ID: nht88-2.88

TYPE: INTERPRETATION-NHTSA

DATE: 08/08/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: KOJI TOKUNAGA -- MANAGER, ENGINEERING, ISUZU MOTORS AMERICA

TITLE: NONE

ATTACHMT: MEMO DATED 4-27-87, FMVSS 124-ACCELERATOR CONTROL SYSTEMS, OCC-448, DET-87-063

TEXT: This letter responds to your inquiry in which you ask a number of questions concerning Federal motor vehicle safety standard (FMVSS) 124 Accelerator Control Systems. I apologize for the delay in this response. In your letter, you describe a new acceler ator control system that operates through electrical rather than mechanical signals.

You state that the moving components of this system are the accelerator pedal, stepping motor arm, linkage, and the throttle lever. When a driver depresses the accelerator pedal, a pedal sensor converts the displacement into a proportional electric sign al. The signal goes through a control unit to a position switch, and then to a stepping motor. This stepping motor works to move the motor's arm and linkage, and they in turn work the throttle lever. Therefore, you say, the engine speed is controlled i n proportion to the amount of accelerator pedal displacement.

You further inform us that Isuzu already has distributed vehicles equipped with this system in Japan, and that the company would like to market this kind of vehicle in the United States. You present three questions and a diagram of the system components , and request an agency response.

First, please be aware that in issuing this interpretation, NHTSA is neither approving, certifying, nor endorsing your new accelerator control system. Under the National Traffic and Motor Vehicle Safety Act, each manufacturer must certify that its produ ct meets agency safety standards, or other applicable standards. However, based on the information you supplied in your letter, I have the following responses.

Question 1: In this vehicle, Isuzu considers the battery that drives the stepping motor to be one of the energy sources under S5.1, and the return springs (accelerator pedal and throttle lever return springs) the other sources. Is this interpretation correct?

P2

We do not have enough information to state whether the battery that drives the stepping motor, or the return springs would be considered energy sources under S5.1. Section S5.1 of Standard 124 requires, among other things, that there be a minimum of two energy sources capable of returning the throttle to idle whenever the driver removes the opposing actuating force, or if there is a single severance or disconnection in the accelerator control system.

With respect to the battery, if all system elements are operating properly, then it would appear that removing the actuating force will cause the electrical circuit from accelerator pedal sensor to stepping motor to return the throttle to idle. On the o ther hand, if there is a failure caused by a severance or disconnection in the accelerator control system between the pedal and the stepping motor, it is not clear to me whether the stepping motor will return to zero, and bring the throttle springs back to idle; or lock the arm and linkage in an "open-throttle" position.

Similarly, it is not clear to me that the accelerator pedal and throttle return springs are capable of returning the throttle to idle in the event of a failure caused by an ACS severance or disconnection. (While you include the throttle lever in your des cription of the accelerator control system, the agency considers it as part of the fuel metering device. However, as NHTSA explained in the preamble to 124, an energy source under the Standard may be attached to the fuel metering device. [37 FR 20033, September 23, 1972.]) Ordinarily, the agency would have no difficulty in finding that either of the throttle return springs is an energy source capable of returning the throttle to idle. But I cannot tell from your description and diagram whether a seve rance or disconnection in the electrical system would cause the throttle to lock in a position other than idle.

I would make the same observation with respect to the accelerator pedal. I can not tell from the information you supplied what impact a severance or disconnection failure would have on the pedal. For example, it is not apparent whether some element in the electrical system senses a severance or disconnection in the accelerator control system, so that a sensor transmits a signal to the appropriate energy sources that the throttle should return to idle. If the pedal and return springs can operate mecha nically and in concert to return the throttle to idle in the event of a failure in the accelerator control system caused by a severance or disconnection, then together they may be an energy source under the Standard.

Question 2a: Is a severance in electric wires in this system a severance or disconnection within the meaning of S5.2? Isuzu considers negative because electric wires are not a moving part.

A severance or disconnection of the electric wires in this system would be a severance or disconnection within the meaning of S5.2 of Standard 124.

Section S4.1 of Standard 124 defines a "driver-operated accelerator control system" as

"all vehicle components, except the fuel metering device, that regulate engine speed in direct response to movement of the driver-operated control and that return the throttle to the idle position upon release of the actuating force."

You stated in your letter that, in this new system, when the driver depresses the accelerator pedal, the mechanical displacement is converted into electrical signals. These electrical signals are transmitted by wires to a control unit that regulates eng ine speed in direct response to pressure on the accelerator pedal, again by means of wires that connect the control unit's electrical signal to the appropriate components. Thus, the control unit, all of the components to which it is connected, and the w ires that make those connections are "vehicle components... that regulate engine speed in direct response to movement of the driver-operated control and that return the throttle to the idle position upon release of the actuating force." Under S4.1, then, the control unit, the components to which it is connected, and the wires that make the connection are components of the driver-operated accelerator control system.

Section S5.2 of Standard 124 requires that the throttle return to idle "from any accelerator position or any speed...whenever any one component of the accelerator control system is disconnected or severed at a single point." Please note that this languag e does not limit the requirement to disconnections or severances of components that are moving parts. Thus, all severances or disconnections of any component of the accelerator control system are within the ambit of the standard. In this case, since th e wires are a component of the accelerator control system, the throttle must return to idle whenever a wire is disconnected or severed.

Question 2b: If a severance in electric wires were a severance or disconnection under S5.2, what about a short-circuiting that may result from such a severance? Does the Standard require that the throttle returns to the idle position even in such a c ondition?

Yes. Section S5.2 of Standard 124 requires the throttle to return to the idle position whenever any component of the accelerator control system is disconnected or severed at a single point, regardless of the other consequences of the disconnection or se verance. In the case of this system, this language requires the throttle to return to idle when any wire is severed, even if the severance results in a short circuit.

Question 2c: Our understanding is that a failure (other than severance or disconnection) of a system component itself (i.e. a failure in the accelerator pedal sensor with pedal position switches, control unit, throttle valve position switch, or steppi ng motor) is not subject to the throttle return requirement under the Standard. Is this correct?

Your understanding is partially correct. Standard 124 addresses those circumstances where (1) the driver removes the opposing actuating force; and (2) a severance or disconnection in the ACS causes a failure. Therefore, you are correct that Standard 12 4 addresses only those

failures resulting from a severance or disconnection within the system. However, for electrical systems, shorted or open circuits are the consequence of a change in one or more of the electrical components in the system. The agency would consider such a change a disconnection or severance in the context of this Standard.

Question 3: It is our interpretation that the battery and the electric wires from the battery to the control unit are not a part of the accelerator control system under this definition. (That is, the definition of "driver-operated accelerator control system.") Is this interpretation correct?

No, your interpretation is incorrect. We have set out the definition of "driver-operated accelerator control system" in section S4.1 above, in response to your Question 2a. With respect to your electrical accelerator control system, the electrical impu lse that travels between the vehicle battery and the control unit is a direct consequence of the driver's applying an actuating force to the accelerator pedal. Given this aspect of your system's design, both the vehicle battery and the electric wires fr om the battery to the control unit fall within the definition of "driver-operated accelerator control system."

I hope you find this information helpful.

ID: aiam5588

Dear Senator Chvala: This responds to a letter from U.S. Senato Russell D. Feingold on your behalf, asking whether a pending redefinition of Wisconsin's 'school bus' definition would violate Federal law. Senator Feingold contacted the National Highway Traffic Safety Administration (NHTSA) because our agency administers the Federal requirements for school buses. I appreciate this opportunity to address your concerns. As explained below, my review leads me to conclude that Wisconsin's contemplated redefinition of a school bus would not conflict with Federal law, insofar as the redefinition relates to the operation of school buses. However, an area of possible conflict relates to the requirements for mirrors on school buses. By way of background information, Chapter 301 of Title 49 of the U.S. Code, authorizes NHTSA to issue Federal motor vehicle safety standards (FMVSS's) applicable to new motor vehicles and motor vehicle equipment. In 1974, Congress directed NHTSA to require new school buses to meet FMVSS's on specific aspects of school bus safety, including floor strength, seating systems, and crashworthiness. The legislation requires each person selling a new 'school bus' to ensure that the vehicle is certified as meeting the school bus FMVSS's. Following the first retail purchase, the use of vehicles becomes a matter of state regulation. NHTSA defines a 'school bus' as a 'bus' that is sold for purposes that include carrying students to and from school or related events, and defines a 'bus' as a vehicle designed to carry 11 or more persons. 49 CFR 571.3. We understand that the new definition contemplated by Wisconsin would exclude some vehicles that are school buses under our definition. Information from Mr. Doug Burnett of your staff indicates that the new definition would define a school bus as 'a motor vehicle which carries 16 or more passengers (in addition to the operator).' Thus, a motor vehicle that can carry 11-16 persons (including the driver) would be a 'school bus' for Federal purposes, but apparently not for Wisconsin's purposes. Since the States, and not NHTSA, regulate the use of vehicles, the inconsistency would be immaterial with regard to requirements adopted by Wisconsin pertaining to the use of school buses. Wisconsin may set the operational requirements for those vehicles the State defines as 'school buses' without regard to our school bus definition. However, the inconsistency would matter at the point of sale of a new school bus. The FMVSS's specify requirements for school buses that do not apply to other buses. See, e.g., 49 CFR part 571.222, School bus passenger seating and crash protection. A decision by Wisconsin to adopt a definition other than the Federal definition of a school bus has no effect on the application of the Federal school bus safety standards to a vehicle. Any person selling a new 'bus' (a vehicle designed to carry 11 or more persons) to a school must sell a certified 'school bus,' regardless of whether the vehicle is considered a school bus under Wisconsin law. The vehicle would have to be equipped with the safety features NHTSA requires for school buses. The information provided by Mr. Burnett indicates that Wisconsin would redefine 'school bus' for two purposes. First, Wisconsin would prohibit the operation of a 'school bus'--a vehicle with a capacity of 17 persons (including the driver)--unless the bus has a specific type of mirror. (Section 347.40) As explained above, this requirement would not affect NHTSA's requirement that vehicles considered to be 'school buses' under our definition must be equipped with the mirrors and other safety features we require for school buses, even if the vehicles are not 'school buses' under Wisconsin law. Chapter 301 further provides that a Federal standard preempts any state or local standard applicable to the same aspect of performance that is not identical to the Federal standard. 49 U.S.C. 30103(b). A State standard for mirrors that is not identical to the Federal standard is preempted unless it imposes a higher level of safety and is applicable only to vehicles procured for the State's own use (e.g., public school buses). Wisconsin's requirements for school bus mirrors could be preempted, depending on the type of mirror required and whether the vehicles equipped with it are public buses. We understand that the second purpose of Wisconsin's contemplated redefinition of a school bus is to require privately-owned vehicles carrying 15 or fewer students to be insured by a policy providing specified minimum coverage. (Section 121.555). This provision concerns matters wholly within State law and would not conflict with Federal law. I hope the above information is helpful to you. If you have any further questions or need additional information, please contact me or Dorothy Nakama of my staff at this address, or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel cc: The Honorable Russell D. Feingold United States Senate 502 Hart Senate Office Building Washington, D.C. 20510;

ID: nht92-1.40

DATE: 12/07/92

FROM: WILLIAM R. WILLEN -- MANAGING COUNSEL, PRODUCT LEGAL GROUP, AMERICAN HONDA MOTOR CO., INC.

TO: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 2-24-93 FROM JOHN WOMACV TO WILLIAM R. WILLEN (A40; PART 571.3)

TEXT: This is to request your confirmation of our interpretation regarding the definition of "designated seating position" in 49 CFR Section 571.3 as it applies to a proposed Honda design. The Honda design is similar to one for which NHTSA provided an interpretation to Jguar Rover Triumph in July, 1980. The hip room is 44.2 inches over the length of our seat, and the seat width is only 39 inches. The seat is flat and does not have stiff inboard seat belt receptacles. (Please see the attached sketches).

We believe that, under the above mentioned definition, two designated seating positions would be required for this design and we would like to receive your confirmation. We also reguest your answers to the following questions regarding the determination of designated seating positions.

1. With regard to this proposed design, is the seat width dimension the key factor in determining the number of designated seating positions? If the seat width was 40 or 42 or 44 inches instead of 39 inches would your interpretation be different?

2. Please explain how you would measure hip room in the examples shown below where the seat is installed in a wider vehicle.

(a) The seat is located close to one side with space for passenger access on the other side.

(GRAPHICS OMITTED)

(b) The seat is located in the middle of the vehicle with space on each side.

(GRAPHICS OMITTED)

(c) Note that the seat does not have armrests in the sketches. Would the answer be different if armrests were provided? Would it also make a difference if the armrests were fixed or if they were able to swing up beside the seatback to provide easy access?

ID: nht95-7.45

TYPE: INTERPRETATION-NHTSA

DATE: November 27, 1995

FROM: Erika Z. Jones -- Mayer, Brown and Platt

TO: Samuel Dubbin, Esq. -- Chief Counsel, NHTSA

TITLE: FMVSS 207/Request for Interpretation

ATTACHMT: 1/4/96 letter from Samuel J. Dubbin to Erika Z. Jones (A44; Redbook 2; Std. 207)

TEXT: I am writing to request an interpretation of FMVSS 207 S4.4, pertaining to labelling of certain motor vehicle seats.

S4.4 provides that:

"Seats not designated for occupancy while the vehicle is in motion shall be conspicuously labeled to that effect."

It is my understanding that S4.4 does not require designated seating positions to be labeled, even if those seating positions are equipped with a folding seat back that enables that seat to be converted to a bed.

This conclusion is consistent with a letter from your office to Mr. Richard Moss, dated June 30, 1971, in which the Acting Chief Counsel advised that FMVSS 207 does not require designated seating positions to be labeled.

The vehicle seat at issue in my question is generally intended for occupancy while the vehicle is in motion, while it is configured as a bench seat. The bench seat contains several "designated seating positions" equipped with safety belts, and the seat is otherwise certified to FMVSS 207 requirements in the seat configuration. When the seat is converted to a bed by folding down the seat back, however, it is no longer "an occupant seat," as that term is defined in FMVSS 207.

Under these circumstances, it is my understanding that the labeling requirement in S4.4 does not apply, and I respectfully seek your concurrence in this conclusion.

Please let me know if I can obtain any additional information for you. I look forward to your response.

ID: aiam2337

Dear Mr. Mercer: This responds to your May 17, 1976, question whether special safet requirements exist for a vehicle that is modified to permit its operation by a handicapped person from a wheelchair that is secured at the driver's position.; Section 108(a)(1)(A) of the A) of the National Traffic and Moto Vehicle Safety Act (the Act) (15 U.S.C. S 1397(a)(1)(A)) specifies that; >>>S 1397 (a)(1) No person shall -- (A) manufacture for sale, sell, offer for sale, or introduce or delive for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment <<<; unless it is in conformity with all applicable standards. If you modifications are made to a new vehicle prior to its first purchase for purposes other than resale and involve more than the addition of readily attachable components or minor finishing operations, Part 567 of our regulations requires that the vehicle remain in compliance following these alterations and that any change of gross vehicle weight rating or type classification be noted (49 CFR 567.7).; Assuming that the vehicle you modify is a multipurpose passenge vehicle under NHTSA regulations (*e.g*., a van-type vehicle that does not qualify as a truck) (49 CFR 571.3), it appears from your description of intended modifications that compliance with the following Federal motor vehicle safety standards might be affected:>>>; Standard No. 101, *Control Location, Identification, and Display* Standard No. 102, *Transmission Shift Lever Sequence, Starte Interlock, and Transmission Braking Effect*; Standard No. 111, *Rearview Mirrors* Standard No. 124, *Accelerator Control Systems* Standard No. 206, *Door Locks and Door Retention Components* Standard No. 208, *Occupant Crash Protection* Standard No. 209, *Seat Belt Assemblies* Standard No. 210, *Seat Belt Assembly Anchorages*<<< I have enclosed an information sheet that explains how to obtain copie of our standards and regulations.; There are no additional Federal motor vehicle safety requirements tha apply to vehicles operated by a handicapped person sitting at the driver's position in a wheelchair. I have enclosed a Veterans Administration document detailing their specifications for vehicle modifications.; Exemptions from the motor vehicle safety standards are available onl to the manufacturers of motor vehicles in accordance with S 123 of the Act (15 U.S.C. 1410).; Sincerely, Frank Berndt, Acting Chief Counsel

ID: 86-2.3

TYPE: INTERPRETATION-NHTSA

DATE: 03/03/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Bobbi Fiedler

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Bobbi Fiedler House of Representatives 1607 Longworth House Office Building Washington, D.C. 20515

Dear Ms. Fiedler:

Thank you for your letter enclosing correspondence from your constituent, Mr. William Griffiths of Newbury Park, who asked several questions about our regulations for safety belts on passenger motor vehicles, buses and school buses. Your letter has been referred to my office for reply.

Your constituent asked why safety belt designs vary between different seating positions and among different types of motor vehicles. He observes that some vehicles have a combination of pelvic and upper torso restraints ("lap and shoulder belts") in the front seats, while providing only lap belts for the rear seats. He further notes that safety belts are not required for passengers in buses and school buses. Apparently Mr. Griffiths believes that shoulder belts are uncomfortable and feels that they should not be installed in the front seats of passenger motor vehicles.

I am pleased to have this opportunity to clarify our requirements for your constituent. The National Highway Traffic Safety Administration (NHTSA) is responsible for developing safety standards for all new motor vehicles and items of motor vehicle equipment. Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection, establishes performance requirements for the protection of vehicle occupants in crashes. Under FMVSS No. 208, motor vehicle manufacturers must provide lap and shoulder belts for front outboard passenger positions in order to comply with the standard. Since persons in the front seating positions of an automobile should be protected from rigid structures forward of those positions, such as the windshield pillars, He believe that an upper torso restraint of some kind is necessary. Our requirements differ for the rear seating positions, where only a lap belt need be provided, because the area forward of those positions does not contain the relatively hard surfaces found in the areas surrounding the front seats.

As Mr. Griffiths has noted, our safety standards for buses and school buses do not require safety belts for passengers. NHTSA does not require safety belts for transit-type buses because the crash forces experienced by those vehicles are less severe than those of lighter vehicles in similar collisions. Also, the safety record for transit buses is good Accordingly, we believe that revising our requirements for their seating systems would not reduce injuries substantially. Safety belts are not required for passengers in large school buses because those vehicles are required to provide high levels of occupant crash protection through a concept called :"compartmentalization." Compartmentalization requires that the interior of large school buses by constructed so that children are protected without the need to use safety belts. The seating improvements include higher and stronger seat backs, additional seat padding, hand improved seat spacing and performance.

Your constituent might be interested to know that we have addressed his concern regarding the discomfort some passengers experience with safety belts equipped with shoulder restraints. We have taken steps to improve the comfort and convenience of safety belt Systems by a recent amendment to our safety standards. A copy of the amendment is enclosed.

I hope this information is helpful. Please do not hesitate to contact my office if you have further questions.

Sincerely,

Original Signed By

Erika Z. Jones Chief Counsel

Enclosure

Congress of the United States House of Representatives Washington D.C.

Dec. 20 1985

Nancy Miller Department of Transportation

Sir:

The attached communication is sent for your consideration. Please investigate the statements contained therein and forward me the necessary information for reply, returning the enclosed correspondence with your answer.

Yours truly,

M. C.

Please Return ATTN: Louise Gessford 1607 Longworth

Rep Fiedler

Why do the car manufacturers have different seat belt configurations, with the belt in the front seats going around the waist and over the shoulder and the back seat only around waist, some have front seat only around waist?

Why do the city buses not have seat belts for the passengers? Also school buses?

We the people are the testing area for the car industry.

These are a few of the negative views after talking to many people about new seat belt law.

Have they thought about people who have had heart surgery, and other people having surgery who still have very tender areas, also women with large breasts, the only relief is to ride with your hand under the belt in these irritating areas in order to obey the law. This seems quite stupid.

Summation: There definitely should be more research done on this problem: either have the car manufacturers install waist belts in all cars or resort to air bags.

Will await your reply

William Griffith 815 492-5432

ID: nht74-4.3

DATE: 06/07/74

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

TO: Engineer/Transit Technology

TITLE: TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 2, 1974, request for a ruling on whether trolley and motor buses equipped with air brake systems and dynamic electric or hydraulic devices are required to be equipped with antilock equipment.

Standard No. 121, Air brake systems, requires stopping distance performance which must be met by any bus equipped with air brakes, whether or not it is equipped with supplementary dynamic braking means, and the stops must be made with only controlled wheel lockup over 10 mph. Although the standard does not require antilock devices, many manufacturers have indicated they will use antilock devices to meet this requirement.

In evaluating a vehicle's compliance with the stopping distance performance requirements of S5.3 and S5.7.2.3, auxiliary braking devices may be utilized in making the stops provided such devices are engaged by means of the same service brake pedal or parking brake control that operates the air brakes. It should be noted, however, that these stops must be made with the transmission selector control in neutral or the clutch disengaged (S6.1.3).

It can be foreseen that at least one difficulty may arise in testing with supplementary brake systems. S6.3 requires that the transmission be in neutral or the clutch be disengaged during deceleration, which might eliminate the torque from your dynamic brake.

Please write again if this or other difficulties arise in the certification of your buses.

Sincerely,

April 2, 1974

National Highway Traffic Administrator

Dear Sir:

The Municipality of Metropolitan Seattle has recently written a specification for the purchase of more than 600 motor and trolley buses. The first draft of this specification is presently in circulation to potential bidders, transit properties, governmental agencies, consultants and other interested individuals for their comments. These comments must be received by the Municipality by April 30, 1974, for evaluation and possible implementation into the final specification which is scheduled for release about the middle of June, 1974.

In a telephone conversation with Assistant Chief Counsel Richard Dyson on March 26, 1974, I brought up a question related to bus brakes and FMVSS 121. The Municipality has a specification requirement for dynamic brakes on our new trolley buses in addition to the standard air brakes. We also have a specification requirement for an electric or hydraulic retarder on two of our new larger types of motor buses in addition to the standard air brakes. The question, as asked of the Municipality by an interested foreign manufacturer, is whether it is still necessary to provide anti-skid equipment or brake equalization with dynamic braking on the trolley bus, and whether it is necessary to provide anti-skid equipment or brake equalization with an electric or hydraulic retarder on the motor buses. The electric retarder operates off the gear box, drive shaft or differential and the hydraulic retarder operates off the transmission.

Mr. Dyson advised me to put the question with supplementary background in written form and address it to you for an interpretation and ruling. I have enclosed a copy of the letter regarding the brake question, a copy of the bus specification of the buses for the Municipality of Metropolitan Seattle, a copy of the information on the electrical retarder and a copy of the information on the hydraulic retarder.

We shall look forward to your reply so that we can advise potential bidders of this decision.

Very truly yours,

Alden G. Olson

Engineer/Transit Technology

Enclosures

TRANSPORTATION EQUIPMENT DEVELOPMENT CO.

MARCH 14, 1974

John Aurelius Mgr., Transit Technology SEATTLE METRO 410 West Harrison Street Seattle, WA 98119

SUBJECT: FMVSS QUESTIONS

Arne Lindqvist and I finally caught up with each other in New York so we had an opportunity to discuss our mutual problems as they relate to bus production for the U.S. market.

As he told you, meeting the Federal Motor Vehicle Safety Standards is a bit of a thorn for European producers inasmuch as there is a somewhat different approach to safety in Europe.

There is one important point which, to our knowledge, has not yet been clarified. This is the question of brake equalization in a trolley coach. With dynamic braking, is it still necessary to provide anti-skid equipment or brake equalization? Is it possible to obtain an exception?

This same line of thinking would lead us to similar questions relating to motor coaches. All new motor coaches in Switzerland are equipped with dynamic braking as are a high percentage of the new commercial vehicles in other countries. The Telma retarder would be recommended for the second and third axlesof the HESS articulated motor coach.

Can you secure a ruling on these points? Perhaps you have already explored this subject and can advise us.

Very truly yours,

H.T. HAWKES---President

ID: aiam1062

Dear Mr. Kourik: This is in reply to your letter of February 16, 1973, requesting a interpretation of paragraph S5.4.1 of Federal Motor Vehicle Safety Standard No. 105a.; Answers to your questions are as follows:>>>1. The reservoi configuration in your Sketch No. 1 would meet the requirements of S5.4.1 for compartmentalized reservoirs. We have provided a similar interpretation to General Motors Corporation on this point, which is enclosed for your reference.; 2. Since the configuration of your Sketch No. 1 conforms to S5.4.1, single fluid lever sensing device is acceptable; 3. The configuration shown in your Sketch No. 2 would not comply wit volumetric requirements of S5.4.2 since your 'reserve' fluid volume plus 'protected' fluid compartment 'A' and 'B' volumes would not be equal to the total volume required by S5.4.2. S5.4.2 requires a volume for *each* reservoir equal to the fluid displacement resulting when all wheel cylinders or caliper pistons serviced by the reservoir move from a new lining, fully retracted position (etc) to a fully worn, fully applied position. Thus, if this final condition existed on both subsystems, one subsystem would not have the specified fluid available.; 4. The configuration depicted in your Sketch No. 3 would meet th requirements of S3.4.1 and S5.4.2 as well as S5.3.1(b) assuming the indicator lamp would be activated at or above the 25 percent level of fluid volume.; 5. The configuration shown in your Sketch No. 4 would meet th requirements of S5.4.1 and S5.4.2 as well as the requirements of S5.3.1(b) with the same assumption that the lamp would be activated at or above the 25 percent fluid volume level<<<; Sincerely, E.T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;

ID: nht95-1.12

TYPE: INTERPRETATION-NHTSA

DATE: January 5, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Randal Busick -- President, Vehicle Science Corporation

TITLE: NONE

ATTACHMT: Attached to 10/14/94 letter from Randal Busick to Mary Versailles

TEXT: Dear Mr. Busick:

This responds to your letter of October 14, 1994, concerning whether a belt design would comply with S7.1.2 of Standard No. 208, Occupant Crash Protection, as amended in a final rule published on August 3, 1994 and effective on September 1, 1997 (59 FR 3 9472). As described in your letter, for this belt design, "the inboard lower FMVSS 210 anchorage is located on the seat frame and thus, as the seat moves fore and aft, the system allows a minimum of two seat belt adjustment positions and the distance be tween the two extreme adjustment positions of the system is more than 5 cm."

The August 3 final rule amended Standard No. 208 to improve the fit and increase the comfort of safety belts for a variety of different sized occupants. After the effective date, S7.1.2 will, in pertinent part, read as follows:

. . . for each Type 2 seat belt assembly which is required by Standard No. 208 (49 CFR 571.208), the upper anchorage, or the lower anchorage nearest the intersection of the torso belt and the lap belt, shall include a movable component which has a min imum of two adjustment positions. The distance between the geometric center of the movable component at the two extreme adjustment positions shall be not less than five centimeters, measured linearly.

As illustrated in the drawing provided with your letter, the inboard anchorage on your seat design is the "the lower anchorage nearest the intersection of the torso belt and the lap belt."

It would appear that, under the definition of "seat belt anchorage" in Standard No. 210, Seat Belt Anchorages, the seat would be considered part of the anchorage for your design. Standard No. 210 defines a "seat belt anchorage" as any component, other t han the webbing or straps, involved in transferring seat belt loads to the vehicle structure, including, but not limited to, the attachment hardware, seat frames, seat pedestals, the vehicle structure itself, and any part of the vehicle whose failure cau ses separation of the belt from the vehicle structure.

If the seat is part of the anchorage, and if the seat can be adjusted more than 5 cm, measured linearly, it appears that your design will meet the requirement of S7.1.2.

While not directly relevant to your question, agency technical staff raised concerns about a device in the drawing enclosed with your letter. The drawing of the system shows a device labeled "Slider Bar" to which the outboard lower end of the seat belt anchorage is attached. While no detail is provided on this device, agency staff are concerned that the device (which appears to function as the lower outboard anchorage) allows the seat belt webbing attachment to slide freely fore and aft longitudinally . If our interpretation of the drawing is correct, this device may prevent the belt system from meeting the occupant protection requirements of Standard No. 208, as well as prevent the anchorage from meeting the anchorage location requirements of S4.3 o f Standard No. 210. Finally, the device may introduce slack in the belt system, preventing the belt from adequately securing a child safety restraint in the seat or providing complete protection to an adult.

I hope this information has been 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,

ID: 10441

Mr. Randal Busick
President
Vehicle Science Corporation
315 East Eisenhower Parkway, Suite 211
Ann Arbor, MI 48108

Dear Mr. Busick:

This responds to your letter of October 14, 1994, concerning whether a belt design would comply with S7.1.2 of Standard No. 208, Occupant Crash Protection, as amended in a final rule published on August 3, 1994 and effective on September 1, 1997 (59 FR 39472). As described in your letter, for this belt design, "the inboard lower FMVSS 210 anchorage is located on the seat frame and thus, as the seat moves fore and aft, the system allows a minimum of two seat belt adjustment positions and the distance between the two extreme adjustment positions of the system is more than 5 cm."

The August 3 final rule amended Standard No. 208 to improve the fit and increase the comfort of safety belts for a variety of different sized occupants. After the effective date, S7.1.2 will, in pertinent part, read as follows:

... for each Type 2 seat belt assembly which is required by Standard No. 208 (49 CFR 571.208), the upper anchorage, or the lower anchorage nearest the intersection of the torso belt and the lap belt, shall include a movable component which has a minimum of two adjustment positions. The distance between the geometric center of the movable component at the two extreme adjustment positions shall be not less than five centimeters, measured linearly.

As illustrated in the drawing provided with your letter, the inboard anchorage on your seat design is the "the lower anchorage nearest the intersection of the torso belt and the lap belt."

It would appear that, under the definition of "seat belt anchorage" in Standard No. 210, Seat Belt Anchorages, the seat would be considered part of the anchorage for your design. Standard No. 210 defines a "seat belt anchorage" as

any component, other than the webbing or straps, involved in transferring seat belt loads to the vehicle structure, including, but not limited to, the attachment hardware, seat frames, seat pedestals, the vehicle structure itself, and any part of the vehicle whose failure causes separation of the belt from the vehicle structure.

If the seat is part of the anchorage, and if the seat can be adjusted more than 5 cm, measured linearly, it appears that your design will meet the requirement of S7.1.2.

While not directly relevant to your question, agency technical staff raised concerns about a device in the drawing enclosed with your letter. The drawing of the system shows a device labeled "Slider Bar" to which the outboard lower end of the seat belt anchorage is attached. While no detail is provided on this device, agency staff are concerned that the device (which appears to function as the lower outboard anchorage) allows the seat belt webbing attachment to slide freely fore and aft longitudinally. If our interpretation of the drawing is correct, this device may prevent the belt system from meeting the occupant protection requirements of Standard No. 208, as well as prevent the anchorage from meeting the anchorage location requirements of S4.3 of Standard No. 210. Finally, the device may introduce slack in the belt system, preventing the belt from adequately securing a child safety restraint in the seat or providing complete protection to an adult.

I hope this information has been 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,

Philip R. Recht Chief Counsel

Enclosure

ref:208 d:1/5/95