ID: nht76-2.43

DATE: 07/15/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 22, 1976, asking for interpretations of Motor Vehicle Safety Standards Nos. 108 and 205.

Paragraph S4.3.1 of Standard No. 108 requires, as you noted, that lamps and reflective devices be securely mounted on a rigid part of the vehicle. You asked "whether or not flexible mount clearance and sidemarker lamps should be permitted for use on motor vehicles." Your question appears directed towards replacement equipment. The answer is that California may regulate mounts for replacement lighting equipment in the manner it deems appropriate. S4.3.1 applies to the mounting of lighting equipment on new motor vehicles, and does not establish a specification for replacement equipment mounts. The replacement clearance and sidemarker lamps themselves are, of course, subject to Standard No. 108.

You also asked whether there was a provision in Standard No. 205, Glazing Materials, that would exempt "Item 3" [AS 3] glazing (to be used for glass partitions and rear side windows of van-type vehicles) from the requirements of ANS Z26 Tests Nos. 1 and 18.

The answer to your question is no. Paragraph S5.1.1 of Standard No. 205 specifies that glazing materials for use in motor vehicles shall conform to the requirements of ANS Z26. The ANS Z26 specifications require "Item 3" glazing materials to comply with Test No. 1, "Light Stability," and Test No. 18, "Abrasion Resistance," regardless of where the "Item 3" glazing is to be used in the vehicle. Thus, there is no provision by which manufacturers of such glazing may be exempted from the test requirements.

SINCERELY,

DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

June 22, 1976

File No.: 61.A2781.A3107

James C. Schultz Chief Counsel National Highway Traffic Safety Administration

We would appreciate your interpretation of Federal Motor Vehicle Safety Standards Nos. 108 and 205 with regard to the following situations:

1. FMVSS No. 108, Section S4.3.1 requires, in part, that lamps and reflective devices be securely mounted on a rigid part of the vehicle. For several years, clearance or sidemarker lamps have been available which have a rubber strap between the mounting plate and the lamp housing that allows the lamp great freedom of movement when attached to "a rigid part of the vehicle".

Each of the lamps we have examined has a small degree of rotation between the mounting plate and the lamp. In addition, when the mounting plate is held against an appropriate mounting surface, the lamp axis is neither parallel nor perpendicular to the planes normally associated with lamp orientation. When a truck with this type of lamp installed is in motion, the wind currents cause the orientation of the clearance lamps to be further distorted and the ones used for the sidemarker function are in constant motion.

We assume that the intent of the regulation is to ensure that the device will maintain a fixed orientation. Since this lamp cannot comply with that requirement, we request your opinion as to whether or not flexible-mount clearance and sidemarker lamps should be permitted to be sold for use on motor vehicles.

2. Due to the increasing popularity of glass partitions in van-type vehicles, we have received many requests for our approval of AS-3 glazing manufactured with one or both sides textured to render it translucent or with designs etched or sand-blasted upon it. This glazing is also used in the rear side windows of vans and bathroom windows in buses and recreation vehicles. Several of the manufacturers have asked to have this type of glazing exempted from ANSI Test Number 18, Abrasion Resistance, because such resistance has no safety value in this application.

Since the purpose of the abrasion test is to ensure that the driver will have an undisturbed view in the areas requisite for driving visibility, it appears unreasonable to require Tests Nos. 1 and 18 to be performed on glazing that is not used for driving visibility. We would like to know if there is a provision which would allow these manufacturers to be exempt from these tests for this type of glazing.

WARREN M. HEATH Commander Engineering Section

CC: AAMVA; VESC

ID: 86-2.45

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Marshall D. Carter

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 18, 1986, asking two questions with respect to the Federal motor vehicle safety standards.

With respect to electric vehicles, you have asked "is there a standard regulating the minimum length of time that the hazard light must be able to function at a minimum intensity, on the service battery alone?" There is no such standard. The vehicle must be equipped with a hazard warning signal operating unit designed to conform to SAE J910, January 1966, and a hazard warning signal flasher designed to conform to SAE J945, February 1966, but there is no requirement in the Federal motor vehicle safety standard on vehicle lighting, Standard No. 108, that the hazard warning signal flashers perform for a minimum specified period of time in service.

You have also asked "Is there a requirement that the vehicle be equipped with an illuminated display, indicating gear selection?" We are unable to confirm your conclusion that there is no such requirement under Standard No. 101. Paragraph S3.2 of Standard No. 102 requires that identification of shift lever positions or patterns be permanently displayed in front of the driver. Paragraph S5.3.1 of Standard No. 101 requires illumination of the "gauges" listed in Column 1 of Table 2 that are accompanied by the word "Yes" in Column 5. The last "gauge" listed is "Automatic gear position", and the word "Yes" appears in Column 5. The automatic gear position is a "gauge" as defined by paragraph S4 of Standard No. 101, "a display that is listed in . . . Table 2 and is not a telltale". Thus the Federal standards do require illumination of the gear positions of automatic transmissions, but not of manual ones.

I hope that this responds to your questions.

SINCERELY,

Whisper Electric Car AS National Highway Traffic Safety Administration Att: Erika Jones, Office of the Chief Counsel

Dear Ms. Jones,

I am writing to obtain confirmation that the FMVSS do not regulate certain specifications and parameters of automobile performance and design.

First, I should explain that our vehicle is exclusively battery powered, with 12 X 6-volt traction batteries, plus a service battery for the auxilliary functions (lights, windshield wipers, etc.). The service battery is charged at the same time as the traction batteries. In addition, the service battery is charged while driving through a converter between the 72-volt system (traction batteries) and the 12-volt system (service battery).

Now comes an engineer with the following hypothetical: The vehicle is unable to drive because of mechanical breakdown, therefore the converter between the 72-volt and 12-volt systems cannot recharge the service battery. There is no supply of electricity nearby to recharge through the main charger. The hazard lights are engaged, running only on the service battery. The characteristics of the hazard light design and intensity aside, is there a standard regulating the minimum length of time that the hazard light must be able to function at a minimum intensity, on the service battery alone?

In the absence of NHTSA direct regulation or past practice with respect to this situation, may we suggest that fulfilling the European standard is this regard also be sufficient to the U.S. market.

A second question involves illumination within the passenger cabin. Is there a requirement that the vehicle be equipped with an illuminated display, indicating gear selection? I do not see that SN 101 requires either a display or illumination, but we request your comments.

SINCERELY,

Marshall D. Carter

(Graphics omitted)

(Graphics omitted)

MARCH 18, 1986

Dear Ms Jones,

I am also enclosing some guidelines which one of our people found by chance. I understand these to be requirements for the electric vehicles for which the Fed. Gov. has granted funding or subsidies and requirements for vehicles which the Fed. Gov. might purchase, but, while useful guide-lines, not requirements which apply generally to electrical vehicles. I would ask you to please confirm this interpretation.

WHISPER ELECTRIC CAR A/S

Marshall D. Carter

encl.: FR Part 475

Whisper Electric Car AS

ID: nht79-2.42

DATE: 07/31/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck-Lite Co. Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 19, 1979, to Mr. W. M. Elliott of this agency requesting clarification of Paragraph S4.3.1.1.1 of Federal Motor Vehicle Safety Standard No. 108.

This Paragraph states:

"Clearance lamps may be mounted at a location other than on the front and rear if necessary to indicate the overall width of a vehicle, as for protection from damage during normal operation of the vehicle, and at such a location they need not be visible at 45 degrees in board."

You have asked the following questions:

"1. Is the decision to use another mounting location made at the discretion of the manufacturer?"

Yes. The manufacturer determines whether placement of the lamps in accordance with Standard No. 108 will indicate overall width or whether they are susceptible to damage if so placed, and there is no requirement that it obtain the concurrence of this agency in its decision.

"2. Are there any specific conditions that are required in order to consider it 'necessary' to mount clearance lamps in other location?"

No. The agency has established no criteria of necessity and questions on variations from front and rear mounting requirements are treated on an ad hoc basis.

"3. When the decision is made to mount the clearance lamps in another location, can a manufacturer use combination clearance/side marker lamps mounted on the side of vehicle to fulfill the clearance lamp requirements."

Yes, as long as the clearance lamp function is visible from the rear and indicates the overall width of the vehicle.

"4. Section S4.1.1.1 states that in 'such a location they need not be visible at 45 degrees inboard'. Does this mean that they need not be visible from 0 to 45 degrees inboard?"

No. SAE Standard J592e, Clearance, Side Marker, and Identification lamps, July 1972, requires clearance lamps to be visible at the H Point at 10 R and L, 20 R and L, 30 R and L, and at 45 R and L. Paragraph S4.3.1.1.1 specifies that under the alternate mounting positions the lamps need not be visible at the 45 degrees positions. They must, however, be visible at the other positions. I hope this answers your questions.

SINCERELY,

June 19, 1979

National Highway Traffic Safety Administration Dept. of Transportation

Attention: W. M. Elliott

Subject: Federal Motor Vehicle Safety Standard 108, Paragraph S4.3.1.1.1 which states that "Clearance lamps may be mounted at a location other than on the front and rear if necessary to (Illegible Word) the overall width of a vehicle, or for protection from damage during normal operation of the vehicle, and at such a location they need not be visible at 45 degrees inboard".

Dear Mr. Elliott:

We would appreciate some clarification as to the proper application of the paragraph above which is Section S4.3.1.1.1 of FMVSS 108.

More specifically, it would be most helpful if you might be able to provide information that would help us answer the following questions:

1. Is the decision to use another mounting location made at the discretion of the manufacturer?

2. Are there any specific conditions that are required in order to consider it "necessary" to mount clearance lamps in another location?

3. When the decision is made to mount the clearance lamps in another location, can a manufacturer use combination clearance/sioemarker lamps mounted on the side of vehicle to fulfill the clearance lamp requirements?

4. Section S4.3.1.1.1 states that in "such a location they need not be visible at 45 degrees inboard". Does this mean that they need not be visible from 0 to 45 degrees inboard?

Any insight (official or otherwise) that you might be able to provide regarding these questions would be most appreciated. If you or someone in the department would like to contact us, feel free to telephone collect at 716/665-6214, ext. 32.

Thank you for your consideration.

A. L. Bragg Laboratory Manager

CC: J. BENNETT; R. TARR; C. POWLEY

ID: nht79-2.8

DATE: 03/27/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 1, 1979, letter asking the National Highway Traffic Safety Administration to withdraw an earlier interpretation of Standard No. 222, School Bus Passenger Seating and Crash Protection, which stated that any contactable objects falling within the head protection zone must comply with the head impact and force distribution requirements. The head protection zone might include some areas in the driver's seating location, and therefore, any contactable object in the driver's seating location that falls within the zone must comply with the requirements. The agency declines to alter its interpretation.

The standard is clear in its specification of zones for head form impact and force distribution testing. These zones help to ensure that any contactable objects falling within them will be sufficiently padded to protect a child from serious injury in an accident. The head protection zone for any passenger seat extends into the seat area of the passenger seat immediately in front of it. Similarly, the zone for the front passenger seat might extend into the driver's seating location. You argue that the restraining barrier between the front seat and the driver's seat removes the need for head protection zone requirements in the driver's seating area.

The fact that a restraining barrier separates the driver's seating location from the passenger seat bears no relevance to the need for head impact protection in the head protection zone for the front passenger seat. The head protection zone extends above and beyond the restraining barrier recognizing the possibility that the heads and upper bodies of larger children are likely to be impelled somewhat beyond the barrier in an accident. The barrier should help to prevent a child from being thrown entirely out of its seating position, but a barrier cannot prevent a child's head from being propelled beyond the barrier in some instances. Since the head protection zone requirements are designed to provide protection in these situations and that protection is needed for all passenger seats including the front seat, the agency will not alter its interpretation of the requirements as they apply to the head protection zone for the front passenger seat.

SINCERELY,

BLUE BIRD BODY COMPANY

March 1, 1979

Joseph J. Levin Chief Counsel National Highway Traffic Safety Administration

Reference: 1. FMVSS 222 2. Robert B. Kurre to Frank A. Berndt, April 1, 1977

3. Frank A. Berndt to Robert B. Kurre, N40-30, May 11, 1977

Dear Mr. Levin:

Paragraph S 5.3.1.1 of reference 1 defines a head impact zone relative to the passenger seating reference point which must meet certain performance requirements with respect to head impact testing.

Reference 2 requests a clarification of the zone with respect to the drivers area. Reference 3 states that contactable surfaces in the zone of S 5.3.1.1 must meet the requirements as specified in S 5.3.1.

The purpose of this letter is to question the interpretation given in reference 3.

The driver's side barrier required by S 5.2 effectively isolates passengers from the driver's compartment. To require padded driver's seat frames in addition to isolating them from the passenger compartment is a redundant requirement which adds cost without any corresponding safety benefit.

The only other alternative is to provide more clearance between barrier and the driver's seat. By doing this, driver's seat padding requirements could be avoided. However, since most states have an overall length limit to which specific bus models are designed, this would eliminate at least three passenger positions.

As can be seen from the attached photos, taken before and after a barrier performance test, there is no need to pad the driver's seat since it is isolated from possible passenger impact. The posttest photograph is taken from NHTSA's compliance test report no. 780903 of a Blue Bird All American Schoolbus.

Therefore, on the basis of practicality we would ask that the interpretation given in reference 3 be reversed.

Thank you for your early reply.

W. G. Milby Manager, Engineering Services

Barrier / Driver's Seat relationship, Protest.

(Graphics omitted)

(Graphics omitted)

FIGURE 3-16 (CONT) FORCE/DEFLECTION TEST, DRIVER BARRIER, PRETEST & POSTTEST

ID: nht80-3.13

DATE: 06/30/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mercedes-Benz

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION

Mr. Craig Jones Mercedes-Benz One Mercedes Drive Montvale, New Jersey 07645

Dear Mr. Jones:

This responds to the questions you raised with Stephen Oesch and John Carson on May 8, 1980, about Standard No. 101-80, Controls and Displays. your question concerned a heating and windshield defrosting and defogging system developed by Mercedes. As requested, I have enclosed the originals of the drawing and photoqraph of the system you left with the agency.

The system consists of five controls: three rotating knobs, one of which controls the heat for the left side of the vehicle, one to control the heat on the right side, and one to control a fan. The other two controls are sliding levers, one of which directs the air flow to the windshield and the other directs air toward the floor. Your first question concerned the use of a green dot and the symbol specified by column 3 of Table 1 for identifying the defrosting and defogging system. You wish to place the symbol adjacent to the slide lever that controls air flow to the windshield and to place the green dot immediately below the symbol. The green dot would be used to identify the position on each of the other four controls that would provide the maximum defrosting or defogging of the windshield.

Section 5.2.1 provides that the identifying symbol specified in column 3 of Table 1 "shall be placed on or adjacent to the control." The section also provides that "additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity." In this case, Mercedes has properly identified the control used to defrost or defog the windshield (the slide that directs air to the windshield) with the symbol specified in column 3 of Table 1 and placed it adjacent to the control. In addition, Mercedes has used the green dot to identify the positions on the heating system needed to obtain maximum defrosting and defogging. Since the additional symbols clarify the use of the heating controls, the use of the green dot is permissible.

Your second question concerned the identification required for the heating system. Section 5.2.2 specifies that "Identification shall be provided for each function of any ...heating and air conditioning control, and for the extreme positions of any such control that regulates a function over a quantitative range." Section 5.2.2 further provides that "If this identification is not specified in Tables 1 or 2, it shall be in word form unless color coding is used. If color coding is used to identify the extreme positions of a temperature control, the hot extreme shall be identified by the color red and the cold extreme by the color blue." The rotary knobs Mercedes uses for the heating system control a single function over a quantitative range, from no heat to maximum heat and thus the extreme positions require identification. The rotary knob shown in your drawing does not comply with section 5.2.2 because it does not identify the extreme positions of the control either in words or in the color coding system required for temperature controls.

Your final question concerned the identification necessary for the slide levers that control the air flow to the windshield or the floor. As mentioned above, section 5.2.2 specifies that "Identification shall be provided for each function of any...heating and air conditioning control, and for the extreme positions of any such control that regulates a function over a quantitative range." Section 5.2.2 further specifies that "If this identification is not specified in Tables 1 or 2, it shall be in word form unless color coding is used." The slide lever Mercedes uses for the air flow controls a single function over a quantitative range, from no air to maximum air, and thus the extreme positions require identification. Mercedes has used a series of geometric shapes-which are highlighted by a color (white) to indicate which direction to move the slide lever to obtain more air. That color in and of itself has no meaning and therefore, it is not part of a color coding system. Those geometric shapes must be accompanied by or replaced by words in order to identify the positions for minimum and maximum air or an appropriate color coding system should be used.

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

Sincerely,

Frank Berndt Chief Counsel

Enclosure

ID: nht81-1.26

DATE: 03/05/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Travel Accessories, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION Mr. Ed Detwiler President Travel Accessories, Inc. P.O. Box 248 Orland, CA 95963

Dear Mr. Detwiler: This is in reply to your letter of February 12, 1981 with reference to the automotive aftermarket cruise control device offered by a competitor of yours which you believe does not comply with paragraph SS.3.1 of Standard No. 101.

That section, in pertinent part and in conjunction with Table 1 requires the illumination of the identification of automotive vehicle speed controls that are hand-operated if located other than on the floor, floor console, steering column or in the windshield header area. You have told us that the installation instructions advise that the control module "be mounted on the automobile's dashboard or console, as well as the steering column, the dashboard listed as being the preferred location."

Standard No. 101 is intended to apply to vehicles as delivered to their purchasers, rather than to individual aftermarket equipment items installed on them. If the device you describe is added after first purchase of the vehicle for purposes other than resale, there is no requirement that the device comply with Standard No. 101. If it is added before such purchase, the dealer selling the vehicle would have the legal responsibility of insuring that the identification of any dashboard mounted control was illuminated. We do not require a separate lamp for each control, and ambient illumination provided by lights for other controls could be sufficient to meet the requirements.

Under the circumstances, the manufacturer or importer of the device you describe would not appear to be in violation of Standard No. 101.

Sincerely,

Frank Berndt Chief Counsel

February 12, 1981

Mr. Frank Berndt U. S. Department of Trasportation 400 Seventh Street S.W. Washington, D.C. 20590

Dear Mr. Berndt:

I would like to notify your agency that at present an automotive aftermarket cruise control device is being marketed in this country which is in direct violation of the Federal Motor Vehicle Safety Standard No. 101, section 5.3.1.

The unit in question is called the Zemco Zt and Zemco Ztll currently marketed by Zemco, Inc. 12907 Alcosta Blvd. , San Ramon, California. These wits feature a control module , which according to the manufacturer' s installation instructions ad advertising materials is designed to be mounted on the automobile's dashboard or console , as well as the steering column, the dashboard listed as being the preferred location. This control module is not illuminated as required under the aforementioned standard.

The result of this violation is obvious. When the module is installed as recommended, it becomes a safety hazard. Travel Accessories, Inc., as a domestic manufacturer of a electronic cruise control which is in full accord of all U. S. Department of Transportation safety standards , objects that this product which is manufactured in Taiwan be allowed to be continued to be sold in this country while in obvious violation of our own government's regulations.

Continued condoning of this violation perpetuates a unfair competitive advantage. Zemco, Inc. currently enjoys a pricing advantage over Travel Accessories and other domestic manufacturers of this product category because of lower costs of materials and labor by not having to meet U.S. standards.

Travel Accessories, Inc. owns two plants in the United States totalling over 150,000 square feet and employing in excess of two hundred and fifty people. We have spent over a three year period of research and development and a great deal of funds bringing to market a quality piece of merchandise which complies with all of our own government regulations at what we believe to be a fair ad equitable price. file are forced to meet stringent government requirements ad standards in those countries we attempt to export to, only to find that a product such as this finds its way into our own domestic channels of distribution unregulated, with a minimal investment.

We request that the department of transportation take immediate action to have existing inventories of this product upgraded to meet all safety standards of the U. S. Department of Trade and further requires all future shipments of product received in this country to meet those stated requirements, as well.

I await your earliest response.

Sincerely,

Ed Detwiler President ED/sv

ID: nht81-2.23

DATE: 05/12/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Gateway Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 12 1981

NOA-30

Mr. John S. Miskowicz Gateway Industries, Inc. 17512 Carriage Way Drive Hazel Crest, Illinois 60429

Dear Mr. Miskowicz:

This responds to your letter of March 2, 1981, to Vladislav Radovich concerning Standard No. 213, Child Restraint Systems. Your letter was forwarded to this office for reply.

You asked whether a child restraint belt buckle must meet the buckle force release requirements when tested in an unloaded condition. As explained below, the answer is no. The buckle force requirements only apply to buckles tested in a loaded condition. In addition, you asked whether section 4.3(a) and 4.3(b) of Standard No. 209, Seat Belt Assemblies, are the only requirements of that standard which apply to buckles in child restraint systems. The answer is yes.

Section 5.4.3.5 of Standard No. 213 provides that each child restraint belt buckle, when tested in accordance with S6.2, must not release when a force of not more than 12 pounds is applied before the dynamic sled specified in S6.1 is conducted. The buckle must release when a force of 20 pounds is applied after the dynamic sled test. Section 6.2 provides that in conducting the belt buckle release force test, the appropriate test dummy is placed in the restraint and either a pull force of 20 pounds is applied, in the case of 6 month-old-test dummy, or a 45 pound pull force is applied, in the case of the three-year-old test dummy. Thus, the buckle is not tested in an unloaded state.

Section 5.4.2 of the standard provides that each belt buckle has to conform to the "requirements of S4.3(a) and S4.3(b) of FMVSS No. 209." No other provisions of Standard No. 209 apply to belt buckles used in child restraints.

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

Sincerely,

Frank Berndt Chief Counsel

March 2, 1981

Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street S.W. Washington D.C. 20590

Attention: Mr. Vladislav Radovich

Dear Mr. Radovich:

Enclosed please find three prototype samples of our child seat buckle we would like to market. Gateway Industries is a major supplier of seat belts to General Motors and Chrysler and we hope to expand our product line by offering this item to child seat manufacturers.

We feel that our buckle meets all of the specifications of Standard 213, however, there is one area we wish you would clarify in regard to the 12 lb. to 20 lb. release force. (You may recall my phone call to you in the first week of January.)

Our buckle meets the letter of the spec as written. That is, as specified in S5.4.3.5 we meet S6.2 before and after the test specified in S6.1. Standard 213 makes no mention of how to test the buckle in an unloaded state. Does the 12 to 20 lbs. apply to the unloaded condition?

The three enclosed buckles do meet the 12 lb. minimum in the unloaded state, however, we are marginal and I doubt we can consistently obtain this on a large volume product basis. I theorize that on cccasion we will have release efforts of 10 lbs. in the unloaded state. Would this mean that we do not comply with Standard 213? With the slightest load applied to the buckle (approximately 5 lbs.), the release efforts increase and we again are in compliance. Also, in the "Summary of Final Rule Provisions", No. 5 states the requirements in 209 apply and S5.4.2 states S4.3(a) and S4.3(b) of 209 apply. Does this mean that only the requirements of S4.3(a) and S4.3(b) apply or do all the requirements of 209 apply?

We thank you for your time in reviewing this matter and would appreciate your written response. Please feel free to include any comments you may have concerning our product.

I would like to add that our buckle has been dynamically tested to Standard 213 on a Strolee Seat System at the University of Michigan in Ann Arbor and proven successful. We can guarantee a tensile load of 750 lbs.

Truly yours,

GATEWAY INDUSTRIES, INC.

John S. Miskowicz Manager, Design Engineering

ID: nht93-4.4

DATE: May 19, 1993

FROM: Richard A. Zander -- Project Engineer, AlliedSignal Automotive Proving Grounds

TO: Office of Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/23/94 from John Womack to Richard A. Zander (A42; Std. 105)

TEXT:

I am writing to obtain your official interpretation of the following statement in 49 CFR 57, 105 Section S5.1.4.2(a) "each vehicle with GVWR of 10,000 lbs. or less shall be capable of making 5 fade stops (10 fade stops on the second test) from 60 mph at a deceleration not lower than 15 fpsps for each stop, followed by 5 fade stops at the maximum deceleration attainable from 5 to 15 fpsps."

I am requesting your official interpretation of the phrase "at a deceleration not lower than 15 fpsps for each stop." As further reference Section S7.11.2.1 states "Attain the required deceleration within 1 second and, as a minimum, maintain it for the remainder of the stopping time."

Within the industry, I know of three different interpretations of this statement, there could by more:

1. The average deceleration for the stop must be greater than 15 fpsps. The average deceleration is calculated from one second after the stop begins to a vehicle speed of 5 mph.

2. After 1 second the deceleration can not drop below 15 fpsps even for an instant. If the deceleration drops below 15 fpsps at any time it is considered a failure even if the average deceleration is greater than 15 fpsps. 3. The average deceleration for the stop must be greater than 15 fpsps and the deceleration must be greater than 15 fpsps for at least 75% of the stop excluding the first second of the stop.

In the "Laboratory procedures for FMVSS No. 105-83, TP-105-83-00, dated January 31, 1984, page 1.49, data sheet No. 1.16 for the fade stops, requests the following information for the deceleration "Average Sust Decel" see pages 1 and 2 of Attachment A. Therefore, it appears that NHTSA's interpretation of the statement "at a deceleration not lower than 15 fpsps for each stop" is "the average sustained deceleration."

Pages 3 & 4 of attachment A are a typical fade stops. The X axis is time and on the Y axis is deceleration and pedal force.

Interpretation ONE would consider these a pass because the average deceleration was greater than 15 fpsps and the pedal force did not exceed 150 lbs.

Interpretation TWO would consider these a fail because several data points fell below 15 fpsps. This interpretation appears to not consider the intent of the fade procedure. The intent being that a vehicle be capable of making multiple

high deceleration stops in a short period of time without drastic changes in effectiveness. Thus the recovery stops have a maximum and a minimum pedal force requirement based on the baseline check stops.

Maintaining an average deceleration of at least 15 fpsps insures adequate heat build up in the linings to determine if they will fade or drastically change effectiveness.

The deceleration could fall below 15 fpsps for short periods of time due to instrumentation noise or in stop fade which was not immediately compensated for by the driver. Interpretation THREE would consider these a pass because the average deceleration is greater than 15 fpsps and the deceleration is greater than 15 fpsps for 75% of the stop after the first one second.

Considering the intent of the fade procedure, the 75% requirement is not necessary to insure adequate heat build-up in the linings.

The NHTSA interpretation "average sustained deceleration" would also consider these a pass.

I am also requesting that you send the latest version of the test procedure for FMVSS No. 105 from the office of vehicle compliance. Please send to:

Richard Z. Zander Allied Signal Automotive Proving Grounds 3214 State Road 2 New Carlisle, IN 46552

Thank you for your time and effort to respond to my requests.

ATTACHMENT

Laboratory Procedures for Federal Motor Vehicle Safety Standard No. 105-83; TP-105-83-00; January 31, 1984. (Text omitted)

ID: nht76-4.48

DATE: 05/18/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: NSK Warner Kabushiki Kaisha

TITLE: FMVSS INTERPRETATION

TEXT: This responds to NSK Warner's April 12, 1976, question whether the release and buckle requirements of Standard No. 208, Occupant Crash Protection, and Standard No. 209, Seat Belt Assemblies, permit the use of a latch mechanism that consists of a fixed hook over which belt webbing (presumably from the upper torso and pelvic portions of a continuous loop system) is slipped by the occupant, causing a rotating catch to close the open end of the hook and secure the webbing. Release is accomplished by depression of a push button that rotates the catch away from the open end of the hook, followed by occupant action to slip the belt webbing off the hook.

Standard No. 208 specifies that a seat belt assembly installed in a motor vehicle shall have a latch mechanism "[that] releases at a single point by a push-button action" (S7.2(c)). "Release" in this context means that the portions of the belt assembly on either side of the latch mechanism disengage from one another. From your description of the hook mechanism, it would not disengage the two portions of belt assembly by a push-button action, because an additional action by the occupant is required. It therefore appears that such a mechanism would not conform to S7.2(c) of Standard No. 208.

Standard No. 209 specifies that "A Type 1 or Type 2 seat belt assembly shall be provided with a buckle or buckles readily accessible to the occupant to permit his easy and rapid removal from the assembly" (S4.1(e)). "Buckle" is defined in S4 as "a quick release connector which fastens a person in a seat belt assembly." Section S4.3 further specifies that "The buckle of a Type 1 or Type 2 seat belt assembly shall release when a force of not more than 30 pounds or 14 kilograms is applied" (S4.3(d) (1)). "Release" in this standard is also interpreted to mean that the portions of the belt assembly on either side of the latch mechanism disengage from one another. For this reason, it appears that the described device would not comply with the listed requirements of Standard No. 209.

I trust that this answer is responsive to your inquiry.

SINCERELY,

NSK WARNER KABUSHIKI KAISHA

April 12, 1976

Francis Armstrong Director Office of Standard Enforcement Motor Vehicle Programs U.S. Department of Transportation National Highway Traffic Safety Administration Re Interpretation of "buckle" for seat belt

One of our customers has developed a kind of latching device for seat belt buckle. We are obliged if you will read followings and give your opinion to us.

Structure

As illustrated in the attached sheet, the device books like a hook with a stopper and it has an arm fixed stationary to a base, a rotatable c shape catch and a pushbutton.

If a thin and not so soft article such as plastic-covered webbing enters into a slot between the arm and the base, the article pushes the right claw of the catch (Fig. 1) and rotates it. Then, the left claw of the catch shuts the entrance of the slot (Fig. 2).

Pushing the button makes the entrance open by using a mechanical linkage.

Our doubt

We have no doubt of its mechanism but there is a doubt raised after consideration of requirements of FMVSS 208 and 209 if this device should be used for the seat belt buckle.

When a passenger pushes the button and opens the entrance of the slot to release himself from a seat belt restraint, the webbing remains in the slot and it does not make him free. The device, therefor, needs one more action; "picking the webbing off the device", to release the passenger completely.

Especially in a case after a turn-over accident, we may be unable to release the passenger because the seat belt is under tension caused by his weight if the webbing has been caught by the hook.

The above is our anxiety about introducing the device to the seat belt buckle.

We would appreciate very much if you could judge and let us know whether the device could be regarded as a buckle.

A. Mita, Chief Engineering Dept.

Fig. 1 Released Position

(Graphic omitted)

ID: nht74-3.8

DATE: 07/17/74

FROM: JACK R. GILSTRAP -- SOUTHERN CALIFORNIA RAPID TRANSIT DISTRICT

TO: RICHARD B. DYSON, -- ASSISTANT CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION DEPARTMENT OF TRANSPORTATION

COPYEE: CHARLES R. SHARP -- GM

TITLE: FEDERAL MOTOR VEHICLE SAFETY STANDARD 108

ATTACHMT: ATTACHED TO LETTER DATED 08/05/74, FROM RICHARD B. DYSON -- NHTSA TO JACK P. GILSTRAP; N40-30 [ZTV]; STANDARD 108; LETTER DATED 12/26/73 FROM WARREN M. HEATH TO JACK R. GILSTRAP

TEXT: Dear Mr. Dyson:

On April 30, 1974, the Southern California Rapid Transit District entered into a contract with GMC Truck & Coach Division of General Motors Corporation for the furnishing of 200 heavy duty transit buses. This purchase is funded under a Capital Grant from the Urban Mass Transportation Administration of the Department of Transportation.

The specifications for these buses required the provision of spare wires serving the clearance and marker lamps around the roof of the bus, as well as the installation of a silent flasher in the engine compartment. This additional wiring was required in order to enable the District to install dual-filament bulbs in the corner clearance lamps. The 32 candlepower filament of these bulbs would be connected in a manner to be put into operation in a flashing mode as a part of an experiment in improving safety onboard transit buses. In December 1973, the District received a permit from the California Highway Patrol to install flashing lamps in the corner clearance lamps. A copy of this permit is enclosed.

The flashing lamps are controlled by a hidden switch which can be secretly activated by the driver in the event of a hijacking, robbery or other crime in progress on the bus. This same switch activates a radio silent alarm on those buses which are radio equipped. In addition, all District buses have identification numbers painted on the roof. These features, the flashing lamps, the radio silent alarms, and the roof numbers are all part of a program initiated jointly by the District and law enforcement agencies in an attempt to combat the growing incidence of crime onboard public trans buses. The District presently operates more than 1700 buses outfitted with these flashing lamps as approved by the California Highway Patrol. Most of the local law enforcement agencies have expressed to the District the opinion that the flashing lamps are a significant aid in spotting a bus with a crime in progress. No objections or complaints have been received.

2

General Motors, although it did not take exception to the Specifications prior to award of the contract, has now advised us of their refusal to manufacture the buses with the specified additional wiring. The purported grounds for their refusal is that to do so would violate the intent of Federal Motor Vehicle Safety Standard 108, in particular, Paragraph S 4.6, even though GMC has not been requested to connect any operating lamp or other device to this wiring.

The District's interpretation of Paragraph S 4. 6 is that it applies only to turn signal lamps, hazard warning signal lamps and school bus warning lamps as cited therein. It is not the intent, nor would it be a permitted practice, to activate the flashing crime warning lamps at the same time as, or in conjunction with, any of the lamps cited in Paragraph S 4.6. In any case, it is the District's interpretation of the Federal Motor Vehicle Safety Standards that the mere provision of wiring would not create or constitute a violation on the part of GMC.

Nevertheless, General Motors has asked that we obtain an opinion from your office that the installation of the additional wiring by GMC would not constitute a violation of FMVSS 108. The District is prepared to take full responsibility for installation of any flashing lamps under the experimental permit issued by the California Highway Patrol in December 1973. Please note that buses of the District do not operate in any service outside the State of California.

Should there be problems of which the District is not aware we request that you consider this letter as a petition for the amendment of FMVSS 108 to allow the installation and use of dual filament flashing bulbs in the corner clearance lamps to signify a crime in progress onboard a transit bus.

Should you have any questions of a legal nature, please contact Miss Suzanne B. Gifford, our Assistant General Counsel. If there are questions on mechanical or technical matters, please contact Mr. Frank Barnes, our Deputy Administrator of Operations.

We would appreciate your consideration of this matter.

Cordially,