lamp which activates only upon application of the brake pedal with a control force if 50 pounds or more to signal a 'gross loss of pressure' would meet the requirements of S5.3.3 of Standard no. 105-75, *Hydraulic brake systems*:; >>>S5.3.3 Each indicator lamp activated due to a condition specified i S5.3.1 shall remain activated as long as the condition exists, whenever the ignition (start) switch is in the 'on' ('run') position, whether or not the engine is running.<<<; Your question arises as to the meaning of the phrase in S5.3.3. whic requires that the lamp 'remain activated as long as the condition exists', with reference to the condition described in S5.3.1(a) as 'gross loss of pressure (such as caused by rupture of a brake line but not by a structural failure if a housing that is common to two or more subsystems)'. You point out that a condition involving loss if pressure cannot exist in the absence of pressure, that is, after control force is remove from the brake pedal.; While the NHTSA has always believed that the requirement in questio can best be satisfied by an indicator lamp which remains activated after the loss of pressure has occurred, we agree that the language in question could be more clearly drafted to express this intent.Accordingly, we plan to propose an amendment to the standard to eliminate this ambiguity. The proposed effective date of the amendment will be far enough in the future so that any new design changes required to comply may be effected without undue burden on affected manufacturers.; Because we conclude that the reliance Volkswagen has placed on it alternative reading if S5.3.3 can be justified in this case, we would accept the limited warning offered by the system you describe as satisfying the current requirement in S5.3.3 with regard to S5.3.1(a).; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam4274

Dear Mr. Doi: Thank you for your letter of November 14, 1986, to Stephen Oesch of m staff concerning how our regulations would apply to a device intended to make it easier to reach the belt or latchplate of a safety belt system. I hope the following discussion answers your questions.; You enclosed a sketch with your letter that shows that the device woul be attached to the vehicle by the anchorage bolt for the upper torso portion of a lap/shoulder safety belt. You explained that the device called an 'arm' or 'belt reacher', is made of material which 'does not interfere with the general safety/comfort of passenger and is installed semi-rotationally around the shoulder-anchor point so that it can hold the tongue in a convenient position' for the occupant to reach the belt.; There are no safety standard that directly apply to the devic described in your letter. However, if the device is installed as an item of original equipment on a new vehicle, then the vehicle's safety belt system would have to continue to comply with all of the requirements of Standard No. 208. Thus, for example, if the device is installed on a vehicle that must comply with the comfort and convenience requirements, such as the retraction requirement of S7.4.5, with the device in place. Likewise, the safety belt anchorage would have to continue to comply with all of the performance requirements of Standard No. 210.; There is one further issue associated with the device shown in you letter that I want to address. The agency supports the use of equipment that will make safety belts easier and more comfortable to use. However, it is equally important that those devices not introduce excessive slack in the upper torso belt and thereby reduce the effectiveness of that belt. You stated in your letter that the device is made of a material that makes it compliant so that it moves with the belt and does not interfere with the 'original protective function' of the safety belt. If you should implement the design depicted in your letter we encourage you to continue to make sure that the device will not introduce excessive slack in the belt.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam3092

Dear Mr. Brooks: This responds to your note we received on August 29 enclosin correspondence from one of your constituents, Mr. Don Bush. Mr. Bush requests information concerning passive seat belts on a 1977 Volkswagen Rabbit. Apparently, he was told by the Society of Automotive Engineers that there are currently no standards for this type of restraint system.; The information given Mr. Bush by the Society of Automotive Engineer was incorrect. The National Highway Traffic Safety Administration issues safety standards and regulations governing the manufacture of new motor vehicles and motor vehicle equipment. Safety Standard No. 208, *Occupant Crash Protection*, specifies requirements for restraint systems in passenger cars and other vehicles (49 CFR 571.208). For 1977-model passenger cars manufacturers had three options: (1) total passive protection (protection by means that require no action by vehicle occupants), (2) head-on passive protection, (3) the installation of combination lap and shoulder belts for front, outboard seating positions and lap belts for center and rear seating positions.; Volkswagen apparently certified its 1977-model deluxe Rabbit under th second option of the standard. This option requires the vehicle to meet specified injury criteria in a perpendicular barrier crash test, and to either meet lateral and rollover criteria in dynamic impact tests by automatic means or to install lap belts at front, outboard seating positions. Volkswagen used a single, diagonal passive belt to comply with the automatic frontal crash protection requirement of the second option. Additionally, paragraph S4.5.3 of Safety Standard No. 208 allows a passive belt to be used in lieu of any other belt required by any option of the standard. Therefore, Volkswagen's single, diagonal passive belt also qualifies as a lap belt for purposes of complying with the lateral and rollover requirements of the second option.; I am enclosing a copy of Safety Standard No. 208 for Mr. Bush' information. Please have him contact Hugh Oates of my office if he has any questions after reviewing the standard (202-426-2992). Mr. Bush might also note that General Motors voluntarily installed an active lap belt in its Chevettes that have passive shoulder belts (these vehicles were introduced in the spring of this year). Active lap belts in these vehicles are not required by the standard, however.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam2362

Dear Mr. Lerche: This responds to your June 11, 1976, request that Madico sola protective polyester film be 'designated as acceptable' under Ford Motor Company's DOT code number for the Ford product 'Privacy Glass' or, in the alternative, that the Madico product be assigned a separate DOT glazing code number. You state that the Madico film achieves the same effect as 'Privacy Glass' for reduction of solar heat, glare and fading.; Federal Motor Vehicle Safety Standard No. 205, *Glazing Materials* specifies requirements for glazing materials for use in motor vehicles and motor vehicle equipment. Section S6 of the standard outlines the procedures required for certification and marking of glazing materials, to certify that the glazing complies with all the requirements of the standard. Paragraph S6.2 of that section requires certain manufacturers to mark their glazing materials with the 'DOT' symbol and a manufacturer's code number, which is assigned to the manufacturer by the National Highway Traffic Safety Administration upon written request. Each code number is the unique mark of a single manufacturer, and is intended to facilitate the traceability of the glazing to the original manufacturer. Therefore, Ford's code number (DOT - 75 FM-M73) cannot be used by Madico or by another glazing manufacturer or distributor.; Your letter states that the Madico Product is a solar protective fil that is 'bonded or laminated to existing, installed clear glass.' We conclude that this 'protective film' is not glazing material and is not subject to the requirements of Standard No. 205. Therefore, a glazing manufacturer's code number cannot be assigned for the product.; Whether or not the Madico protective film is otherwise subject t Federal Requirements depends upon who uses the product. If a vehicle manufacturer or a dealer places the film on glazing in a vehicle prior to sale of the vehicle, he must certify that the glazing continues to be in compliance with the requirements of Standard No. 205.; On the other hand, the vehicle owner may alter his vehicle as h pleases, so long as he adheres to all State requirements. The owner could install the protective film on glazing in his vehicle whether or not such installation affected compliance with Standard No. 205. It should be noted, however, that section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966 provides that no manufacturer, dealer, distributor, or motor vehicle repair business shall knowingly render inoperative any device or element of design installed in a motor vehicle in compliance with an applicable Federal motor vehicle safety standard. Therefore, no manufacturer, distributor, dealer or repair business may knowingly install the Madico protective film on a vehicle for its owner in a manner that would destroy the conformity of the glazing with the requirements of Standard No. 205.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: 1983-3.28

TYPE: INTERPRETATION-NHTSA

DATE: 11/28/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Porsche Aktiengesellschaft

TITLE: FMVSS INTERPRETATION

TEXT:

NOV 28, 1983

DR. ING.h.c. F. Porsche AG z. H. Herrn Mayer/ESV Postfach 11 40 7251 Weissach West Germany

Dear Mr. Mayer:

This is in response to your 1etter of October 13, 1983, to Nelson Erickson of this agency, requesting our interpretation of certain requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 118, Power-Operated Window Systems.

A recent amendment to section 3(d) of FMVSS 118 (48 Fed. Reg. 46793, October 14, 1983, copy enclosed) permits power window operation during the "interval between the time the locking device which controls the activation of the vehicle's engine is turned off and the opening of either of a two-door vehicle's doors or, in the case of a vehicle with more than two doors, the opening of either of its front doors." As you point out in your recent letter, the opening of the vehicle's front doors would typically be sensed through the interior roof lamp electrical circuit. This circuit would be activated when the door is opened 8 to 10 inches from the frame. You ask whether it is permissible under the standard to have power windows remain operable until the door is opened to this point where the roof lamp is activated.

FMVSS 118 is primarily intended to prevent the unsupervised operation of power windows by children remaining in a vehicle. See 48 Fed. Reg. 46793. Paragraph 3(d) was drafted to be consistent with this goal, since it is highly probable that the driver would still be in the vehicle during the specified time interval. Your proposed interpretation is also consistent with the standard's goal, since the driver would not likely be able to leave the vehicle with the door only ajar.

Therefore, we agree that power systems may remain operable under paragraph 3(d) of FMVSS 118 until the door is opened far enough to permit a small adult to leave the vehicle. The 8 to 10 inch point where the roof lamp is activated appears to be within this permissible range

Sincerely,

Frank Berndt Chief Counsel

Enclosure

Mr. Nelson Erickson Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh St., S.W.

Washington,D.C. 20590

USA

ESVG-My-re Weissach,October 13,1983

Subject: Request of Clarification of the term "opening" - FMVSS 118

Dear Mr. Erickson,

We kindly ask for clarification of the above mentioned term.

Your early favorable consideration of our request would be greatly appreciated as we presently can not continue to design any further on this matter until we receive an answer from you.

Sincerely yours,

Dr. Ing.h.c.F. Porsche AG -Technical Administration-

Dr.Ing. h.c.F.porsche AG z.H. Herrn Mayer/ESV Postfach 11 40 7251 Weissach WEST GERMANY

Mayer Enclosure

Request of Clarification of the term "opening" in relation with FMVSS 118, Power-Operated Window System

With publication of Docket No. 82-07; Notice 2 (Federal Register Vol. 48, No. 88, Page 20237 of May 5, 1983) Standard 118 was amended to the extent that the use of the power window or partition systems are admissible, pursuant to S 3 (d), which states that: "during the interval between the time a running engine is turned off and the opening of either of a two door vehicle's door or, in the case of a vehicle with more than two doors, the opening of either of "its front doors".

Porsche welcomes this amendment and would like to use this as a future opportunity to improve comfort and still maintain the present safety level.

In design, the interior roof lamp door switch is normally used to signal to the power source of the window regulators if the door is in an "opened" or in a "closed" position.

We now ran into the following problem which we believe to be a basic problem for all the automakers:

In practice it is not common to adjust the door switch or to locate the switch on the carbody in order to function if the door is opened just for a crack, forexample a fraction on an inch.

The building tolerances of the carbody in the area of the door-post are the result of a series of individual tolerances of various parts, including the door switch and is for this reason usually not to small.

Normally this switch actuates when the door is opened between 8" to 10" - the distance between the carbody and the rear end of the door. Even a slim adult will not be able to get out of the car through an opening like this. In our opinion it is admissible and for design necessary to pinpoint the extent of the opening in order to define the difference between the terms "opened" and "closed" in relation to a car door.

Your early favorable consideration of our request would be greatly appreciated since we have stopped designing until we receive an answer from you.

Sincerely yours,

Dr. Ing.h.c. F. Porsche AG -Technical Administration-

ID: aiam4984

"Dear Mr. Sedlack: This responds to your letter seeking a interpretation of Standard No. 213, Child Restraint Systems (49 CFR 571.213). More specifically, you asked how compliance testing would be conducted for a rear-facing child restraint labeled for use by children weighing up to 25 pounds. The initial question we must address is what size test dummy would be used for compliance testing. S7.1 of Standard No. 213 provides that the six-month-old dummy is used for testing a child restraint system that is recommended by its manufacturer for use by children in a weight range that includes children weighing not more than 20 pounds. S7.2 of Standard No. 213 provides that the three-year-old dummy is used for testing a child restraint system that is recommended by its manufacturer for use by children in a weight range that includes children weighing more than 20 pounds. Since the rear-facing child restraint in your example is recommended for use both by children weighing less than and more than 20 pounds, either the six-month-old or the three- year-old dummy could be used in the agency's compliance testing, as provided in S6.1.2.3 of the standard. Your letter stated that you understood that this rear-facing child restraint would be subject to testing using the three- year-old dummy. However, you indicated that neither your company nor a testing facility understood how the three-year- old dummy could be installed in a rear-facing child restraint. You asked for clarification of how the three- year-old dummy could be installed. At the outset, I must note that it is impossible for me to offer any guidance for how to install the test dummy in your particular rear-facing child restraint because I do not know the details of your design. I can offer general guidance that you should be able to apply to your particular design. The procedures to be followed in positioning the three-year- old dummy in any child restraint other than a car bed are set forth in S6.1.2.3.1 of Standard No. 213. If the rear-facing child restraint does not physically permit the three-year-old dummy to be positioned in accordance with S6.1.2.3.1, then that rear-facing child restraint cannot be recommended by its manufacturer for use in the rear-facing position by children weighing more than 20 pounds. This conclusion is similar to the agency conclusion announced in a July 8, 1988 letter to Mr. Donald Friedman that an infant restraint so small it cannot accommodate the six-month-old test dummy cannot be certified as complying with Standard No. 213. In our letter to Mr. Friedman, the agency indicated that rulemaking could be initiated to sanction the use of an additional test dummy to evaluate the performance of a child restraint. However, that rulemaking would have to include an agency determination that this additional test dummy is a reliable surrogate for measuring the system's performance in an actual crash. We can make the same statements with regard to the situation described in your letter. You stated in your letter that you have tested your company's existing convertible seats in the rear-facing position 'with a CAMI dummy modified to 25 pounds with satisfactory results.' If you have any information or test data showing that the CAMI dummy so modified is a reliable surrogate for measuring the performance of your convertible systems in the rear-facing position, such information might be helpful to this agency in deciding whether to initiate rulemaking in this area. Until such a rulemaking action were completed and amended provisions in effect, however, you cannot recommend that a child restraint be used for children weighing more than 20 pounds if that child restraint cannot accommodate the three- year-old test dummy. I hope this information is helpful. If you have any further questions or need some additional information on this subject, please feel free to contact Deirdre Fujita of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel";

ID: aiam3173

Dear Mr. Johnson: This responds to your recent letter asking about the applicable Federa requirements for seat belts in a pickup truck that has been modified to be a convertible by removal of the top. Specifically, you ask what should be done with the shoulder portions of the seat belt assemblies in these vehicles.; I am enclosing for your information a past agency interpretatio concerning this same question. You will note that the modified pickup must be in compliance with the Federal safety standards that would have been applicable to a convertible truck at the time the pickup was originally manufactured. Since Safety Standard No. 208, *Occupant Crash Protection*, permits convertible trucks to be equipped with either Type 1 belts (lap belts) or Type 2 belts (lap and shoulder combination belts) at front outboard designated seating positions, the modified pickup would only be required to have a lap belt. Of course, your client is certainly permitted to retain the lap and shoulder belt if he chooses. We cannot, however, recommend how the shoulder portion of the belt assembly should be attached to the modified vehicle.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0335

Dear Mr. Gerth: Thank you for your letter of April 20, 1971, regarding a interpretation for seat belt assemblies required by Federal Motor Vehicle Safety Standard No. 208 - Occupant Crash Protection.; It is our intent that an integral (3-point) lap and shoulder bel system, with a sliding attachment, could meet the requirements of the subject standard. Since paragraph S7.1.1 requires automatic adjustment by means of an emergency-locking retractor for this type of integral system (see S7.1.1.3), the sliding attachment friction could not unduly restrict adjusting movements of the belt, however, a nominal friction is permissible and is expected.; The seat belt assembly which you submitted to Mr. Clue Ferguson' Office of Crash Worthiness has been placed in Docket 69-7. This system would appear to have a nominal friction at the sliding adjustment, however, an actual vehicle installation is necessary to enable a full evaluation.; Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs;