ID: 571.209--Attachment hardware--Freedman--17-0328

Mr. David Klopp, Director

Quality, Testing & Compliance

Freedman Seating Company

4545 W. Augusta Blvd.

Chicago, IL 60651

Dear Mr. Klopp:

This responds to your request for an interpretation concerning the attachment hardware requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 209, Seat belt assemblies.  You ask whether it is acceptable to use attachment hardware smaller than that specified in the standard if the seating system complies with the strength requirements of FMVSS No. 210, Seat belt assembly anchorages.  As we explain below, under FMVSS No. 209 it is acceptable to provide attachment hardware other than the 7/16-20 UNF-2A or 1/2-13 UNC-2A attachment bolts specified in the standard if it meets 209’s S4.3(c) strength requirements [FD(1] when tested under the demonstration procedures of FMVSS No. 209’s S5.2(c).[JP2]   The agency will not use the FMVSS No. 210 demonstration procedures in place of those of S5.2(c).

Background

FMVSS No. 209 specifies a variety of requirements for seat belt assemblies, including S4.3(c), which specifies strength requirements for attachment hardware that must be met when tested to a procedure in S5.2(c).  [FD(3] Section S4.1(f) generally requires, among other things, that a seat belt assembly include all hardware necessary for installation in a motor vehicle.  However, S4.1(f) goes on to exempt certain seat belt assemblies from this requirement:

[S4.1](f) Attachment hardware.  *  *  *  However, seat belt assemblies designed for installation in motor vehicles equipped with seat belt assembly anchorages that do not require anchorage nuts, plates, or washers, need not have such hardware, but shall have 7/16-20 UNF-2A or 1/2-13 UNC-2A attachment bolts or equivalent metric hardware.[1]

Your question concerns the meaning of the phrase “equivalent metric hardware.”  You ask whether it is acceptable to use smaller (3/8” or M10 diameter) attachment hardware if the seating system (seat belts anchored to the seat structure) complies with the strength requirements of FMVSS No. 210. 

Discussion

After examining the history of S4.1(f) regarding the phrase in question, we conclude that “equivalent” is referring to the alternate bolts’ meeting the strength requirements of S4.3(c) of FMVSS No. 209.  When the initial FMVSS No. 209 was promulgated in 1967 it incorporated by reference existing seat belt requirements codified at 15 CFR § 9.[2]  Section 9 required 7/16-20 UNF-2A or 1/2-13 UNC-2A fasteners; there was no provision for equivalent hardware.  The “equivalency” language was added later to FMVSS No. 209:

S3. Requirements.  Seat belt assemblies shall meet the requirements of [15 CFR §9] using the attachment hardware specified in paragraph (f) of 15 CFR 9.3 or approved equivalent hardware.”[3] 

NHTSA explained in the preamble to the final rule adding the equivalency language that the agency had “determined that other fasteners that meet or exceed the strength requirements of paragraph (c) of 15 CFR 9.5 may be suitable for use.  Therefore Standard No. 209 is being amended to provide for the use of an approved equivalent of equal or superior performance as an alternative to the fasteners specified.”[4]  The strength requirements in 15 CFR § 9.5(c) for attachment hardware were later re-codified at S4.3(c) of FMVSS No. 209.[5]  In sum, this history shows that the equivalency language was intended to allow the use of hardware other than 7/16-20 UNF-2A or 1/2-13 UNC-2A attachment bolts as long as the hardware meets or exceeds the strength requirements specified in S4.3(c).[6] 

These S4.3(c) strength requirements remain the same today.  They specify that attachment hardware must withstand specified forces when subjected to the test procedures in S5.2(c) of FMVSS No. 209.  This test involves applying a load to the bolt through attachment hardware from the seat belt assembly, or through a special fixture which simulates the loading applied by the attachment hardware. 

Note that S4.1(f) and S4.3 do not contemplate an FMVSS No. 210 strength test to assess the equivalency of alternate hardware.  Thus, to answer your question, NHTSA will not assess compliance with S4.3(c)’s strength requirements using the FMVSS No. 210 demonstration procedures.

“Equivalent Metric Hardware”

We recognize that the agency’s intent to state in FMVSS No. 209 that a manufacturer may provide equivalent hardware was somewhat obscured by a subsequent amendment.  The “equivalent hardware” language remained until 1998, when the standard was amended as part of a rulemaking that converted English system measurements in selected FMVSSs to the metric system.[7]  Section S4.1(f) of FMVSS No. 209 was amended by changing the phrase “equivalent hardware” to “equivalent metric hardware.”[8]  It was not the intent of the 1998 metric conversion rulemaking to make a substantive change to FMVSS No. 209.[9]  Instead, the intent was that “equivalent hardware” was still the rule.  Therefore, the agency interprets the S4.1(f) requirements to permit, as they have since 1967, fasteners other than 7/16-20 UNF-2A or 1/2-13 UNC-2A that meet or exceed the strength requirements in S4.3(c) when tested according to S5.2(c). 

If you have any further questions, please contact John Piazza of my staff at (202) 366-2992.

Sincerely,

Jonathan C. Morrison

Chief Counsel

Dated: 8/12/19

FMVSS No. 209

[1] (Emphasis and footnote added.)

[2] 32 FR 2408 (Feb. 3, 1967).

[3] 32 FR 3390-91 (Mar. 1, 1967) (emphasis and footnote added).

[4] Id. (emphasis added).

[5] 34 FR 115, 117 (Jan. 4, 1969) (recodification).  Also, NHTSA amended FMVSS No. 209 to remove the word “approved” from “approved equivalent hardware.” 

[6] See also NHTSA’s letter to Takata Kojyo Co, Ltd. (Apr. 9, 1973) (stating that “[u]nder the provisions of S4.1(f), ‘equivalent hardware’ is permissible in lieu of the 7/16" bolts.  In such a case, the tests required under S4.3(c), as prescribed under S5.2(c), would be performed on the entire equivalent hardware, rather than or the individual components (bolts).”).

[7] 62 FR 19253 (Apr. 21, 1997).

[8] 63 FR 28922, 28936 (May 27, 1998) (final rule).  See also letter from Paul Jackson Rice, Chief Counsel, to J.W. Lawrence, Volvo GM Heavy Truck Corporation (May 8, 1992) (stating that equivalent metric hardware is permitted).

[9] 63 FR 28922 (“The [metric] conversions are not intended to make any changes in the stringency of the affected FMVSS”).

ID: GF008126

Mr. Dietmar K. Haenchen
Safety Affairs and Vehicle Testing
Volkswagen of America, Inc.
Mail Code 3C02
3800 Hamlin Road
Auburn Hills, MI 48326

Dear Mr. Haenchen:

This responds to your letter of November 4, 2003, and subsequent phone conversation with George Feygin of my staff regarding applicability of certain provisions of Federal Motor Vehicle Safety Standard (FMVSS) No. 201 "Occupant protection in interior impact," to sliding interior compartment doors. Specifically, you ask whether a sliding interior compartment door that does not project outward like a pivoting or hinged door would is subject to the requirements of S5.3 of FMVSS No. 201. In short, our answer is yes.

By way of background, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, manufacturers are required to certify that their vehicles and equipment meet applicable requirements prior to the initial sale of the vehicle.

FMVSS No. 201 establishes performance requirements designed to reduce the risk of injury in the event an occupant strikes the interior of a vehicle during a crash. S5.3 of FMVSS No. 201 specifies that doors to interior compartments must remain latched when subjected to certain forces that might be experienced in a crash. The determination of whether an interior compartment door is subject to the requirements of S5.3 is determined by both the location of the door and whether the door fits within the definition of "interior compartment door."S5.3 applies only to interior compartment doors located in the instrument panel, console, seat back or side panels adjacent to a designated seating position. We are assuming that the interior compartment in question is located in either the instrument panel, the console, the seat back or a side panel.

49 CFR 571.3(b) defines "interior compartment door" as "any door in the interior of the vehicle installed by the manufacturer as a cover for storage space normally used for personal effects" (emphasis added). For example, an ashtray is not normally used for storing personal effects, and therefore its cover is not considered to be an interior compartment door. [1] Similarly, the agency has also indicated that a fuse box door [2] and a cup holder door [3] are not interior compartment doors subject to the requirements of S5.3. In your phone conversation with George Feygin you indicated that the interior compartment in question is intended to store personal effects, thus making it subject to the requirements of S5.3.

The agency has never made a distinction between a sliding interior compartment doors and other, pivoting or hinged doors that project outward when opened. In your letter you assert that an open sliding compartment door does not present a potential for occupant injury because an open sliding compartment door does not project outward into the interior of the vehicle. S5.3 of FMVSS No. 201 requires that doors in the console or a side panel remain closed regardless of the method by which a manufacturer chooses to open or close them. The concern that an open door could cause occupant injury when there is a lateral or diagonal impact is not limited to a protrusion created by an open door. Rather, the concern addressed by the requirement is that a sharp or rigid surface does not expose an occupant to undue risk of injury.

I hope you find this information helpful. If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:201
d.2/12/04

ID: aiam5020

"Dear Mr. McLean: This responds to your request for additiona information on the requirements applicable to automatic belts. In response to your March 9, 1992 letters, I sent you a March 30, 1992 letter explaining how our requirements apply to automatic belts. Specifically, I explained that an automatic shoulder belt is not a Type 2a belt, as defined in Standard No. 209, and that automatic belts are not required to include any warnings required for Type 2a belts. I noted that all the requirements applicable to automatic belts are set forth in S4.5.3 of Standard No. 208. On May 19, 1992, you sent a FAX to Steve Kratzke of this office asking for a further clarification of the requirements applicable to automatic belts. You followed the FAX up with a telephone call on May 27, 1992, during which you explained that you were seeking an opinion from me with respect to an interpretation that is being asserted in litigation in which you are involved. The issue involves the crash protection requirements in Standard No. 208. S4.1.2 of Standard No. 208 gives vehicle manufacturers a choice of three options for providing occupant crash protection and sets forth specific belt installation requirements for each option. However, S4.5.3 of Standard No. 208 contains an important proviso. This section provides that an automatic seat belt assembly may be used to meet the crash protection requirements of any option set forth in S4.1.2 and in place of any seat belt assembly that would otherwise be required by that option. You explained that another party in your litigation is asserting that an automatic belt, which consists solely of a shoulder belt, could not be used pursuant to S4.5.3 of Standard No. 208 to meet the crash protection requirements of any option in S4.1.2 of Standard No. 208. This is so because, according to this argument, an automatic belt which consists solely of a shoulder belt is not a 'seat belt assembly.' The reason it is asserted that a shoulder belt alone cannot be a 'seat belt assembly' is that S4.1(b) of Standard No. 209 requires that 'a seat belt assembly shall provide pelvic restraint.' Since an automatic belt that consists solely of a shoulder belt does not provide pelvic restraint, this argument concludes that automatic belts that do not provide pelvic restraint must not be 'seat belt assemblies' within the meaning of Standard No. 209. If these belts are not seat belt assemblies, they are not eligible to be used pursuant to S4.5.3 of Standard No. 208 in place of seat belt assemblies otherwise required by Standard No. 208. This argument is without merit. Contrary to the assertion in this argument, automatic belts which consist solely of a shoulder belt are 'seat belt assemblies' within the meaning of S3 of Standard No. 209. That section defines a 'seat belt assembly' as 'any strap, webbing, or similar device designed to secure a person in a motor vehicle in order to mitigate the results of any accident, including all necessary buckles and other fasteners, and all hardware designed for installing such seat belt assembly in a motor vehicle.' An automatic belt consisting solely of a shoulder belt falls squarely within this definition. Thus, an automatic belt consisting solely of a shoulder belt may be used pursuant to S4.5.3 of Standard No. 208 to meet the crash protection requirements of the standard and in place of any seat belt assembly that would otherwise be required. It may be that this argument was offered because the person was not aware that automatic belts are not generally subject to the provisions of Standard No. 209 that apply to manual seat belt assemblies, as explained in my March 30, 1992 letter to you. Thus, S4.1(b) of Standard No. 209 does not apply to automatic belts. In place of Standard No. 209's general requirements for manual seat belt assemblies, S4.5.3 of Standard No. 208 sets forth special requirements for automatic belts. No provision of S4.5.3 of Standard No. 208 precludes the use of automatic belts that consist solely of a shoulder belt. I hope this information clarifies any lingering questions you may have had. As before, if you need any further information on the requirements applicable to automatic belts, feel free to contact Steve Kratzke at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel";

ID: aiam4588

"Dear Mr. Story: This responds to your letter asking whethe manufacturers are required to install rear seat lap/shoulder belts in cars originally equipped with rear seat lap belts at no additional cost to the consumer. The answer to this question is no. The lap belts that are installed in the rear seat of your car are effective in reducing the risk of death and injury in a crash. Based on this agency's analysis of a number of crash data files, we estimate that rear seat lap belts saved about 100 lives and prevented over 1500 serious injuries in 1987 alone. These figures would have been substantially higher if more rear seat occupants used their lap belts. In fact, if everyone had worn their rear seat lap belts each time they rode, those belts would have saved about 660 lives and prevented more than 10,000 serious injuries in 1987 alone. Even though lap belts have been proven to be effective in reducing the risk of death and injury in a crash, we agree that properly designed lap and shoulder belts have the potential to offer even greater crash protection than lap belts alone. For this reason, we have proposed to require that all new passenger cars sold in the United States be equipped with rear seat lap and shoulder belts beginning in the 1990 model year. For cars made in earlier model years, we have actively sought the car manufacturers' cooperation in providing retrofit kits to interested consumers. You indicated in your letter that Ford offers a rear seat lap and shoulder belt retrofit kit for your car, the 1988 Thunderbird. We encourage consumers to consider having rear seat lap and shoulder belts fitted into their cars when manufacturers have made a retrofit kit available for the car, because of the additional crash protection afforded to rear seat passengers. However, NHTSA has no authority to require manufacturers to provide these retrofit kits and installation free of charge to the consumer. Thus, the individual consumer who desires the added protection of lap and shoulder belts in the rear seat will have to pay for that additional protection. I hope this information is helpful. If you have any further questions or need additional information on this subject, please let me know. Sincerely, Erika Z. Jones Chief Counsel";

ID: 86-6.3

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Douglas MacGregor

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Douglas MacGregor Terralab Engineers 3585 Via Terra Salt Lake City UT 84115

Dear Mr. MacGregor:

Thank you for your letter of August 28, 1986, to Stephen Oesch of my staff concerning Standard No. 301, Fuel System Integrity. You asked whether the performance requirements of the standard would apply to a propane-fired engine block heater. You explained that the heater has its own fuel system that is independent of the vehicle's fuel system. As explained below, a propane-fired heater would not be covered by Standard No. 301.

Standard No. 301 sets performance requirements for the fuel system used in certain motor vehicles. The heater you have described apparently does not have any connections to the fuel tank or fuel lines of the vehicle. Instead, the heater has its own propane fuel system. Since the heater is not connected to the vehicle's fuel system, it would not be covered by the standard. Even if the heater were connected to the vehicle fuel system, it would not have to meet the performance requirements of the standard, since it is a propane-fired heater. S3 of Standard No. 301 limits the application of the standard to vehicles that use a fuel with a boiling point above 32o F. Propane has a boiling point below 32o F.

Even though the heater is not covered by the requirements of Standard No. 301, it would be considered an item of motor vehicle equipment. I have enclosed a copy of an information sheet that describes how our regulations, including those on defect notification and remedy campaigns, apply to equipment manufacturers.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

28 August 1986

Steve Ashe Chief Counsel's Office Department of Transportation NHTSA 400 7th Street SW Washington, DC 20596

Dear Mr. Ashe:

Per our conversation I am writing to obtain an opinion.

We have been approached to test a propane-fired engine block heater. The propane fuel for the heater is separate and independent of the vehicular fuel system.

While there are standards which cover the test requirements for the heater itself, we need an Opinion which will determine whether impact (crash) and roll-over tests are required per 301, even though the language of 301 excludes LPC since its boiling point is below 32 F.

Also, if the Opinion should state the testing is necessary, would the system have to be tested for each truck and bus style, or would one representative test be acceptable for all installations?

Sincerely

Douglas MacGregor

ID: aiam3741

Dear Mr. Ziwica: This responds to your letter requesting an interpretation of Standar No. 105, *Hydraulic Brake Systems*. Your request was in regard to a type of brake reservoir you are considering producing which would contain common fluid for the brake circuits and the brake hydraulic power assist unit. The issue raised by your letter was whether section S5.4.2 of the standard permits the common fluid to be counted as part of the minimum capacity required for the braking system. As discussed below, the answer to that question is no.; The first sentence of section S5.4.2 states: >>>Reservoirs, whether for master cylinders or other type systems shall have a total minimum capacity equivalent to the fluid displacement resulting when all the wheel cylinders or caliper pistons serviced by the reservoirs move from a new lining, fully retracted position (as adjusted initially to the manufacturer's recommended setting) to a fully worn, fully applied position, as determined in accordance with S7.18(c) of this standard.<<<; As noted by your letter, the agency has previously interpreted thi section with respect to a brake reservoir servicing both the braking system and the clutch. In an October 9, 1981, letter to Toyota, we explained:; >>>This section specifies the total minimum fluid capacity that vehicle's braking system reservoirs must have. That amount is determined by reference to the vehicle's braking system, i.e., by the fluid displacement which results when all the wheel cylinders or caliper pistons serviced by the reservoirs move from a new lining, fully retracted position to a fully worn, fully applied position. The purpose of this requirement is to assure that a vehicle's braking system reservoirs have adequate fluid capacity to service the brakes.<<<; >>>The agency interprets section S5.4.2 to require that the minimu fluid capacity requirements be met by fluid which is solely available to the brakes. If fluid is available to both the brakes and the clutch, some of that fluid is available to both the brakes and the clutch, some of that fluid will be used by the clutch in normal service and thus be unavailable to the brakes. In the event of clutch failure, all of the common fluid may be used by the clutch. Therefore, while standard No. 105 does not prohibit manufacturers from producing master cylinders with reservoirs that have some fluid available to both the braking system and the clutch, none of that common fluid may be counted toward meeting the minimum requirements of section S5.4.2.<<<; This same rationale applies to a reservoir which contains common flui for the brake circuits and brake hydraulic power assist unit. As indicated in our October 1981 letter, the minimum fluid capacity requirements were determined by reference to the vehicle's braking system for the purpose of assuring that a vehicle's braking system reservoirs have adequate fluid capacity to service the brakes, i.e., the wheel cylinders and pistons. More specifically, the requirement for minimum capacity equivalent to the fluid displacement resulting when all the wheel cylinders of clipper pistons serviced by the reservoirs move from a new lining, fully retracted position to a fully worn, fully applied position, was based upon maintaining a sufficient supply of fluid to enable a vehicle to stop even when there was complete brake lining wear-out in the service brake. Put another way, the requirement assures an adequate supply of brake fluid over the lifetime of the brake linings, even if a driver fails to add fluid as part of routine maintenance.; This purpose would not be met if fluid available to both the brak circuits and brake hydraulic power assist unit was counted toward meeting the minimum fluid capacity requirements. Some of the common fluid would be used by the brake hydraulic power assist unit in normal service and thus be unavailable to the brake circuits. Moreover, in some instances of brake hydraulic power assist unit failure (e.g., a failure in the brake hydraulic power assist unit return line), all of the common fluid might be used by that unit.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam4473

"Dear Mr. Hunt: This letter responds to your inquiry of November 3 1987, in which you enclosed a diagram to show the relationship between your company, Telex Communications, Inc. (Telex or your company), and a Telex customer you designated as Company XYZ (or your customer). As I understand your diagram, Telex manufactures a trailer which it sells to Company XYZ. Company XYZ then delivers the trailer to its subcontractors, Companies ABC and DEF, who install items such as generators and communications equipment. Your letter suggests that you are uncertain about your company's certification responsibility. It is your company's position that as an incomplete vehicle manufacturer, you should provide the document specified in 49 CFR 568.4(a). On the other hand, your customer asserts that as the incomplete vehicle manufacturer, Telex must assume legal responsibility for the incomplete vehicle under 49 CFR 568.7(a), and certify the vehicle's compliance under Part 567. On a number of occasions, you spoke with Joan Tilghman of my staff on the matters raised in your letter. On the diagram enclosed with your letter, you state that the trailers Telex delivered to Company XYZ are equipped with 'running gear, brakes, lights, etc.' Telex assigns a VIN, gross axle weight rating, and a gross vehicle weight rating to each trailer it delivers to Company XYZ. You are concerned because two contractors with whom you have no relationship add equipment to the trailer after you deliver it to your customer. First, having reviewed the drawing of the trailer and the narrative information in your letter, it is not clear to me whether your trailers are, in fact, incomplete vehicles. You may wish to provide me with information that more completely describes your trailer so that I may give a more definitive answer to your question. A photograph showing the trailer as it is delivered to Company XYZ would be helpful. However, I shall be as responsive as I can be given the information you supplied in your letter. If the trailers are incomplete vehicles, then Part 568 would not compel your company to certify the trailers' compliance with all applicable Federal safety standards. Under 568.7, Telex may elect to assume legal responsibility for all the certification duties and liabilities imposed on a manufacturer under the National Traffic and Motor Vehicle Safety Act, and affix the certification label as specified in 567.5(e). But if Telex decides against assuming certification responsibility, then it must supply the incomplete vehicle document specified in 568.4. If the trailers are completed vehicles which are converted to a different use by Company XYZ through its subcontractors, you must certify them irrespective of whether your customer contracts to have other equipment added to the vehicles after delivery. The fact that your customer contracts to have a generator and communications equipment added does not mean that the vehicle requires further manufacturing operations to perform its intended function. The determination of whether a vehicle requires further manufacturing operations to perform its intended functions is not a subjective inquiry into what use the particular person to whom the vehicle is delivered intends to make of the vehicle. In previous interpretations, we have explained that the question is whether the particular vehicle type (e.g., trailer, van) requires further manufacturing operations to perform the customary functions that an ordinary purchaser would expect of this vehicle type. For example, a van that is delivered to a dealer ready for road use is a completed vehicle, even if the dealer intends to send it to a van converter to have different equipment (seats, refrigerators, etc.) installed before selling the van to a retail customer. Similarly, the trailer your company delivers to Company XYZ is a completed vehicle if it needs no further manufacturing operations to perform the functions an ordinary purchaser would expect of a trailer. Under the National Traffic and Motor Vehicle Safety Act (Vehicle Safety Act), a complete vehicle manufacturer's certification responsibilities apply up to the vehicle's first purchase in good faith for purposes other than resale. It appears from your letter that Company XYZ purchases your trailers for purposes other than resale, and that after its purchase, Company XYZ subcontracts with two other companies to add a generator and communications equipment to the trailers. If my assumptions are correct, then the two subcontracting companies have no certification responsibilities under the Vehicle Safety Act, because they are modifying vehicles after their first purchase in good faith for purposes other than resale. The only limitations on the modifications those subcontractors can make to the trailers is set out in 108(a)(2)(A) of the Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A)). That section states that: No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard... If Company XYZ's subcontractors are 'manufacturers,' distributors,' 'dealers,' or 'motor vehicle repair businesses' within the meaning of 108(a)(2)(A), they may not remove, disconnect, or degrade the performance of safety equipment or designs that Telex installed in the trailers in compliance with an applicable Federal safety standard. I hope you find this information helpful. If you have any further questions on this subject, or wish to provide additional information about the particular relationships that were the subject of this letter, please feel free to contact Ms. Tilghman at this address or by telephone at (202) 366-2992. Sincerely, Erika Z. Jones Chief Counsel";

ID: nht76-2.25

DATE: 05/11/76

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Thomas Kupensky

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 8 to the Department of Transportation, regarding your CAUTION and THANK YOU signals which would flash simultaneously with the turn signal lamps on trucks and trailers.

Since such signs, flashing CAUTION or THANK YOU when actually "turn" is intended, may be confusing in many circumstances, they would be prohibited by paragraph S4.1.3 of Federal Motor Vehicle Safety Standard (FMVSS) No. 108, "Lamps, Reflective Devices and Associated Equipment," (copy enclosed), because they would appear to impair the effectiveness of the turn signals. If these signs were manually operated by the driver, separately from the turn signals, at appropriate times, whether flashing or steady burnings, they would be considered auxiliary devices which did not impair the effectiveness of the turn signals, and would be permitted by Standard No. 108. In this situation, however, they would be subject to the motor vehicle regulations of the individual States.

Sincerely,

Enclosure

ATTACH.

April 8, 1976

Department of Transportation 400 - 7th Street, S. W. Washington, DC 20590

Gentlemen:

Enclosed is a copy from my Patent Attorney of a description of Safety Signal Lights, which I would like to market. I feel these lights add safety for over the road truckers, and act as a backup system for a burned out turn signal, as explained in the attached write-up. They also indicate to the vehicle following of the drivers' intentions.

I have called on a major trailer manufacturer and found that this is creating quite an interest. But the question remains -- would these be acceptable by the Department of Transportation.

Hoping that you can advise me on the above, I thank you for your assistance and any information you might be able to forward.

Sincerely,

Thomas Kupensky

Enc.

(Graphics omitted)

VEHICLE SIGNAL LIGHT ABSTRACT OF THE DISCLOSURE

A signal light system for a vehicle. A pair of auxiliary lights are mounted, preferable, on the rear of the vehicle and operate in conjunction with the vehicle turn indicator lights. Each of the lights is a (Illegible Words) enclosure having a replaceable face plate. The removable plates carry suitable logooda which are visible when the light is illuminated.

SPECIFICATION

The present invention relates to a vehicle signal system and more particularly to a system which (Illegible Word) additional information to other drivers on the road.

The continuous increase of super highway mileage and of the volume of traffic on those highways has brought (Illegible Words) systems which rapidly convey information between the vehicle and other drivers on the road. (Illegible Word) and others who do a considerable amount of high speed driving have developed (Illegible Words). The (Illegible Word) of turn signals to indicate (Illegible Word) changes and the blinking of lights by a vehicle being overtaken to indicate that the passing vehicle has cleared and can pull back into the slower speed lane (Illegible Word) among (Illegible Words). Also, a vehicle which has completed passing will blink his lights to thank the following vehicle. However, there are many people who do relatively little super highway driving and are not aware of these conventions. There is a need for a signaling system which will clearly convey the intentions of the signaling vehicle (Illegible Words) inexperienced drivers do not become confused. (Illegible Word) the practice of blinking the vehicle lights causes the vehicle driver to be momentarily distracted from his primary function, thereby increasing the risk of accident.

It is the primary object of the present invention to provide a signaling system for a vehicle which will clearly alert the following vehicles even if the operators of such vehicles are not aware of the usual signaling conventions.

It is also an object of the present invention to provide a vehicle signaling system which permits the vehicle operator to signal to following vehicles without being distracted from the primary function of driving the vehicle.

Yet another object of the invention in the provision of a signal system which may be easily applied to existing vehicles with a minimum of modification thereof.

The above and other objects of the invention which will become apparent in the following detailed description are achieved by providing a vehicle signal system which employs a pair of auxiliary light units mounted on the rear of the vehicle with the units operating in conjunction with the right and left turn signals, respectively, and with each light unit consisting of an enclosure having a removable face plate which is provided with information conveying markings visible when the signal is illuminated.

For a more complete understanding of the invention and the objects and advantages thereof reference should be had to the following detailed discription and the accompanying drawing wherein there is shown a preferred embodiment of the invention.

In the drawing:

Fig. 1 is a rear (Illegible Word) view of a trailer equipped with the signal lights of the (Illegible Word) invention;

Fig. 2 is a perspective view of one signal light unit of the present invention;

Fig. 3 is a sectional view of the light assembly of Fig. 2;

Fig. 4 is a transverse sectional view taken along the line 4-4 of Fig. 3; and

Fig. 5 is a schematic showing of the control circuit for the lights of the present invention.

A conventional semi-trailer 10 is shown in Fig. 1. The trailer is provided with rear brake lights 12 and left and right turn indicator lamps 14 and 16, respectively, in accordance with conventional practice. These lights are controlled from the vehicle cab in the usual manner. In order to convey additional information to motorists following the trailer two illiminated signs 18 and 20 are also provided on the rear of the trailer 10. While these signs are shown as being mounted at approximately the vertical mid-point of the trailer, it will be understood that the two units may be positioned at any convenient locations.

As will be described in greater detail below, the illuminated sign 18 operation in sequence with the left turn signal 14 while the illuminated sign 20 operates in sequences with the right turn signal 16. Any suitable wording or other indicators may be provided on the two signs 18 and 20. The two signs illustrated, "CAUTION" and "THANK YOU" are considered desirable as these indications reinforce the conventional turn signal indications. Thus, when the left turn signal is operated the word "CAUTION" is flashed simultaneously thus clearly alerting the following motorist to the fact that the vehicle is about to shift to the left lane. This is particularly advantageous when the truck in one of a line of trucks as following motorists frequently cannot see the right turn signals of such a truck and may misinterpret the flashing turn signal as a flashing brake light.

The use of the word "THANK YOU" in conjunction with the right turn signal allows the overtaking vehicle to express his consideration to the vehicle which has been passed without requiring him to perform any action except the operation of his right turn signal which is conventionally done when pulling back into the right lane.

The construction of the light assembly 18 is shown in greater detail in Figs. 2, 3, and 4. It will be understood that the unit 20 is of identical construction. Each of the light units consists of a rectangular bon-like housing 22 which is open on one face to receive a plastic face plate 24 which is provided with the desired indecia. The indecia 26 may be incorporated in any suitable arrangement such as the use of contracting colors or of opaque and translucent regions. The casing 22 has a rear wall 28, and walls 30, and top and bottom walls 32 and 34, respectively. The forward wages of the top and bottom walls are bent to form (Illegible Word) 36. These (Illegible Word) 36 define a channel in which the facing plate 24 in slidably received, the end walls 30 (Illegible Word) the engage the inner face of the plate 24. If desired and depending on the material used to form the face plate 24 a ridge 40 may be provided on the inner surfaces of the upper and lower walls 32 and 43, respectively, in spaced parallel relation to the (Illegible Word) 36 to provide for additional support to the face plate 24. Suitable gaskets 38 and 41 are provided to form a fluid tight seal between the face plate 24 and the casing 22. The wire leads 43 for the lamps within the casing are routed through a suitable grommet 45 to provide a fluid tight seal between the wires and the casing 22.

A vertically extending wall 42 is provided within the casing 22 and midway between the opposite ends 30. The wall may, for example, have a tab portion 44 which is welded or otherwise secured to the rear wall 28 of the casing 22. Affixed to opposite sides of the wall 42 are sockets 46 and 48 for receiving (Illegible Word) 50 and (Illegible Word) respectively. As is shown in Fig. 4, a number of holes or apetures 54 may be provided in the plate 52 so that light can be transmitted from either bulb or both sides of the casing. This assures that even if one bulb should fail at least partial illumination of the whole sign will still be possible.

One possible circuit for controlling the signal lamps 18 and 20 of the present invention is illustrated in Fig. 5 where the vehicle power source, such as the battery 60, is connected to the conventional turn signal switch 62 through a flasher assembly 64 which is also a conventional (Illegible Word). In a first position the turn signal switch 62 causes the left front signal lamp 661, the left rear lamp 14, and the two lamps 50 and 52 of the unit 18 to flash in unison. In the opposite position the switch 62 (Illegible Word) the right forward signal lamp 66r, the rear right signal lamp 16 and the two bulbs of the unit 20. It will be noted that the two bulbs 50 and 52 of each unit are connected in parallel to one another and in parallel to the other signal lamps on the corresponding side of the vehicle. If desired, suitable means such as the double hole signal throw switch 70 may be provided for disconnecting the signaling units 18 and 20 when desired.

While only the best known embodiment has been illustrated and described in detail herein, it will be clearly understood that the invention is not limited thereto or thereby. Reference should therefore be had to the appended claims in determining the true scope of the invention.

What is claimed is

1. An auxiliary signal system for a vehicle having a conventional turn signal system which comprises:

a pair of lamp housings, each having a removable face plate carrying a distinctive legend, the housings being mounted on the rear of the vehicle and adjacent the opposite sides thereof;

at least one lamp within each housing for illuminating the face plate thereof to make the legend visible; and circuit means connecting the lamp of each housing to the actuating circuit of the respective turn signal whereby the lamp operates in conjunction with the respective turn signal.

2. The auxiliary signal system according to Claim 1 wherein each housing comprises a bon-like member having a rectangular opening in one side thereof, the face plate covering the opening.

3. The auxiliary signal system according to Claim 2 wherein two lamps are provided within each housing, the lamps being connected in parallel and positioned so as to illuminate opposite ends of the enclosure.

4. The auxiliary signal system according to Claim 3 wherein each housing has a vertically extending center wall, the two lamps being mounted to the center wall on opposite sides thereof.

5. The auxiliary signal system according to Claim 1 wherein the legend carried by the facing plate of the left housing is "CAUTION" and the legend carried by the facing plate of the right housing is "THANK YOU".

ID: nht88-4.40

TYPE: INTERPRETATION-NHTSA

DATE: 12/16/88

FROM: RAYMOND F. BRADY -- RODNEY D. MCGALLIARD

TO: OFFICE OF CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/13/89 FROM ERIKA Z. JONES TO RAYMOND F. BRADY, REDBOOK A33, PART 571.3; LETTER DATED 02/14/89 FROM RAYMOND F. BRADY TO NHTSA, REF 2912

TEXT: Dear Chief Counsel:

I would like to obtain your written opinion on the issue of whether a certain seat contained in a limousine constitutes a "designated seating position," as that term is defined in Section 571.3 of Title 49 of the Code of Federal Regulations. Specific ally, I am referring to two rearward-facing passenger seats, separated by a wooden stereo/television console, inserted by O'Gara Coachworks company in a 1985 Cadillac Fleetwood Brougham which was extended 46 inches into a limousine. O'Gara Coachworks re ferred to this limousine as its "Moritz" model. I have attached as Exhibit A hereto, a copy of a promotional brochure relating to the Moritz limousine. The two rearward-facing seats at issue are highlighted in yellow.

As you can see from Exhibit A, the rearward-facing seats are freestanding, and by that I mean that the seats have their own bottom and back cushions, the seats are mounted to the floor, and the seats are not attached to, nor do they fold up into, the back of any other seat. Furthermore, the bottom cushions of these seats are not spring-loaded to keep them in a retracted position, although it is possible to raise the bottom cushions manually to some extent. The seats are not labelled in any way to i ndicate that the seats are not designated for occupancy while the limousine is in motion. Finally, I would note that the rear passenger compartment of the Moritz limousine has been described by O'Gara Coachworks as having seating capacity for five perso ns.

Please let me know if you need further information in order to make this determination. Otherwise, I look forward to receiving your opinion.

Sincerely,

(PICTURES OF SINGLE SIDE CONSOLE AND CENTER CONSOLE OMITTED)

ID: aiam1001

Dear Mr. Utsunomiya:#This is in reply to your letter of February 8 1973 concerning the operating point of a hand-operating parking system (Standard No. 105a)#We intend to specify an operating point in the response to petitions for reconsideration of Standard No 105a. This Notice should be published not later than May 1, 1973.#Yours truly,Richard B. Dyson,Assistant Chief Counsel;