ID: nht72-1.35

DATE: 03/23/72

FROM: HARTMAN FOR DOUGLAS W. TOMS -- NHTSA

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of February 18, 1972, dealt with three aspects of Standard 215 that continue to be of concern to Chrysler and with one feature of Standard 210 that you regard as inappropriate.

Your first problem with Standard 215 is the requirement for corner impacts at heights below 20 inches. Our response to the objections raised by Chrysler and others when this requirement was made a part of the standard was to grant an additional two years for compliance. We did this in the expectation that the additional time would permit the manufacturers to make the necessary changes within their normal tooling cycle.

The agency considered the corner impact requirement to be justified, and it is not now persuaded to the contrary. We would be willing, however, to review any additional information you can provide on the subject of the costs and the benefits of the improved corners.

Your second concern has also been expressed at several points in the rule-making process. In response to comments advocating the use of resilient materials in the bumper itself, the standard was amended to specify a broader impact ridge, rather than to specify the resiliency of material with which contact would be permitted. The agency has not considered the styling effects of the pendulum requirement to be sufficient to justify amending the standard to permit cosmetic additions of the type you describe. Of course you are free to submit additional information to support the need for such an amendment.

The photometric requirements from Standard 108 that are proposed for incorporation in Standard 215 have been the subject of several comments under Notice 10 in Dockets 1-9 and 1-10. The issue has not been resolved by issuance of a final rule and we will therefore consider your remarks as an addition to Chrysler's comments on Notice 10.

In the area of seat belt anchorages, the question of whether to use dynamic or static test methods was resolved in October 1970 by specifying a static test with a 10-second holding period. It was thought that this was the surest means of testing the basic strength of the metal and that it therefore carried out the original intent of the standard. Although it may be that the resulting anchorages are able to withstand barrier crashes at speeds considerably higher than 30 mph, we do not consider this to be sufficient cause for relaxing the anchorage requirement. If you have information concerning the force levels at which accidents are survivable, and the relation of these levels to anchorage strength, we would be glad to receive this information.

ID: 86-5.30

TYPE: INTERPRETATION-NHTSA

DATE: 10/16/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Alan Cranston

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter on behalf of Mr. Raymond Kesler. He asked for this agency's response to a letter from Mr. Robert R. Phillips concerning the bi-focal mirror developed by Mr. Kesler. In his letter, Mr. Phillips asked whether an outside rearview mirror, which has both a planar surface of unit magnification and a convex surface, complies with Standard No. 111, Rearview Mirrors. I regret the delay in responding to this letter.

As we understand the information supplied by Mr. Phillips, the bi-focal mirror would be installed on the driver's side of motor vehicles to give the driver a wider field of view by combining a convex mirror and a planar mirror as the outside rearview mirror on the driver's side. The convex portion would abut the planar portion and be located to the left of the planar portion. Thus, both normal and wide-angle vision would be provided at the same horizontal viewing level.

By way of background information, this agency does not give approvals of vehicles or their equipment. The National Traffic and Motor Vehicle Safety Act of 1966, as amended (the Act), places the responsibility on the manufacturer to ensure that items of motor vehicle equipment, such as rearview mirrors, comply with any applicable requirements. A manufacturer certifies that its equipment complies with all applicable safety standards.

Mr. Phillips asked this agency to confirm his interpretation that this bi-focal mirror meets the requirements of Standard No. 111 if its planar or unit magnification surface has an area of at least 19.5 square inches, regardless of the existence of the convex portion. The 19.5 square inch requirement is one applicable to multipurpose passenger vehicles, trucks, and buses (other than schoolbuses) with a GVWR of 10,000 pounds or less. Those types of vehicles are required by S6.1 of the standard either to have a set of inside and outside rearview mirrors that comply with the requirements applicable to passenger cars or to have outside mirrors of unit magnification, each with not less than 19.5 square inches of reflective surface, on both sides of the vehicle. If Mr. Phillips' mirror meets that size requirement, is located on a vehicle so as to provide the required view and is adjustable in the required manner, it complies with S6.1.

There are no minimum size requirements for unit magnification outside rearview mirrors on passenger cars. Mr. Phillips' mirror can be installed on the driver's side of passenger cars if the mirror's unit magnification portion, independently of the convex portion, meets the field of view and mounting requirements specified in S5.2.

In one drawing accompanying Mr. Phillips' letter, there appears to be a warning on the planar portion of his bi-focal mirror stating "Objects Appear Within Markers: Caution." There is no requirement in Standard No. 111 for such a warning. The agency is concerned that the message conveyed by this warning is unclear and could confuse motorists. The warning ("CAUTION When Vehicle Appears Here") in Mr. Phillips' other drawing seems more easily understood. He might consider providing purchasers with written instructions explaining that the purpose of the message is to warn drivers that the appearance of a vehicle in the convex portion of the mirror means that the vehicle is so close that a lane change would be unsafe.

Unit magnification and convex mirrors on other types of vehicles must meet the specific performance and location requirements for those types of vehicles, as set out in the standard. Again, please note that a vehicle manufacturer installing a bi-focal mirror on different types of vehicles must ensure that the unit magnification portion of the mirror meets any applicable requirements of the standard independently of the convex portion.

If Mr. Phillips' mirror meets the requirements of Standard No. 111 for a particular vehicle type, then it may be installed on new vehicles of that type. It may also be installed on used vehicles of that type. Conversely, if the mirror does not meet those requirements, then it may not be installed on new vehicles. Further, manufacturers, distributors, dealers and repair businesses would be prohibited from installing it on used vehicles. However, the Act does not establish any limitations on an individual vehicle owner's ability to alter his or her own used vehicle.

Under Federal law, individual vehicle owners can themselves install any product they want on their used vehicles, regardless of whether that product would render inoperative the compliance of the vehicle's rearview mirrors with the performance or location requirements of Standard No. 111.

I hope this information is helpful to you.

SINCERELY

United States Senate

August 19, 1986

To: Congressional Laision Department of Transportation National Highway Traffic Safety Administration

Enclosure From:

Mr. Ray Kesler

Re: Mr. Kesler would appreciate a letter confirming his bifocal safety mirror conforms to federal safety standards. Is this possible?

I forward the attached for your consideration.

Your report, in duplicate, along with the return of the enclosure will be appreciated.

Alan Cranston

Please address envelope to:

Senator Alan Cranston

August 6, 1986

Dear Senator Cranston,

I am seeking a letter to confirm, yes it does provide the plane flat mirror (unit of manification) on the required amount because it is comformity of the standards. I would expect they would simply state it back to us so I can present it to the S.A,E, (society of automotive engineers) and the automotive industry that they have no question, it does meet the federal safety standards, but that has not happened and would appreciate a answer on this soon. This has held up this project for many monthes. I believe we can start saving lives with the new mirror concept in safety vision soon. I know you will give federal support on this matter. You have been so helpful before and I sincerely thank you.

Ray Kesler

enclosure. Drawings (2)

Instructions on viewing bifocal safety mirror

July 25, 1980

The Honorable Alan Cranston UNITED STATE SENATE

Dear Senator Cranston:

Your concern for public safety is well known to us, and because of your reputation as a strong-willed combatant for causes you believe in, we are soliciting your advice and support for our project.

My client, Mr. Raymond Kesler, has recently developed a bifocal safety mirror for automobiles that has the potential to make a major contribution to the cause or automotive safety. You have previously been kind enough to lend support to Mr. Kesler on this project (i.e. your letter to Diane Steed at NHTSA on Feb. 5, 1985), and we are once again in need of someone to help break what appears to be a bureaucratic logjam.

The enclosed letter was written to Brika Jones, Chief Counsel at NHTSA upon the advice of Dr. Carl Clark, Investor Contact Code NRD-12 in the Office of Vehicle Research. As the letter indicates, we are simply seeking interpretation of the code of federal regulations governing automotive mirrors. Our question is, we believe, specific and clear, yet to date no response from Ms. Jones was received.

If you could assist us in getting some official interpretation as to how the federal regulations affect this bi-focal mirror, we would be most grateful.

Robert R. Phillips Project Manager enclosure: Erika Jones Letter (March 27, 1986)

P.S. We are also enclosing a copy of an article on the mirror that recently appeared in Automotive News.

March 27, 1980

Erika Jones Chief Counsel NATIONAL HIGHWAY TRAFFIC AND SAFETY ADMIN.

Dear Ms. Jones:

At the suggestion of Dr. Carl Clark in the Office of Vehicle Research, we are seeking from you some interpretation of existing federal regulations regarding outside rear-view mirrors for automobiles.

In particular, we are concerned about a mirror that was recently developed by Mr. Raymond Kesler, a California inventor. The enclosed article in Automotive News plus the other material provides information on the mirror, but our inquiry is, I believe, specific and clear.

It is our interpretation or the NHTSA regulations that this bi-focal mirror (i.e. a planar surface abutted to a convex mirror of fixed radius) does meet the requirements if its planar (unit magnification) surface has an area of at least 19.5 square inches, regardless of the existence of the convex portion.

We would greatly appreciate your comments on this interpretation prior to final approval of the mirror's specific dimensions.

Thank you for your assistance.

Robert R. Phillips

Automotive News

March 24, 1986

engineering

Mirror wipes out blind spot

An inventor in West Hollywood, Calif., believes car mirrors have been overlooked for too long. He has taken what he calls a revolutionary approach to the subject and has eliminated the pesky -- and dangerous -- passing-car blind spot.

The first auto mirror, patterned after one seen on a carriage in Chicago, was used on the winning car in the first Indianapolis 500 race in 1911. Driver Ray Harroun installed the 8-inch-by-3-inch mirror to avoid using the riding mechanic who usually kept one eye rearward in races of the era.

It would appear that little change has taken place over the years, and 47-year-old inventor Raymond Kesler said his latest work will refocus attention of safety authorities on the mirror.

Others say that attention is overdue. They contend that because the U.S. population is aging, the left-side blind spot is growing as a danger point. (Illegible Word) one's peripheral vision diminishes with age.

Kesler said he has combined the positive characteristics of two different optics -- a planar, or flat, surface connected to a curved surface of fixed radius.

"This achieves a remarkably effective enhancement of the field of view without the distortion associated with variable-curvature convex mirrors," he said.

"The Kesler approach uses the flat surface for 70 percent of the mirror with the remaining 30 percent devoted to the convex portion for wide-angle vision."

On the convex surface, there are what Kesler calls "reflective caution arrows" which warn the driver of traffic approaching from the rear and act as a distance finder for position and size of objects.

"The overall unit is rectangular to fit most 1985/86 original equipment mirror housings," Kesler said, "It also it well-suited for the aftermarket manufacturers who utilize the new rectangular design for their mirrors."

A patent is pending, Kesler said.

The inventor has been interested in automotive accessories and automotive phenomena for many years, said Robert R. Phillips, of the Woodland Hills (Calif.) consulting firm that bears his name. Phillips is handling inquiries about Kesler's device.

In most other attempts at bifocal mirrors, distortion has been the major problem, and NHTSA regulations have kept them off the road. Hopes of other inventors have been shattered by NHTSA investigations.

Small, convex anti-blind-spot mirrors that adhere to flat mirrors are sold by parts stores and are not installed as original equipment. Therefore, their distortion escapes the regulatory eye of NHTSA. Also, such mirrors stand out physically from the flat mirror and it is not likely a driver would confus, images seen in them with images in the flat mirror.

A mirror manufacturer in Michigan said some drivers become nauseated from multiple radius mirrors. The eyes see differing images simultaneously, and the brain becomes confused.

Several mirror makers have petitioned NHTSA for regulation changes. European regulations are reported to be similarly rigid, but Saab in 1982 introduced in Europe a mirror it says eliminates the blind spot.

The Saab mirror, as does Kesler's, shows two fields of view at the same time.

The mirror glass has two surfaces. One is a large plane surface closest to the driver. It is separated from the second, a narrow convex surface, by an etched line.

Together, the two surfaces enable the driver to follow a passing vehicle until it becomes visible in the driver's direct vision, even in the blind spot, Saab said.

Saab said European legislation is very strict regarding the design of side mirrors and requires that the division between the two fields be clearly marked. In Saab's case, this is achieved by the etched line, the company said.

Kesler said the Kesler Bi-Focal Safety Mirror meets federal safety standards. He also said there are no other similarly qualified mirrors that have normal and wide-angle vision at the same horizontal viewing level.

The Kesler Bi-focal Wide Angle Automotive Safety Mirror

(Meets Federal Motor Vehicle Safety Standard No. 111.) D.O.T.

REFLECTIVE CAUTION ARROWS RNS DRIVER OF APPROACHING TRAFFIC

(ACTS AS A DISTANCE FINDER FOR POSITION AND SIZE OF OBJECTS)

PLANAR MIRROR (NORMAL VISION OF STANDARDS) D.O.T.

ABUTTED JUNCTURE TANGENT TO PLANE KESLER PATENT PENDING

(C) 1986 KESLER RESEARCH ENTERPRISES

PICTORIAL CONCEPT OF WIDE ANGLE OPTIC

(Graphics omitted)

Traffic in "BLIND SPOT" Appears Here

CAUTION When Vehicle Appears Here

Traffic Leaves View of Planar Mirror Here

Anti-Blind Spot Mirror

(Graphics omitted)

KESLER RESEARCH ENTERPRISES

"Avoid an Accident at a Glance"

SAFETY ADVANTAGES OF VIEWING BIFOCAL REARVIEW SAFETY MIRROR

1. Plane section of mirror is for normal viewing of traffic with no depth perception loss. This section complies with FMVSS III D.O.T. standards.

2. The constant radius convex section of the mirror provides an extra margin of safety with uniform vision on a horizontal level, allowing extra vision for better view of the far lane, pulling away from curbs, and backing out of driveways.

3. A conventional mirror out of adjustment can cause an accident. The fact is that a convex section of the bi-focal safety mirror provides the extra vision, even when out of adjustment.

4. The reflective caution safety markers on the convex section aid the user for judging distance, position, and size or objects.

5. Both plane and convex mirrors can be viewed to cut glance duration time to a minimum when objects (traffic) appear in the safety markers.

6. Both separate sections can be viewed as one (integrated) mirror when objects meet the transition.

Copyright, 1986 KESLER RESEARCH

ID: nht68-3.28

DATE: 04/24/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Schein Body and Equipment Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of February 29, 1968, to Dr. William Haddon, Jr. concerning the location of lamps and reflectors on your dump semi-trailers and equipment loaders.

Initial Motor Vehicle Safety Standard No. 108 requires that the side reflex reflectors be mounted not less than 15 inches nor more than 60 inches above the road surface. To meet this requirement, the front side reflex reflectors on your dump semi-trailers may be mounted below the side rail of the body. If necessary, a protective shield or housing could be provided to prevent the reflector from being damaged by rocks and mud.

With respect to the location of rear clearance lamps on your dump semi-trailers, Standard No. 108 requires that these lamps be located as near as practicable to the upper left and right extreme edges of the vehicle, except that optional heights are permitted when the rear identification lamps are mounted at the extreme height of the vehicle. Your photograph does not show identification lamps on the rear of your trailer; however, it does not appear that these lamps could be mounted at the extreme height of the vehicle, since the tail gate is often removed. In this case, the rear clearance lamps must be located as near as practicable to the upper left and right extreme edges of the vehicle. It appears that clearance lamps located immediately forward of the rear post of a point not obscured by the covering tarpaulin would meet this requirement of the standard. A combination clearance and rear side marker lamp at that location would also be permitted by the standard.

On your tilt type and roll-back equipment loaders, location of tail, stop, turn signal, and identification lamps 30 inches from the extreme rear of the platform, and location of the rear clearance lamps and rear reflectors 44 inches from the extreme rear of the platform, appear to be in accordance with the location requirements of Standard No. 108.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

ID: aiam5177

"Dear Mr. Zang: This responds to your letter asking about governmen rules applicable to your product, which you describe as an aftermarket child's car seat cover made out of a plastic-coated fabric. In particular, you were concerned about flammability restrictions that would be applicable to your product. I am pleased to have this opportunity to explain our requirements to you. After providing background information, I will answer the specific questions raised in your letter. By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, the Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The agency periodically tests new vehicles and items of equipment for compliance with the standards. In response to your question, there are currently no Federal motor vehicle safety standards (FMVSS's) that directly apply to the product you wish to manufacture. Under the authority of the Safety Act, NHTSA has issued Standard No. 213, Child Restraint Systems, which specifies requirements for child restraint systems used in motor vehicles and aircraft. However, Standard No. 213 applies only to new child restraint systems and not to aftermarket components of a child restraint system, such as an aftermarket seat cover. I note, however, that there are other Federal requirements that indirectly affect your manufacture and sale of your product. Under the Safety Act, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you are subject to the requirements in 151-159 of the Safety Act concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those responsibilities. In the event that you or NHTSA determines that your cover contains a safety-related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge. Manufacturers, distributors, dealers, and motor vehicle repair businesses are subject to 108(a)(2)(A) of the Safety Act, which states: 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative ... 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 ....' A child restraint has elements of design that could be rendered inoperative by a child seat cover. Standard No. 213 sets flammability resistance requirements for materials used in a child restraint system. (See S5.7 of Standard No. 213, referencing Standard No. 302, 'Flammability of Interior Materials.') While it appears unlikely that persons in the aforementioned categories would be installing your product, if they were to install it, they should ensure that they do not compromise the safety protection provided by the child restraint system. The 'render inoperative' prohibition of 108(a)(2)(A) does not apply to the actions of vehicle owners in adding to or otherwise modifying their vehicles or items of motor vehicle equipment. Thus, if your seat cover were placed on restraints by the restraint owners, your product need not meet any FMVSS's. Nevertheless, in the interest of safety, we suggest you consider conforming your product to a flammability resistance standard equivalent to Standard No. 302. I will now take this opportunity to answer your specific questions. Question One 1. Where can the fabric be tested? The agency does not recommend any test laboratory. However, the following laboratories have conducted similar tests for this agency. Commercial Testing Co Detroit Testing Laboratory 1215 S. Hamilton Street P.O. Box 869 Dalton, GA 30722-0985 Warren, MI 48090-0869 Phone: (404) 278-3935 Phone: (313) 754-9000 Fax: (404) 278-3936 Fax: (313) 754-9045 United States Testing Co. Engineering Services Division 291 Fairfield, NJ 07006 Phone: (201) 575-5252 Fax: (201) 575-8271 Question Two 2. What are the test specifications? As explained above, Standard No. 302 specifies the Federal motor vehicle safety standards applicable to flammability resistance. This standard does not directly apply to aftermarket products such as a seat cover for a child restraint. However, we have enclosed a copy of Standard No. 302 for your information. Question Three 3. Are these questions something that are already available from the factory? We are not certain what information you wished to obtain by this question. We assume that you were asking whether a manufacturer of a product subject to Standard No. 302 can rely on the assurances from the fabric manufacturer that the material meets the standard's flammability requirements. The manufacturer of the product (e.g., a new child restraint system) would be responsible for exercising due care in certifying that the product meets all applicable FMVSS's. The manufacturer of the product would thus be responsible for ensuring that its reliance on the fabric manufacturer's assurances were reasonable and that the assurances were bona fide. Question Four 4. Whether the packaging can state that the fabric has been tested and found to be within compliance with government regulations. Only motor vehicles and motor vehicle equipment that are subject to and that meet the FMVSS's may be certified as complying with those standards. NHTSA does not permit manufacturers of products that are not subject to the FMVSS's to certify to those standards because consumers might be confused or misled about a statement that a product complies with a standard when in fact no standard applied. Accordingly, since no FMVSS applies to an aftermarket child seat cover, you must not state on the packaging that the fabric of your product complies with the FMVSS's. Question Five 5. Seeks any other government regulations for children's products. We are not aware of any other Federal government agency that regulates items of motor vehicle equipment. More generally, please be aware that the United States Consumer Product Safety Commission regulates certain consumer products used by children. You may wish to contact that agency at (301) 492-6580 for information about their statutes and regulations related to children's products. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosure";

ID: aiam4907

"Dear Mr. Shimp: This responds to your letter of September 17, 1991 regarding the addition of a seat to your company's cargo vans. I am pleased to have this opportunity to explain the requirements of Federal law for you. The National Traffic and Motor Vehicle Safety Act (Safety Act) authorizes this agency to issue safety standards for new motor vehicles and new items of motor vehicle equipment. The Safety Act requires manufacturers to certify that each of their new vehicles or new items of equipment complies with all applicable safety standards at the time the product is delivered to the first purchaser in good faith for purposes other than resale. After a vehicle is delivered to the first purchaser for purposes other than resale, modifications to the vehicle are affected by section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section prohibits any manufacturer, dealer, distributor, or repair business from 'rendering inoperative' any device or element of design installed in a vehicle in compliance with a safety standard. Please note that section 108(a)(2)(A) does not affect modifications made by vehicle owners to their own vehicles. Therefore, Baltimore Gas and Electric may install additional seats in the cargo vans it owns without violating the 'render inoperative' provision or any other provisions of the Safety Act, providing Baltimore Gas and Electric performs the work themselves. However, the individual States have the authority to regulate the modifications that owners can make to their own vehicles. You should contact the State of Maryland to learn if it has enacted any laws or regulations that apply to your planned modifications to your vans. In addition, you may wish to consult with an attorney familiar with the law in the State of Maryland regarding potential liability for your company in connection with adding a seat to these vans. Finally, although Federal law does not regulate your company's planned addition of seats to its vehicles, we urge you to carefully consider the safety issues that would arise if your company proceeds with the installation of these additional seats. Specifically, this agency encourages your company to select and install any additional seats in a way that will not degrade occupant protection, and to install a safety belt for those additional seats, so that your employees using the additional seat will be protected in the event of a crash. I hope you find this information helpful. If you have further questions, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel";

ID: aiam0322

Dear Mr. Hartman: This is in reply to your letter of April 9, 1971 concerning certai provisions of Motor Vehicle Safety Standard No. 213, 'Child Seating Systems.' In your letter you ask whether S4.4 of the standard requires the child seating system itself to be restrained by the seat belt assembly. You state that S4.5.1 indicates to you that the vehicle seat belt assembly is employed to restrain both the child and the seating system, and request that this issue be clarified.; S4.4(a) of the standard requires each child seating system, whe installed as the manufacturer directs, to be restrained by the vehicle seat belt assembly. The vehicle seat belt assembly may *also* be used to directly restrain the child, but it is not required to do so. When it is used for this purpose, however, it must distribute the restraint forces as specified by S4.5.1 of the standard.; The statement in the preamble of the notice of March 23, 1970 to whic you refer describes the scope of the standard. This statement means that any device for seating children in a motor vehicle that is designed to utilize the vehicle restraint system or provides restraint by itself, or both, is a 'child seating system' and must comply with all the requirements of the standard.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: 12415.ZTV

Herr P. Binder
ITT Automotive Europe
Stuttgarterstrasse 119
74321 Bietigheim-Bissingen
Germany

Dear Herr Binder:

This replies to your FAX of September 3, 1996, asking for the regulations to be met by a new design for a center highmounted stop lamp (CHMSL).

As you describe it, in the intended design a passenger car will have two CHMSLs, one mounted in the car body and other mounted in the rear spoiler. The car body CHMSL will function until the rear spoiler extends at speed, and at the point "at which the spoiler will shade the CHMSL" the second CHMSL operates when the brake pedal is applied.

We assume that the second CHMSL is provided because as the spoiler extends it will mask to some extent the first CHMSL and may create a failure of the first CHMSL to comply with photometric and visibility requirements. This situation is addressed by paragraph S5.3.1.1 of Standard No. 108. This paragraph first specifies that lamps shall be located so that they meet visibility requirements specified in any applicable SAE Standard or Recommended Practice. In addition, this paragraph specifies that no part of a vehicle shall prevent any lamp from meeting the photometric output at any test point specified in any applicable SAE Standard or Recommended Practice. However, if motor vehicle equipment such as a spoiler prevents compliance by a lamp, an auxiliary lamp meeting the visibility and photometric specifications required for the original lamp shall be provided. We assume that the second CHMSL in the spoiler will meet these requirements.

Your letter does not say whether the first CHMSL is extinguished when the second CHMSL operates, or whether they would both operate together. Either method is acceptable to us and would not cause a noncompliance with Standard No. 108.

If you have any questions, you may refer them to Taylor Vinson of this Office.

Sincerely,

John Womack

Acting Chief Counsel

ref:108

d:10/16/96

ID: aiam4149

Dear Mr. Hutton: This responds to your letter asking about inertial-locking seatbelt and seatbacks. We apologize for the delay in our response. You stated that your firm represents a woman who was injured in a 1982 Ford Escort GT. According to your letter, while braking to exit a highway, the driver's seatback was thrown forward, not locking, causing your client to lose control of the car and crash into a guardrail. You asked for information about inertial-lock mechanisms on automobiles, particularly for seat backs and belts in that car, and references to government safety standards. You specifically asked whether there was a standard for the maximum distance the seatback can travel before locking under load.; The National Highway Traffic Safety Administration (NHTSA) issue Federal motor vehicle safety standards, pursuant to the National Traffic and Motor Vehicle Safety Act. Two of our standards are relevant to inertial-lock mechanisms.; Federal Motor Vehicle Safety Standard No. 209, *Seat Belt Assemblies* specifies requirements for inertial-locking safety belts. Section S4.3(j) specifies the following:; >>>(j) *Emergency-locking retractor*. An emergency-locking retractor o a Type 1 or Type 2 seat belt assembly, when tested in accordance with the procedures specified in paragraph S5.2(j)--; (1) Shall lock before the webbing extends 1 inch when the retractor i subject to an acceleration of 0.7 g. . . .<<<; Thus, for safety belts, there is a specific requirement for the maximu distance the webbing may extend before locking under load.; Federal Motor Vehicle Safety Standard No. 207, *Seating Systems* (4 CFR S571.207), specifies requirements for restraining devices for hinged or folding seats and seat backs. See section S4.3. The standard requires that such seats be equipped with self-locking restraining devices, and specifies both static force and acceleration performance requirements which the restraining devices must meet once engaged. However, the standard does not specify either the load at which an inertial-locking seatback must lock or the maximum distance the seatback can travel before locking under load.; In response to your request for information that relates to th particular car involved in your client's accident, we have enclosed a computer printout listing relevant vehicle owner reports which allege problems similar to that identified by your letter.; I hope this information is helpful. There is no fee for th information.; Sincerely, Erika Z. Jones, Chief Counsel

ID: nht94-3.99

TYPE: INTERPRETATION-NHTSA

DATE: August 15, 1994

FROM: Amin Ahmadi

TO: Office of Rule Making

TITLE: NONE

ATTACHMT: Attached to 1/5/95 letter from Philip R. Recht to Amin Ahmadi (A43; Std. 111)

TEXT: Dear Sir/Mom

Recently I made an application to Patent a safety device with Office of Patent and Trade Mark which it will reduce the risk of accidents caused in connection with car side mirror Blind Spot.

As a matter of safety I am sure your office is interested in implementing new devices that can increase the safety factor and decrease the risk factor for drivers of all types of motor vehicles.

My mirror can reduce dramatically (if not eliminating) Blind Spots.

It is a regular mirror that can be manufactured in various shape and size.

To demonstrate how this mirror works, imagine, for example, a 6 inch mirror that has 4 inches shaped at a straight angle and 2 inches angle of 3-5 degree outward variance. This combination of straight and outward angles can cover and eliminate the Blind Spot.

The mirror should have two specifications in molding Process which:

1 - At the point of angle there should not be any line of demarcation (to prevent a "Broken" image).

2 - At the point of angle it should have a very slight bend (to prevent a convex image).

This device will seriously impact and greatly increase the safety and well being of literally every driver of any type of motor vehicle,, and deserves serious consideration in being mandatory on all motor vehicles

Please keep it confidential and I will be more than happy to answer any question.

Sincerely yours

Enclosure

From AMIN AHMADI 8990 19th St. # 319 Alta Loma CA 91701 To MR. MARVIN SHAW

DEAR MR. SHAW

It was a pleasure talking to you. Here is a Drawing for Blind Spot Remover that can be used in Motor Vehicle Industry The Angle should be so Disgned that Eliminates Broken or two Images & also eliminate Conver Image. So there is Very fine line Between Sharp angle & Curve that is the most Important of the MIRROR that gives two picture without Distortion. Please pay attention the drawing is just for Demonstration only in reality as I mentioned there should be no Line in the PART of angle.

[PHOTOGRAPH OMITTED - SEE ORIGINAL SOURCE]

ID: nht92-4.5

DATE: 09/15/92

FROM: WILBUR D. OWENS, III -- BOUHAN, WILLIAMS AND LEVY

TO: OFFICE OF VEHICLE SAFETY STANDARDS, NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

COPYEE: ROY E. PAUL, ESQ.

TITLE: RE: JOSEPH L. PHELPS, JR. VS. GENERAL MOTORS CORPORATION AND GRUMMAN OLSON, A DIVISION OF GRUMMAN ALLIED INDUSTRIES, INC., UNITED STATES DISTRICT COURT, SOUTHERN DISTRICT OF GEORGIA, SAVANNAH DIVISION, CASE NO. CV 492-115

ATTACHMT: ATTACHED TO LETTER DATED 11-10-92 FROM PAUL J. RICE (SIGNED BY JOHN WOMACK) TO WILBER D. OWENS, III (A40; PART 571.3)

TEXT: Please note that we are the attorneys for Grumman Olson in the above-referenced lawsuit. Grumman Olson and General Motors have been sued by Mr. Phelps as a result of injuries he received in an accident while driving a 14-foot Kurbmaster, manufactured in 1977, and generally consisting of Chevy and Grumman Olson parts.

The Plaintiff has centered his case upon allegations that the vehicle had too great a tendency to roll over, that there was no three-point seat belt restraint system, and that the steering column and wheel were allowed to intrude into the space of the driver. We have looked at the current regulations concerning vehicles and would request your assistance in interpreting same and in carrying some of these regulations back to 1977.

We are interested in the current regulations covering these "step-vans" and, in particular, those which concern areas covered by the Plaintiff's theories of liability. Thus, some of our main areas of interest are from 49 CFR 571.20 through 49 CFR 571.220. We note that most of these regulations in @ S2 set forth the vehicles to which said regulation applies. Most apply to passenger cars, multi-purpose passenger vehicles, trucks, and busses. However, there are a number of exceptions for "walk-in vans". The first question we have is whether a 14-foot Kurbmaster would be considered a truck or a walk-in van, or sometimes both.

We would appreciate your assistance in informing us of how we can receive corresponding regulations for 1977. In particular, if you have someone who works for you with knowledge in the area of step-vans, we would like to be able to speak to them on the telephone to obtain a clearer understanding of the current regulations and the past regulations.

We sincerely appreciate your assistance concerning the above and look forward to speaking to you in the near future.

With best wishes, I am very truly yours.