ID: nht75-4.31

DATE: 11/21/75

FROM: AUTHOR UNAVAILABLE; G. G. Mannella for James B. Gregory; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of November 11, 1975, requesting confirmation that a 1976 Ford Motor Company "deluxe continuous-loop seat belt system" satisfies the requirements of Section 7.1.1 of Standard No. 208, Occupant Crash Protection.

Section 7.1.1 requires adjustment of the lap belt portion of a front outboard seat belt assembly "by means of an emergency-locking or automatic-locking retractor" and adjustment in most cases of the upper torso portion "by means of an emergency-locking retractor." The language permits some single retractor, continuous loop systems as long as the single retractor does "automatically adjust" the tension of the lap belt portion to prevent excessive slack. Because of the submarining danger of a slack lap belt, the National Highway Traffic Safety Administration (NHTSA) has restricted the acceptability of continuous loop systems under S7.1.1 in two areas.

In the NHTSA's September 25, 1972, letter to Renault to which you refer, the level of friction in the tongue is discussed and our position is stated that it must have a sufficiently low level to qualify the lap belt portion as "automatically adjustable." In your recent demonstration of the tongue frictions in the Ford 1976 "standard" and "deluxe" continuous loop seat belt systems to NHTSA personnel, we saw no evidence of design deficiency in limited use of those systems.

The other restriction concerns the use of manual and automatic tension relieving devices on the upper portion of continuous loop systems. In our letters of March 9, 1973, and March 27, 1975 (to General Motors), June 13, 1975 (to Chrysler Corporation), and September 5, 1975 (to Takata-Kojyo), the NHTSA has limited the use of tension relieving devices to the upper torso portion of seat belt assemblies that have "an individually adjustable lap belt." It is our view that the 1976 Ford deluxe continuous loop system does not have "an individually adjustable lap belt" within the meaning of Standard No. 208. In this system slack which is introduced into the continuous loop by the "window shade" tension relief device on the upper retractor is directly transferred to the lap belt, thus increasing the risk of submarining if a crash should occur. I would like to point out that issues related to tension relief devices are, however, still outstanding in an NHTSA proposal (Docket 74-32, Notice 1).

I am enclosing a report on "Comfort and Convenience Analysis of Advanced Restraint Systems" of August 1975. This study, conducted by the NHTSA Safety Research Laboratory on a number of different safety belt designs concludes that: "Several aspects of the systems caused difficulties or confusion, but the single-loop 'window-shade' feature most frequently produced problems." In light of our mutual desire to improve safety belt usage levels, I should also like to again recommend to your attention the results of the earlier NHTSA sponsored study "Sources and Remedies for Restraint System Discomfort and Inconveniences" by Man Factors, Inc., that I sent to your company in January 1975.

SINCERELY,

Ford Motor Company

November 11, 1975

Dr. James B. Gregory Administrator National Highway Traffic Safety Administration

Re: Request for Interpretation of FMVSS 208 with regard to the Performance Requirements for a 1976 Ford Motor Company Deluxe Continuous-Loop Seat Belt System

Reference 1: September 25, 1972 letter from Richard B. Dyson (NHTSA) to Mr. Francois Louis (Renault, Inc.)

Reference 2: March 27, 1975 letter from Robert L. Carter (NHTSA) to David E. Martin (General Motors)

On October 23, 1975 we met with you and members of your staff to review and discuss the subject deluxe seat belt system which is contained on the driver side of one of the two 1975 Pinto vehicles that we left for your further review. This continuous-loop belt system incorporates many customer convenience and comfort features which we believe would result in increased belt usage. We also believe we have interpreted correctly the performance requirements of Section 7.1.1 of Standard 208 in light of the two subject references. However, Ford would appreciate receiving assurance that the Administration agrees with our interpretation.

It is the interpretation of the Ford Motor Company, based on the referenced documents, that we as a manufacturer have designed the subject seat belt system to provide:

1. Excellent fit of the lap strap with "automatic adjustment" while donning, due to the constant stored position of the free sliding tongue as specified in Reference 1, which states:

"The characteristic to be avoided is the tendency of the buckle to trap an excessive amount of webbing on the lap belt side of the buckle. This tendency is overcome . . . if the buckle slides down of its own weight while the assembly is stored on the B-pillar so that the next occupant must lengthen the lap belt as he fastens the buckle".

2. A belt system having a tension reliever which, during normal usage of the belt system, will not result in "excessive slack" in the lap strap.

In most instances an intentional, overt act on the part of the user is required to transfer any slack from the shoulder strap to the lap strap without cancelling the tension reliever. Such cancelling permits the retractor spring to "automatically adjust" the lap strap. However, in the unlikely event that occupant action would force "excessive slack" into the lap strap without cancellation of the tension reliever, it would be expected that a conscientious user of seat belts would recognize that he has loosened the lap strap and would readjust the belt system by a simple manual cancellation of the tension reliever.

Ford will provide on the visor sleeve and in the owner's manual instructions to customers indicating the possibility of a loose lap strap and what to do to correct it, such as:

Avoid a loose lap strap; if for any reason you have created slack in your lap strap, lean forward to cancel the tension reliever which will permit the shoulder strap retractor spring to snug the lap strap automatically. Your normal motions while driving will then again activate the tension reliever.

Hence, our belt system with the tension reliever, if used as instructed ("during normal usage"), will, as specified in Reference 2, "automatically adjust the tension of the lap belt portion to prevent excessive belt slack".

Ford also emphasizes that the free-sliding tongue overcomes many customer inconvenience items found in other systems by providing:

* convenient and consistently positioned parking of the tongue for easy access,

* freedom of movement without lock-up to extend webbing during donning due to the free sliding action,

* improved stowage of webbing since the retractor spring does not have to lift the tongue,

* no interference with seat adjustment.

An early response to this letter is urgently requested since this improved belt system is planned for production as a running change during the 1976 model year.

R. E. KIMBALL FOR

J. C. Eckhold Director Automotive Safety Office

ID: nht68-3.2

DATE: 02/20/68

FROM: AUTHOR UNAVAILABLE; H.M. Jacklin, Jr; NHTSA

TO: Toyo Kogyo Company, Limited

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 30, 1968 (your reference No. CSAI-25) requesting information to a number of questions related to the Federal Motor Vehicle Safety Standard. I(Illegible Word) that we did not receive your October 5, 1968 letter and that the(Illegible Word) of work has delayed my answer to your most recent letter.

I am glad to send you the following information:

a.(Illegible Word) No. 112 - Headlight Concealment Devices.

1. It is stipulated in 3.4.5 that "each headlamp concealment device shall, within an ambient temperature range of -70 to +120 degrees F., be capable of being fully opened in not(Illegible Line) described in S.4.3." With regard to the temperature condition at the time of a test, if only the(Illegible Word) temperature satisfied the cold temperature conditions, is it all right to try no regard to other conditions, such as the sticking of frost, ice, etc.?

ANSWER: It is only necessary that the ambient temperature conditions (-20 to +120 degrees F.) be(Illegible Word) at the time of the test.

b.(Illegible Word) No. 114 - Thoft Protection.

1. With regard to the regulation in s.4.2 that "The prime cause for deactivating the csr's engine or other main source of motive power shall not activate the(Illegible Word) required by S4.11(b)," we have provided the ignition switch with four stages as shown in the batch below; our key-locking system is of the(Illegible Word) that the system does not activate(Illegible Line)(Illegible Line)

ANSWER: The system as you describe it appears to conform to(Illegible Line)(Illegible Line) with this requirement to the responsibility of the individual manufacturer.

2. With reference to the stipulation in S.4.1. "Each passenger car shall have a key-locking system that, whenever the key is removed, will prevent ----.", we would like to know whether or not we must provide such a mechanism as the key can be removed only at the stage "Lock" and cannot at the stage "Off".

ANSWER: A locking system having such a position that the key may be removed without activating either the cars' steering lock or its self-mobility lock would not conform to the standard in its present form, since paragraph S4.1 of the standard requires each car to have a key locking system that, whenever the key is removed, will prevent either steering or self-mobility of the car, or both.

c. MVSS No. 201 - Occupant Protection in Interior Impact 1. With regard to the interpretation of the stipulation in S.3.1 " , the deceleration of the head form shall not exceed 80 g for more than 3 milliseconds," when the deceleration wave -- shown in the chart below -- is obtained.

in case DELTA t[1] < 3 milliseconds, we interpret that the standard is satisfied even when delta t[1] +="Sigma" t[2] t[3] t[i] milliseconds.

Is our interpretation correct? (Illustration omitted)

ANSWER: Your interpretation is correct. The standard permits more than one peak that exceed 80g which, cumulatively, may add to more than 3 milliseconds. No single peak may continuously exceed 80g for more than a 3 millisecond duration.

2. When the areas stipulated in S.3.1.1.(d) -- "Areas outboard of any point of tangency on the instrument panel of a 6.5 inch diameter head form tangent to an inboard of vertical longitudinal plane tangent to the inboard edge of the steering wheel," -- are illustrated, which of the following hatched portions in the figures below is in conformity to the stipulation? (Illustration omitted)

ANSWER: Figure (a) is correct for the inboard side. Present requirements do not apply to the area outboard of the steering wheel on the instrument panel.

d. MVSS No. 207 - Anchorage of Seats.

S.3.3 Folding and hinged seats. Except for folding auxiliary seats and seats with backs which are adjustable for occupant confort only.

1. Is it correct to interpret that the underlined part is referring to seats with backs reclining mechanism enabling to adjust the angle of the back?

ANSWER: Yes.

2. Or, should we interpret that the seats with reclinable backs come under the hinged seats?

ANSWER: No.

3. a. In the case of car with four doors, if the front seats are those with reclinable backs, these are presumed to be the ones corresponding to (1). Is this interpretation correct?

ANSWER: Yes.

b. In the case of a car with two doors, we would like to interpret that only the reclinable seat backs with folding mechanism enabling the passenger on the rear seat to get in and out are in conformity to (2). Is our interpretation correct?

ANSWER: Yes.

S.3.3.1 The release control shall be readily accessible to the occupant of that seat and to the occupant of any seat immediately behind that seat.

1. The above stipulation is presumed to be laid down for the egress of the passengers on the rear seat. Therefore, when the reclining seats are installed in a four-door car, we would like to consider it unncessary to pay regard to the underlined part. Is this interpretation correct?

ANSWER: Yes.

2. In the case of a two-door car, if the control which can be easily operated by passengers on the rear seat is installed only on one side (the right side), the passengers on the rear seat can operate the control by moving to the right side. Consequently, we consider it sufficient to install only on the right side the control which is easily accessible to the passengers on the rear seat. Is this interpretation correct?

ANSWER: In the case of a two-door car, for a split back or bucket seat arrangement, where both seat backs fold, a release control should be provided on the outboard side of each folding seat back. If the seat back is split and only one seat back folds, only one release control is required on the outboard side.

e. MVSS No. 210 - Seat Belt Assembly Anchorages

1. We judge that the fastening strength of the seat belt anchorage will change, depending on the shape of the eye bolt attaching the seat belt to the seat belt anchorage point.

If an anchorage is tested by using our designed seat belt assembly and the strength of the anchorage can be assured, we understand that the anchorage fully conforms to the standard, and also understand that it is not necessary to guarantee the owners of Mazda vehicles if they attach a seat belt assembly other than the one designated by us. Is our interpretation correct?

We, of course, will specify in our Operation Manual that the seat belt assembly designated by our company must be used.

ANSWER: Under Paragraph S.5.1 of Federal Motor Vehicle Safety Standard No. 210, anchorages are to be tested by using a Type 1 or Type 2 seat belt assembly as defined in FMVSS No. 209. If you follow this procedure, using a belt which complies to No. 209, and your anchorages meet the requirements of Standard No. 210, then you are in compliance with this standard.

I must point out that this Bureau does not issue approvals on items of equipment or on vehicle designs. 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 Standards.

ID: 1983-3.33

TYPE: INTERPRETATION-NHTSA

DATE: 12/15/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: State of New Jersey Department of Transportation

TITLE: FMVSS INTERPRETATION

ATTACHMT: 8/18/83 letter from Frank Berndt to Champion Home Builders Co. (Std. 217)

TEXT:

Mr. Vincent L. Lobascio Senior Investigator, Motor Carriers State of New Jersey Department of Transportation Motor Carrier Inspection Box 10009 Newark, New Jersey 07101

Dear Mr. Lobascio:

This responds to your letter to Mr. Kratzke of my staff, in which you questioned a prior interpretation of Safety Standard No. 217, Bus Window Retention and Release (49 CFR S 571.217). You noted that you disagree with an August 18, 1983 interpretation addressed to Champion Home Builders, which stated that doors may be considered as emergency exits for the purposes of section S5.2.1, provided that those doors meet the requirements applicable to emergency exits. I have enclosed a copy of this interpretation for your information.

You stated in your letter that you agree that doors may be counted as emergency exits, but only if the requirements of S5.2.1.1 are met. In other words, the only time doors can be counted as emergency exits in your opinion is when a bus has at least one side door for every three designated seating positions. That statement reflects an incorrect interpretation of the requirements of section S5.2.

Section S5.2 of Standard No. 217 sets forth requirements for the provision of emergency exits in buses. Section S5.2.1 contains the requirements applicable to buses with a gross vehicle weight rating in excess of 10,000 pounds. This is the group of vehicles your letter addresses. Section S5.2.1 requires that all buses provide side exits and at least one rear exit (a roof exit may be substituted for the rear exit). S5.2.1 places no limit on the types of openings that may be used as exits. As noted in my August 18 interpretation, the agency has never stated that doors could not be counted as side exits, provided that they met all other requirements applicable to emergency exits. Section S5.2.1.1 allows, as an alternative to complying with the requirements for side exits and a rear exit, the exclusive use of side doors as emergency exits. Under section S5.2.1.1, buses may be equipped with one side door for every three designated seating positions. This section in no way limits the availability of side doors as side exits under section S5.2.1; it merely adds a special case for buses not equipped with a rear exit or roof exit.

You went on to state your opinion that a particular manufacturer's bus does not comply with the requirements of section S5.2, because the door designated as an emergency exit does not satisfy the requirements applicable to emergency exits. I am sure that you understand it is impossible for this agency to determine, based on photographs and a description of the bus, whether a bus certified as complying with those requirements in fact does not comply. Our enforcement personnel will specifically check one of these buses to ensure that they do comply with Standard No. 217.

I thank you for your efforts to ensure the safety of bus passengers, and hope that you will contact us again if you believe that some model of bus fails to comply with the requirements of a Federal standard. The cooperation of State officials is essential to this agency's efforts to improve safety on the public roads.

Sincerely,

Frank Berndt Chief Counsel Enc. 8/18/83 letter from Frank Berndt to John G. Sims (omitted here).

September 28, 1983

Mr. Stephen Kratzke Office of Chief Room 5219 400 7th Street S.W. Washington, D. C. 20590

Dear Mr. Kratzke:

This letter follows recent conversation with you and relates to the application and intent of Federal Motor Vehicle Safety Standard No. 217 regarding bus window retention and release. The objective of this correspondence is to bring about a clear interpretation of the subject standard which my agency, Motor Carrier Inspection of the New Jersey Department of Transportation, is committed to enforce.

It is understood that Arcola Bus Sales of East 15 Pleasant Avenue, Paramus, New Jersey 07652 has received an opinion from you which states that the front entrance door (s) can be included in meeting the requirements of S5.2. Please be reminded that the subject vehicles are all over 10,000 lbs. GVWR and accordingly all FMVSS-217 requirements apply except for S5.2.2, the latter section applicable to buses with a GVWR of 10,000 lbs. or less.

In my conversation with you on September 22, 1983, you stated that FMVSS-217 does not exclude doors with respect to meeting the emergency exit requirements of S5.2 and you further stated that no area of the requirements excludes doors on vehicles over 10,000 lbs. GVWR. I pointed out that I agreed with you that doors could be included, but that the requirements of S5.2.1.1 must be met, said requirement very clearly stating that a bus having a GVWR of more than 10,000 lbs. may satisfy the unobstructed opening requirements by providing at least one side door for each three passenger seating positions in the vehicle. The vehicles in question do not provide such an arrangement, but merely have one push-out window on each side, plus a right front entrance door of the "scissor type" having a lever assembly actuated by the driver and a "sedan type" door on the driver's side. The vehicles all have a GVWR of 11,000 lbs. or over. (Please refer to enclosed photographs showing the type vehicle and doors, etc.).

The two push-out windows on the subject vehicles (one on each side) measure 28 1/4" x 22 1/2", giving a total opening of 635.6 sq. in. Accountable area cannot exceed 536 sq. in. Seating ranges from 19 to 21 (or over), not including driver. S5.2 states designated seating positions". It does not state that the driver's seat is not a designated seating position). Computations with respect to 19 ro 20 seats indicate a 40% requirement for each side as being 509.20 sq. in. and 536 sq. in. respectively. Since no emergency exit can be credited for more than 536 sq. in. the subject vehicle requires more than the one emergency exit on each side, if seating is over 20.

The following sections of FMVSS-217 are respectfully brought to your attention along with the matters in dispute:

S5.2.1.1 as per Federal Register, Vol. 37, No. 173-Wed., Sept. 6, 1972 this section allows for doors to satisfy the requirements if at least one side door for each three passenger seating position is provided. This section does not state that a front entrance door, not adjacent to any seat will meet the requirements, this includes the driver's sedan type door. The section is explicit in it's intent and wording and is not meant for a bus of the subject type.

S5.2.2 applies to buses with a GVWR of 10,000 lbs. or less and allows doors (c) which may meet the unobstructed opening requirements of S5.2. The subject vehicles are all over 10,000 lbs. GVWR.

S5.3.1 relates to release mechanisms and areas of their locations. The front entrance door on subject vehicles have a lever actuated (by driver) mechanism and it is felt that FMVSS-217 is not intended to include such a mechanism as a release mechanism especially since any damage to same could render such mechanism inoperable and thus not allow the door to be readily opened for use as an emergency exit.

S5.3.2 relates to the window retention test and force applications (low and high force applications) allowing for the manual release of the exit by a single occupant and states the "push-out motion" of an emergency exit as being outward and perpendicular to the exit surface. The doors on the subject vehicle do not meet this requirement.

S5.4 states very explicitly the requirement regarding the emergency exit extension. This section clearly states that after the actuation of a release mechanism (S6) and before and after the retention test required (S5.1) and using the reach distances and force level factors stated (S5.3.2), the push-out window, or other emergency exit shall be manually extendable by a single occupant. The front entrance door, it is felt, does not meet this requirement. Further the requirements of S5.5.2 are not met by the front entrance door (s) in that markings are required (legible from stipulated areas). The aisle leading to the door is not occupied by passengers.

In summation, the following is presented for your review:

In the Federal Register, Vol. 37, No. 173, Wednesday, Sept. 6, 1972, International Harvester requested and was granted an exemption from requirements of S5.2.1 for its Stageway Coach Conversion because that vehicle provided at least one door for each three passenger spaces in the vehicle. Section S5.2.1 was amended to provide that buses having a GVWR of more than 10,000 lbs. may alternatively meet the unobstructed openings requirement by providing at least one door for each three passenger spaces provided. This was done because the vehicles in question are equipped with transverse seats having a door at each seat location. This is not the case in a bus. Nothing in the Federal Register refers to buses, unless the same requirement is not applicable to doors.

Furthermore, it is questionable whether a front entrance door can be readily opened in an emergency since there are other mechanisms involved which may prevent a passenger from doing so, thus defeating the intent of S5.3.1 and S5.3.2. In addition the front entrance door in the case in question, has not been proven to meet the requirements of S5.4 and S5.1, relative to emergency exit extension and retention test. S5.3.2 clearly explains the manual release of an emergency exit by a single occupant and that the emergency exit shall open outward and perpendicular to the exit surface and states the force applications. The front entrance door of the Vehicle in question has not been proven to meet this requirement.

The exemption given to International Harvester was explicit. The Vehicle in question does not fall into that category. I feel if NHTSA wishes to allow this it should first test the vehicle under the provisions of FMVSS-217 and ascertain that all sections therein are strictly adhered to. I do not feel that the vehicle (front entrance door) will meet the requirements. The exemption was not meant for buses, in the normal sense of the word, unless a door is provided for each three passenger seat spaces. The front entrance door of a bus is located forward of the passenger compartment, in most cases.

Inasmuch as the Motor Carrier Inspection Section of the New Jersey Department of Transportation is a regulatory body enforcing the safety regulations adopted, it is imperative that a complete clarification based on the "intent" of requirements be made. The safety of passengers with respect to emergency egress is a prime concern of our agency. It is respectfully requested that a thorough evaluation of FMVSS-217 be made as it pertains to the matter at hand and that we will receive an expeditious answer to this correspondence because of it's importance.

Thank you kindly for your cooperation in this matter.

Yours truly,

Vincent L. Labascio, Senior Investigator, Motor Carriers

cc: S. T. Messina, Supervisor, Motor Carriers

NOTE:

Please direct all correspondence to the below named office.

State of New Jersey Department of Transportation Motor Carrier Inspection Box 10009 Newark, New Jersey 07101

ID: 09-001076as

ID: 04-009678drn-2

Mr. Mark Swallen
Design Engineer
Eaton Corporation
1660 Indian Wood Circle
Maumee, WI43537




Dear Mr. Swallen:

This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 106, Brake Hoses (49 CFR 571.106). You asked about which set of measurements to use from Table 1 for the expansion test for hydraulic brake hoses when the inside diameter of the brake hose falls between the listings. The answer is provided below.

In responding to your letter, I note that 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.

FMVSS No. 106 at S5.3.2 Expansion and burst strength states:

The maximum expansion of a hydraulic brake hose assembly at 1,000 psi and 1,500 psi shall not exceed the values specified in Table I (S6.1). The hydraulic brake hose assembly shall then withstand water pressure of 4,000 psi for 2 minutes without rupture, and shall not rupture at less than 5,000 psi (S6.2).

In Table 1, the descriptions of the hydraulic brake hose, inside diameter, are: "1/8 inch or 3 mm or less," "3/16 inch or 4 to 5 mm," and "1/4 inch or 6 mm or more". You indicated that the inside diameter of your hydraulic brake hose falls in between the first and second of these sets, and asked which set of measurements should be used.

Reading this provision as a whole, it is our opinion that the second set of hydraulic brake hose (3/16 inch or 4 to 5 mm) covers all hydraulic brake hose with inside diameter greater than that specified for the first set and less than that specified for the third set. In other words, the set covers brake hose with inside diameter greater than "1/8 inch or 3 mm" and less than "1/4 inch or 6 mm". Thus, the inside diameter of your hydraulic brake hose falls into the category described in Table 1 as "3/16 inch or 4 to 5 mm".

I note that on December 20, 2004 (69 FR 76298), NHTSA issued in the Federal Register, a final rule updating FMVSS No. 106, including the requirements for air brake hose, brake hose assemblies, and brake hose end fittings. The final rule takes effect on December 20, 2006. However manufacturers that wish to do so may begin complying with this new rule beginning on February 18, 2005.

I hope this information is helpful. If you have any questions, please contact Dorothy Nakama at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:106
d.1/26/05

ID: 1982-1.14

TYPE: INTERPRETATION-NHTSA

DATE: 02/16/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: FWD Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking whether Safety Standard No. 205, Glazing Materials, permits the use of Items 4 and 5 rigid plastics in rear windows on fire trucks. You were confused because the "ANS Z26" standard permits rigid plastics in these locations, yet Standard 205 is silent on the issue.

The fact that Standard No. 205 does not specifically state that Items 4 and 5 rigid plastics may be used in rear windows in trucks does not mean that such use is not permitted. The "ANS Z26" standard is incorporated by reference in Standard No. 205 (paragraph S5.1.1). Therefore, glazing materials that conform with "ANS Z26" may be used in the locations specified in that standard. In addition to the requirements and specified locations in "ANS Z26," Standard 205 includes other locations and requirements for additional types of glazing, as well as other locations for the Items of glazing that are specified in "ANS Z26."

Sincerely,

ATTACH.

November 18, 1981

U. S. Department of Transportation -- National Highway Traffic Safety Administration,

Attn: Hugh Oates, Office of Chief Counsel

Dear Mr. Oates:

Subject: FMVSS205 - Glazing Materials

In reviewing this standard, particularly the requirement and usage of rigid plastic, I noticed that the standard omits one usage of rigid plastics that ANS Z26.1 allows. That usage under Item #4 and Item #5 refers to, "Glazing to the rear of the driver in trucks or truck tractor cabs where other means of affording visibility of the highway to the side and rear of the vehicle are provided."

We have a request from a customer to provide a rigid plastic in a fire truck cab in all windows except the windshield and door windows immediately to the right and left of the driver. See attached sheet. windows are in the canopy area of the cab where two jump seats are provided for additional firemen.

As the standard doesn't specifically address this cab arrangement and rigid plastics would reduce the safety hazards and maintenance cost resulting from deliberate breakage of the windows, since plastic glazing is more difficult to break than regular glass, I would appreciate a response to the question of meeting the standard requirements if a rigid plastic glazing was used in positions indicated on attached sheet.

Very truly yours, FWD CORPORATION; Leon W. Steenbock -- Project Engineer

(Graphics omitted)

ID: nht78-3.20

DATE: 08/18/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Alfa Romeo, Inc.

TITLE: FMVSS INTERPRETATION

ATTACHMT: ATTACHED TO LETTER DATED 10/13/88 TO PAUL UTANS FROM ERIKA Z JONES, REDBOOK A32 STANDARD 208, STANDARD 210; LETTER DATED 08/11/88 TO ERIKA Z JONES FROM PAUL UTANS, OCC - 2405; LETTER DATED 12/01/86 TO FRANCOIS LOUIS FROM ERIKA Z JONES, STANDARD 208

TEXT: This responds to your recent letter concerning Alfa Romeo's proposed designs for Type 2 seat belt assemblies to be used on convertibles. You ask for clarification of the anchorage location requirements specified in Safety Standard No. 210, as they would apply to your proposed designs.

Paragraph S4.1.1 of Safety Standard No. 210, Seat Belt Assembly Anchorages, specifies that anchorages for a Type 2 belt shall be installed for each forward-facing outboard designated seating position in passenger cars other than convertibles. Manufacturers are permitted to install Type 2 belts in convertibles, however, under paragraph S4.1.2 of the standard which specifies that either a Type 1 or Type 2 belt may be installed for designated seating positions not required to have Type 2 belts under the previous section.

Since convertibles are only required to have Type 1 belts, only the pelvic portion of your proposed Type 2 designs must meet the anchorage location requirements of the standard. These location requirements are specified in S4.3.1, and the pelvic portion of your two proposed designs (Figures 2 and 3 in your letter) appear to fall within the 20 degrees - 75 degrees acceptable range. The upper torso portions of the belt designs do not have to comply with the 40 degrees acceptable range specified in S4.3.2, since those portions are in addition to what is required by the standard.

In response to your general question, "seat belt anchorage" is defined in Standard No. 210 as the "provision for transferring seat belt assembly loads to the vehicle structure." For purposes of determining compliance with the anchorage location requirements of the standard, the agency interprets anchorage to include any load-bearing element of the seat belt assembly that is capable of meeting the force requirements of Standard No. 210. For example, in your Figure 1 you state that the lap belt is anchored "at point 'C' within the 40 degrees zone and then passes through a webbing guide anchorage." The 40 degrees zone is not the applicable location requirement for lap belts and if this were the only anchorage, the belt would not comply with the standard. However, since the "webbing guide anchorage" appears to be within the applicable 20 degrees-75 degrees zone, the belt would be in compliance if that anchorage is capable of meeting the force requirements of the standard. The agency considers an assembly to be in compliance if there is one force-complying anchorage within the acceptable ranges specified in the standard, and that anchorage is determinative of the angle the belt crosses the vehicle occupant.

To summarize, both of your proposed Type 2 seat belt assemblies would comply with the location requirements of Standard No. 210 if used in convertibles, since only the pelvic portions of the assemblies would have to meet the requirements of the standard and the anchorages for those portions appear to be within the acceptable ranges. Further, either assembly design can be used in hard-top automobiles if it has one anchorage capable of meeting the force requirements of the standard that is located in the 40 degrees acceptable range for upper torso portions of Type 2 belts.

Please contact Hugh Oates of this office if you have any further questions concerning this subject (202-426-2992).

Sincerely,

Alfa Romeo, Inc.

May 12, 1978

Joseph J. Levin, Jr. Office of Chief Council U.S. Department of Transportation National Highway Traffic Safety Administration

RE: LOCATION OF ANCHORAGE FOR UPPER TORSO RESTRAINT REQUEST FOR CLARIFICATION

Dear Mr. Levin:

Due to recent changes in European law, the upper torso restraint anchor on the Alfa Romeo Spider (roadster) will have to be redesigned. Ideally, an upper torso restraint anchor that complies with both U.S.D.O.T. F.M.V.S.S. and European law in one common design is preferred.

To keep this request brief, we prefer to use graphic references:

DRAWING 1: (Figure 1)

This depicts presently produced U.S. model (115.41) Spider having a "type 1" belt assembly. This lap belt is anchored at point "C" within the 40 degrees zone and then passes through a webbing guide anchorage at outboard points and "B".

Unfortunately this system will not comply with the new European law. Therefore, we consider two alternate substitute designs described below.

DRAWING 2: (Figure 2)

This shows a proposed installation of a "type 2" (3 point) torso/lap harness. Here we see the retractor mounted on the floor (outside the 40 degrees zone) at point 4. The webbing is then fed through a guide anchorage at point 3 (within the 40 degrees zone) up to another webbing guide on the seatback at point 1.

In this proposal, while the retractor is outside the 40 degrees zone, the "anchorage guides" 3 and 1 are well within the acceptable zone. This poses the question as to what is the "anchorage" (i.e., the retractor or the "anchor"?). In mechanical theory the retractor could be outside the 40 degrees zone while the "anchorage" remained within the 40 degrees zone. Our view is that the intent of N.H.T.S.A.'s design limitation is to prevent the torso webbing from attaining a loadline of more than 40 degrees (for well known reasons). This proposal achieves the "intent" of the author of F.M.V.S.S. 210, even though in a "roundabout" manner.

We would like N.H.T.S.A.'s opinion as to whether or not this proposal demonstrates compliance with 210's "40 degrees Fig. 1 zone" by design.

DRAWING 3: (Figure 3)

This proposed design eliminates the point 3 roller of the previous design, for simplicity. Instead, the retractor is mounted "direct" but slightly outside the 40 degrees zone.

Now, at point 1 on the seatback, this guide is well within the acceptable zone. It is in reality the point that determines the position of the webbing in relation to the occupant's torso. (This point is referred to as the "effective point" in the European law. It is the last point at where the webbing changes direction).

Needless to say, the point 1 guide does have sufficient load bearing capability to consider it as an anchorage. It is not merely a "convenience loop" as used on some U.S. vehicles, but an integrally designed part of the seat back.

F.M.V.S.S. 210 S4.1.1

This requirement specifically states that anchorages for Type 2 belt assemblies "shall be installed . . . . . in passenger cars other than convertibles." Does this by exclusion ("shall - other than convertibles") prohibit the installation of Type 2 belt assemblies in convertibles - or does it infer Type 2 as an option?

If the Type 2 is prohibited in convertibles, then we must try and define the word "convertible." What determines "convertibility" and what are we "converting" (the top?). If we are "converting" from a closed to an open vehicle, when and what degree of "open-ness" determines that the vehicle is in fact "open" or a convertible. We feel this is academic and use it only as a means to demonstrate the vagaries of F.M.V.S.S. 210 requirements. We realize that we also are among the minority by virtue of our almost exclusive production of "convertibles".

Our design management would appreciate N.H.T.S.A.'s legal opinion as to the compliance capabilities of our proposals 2 and 3 as soon as is possible as we are delaying tooling pending your decision.

Should the enclosed drawings require clarification or further discussion, please let us know.

D. Black Manager U.S. Engineering Office

cc: ING. FOGLIATA -- DIPRE/LEGO ING. DIMORA -- DIPRE/CARR DIPRE/ESPE ESCA

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(Illegible Word) Present location SEAT BELT ANCHORAGES A-B-C SEAT BELT TYPE "1" PRESENT No DISEGNO Legn 115L1 ed 79 fg1

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ID: 1984-2.19

TYPE: INTERPRETATION-NHTSA

DATE: 07/05/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Grumman Olson

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. David A. White Senior Safety Engineer Grumman Olson 70180 Centerville Road Sturgis, Michigan 49091

Dear Mr. White:

This responds to our letter of May 3, 1984, asking about Standard No. 101, Controls and Displays. Your letter concerned requirements applicable to a proposed design for an instrument panel which would include controls for heating fan, windshield wiper and washer, and defrosting system. The controls would be identified both by the symbol specified in Table 1 of Standard No. 101 and the relevant word listed in that table. You asked whether the symbols are required to be illuminated or whether it is permissible instead to illuminate the identifying words without illuminating the symbols. As discussed below, your interpretation of the standard that the symbols must be illuminated is correct.

By way of background information, I would note that the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the requirements of the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to assure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on the facts provided in your letter.

Section S5.2.1 of Standard No. 101 generally requires that "any hand-operated control listed in column 1 of Table 1 that has a symbol designated n column 3 shall be identified by that symbol." The section states further that "(s)uch a control may, in addition, be identified by the word or abbreviation shown in column 2." The three controls noted above, heating fan, windshield wiper and washer, and defroster system, are all listed in column 1 and have symbols designated in column 3. Thus, the identification required by section S5.2.1 for these controls are the symbols designated in column 3. Use of the words shown in column 2 in addition to the mandatory symbols is permissible but not required.

Section S5.3.1 of Standard No. 101 states:

Except for foot-operated controls or hand-operated controls mounted upon the floor, floor console, or steering column, or in the windshield header area, the identification required by S5.2.1 or S5.2.2 of any control listed in column 1 of Table 1 and accompained by the word "yes" in the corresponding space in column 4 shall be capable of being illuminated whenever the headlights are activated. However, control identification for a heating and air conditioning system need not be illuminated if the system does not direct air directly upon windshield.... Emphasis added.

As discussed above, the identification required by section S5.2.1 for the three controls are the symbols designated in column 3. Since each of the three controls is accompanied by the word "yes" in column 4, the required symbols must be capable of being illuminated whenever the headlights are activated. It is thus not permissible to illuminate the identifying words without also illuminating the symbols.

I would note that your letter does not provide sufficient information to determine whether the controls in your proposed design could come within any of Standard No. 101's exceptions to the illumination requirements.

Sincerely,

Frank Berndt Chief Counsel

May 3, 1984

National Highway Traffic Safety Administration Office of the Chief Counsel 400 Seventh Street S/W Washington, D. C. 20590

ATTN: Frank Berndt

Dear Sir;

Grumman Olson is a manufacturer of walk-in delivery vans. We have a customer who is asking us to use a special instrument panel that I question conforms to F.M.V.S.S. 101. The reason I question the conformity is that S5.2 of F.M.V.S.S. 101 requires that controls listed in column 1 of table 1 that have symbols designated in column 3 shall be identified by those symbols. Optionally the control may, in addition to the symbol, be identified by the word listed in column 2 of table 1.

S5.3 of F.M.V.S.S. 101 states that the identification required in S5.2 shall be illuminated if column 4 of table 1 requires it.

The controls on the instrument panel in question are identified both by the required symbol and the optional word. The symbol, however, is on the control and the word is on the panel itself. Provisions are made to illuminate the word and not the appropriate symbol. I am speaking here of the heating fan, windshield wiper and washer and the defroster system.

I have stated to our customer that the identification that is required is the symbol and it must be illuminated, not the word. I have not been able to convince them of this, so I seek an interpretation from you concerning this matter. The question I ask is, does the symbol have to be illuminated or may the identifying word be illuminated when it is provided with no illumination on the symbol?

I spoke with Ed Glancy of your office concerning this matter and he advised me that N.H.T.S.A. does not give out rulings verbally. He advised me to write this letter requesting an interpretation.

If there are any questions, please call me at your convenience.

David A. White Senior Safety Engineer

DAW/smf

ID: nht90-1.73

TYPE: INTERPRETATION-NHTSA

DATE: MARCH 16, 1990

FROM: D. H. BURNEY -- AMBASSADOR, CANADIAN EMBASSY

TO: JERRY R. CURRY -- ADMINISTRATOR, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-24-90 TO D. H. BURNEY FROM JERRY RALPH CURRY; (A35; PARTS 591, 592, 593 AND 594) TEXT:

I am writing with regard to your Final Rule on the Importation of Vehicles and Equipment Subject to Federal Motor Vehicle Safety Standards on and after January 31, 1990 (Federal Register, Volume 54, No. 188, September 29, 1989).

The Final Rule and the enabling legislation -- the Imported Vehicle Safety Compliance Act of 1988 (P.L. 100-562) -- were drafted to address and correct the enforcement difficulties associated with the previous regulations governing the importation of veh icles which did not comply with the DOT Federal Motor Vehicle Safety Standards (FMVSS). These difficulties arose largely from the export to the United States of vehicles originally manufactured for the European marketplace, in particular luxury and spor t automobiles. Canada is concerned that in seeking to address problems related to these vehicles, the NHTSA will be imposing serious and apparently unintended burdens on Canadian exporters of vehicles certified to Canadian safety standards.

"Canadian market vehicles" are those subject to the Canadian Motor Vehicle Safety Standards (CMVSS) established by Transport Canada. Canadian standards are virtually identical to the FMVSS, and where there are differences these differences are well docum ented. As a practical matter, for most Canadian market vehicles the only relevant difference is the metric instrumentation for speedometers and odometers. Most Canadian market vehicles sold in Canada are produced in the United States to meet both Canad ian and U.S. standards because of the rationalization of North American production. Consequently, a Canadian market vehicle would require only minor modification to bring it into compliance with U.S. standards, in contrast to noncomplying imports from o ther countries, which could require significant modification.

Under the Final Rule, a Canadian market vehicle would be deemed to be a non-complying vehicle if it does not bear the original manufacturer's declaration that it meets all U.S. safety standards. In addition:

a) importation of Canadian market vehicles is restricted to importers registered with NHTSA;

b) registered importers must be U.S. residents;

c) each registered importer is required to pay an annual registration fee of $255;

d) for each make, model and year of non-conforming vehicle, a petition fee of $1560 or $2150, depending on whether the petition concerns a vehicle which is "substantially similar" or "capable or being

modified", is required for filing for a determination of eligibility for importation;

e) the registered importer is required to pay a bond processing fee of $125 for each vehicle imported;

f) the registered importer is required to post a bond, not less than the dutiable value of each vehicle imported, for the production of a statement, after conformance, certifying that the conformance work has been accomplished, and

g) conformance work must be done in the United States.

The Final Rule will not have a direct impact on vehicle manufacturers (e.g., the "Big Three") or secondary manufacturers (e.g., truck-body builders), as these original manufacturers are exempted from the Final Rule requirements if they certify their vehi cles as meeting U.S. standards and are able to provide appropriate documentation.

However, given the cost, complexity and delays that the new procedures would entail, Canadian vehicle brokers, dealers and private citizens, acting independently of original manufacturers, would not, for all practical purposes, be able to export new or u sed Canadian market vehicles to the United States. Further, Canadian individuals and firms would be precluded from providing conformance goods and services for vehicles exported to the United States.

Canadian regulations are being changed to give effect to Article 1003 of the Canada-U.S. Free Trade Agreement. These provisions are designed to maintain the integrity of Canadian safety and emission standards while recognizing that Canadian and U.S. sta ndards are virtually identical. U.S. market vehicles exported from the United States are allowed entry into Canada upon demonstration of a U.S. Department of Transport compliance certificate for U.S. standards and a declaration of intent that the vehicle will be modified as required to conform with Canadian safety requirements (currently the required modification for most U.S. market vehicles involves only meeting the metric and bilingual labelling requirements, for which stickers can be purchased from the Canadian Automobile Association for $2.95). Imports of U.S. market vehicles are subject only to the actual costs of modifications and do not face any fees paid to government. U.S. individuals and firms are able to provide conformance goods and serv ices.

In Canada's view, the Final Rule is inconsistent with U.S. obligations under the Canada-U.S. Free trade Agreement and will unduly restrict trade between the two countries. Canada accordingly requests that NHTSA modify the Final Rule with respect to Cana dian market vehicles, recognizing near-compliance with the FMVSS and accommodating their entry in the least costly and burdensome manner. To this end, Canada requests that NHTSA: a) recognize canadian market vehicles as a special class of non- comp lying vehicles requiring only minor changes to meet the FMVSS;

b) exempt such vehicles from the fees;

c) exempt them from the bonding requirement;

d) exempt them from the requirement that they be imported by registered importers, who must be U.s. citizens, and

e) allow modifications to be done in either the United States or Canada.

I would propose that Canadian and U.S officials meet to discuss the technical details of this request.

ID: 22044

Mr. Matthias Friedrich
Managing Director
Van Riesen GmbH+CoKG
IndustriestraBe 10
D-32130 Enger
Denmark





Dear Mr. Friedrich:

This is in response to your letter asking whether the buckle release on your child restraint system meets the area requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 213, "Child Restraint Systems." The answer is no.

S5.4.3.5(c) of Standard No. 213 requires any buckle in a child restraint system to "[m]eet the requirements of S4.3(d)(2) of FMVSS No. 209 ( 571.209), except that the minimum surface area for child restraint buckles designed for push button application shall be 0.6 square inch." You state that your buckle release design would meet this requirement if we add the "press" area (0.39 square inch) of the release button to the bottom area (0.23 square inch) of the release button.

We do not consider your buckle release to be designed for push button application because a sliding action activates the buckle release. In fact, it is apparent from your letter that you concur that the buckle release is not of a push button type. You state in your letter: "The button is not a push-button as described in the FMVSS-standard, [sic] it is as [sic] slide action release button . . . ." Since your buckle release is not designed for push button application, the 0.6 square inch minimum surface area requirement in S5.4.3.5(c) does not apply.

S4.3(d)(2) of Standard No. 209 reads:

A buckle designed for pushbutton application of buckle release force shall have a minimum of 452 mm with a minimum linear dimension of 10 mm for applying the release force, or a buckle designed for lever application of buckle release force shall permit the insertion of a cylinder 10 mm in diameter and 38 mm in length to at least the midpoint of the cylinder along the cylinder's entire length in the actuation portion of the buckle release. A buckle having other design for release shall have adequate access for two or more fingers to actuate release.

(Emphasis added.)

Because your buckle release is designed for slide application rather than push button or lever application, your buckle release falls under the "other design for release" category. Under the last sentence of S4.3(d)(2), it must have adequate access for two or more fingers to actuate release. None of our staff working on this response was able to place two fingers into your slide action release button to actuate release, and you do not claim otherwise. Thus, we do not agree that your buckle release meets the requirement of S4.3(d)(2).

If you have any further questions, please feel free to contact Mr. Dion Casey of this office at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel

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