ID: nht92-4.31

DATE: August 20, 1992

FROM: Richard Allison -- Program Manager, The Bott Group, Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: FMVSS No. 216, "Roof Crush Resistance-Passenger Cars", Request for Interpretation

ATTACHMT: Attached to letter dated 9/21/92 from Paul Jackson Rice to Richard Allison (A39; Std. 216)

TEXT:

The Bott Group, Inc. (a Design, Sales & Engineering firm for manufacturers of roof racks (luggage racks), decklid racks and accessories), on behalf of all O.E.M. clients who use our products, requests the Agency render an interpretation of the requirements of Federal Motor Vehicle Safety Standard No. 216, "Roof Crush Resistance-Passenger Cars", while considering the conditions as described herein.

To be specific, The Bott Group requests an interpretation of 1) the proper application and orientation of the test device (S6.2 of this standard) and 2) the distance the test device is allowed to travel (paragraph S4 of this standard), when testing vehicles equipped with roof mounted accessories, such as roof racks (luggage racks).

This accessory neither contributes to nor detracts from the actual strength of the roof panel and would collapse easily upon application of the forces as specified in paragraph S6.3 of the standard. The roof rack examples we present for consideration, in the attached documentation, can be easily removed for compliance testing.

Roof racks are positioned on the roof panel surface to lend aesthetic enhancement to vehicle contours. This could influence the positioning of the test device (per S6.2), as well as render impossible compliance with the maximum allowed travel of the test device (per S4), and thus, not achieve the true objective of the standard.

The Bott Group roof rack designs fall into two unique categories:

1) Four Seasons Style Has adjustable/removable crossbar assemblies with end supports that move fore and aft above the vehicle roof in fixed, outer channels. Refer to Figure 1 on attachment "A".

2) Elevated Siderail Style (with fixed position end supports) Has adjustable crossbar assemblies that move fore and aft above the roof surface by sliding in an elevated, channeled siderail assembly, however, the end supports are in fixed positions on the vehicle roof. Refer to Figure 2 on attachment "B".

Please consider, for instance, the roof rack example in Figure 2 on attachment "B". The fixed position, front end support of the siderail assembly is mounted in the area of the "B" pillar on the roof surface.

Under normal conditions this style of roof rack assembly is not removable during use, but it can be easily removed for testing.

The adjustable crossbar assembly on the roof rack example shown in Figure 1 on attachment "A" (normal forward positioning is also in the "B" pillar area) can:

1) be adjusted to its rearward most position out of the contact area of the test device or,

2) be removed completely or,

3) the entire roof rack assembly can be easily removed for testing.

The Bott Group believes that there are three different test conditions which should be considered. We have illustrated the differences in the positioning of the test device (refer to Figure 3 on attachment "C").

Condition 1- Test conducted without a roof rack installed or the roof rack has been removed and the test device has been positioned as outlined in S6.2. The first point of contact has been established and is indicated (marked "A").

NOTE: Test condition 2 & 3 assumes that the "elevated siderail style" roof rack with the fixed position end supports is used.

Condition 2- Test conducted with a roof rack installed and the test device positioned the same as in test condition-1. Using the first point of contact established in condition-1 (marked "A"), as reference, the test proceeded. The actual first point of contact during this condition was to the fixed end support of the roof rack (marked "B") and this was a considerable distance rearward from the original contact point "A" established in condition-1.

The dimension between point "A" and point "B" varies according to the fore/aft positioning of the fixed end support of the roof rack on the roof surface.

When the first point of contact, "B", occurred, the second item we identified was a gap between the bottom of the test device and the roof surface at point "A". This may not comply with S6.2(c).

Condition 3- Test conducted with a roof rack installed and the test device positioned as outlined in S6.2 to the contact point (marked "B") established in test condition-2. This condition seemed to create three situations.

a) The complete test device is relocated some distance rearward of the original positioning in test condition-1 and its established contact point (marked "A"). This may not provide test requirements per S4, S6.2 & S6.4 of the standard.

b) The positioning of the test device left a gap between the bottom surface of the test device and the surface of the roof at point "A". The test device, not being tangent to the surface of the vehicle roof, when first point of contact occurs, may not comply with S6.2(c) of the standard.

c) With the test device not making contact (not tangent) with the roof surface at point "A" when the required pressure is applied to the test device, as specified in S6.3, a considerable amount of test device travel is required before contact (tangency) with the roof surface point "A" is made. This may cause non-compliance with S4, as measured in accordance with S6.4, of the standard.

The Bott Group requests the Agency's interpretation of which test condition above, number 1, 2 or 3, is correct and thus, satisfies the intent of FMVSS No. 216.

If test condition 2 or 3 is deemed correct, can the additional amount of test device travel, required between first point of contact and the actual contact (point "A") on the roof surface, be added to the "allowed distance" of test device travel when determining compliance with paragraph S4 of the standard?

The Bott Group is concerned for the timeliness of this matter because of the design timelines we work under (several model years in advance) and we would like to thank the Agency, in advance, for its kind, prompt, attention and consideration of this matter.

(Figures omitted)

ID: nht75-2.13

DATE: 06/04/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: Volvo of America

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of March 24, 1975, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 110, Tire Selection and Rims -- Passenger Cars.

You have inquired whether the placard required by S4.3 of the standard may display information in addition to the items specified in S4.3(a) through (d). The NHTSA has no objection to such placarding, provided that the additional information is set apart from, not placed among, the required items.

ID: nht72-3.3

DATE: 02/04/72

FROM: CHARLES A. BAKER FOR E.T. DRIVER -- NHTSA

TO: Enterprise Sky Park

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 20, 1972, regarding standards for retreaded automobile and truck tires.

Federal motor vehicle safety standards do not apply to aircraft or aircraft equipment.

Standard No. 117 entitled "Retreaded Pneumatic Tires - Passenger Cars," does not apply to the retreading of aircraft tires and does not supersede Advisory Circular 43.13-1. A copy of the standard is enclosed.

We do not have a safety standard for retreaded truck tires at this time.

ID: 2791o

Ms. C. Dianne Black
Engineering Manager
Jaguar Cars, Inc.
600 Willow Tree Road
Leonia, NJ 07605

Dear Ms. Black:

Thank you for your letter of April l4, l988, providing further information about the Jaguar headlamp levelling system discussed in your letters of June and October l987 to which I responded on February 1, 1988.

We support your efforts to call the driver's attention to the fact that the system does not automatically return to the "zero" position from either of the two adjustment positions when those loading conditions no longer exist.

Sincerely,

Erika Z. Jones Chief Counsel

ref:l08 d:8/l/88

ID: nht67-1.8

DATE: 09/21/67

FROM: William Haddon, Jr., M.D.; NHTSA

TO: Kurzman & Goldfarb

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 29 requesting a verification of the interpretation of Standard No. 205 contained in a letter to you dated August 10 from Max Brand of Mercedes-Benz of North America.

Mr. Brands's understanding that glazing materials manufactured on or after January 1, 1968, for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses must conform to Standard No. 205, but that dealer inventories of prestandard materials manufactured before January 1, 1968, may be used for replacement purposes until exhausted is correct.

ID: nht88-2.80

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88 EST

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

TO: C. DIANNE BLACK -- ENGINEERING MANAGER, JAGUAR CARS, INC.

TITLE: NONE

ATTACHMT: MEMO DATED 4-14-88, TO ERIKA Z. JONES, FROM C. DIANNE BLACK -- JAGUAR, REF: FMVSS 108, HEADLAMP LEVELLING SYSTEM

TEXT: Thank you for your letter of April 14, 1988, providing further information about the Jaguar headlamp levelling system discussed in your letters of June and October 1987 to which I responded on February 1, 1988.

We support your efforts to call the driver's attention to the fact that the system does not automatically return to the "zero" position from either of the two adjustment positions when those loading conditions no longer exist.

ID: nht71-4.50

DATE: 11/17/71

FROM: AUTHOR UNAVAILABLE; J. W. Carson for E. T. Driver; NHTSA

TO: Halfpenny, Hahn & Roche

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of October 18, 1971, and November 1, 1971, to Mr. Douglas Toms, Administrator, National Highway Traffic Safety Administration, concerning the "Panic-Stop" signal system from Donel Corporation.

You are correct in your interpretation that Federal Motor Vehicle Safety Standard No. 108 is not applicable to the "Panic-Stop" system when this system is not installed on motor vehicles as original equipment. The motor vehicle laws and regulations of the individual States, are, however, applicable to the "Panic-Stop" system when sold and used as aftermarket equipment.

ID: aiam3288

Dear Mr. Boyd: This responds to your recent letter requesting confirmation that larg commercial truck tractors do not have to comply with Federal Motor Vehicle Safety Standard No. 216, *Roof Crush Resistance*. You also asked whether large trucks should be designed to comply with the 'belt system' option under Safety Standard No. 208, *Occupant Crash Protection*.; You are correct in your assumption that large commercial trucks woul not have to comply with Safety Standard No. 216 since that standard only applies to passenger cars. You are also correct in stating that trucks with a GVWR greater than 10,000 pounds may meet the seat belt option of Safety Standard No. 208 found in paragraph S4.3.2. Under S4.3.1, manufacturers do have the option of meeting the crash protection requirements of S5 by means that require no action by vehicle occupants (with current technology this means air cushion restraints or automatic seat belts). Further, vehicles manufactured prior to August 15, 1977, were permitted to comply with Safety Standard No. 216 in lieu of the 'roll-over' requirements of Standard No. 208, and for large trucks this would have been a simple test to meet. However, since the vehicle would also have been required to meet the 'frontal' and 'lateral' requirements by automatic means if option S4.3.1 were taken, no truck manufacturers chose to comply with the 'rollover' requirements of Standard No. 208 via the Standard No. 216 option. Rather, seat belts were installed on all large trucks.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0365

Dear Mr. Holland: This is in reply to your letter of May 28, 1971, concerning the markin requirements in the proposed amendment to Standard No. 205, 'Glazing Materials' (Docket No. 71-1, Notice 1). These requirements are only proposed at present, as is their effective date, and do not represent the agency's final decision on the matter. If the agency determines to amend the standard, and before any compliance with new requirements is required, a 'final rule' will be issued that is based on the proposed rule but may differ in some respects from it. The final rule will specify an effective date for these new requirements which, in this instance, will probably be later than the effective date proposed.; You ask whether the effective date of the proposed standard would appl to the manufacture of the glazing, or to the fitting of the material into the vehicle. Standard No. 205 applies to 'glazing materials for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses', and the effective date of any amendment to this standard refers to the date of manufacture of the glazing material, and not to its fitting into the vehicle.; Your second question, whether we will accept your marking without hyphen between the 'DOT' symbol and your code mark, has been answered in our letter to you of May 26, 1971.; I hope this clarifies the situation. Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: aiam2544

Dear Mr. Link: This responds to your February 23, 1977, letter asking whether thre proposed labels satisfy the requirements for label identification found in Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approval of compliance by manufacturers with motor vehicle safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample labels appear to comply with the requirements of Standard No. 120. A review of the labels you supplied indicates that you have used a different format than illustrated in our notice of February 7, 1977 (42 Federal Register 7140). For example, the amended Standard No. 120 does not require the words 'with the tires listed below' or even the word 'with' before the tire size. The deletion of such superfluous words from the label requirements of Standard No. 120 resulted from comments by manufacturers, particularly motorcycle manufacturers, that unnecessary words needlessly increase the size of the label.; The example of label information shown in S5.3 of the standard i intended only as a guide to manufacturers. A manufacturer can vary the illustrated format somewhat as long as the requirements of S5.3 are satisfied. Since the additional words on your labels do not obfuscate the certification statement, the labels appear to comply with the requirements of Standard No. 120 and Part 567.; Sincerely, Frank Berndt, Acting Chief Counsel