ID: 1982-1.34

TYPE: INTERPRETATION-NHTSA

DATE: 03/30/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Norton Motors Limited

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 5, 1982, asking whether a proposed motorcycle taillamp assembly would comply with Motor Vehicle Safety Standard No. 108.

As you point out, the standard requires a minimum distance of 4 inches edge to edge between turn signal lamps and stop/tail lamps. Since you state that you cannot achieve this with your design, the lamp as currently designed would not be permitted by our standard. This will confirm the oral interpretation provided by Taylor Vinson of this office when you telephoned on March 22.

You will be interested to know that we are presently studying side and rear conspicuity of motorcycles. This research is being conducted by Ketron in Philadelphia. Pennsylvania, and the final report is expected in July 1982 should you wish to obtain a copy of it from us.

As you requested confidential treatment of your engineering drawing, we are returning it to you.

ENC.

CONFIDENTIAL DRAWING

NORTON MOTORS (1978) LIMITED

MARCH 5, 1982

Frank Berndt Legal Counsel National Highway Traffic Safety Administration Dept of Transportation

Dear Sir,

NORTON REAR LAMP UNITS 92-1068

1. We have designed a new rear lamp unit, and enclose a print of the drawing, which we would ask you to regard as confidential.

2. As you will see, the rear lamp unit comprises a very wide stop/ tail light assembly, with three separate lenses.

3. Your regulation (MVSS 108 issue 1, March 79) calls for minimum horizontal separation centre line to centre line, of 9 inches between turn signal lamps. Ours are 12.2 inches apart.

4. However, you also call for a minimum distance of 4 inches, edge to edge between turn signal lamps and stop/tail lamps. This we cannot achieve because of our very wide rear light.

5. We feel the wide rear light makes a positive contribution to road safety. We need your assistance to determine whether or not you consider this rear lamp unit satifies the spirit of your legislation, if not the letter.

We shall await your reply with great interest, and thank you for your assistance.

G.K. BLAIR SALES MANAGER

ID: GF0002060

Don Brown, Director of Engineering
Trailer Service, L.L.C.
1000 South Caraway
Suite #211
Jonesboro, AR 72401




Dear Mr. Brown:

This responds to your February 23, 2005, letter asking whether Federal Motor Vehicle Safety Standard (FMVSS) No. 108, Lamps, Reflective Devices and Associated Equipment, permits relocating front trailer clearance lamps in order to limit their exposure to damage. Your letter indicates that you intend to relocate the clearance lamp so that it is recessed into the "top rail".

Table II of FMVSS No. 108 specifies that for a trailer with an overall width of 80 inches or more, two amber clearance lamps must be located at the front edges of the trailer as near the top as practicable. S5.3.2.1 (formerly S5.3.1.1.1) of FMVSS No. 108 specifies that clearance lamps may be located elsewhere, if necessary for protection from damage during normal operation of the vehicle. Accordingly, our regulations do not prohibit relocation of clearance lamps in order to limit their exposure to damage.

Please note that S5.3.2.1 also specifies that a relocated clearance lamp need not meet the applicable photometric output requirements at any test point that is 45 degrees inboard. Other applicable photometric output requirements remain (see SAE Standard J592e "Clearance, Side Marker, and Identification Lamps", July 1972).

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

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:108
d.4/26/05

ID: nht79-3.38

DATE: 03/01/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent petition to amend Safety Standard No. 210, Seat Belt Assembly Anchorages, to exempt active lap belts installed in conjunction with passive upper torso restraints from the anchorage location requirements of the standard.

The agency has determined that amendment of the standard as you request is unnecessary since active lap belts and their associated anchorages are not required to comply with Federal safety standards if installed voluntarily by a manufacturer in addition to a single, diagonal passive belt. The passive restraint requirement of Safety Standard No. 208 will require passive protection in frontal crashes and, either passive protection in lateral and rollover crash modes or the provision of Type I or Type II active belts for protection in lateral and rollover crash modes. The agency has previously stated, most recently in a letter to Volkswagen dated August 1, 1977, that the provision in S4.5.3 of Standard No. 208 allowing the substitution of any passive belt system (whether or not including a lap belt) for any other belt system otherwise required, is intended to apply to the provisions of S4.1.3(c) that specify either passive protection or the provision or Type I or Type II belts.

Since active lap belts installed in conjunction with single, diagonal passive belts are not required, they are voluntary additions by the manufacturer. The agency has stated in past interpretations that systems or components installed in addition to required safety systems are not required to meet Federal safety standards, provided the additional components or systems do not destroy the ability of required systems (the passive belt in this case) to comply with Federal safety standards. This means that your proposed restraint system would have to meet the frontal crash protection requirements of Standard No. 208 both with and without the active lap belt fastened.

Since the change you requested is unnecessary in light of this interpretation, the agency will consider your petition withdrawn.

SINCERELY,

Ford Motor Company

December 14, 1978

Joan B. Claybrook Administrator Nationalk Highway Traffic

Safety Administration

Dear Ms. Claybrook: Re: Petition for Amendment of Federal Motor Vehicle Safety Standard No. 210 - Seat Belt Assembly Anchorages

Ford Motor Company (Ford), pursuant to Section 124 of the National Traffic and Motor Vehicle Safety Act, as amended, and 49 CFR, Section 552.3, submits this Petition for Amendment of Federal Motor Vehicle Safety Standard (FMVSS) No. 210, Seat Belt Assembly Anchorages (49 CFR 571.210) hereinafter "the Standard". Ford requests the Standard be amended to exempt active lap belts used in conjunction with passive upper torso restraints from the location requirements specified in S4.3.1.1.

Ford plans to offer in two of its 1980 passenger cars an optional passive belt restraint system for front seat occupants. This optional passive belt system will include a passive upper torso restraint, knee bolsters and an active lap belt. The active lap belt when used will provide additional protection to occupants in side and rollover type accidents. The passive belt system will comply with the passive restraint criteria required by Section 4.5.3 of FMVSS 208 with the without the active lap belt being employed. One of the design configurations of the active lap belt being developed, however, does not meet the anchorage location requirements of the Standard.

In this design, the lap belt retractor will be located on the inboard side of the bucket seat and its anchorage is located forward of the zone specified in Section 4.3.1.1 of the Standard. This configuration will permit forward motion (translation) of the occupant in a crash, which in turn will allow the occupant's knees to contact the knee bolster -- a desirable circumstance. We believe permitting increased forward translation of the occupant will result in more efficient distribution of impact forces during a frontal collision.

As the Administration indicated in its preamble to Docket 72-23; Notice 5, published November 16, 1978, ". . . the agency has determined manufacturers should be given wide latitude in passive belt design in order to facilitate the early introduction of passive systems. . . ." In a similar sense, this request for amendment will contribute to earlier introduction of passive systems. Further, if this petition is not granted on a timely basis, it could hinder our efforts to introduce a passive belt option prior to the required incorporation date.

As Ford intends to certify that vehicles equipped with the passive belt meet the injury requirements of Standard 208 with and without the active lap belt, and because the additional active lap belt will provide added protection in side and rollover accidents, we believe this petition, if granted, should contribute to the safety of front seat occupants.

Ford, therefore, respectfully requests that the last sentence of S4.3 of Standard 210, Seat Belt Assembly Anchorages (49 CFR 571.210) be amended as follows (added text indicated by underlining):

"S4.3 . . . Anchorages for passive belt systems that meet the frontal crash protection requirements of Standard No. 208, and active lap belt systems, installed in conjunction with such passive belt systems, are exempt from the location requirements of this section."

J. C. Eckhold Director Automotive Safety Office (Graphics omitted)

ID: nht81-3.6

DATE: 08/07/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking which of the specific requirements of Safety Standard No. 209, Seat Belt Assemblies, must be met by an automatic seat belt assembly that is installed in a vehicle in accordance with the automatic restraint requirements of Safety Standard No. 208, Occupant Crash Protection.

The agency has stated in the past that automatic seat belt assemblies must meet the adjustment requirements of paragraph S7.1 of Safety Standard No. 208, and those parts of Safety Standard No. 209 that are incorporated by reference in S7.1, whether or not the automatic belts are installed to meet the frontal crash protection requirements of paragraph S5.1 of Safety Standard No. 208. Automatic belts that are installed to comply with the frontal crash protection requirements are excepted from the other requirements of Safety Standard No. 209 by paragraph S4.5.3.4 of Safety Standard No. 208. As noted in your letter, paragraph S7.1 of Safety Standard No. 208 requires the automatic belt assembly to have a retractor that complies with Safety Standard No. 209. However, the requirements for retractor performance in Safety Standard No. 209 are based on other tests in the standard which are used for preconditioning or as prerequisites. Therefore, you state that it is not clear which requirements must be met by a retractor on an automatic belt assembly.

Paragraph S7.1 of Safety Standard No. 208 is only intended to incorporate by reference those provisions in Safety Standard No. 209 that are directly related to retractor performance. Therefore, all automatic belt retractors are required to comply with the following provisions of Safety Standard No. 209: S4.3(j); S4.3(k); and S5.2(a), (b), (j), and (k). Please note, however, that the retractors do not have to comply with paragraph S4.4 which is incorporated by reference in S4.3(k), since S4.4 relates to the performance of entire belt assemblies.

I hope this has been responsive to your inquiry. We apologize for the delay.

Sincerely,

ATTACH.

VOLKSWAGEN OF AMERICA, INC.

APRIL 29, 1981

Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration SUBJECT: Request for Interpretation - FMVSS 208 and 209 Requirements for Automatic Belts

Dear Mr. Berndt:

Federal Motor Vehicle Safety Standard (FMVSS) 208, which specifies restraint system requirements for passenger cars, includes a paragraph (S 4.5.3.4) which modifies the applicability of FMVSS 209 to automatic belts. The paragraph actually states that an automatic belt which is not subject to perpendicular frontal crash protection requirements of FMVSS 208 shall meet the webbing, attachment hardware, and assembly performance requirements of FMVSS 209. We believe that the converse is then also true, i.e., that automatic belts which are subject to the perpendicular frontal crash protection requirements do not have to meet the webbing, attachment hardware, and assembly performance requirements of FMVSS 209. On the face of it, and after examination of FMVSS 209, it would seem that these crash-tested automatic belts are then exempt from the entire FMVSS 209. The agency reinforced this belief in a letter of interpretation to Mr. Nield (Attachments 1 & 2).

However, this situation is confounded by a requirement, also in FMVSS 208 (ref. S 4.5.3.3(a)), that automatic belts comply with S 7.1 of the standard. This section, in addition to specifying belt fit requirements, requires a retractor which conforms to FMVSS 209. This conflict with the agency's letter of interpretation to Mr. Nield was brought up by Mr. Pepe (Attachment 3), and the agency responded with a further letter of interpretation to Mr. Pepe (Attachment 4). This letter stated that the automatic belts must meet the fit requirements of S 7.1, "and those parts of Safety Standard No. 209 incorporated by reference". To the best of our knowledge, this response to Mr. Pepe represents the agency's latest pronouncement on the topic.

This now brings us to our question: Exactly what specific parts of FMVSS 209 are applicable to automatic belts? The language of S 7.1 of FMVSS 208, and the letter of interpretation to Mr. Pepe would imply that the paragraphs which apply would be those relating to retractor performance. Mr. John Smreker of my staff suggested this to Mr. Hugh Oates, and he tentatively concurred. However, the interrelationship of the test sequences in FMVSS 209 and the requirements that one test serve as a prerequisite or precondition for another, would seem to bring in sections of FMVSS 209 which are specifically enumerated as excluded in S 4.5.3.4 of FMVSS 208. n1 We therefore need the agency to clarify exactly which paragraphs and which sections of FMVSS 209 do and do not apply to automatic belts.

n1 FMVSS 209 S 4.3(k) Performance of Retractor specifies that the retractor must meet the requirements of S 4.4 (after the tests in S 5.2(k)). However, S 4.4 is entitled "Requirements for Assembly Performance", a topic which is specifically excluded in FMVSS 208 S 4.5.3.4.

We will appreciate your prompt consideration of this matter.

Very truly yours,

Dietmar K. Haenchen -- Vehicle Regulations

Encl.

ATTACHMENT 1

Joseph Levin -- Chief Counsel, National Highway Traffic Safety Administration

Subject: Request for an Interpretation FMVSS 208/209

Dear Mr. Levin:

In reviewing the requirements presented in FMVSS 209, Seat Belt Assemblies in connection with the design of passive belt systems, there appears to be no distinction between the applicability of the standard as to active and passive belt systems. In reviewing FMVSS 208, Occupant Crash Protection However, paragraph 4.5.3.4 appears to exempt passive belt systems from compliance in any manner with the requirements of FMVSS 209. Since such an exemption would provide the design latitude necessary in the development of an optimum passive belt system, I would appreciate your confirmation that this exemption is intended.

In view of the extensive development efforts now underway in the engineering departments of many manufacturers, an expeditious response to this request would be appreciated.

Sincerely,

ATTACHMENT 2

George C. Nield

George C. Nield -- President, Automobile Importers of America

July 17, 1978

Dear Mr. Nield:

This responds to your recent letter asking whether passive safety belts are exempt from the requirements of Safety Standard No. 209, Seat Belt Assemblies.

The answer to your question is yes, with one exception, (Illegible Words) of Safety Standard No. 208, Occupant Crash Protection, specifies that passive safety belts that are not required for the vehicle to meet the perpendicular frontal crash protection requirements of the standard must meet the requirements of Standard No. 209. Therefore, only passive belts that are installed to meet the frontal crash protection requirements of Standard No. 208 are exempted from the requirements of Standard No. 209.

Sincerely,

Joseph J. Levin -- Chief Counsel, NHTSA

ATTACHMENT 3 Joseph J. Levin, -- Chief Counsel, National Highway Traffic Safety Administration

July 23, 1979

Reference: Your letter dated July 17, 1978 to Mr. George C. Nield, President, Automobile Importers of America - NOA-30.

Dear Mr. Levin:

I have this date, received a copy of your letter, referenced above, concerning the testing of passive seat belt assemblies to FMVSS No. 208 or 209 requirements. I feel that your letter may need some clarification or I need some further interpretation.

The question posed was pertaining to para. S4.5.3.4 of FMVSS No. 208. Your answer to that question was yes, that seat belt passive systems are exempt from FMVSS No. 209 testing with the exception of those that are not required to meet the perpendicular frontal crash protection requirements.

My interpretation of the Standard is that the aforementioned paragraph replaces only the assembly performance requirements of FMVSS No. 209, which is a Static Test, with the Dynamic test requirements of FMVSS No. 208.

Paragraph S4.5.3.3 of FMVSS No. 208 states that the passive belt assembly must meet the requirements of FMVSS No. 209 for retractor performance (para. S7.1 Adjustment). Therefore, all passive belt systems whether or not they are installed to meet the frontal crash protection requirements must conform to paragraph S7.1 (S4.5.3.3) of FMVSS No. 208. If my interpretation is not correct, then a retractor which will encounter more usage in a passive belt system, does not have to be tested for endurance per FMVSS No. 209 (i.e. resistence to environments, cycling and retraction force); but an active belt system which sees far less use, must meet those same 209 tests.

In view of testing programs presently in progress for several manufacturers an early reply would be greatly appreciated.

Very truly yours,

Frank Pepe -- Assistant Vice President, Engineering Division

Frank Pepe -- Assistant Vice President, United States Testing Co., Inc.

ATTACHMENT 4

SEPTEMBER 12, 1979

Dear Mr. Pepe:

This responds to your recent letter concerning the requirements applicable to automatic seat belts under Safety Standard No. 208, Occupant Crash Protection. Specifically, you ask for confirmation that all automatic belts must comply with the adjustment specifications of paragraph S7.1 of the standard.

Your understanding is correct. Automatic seat belts must meet the adjustment requirements of paragraph S7.1, and those parts of Safety Standard No. 209 incorporated by reference, whether or not they are required to meet the frontal crash protection requirements of paragraph S5.1 of the standard. Automatic belts that are installed to meet the frontal crash protection requirements are excepted from the other parts of Safety Standard No. 209 by paragraph S4.5.3.4 of Safety Standard No. 208. Please contact Hugh Oates of my office if you have any further questions (202-426-2992).

Sincerely, STEPHEN P WOOD -- NHTSA

ID: nht95-2.65

TYPE: INTERPRETATION-NHTSA

DATE: May 3, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Lance Tunick -- Vehicle Science Corporation

TITLE: NONE

ATTACHMT: ATTACHED TO 4/14/95 LETTER FROM LANCE TUNICK TO TAYLOR VINSON (OCC 10854)

TEXT: Dear Mr. Tunick:

This is in reply to your letter of April 14, 1995, to Taylor Vinson of this Office asking for an interpretation of Motor Vehicle Safety Standard No. 108.

Specifically, you are concerned with the meaning of the words "outer lens surface" that appear in SAE Standard J586 Stop Lamps for use on Motor Vehicles Less Than 2032 mm in Overall Width FEB84, an SAE standard incorporated by reference in Standard No. 1 08. These words appear as part of the visibility specifications under the installation requirements. You point out that "outer lens surface" as not been defined either by the SAE or by NHTSA. You believe that the phrase within the context of SAE J586 can mean "light emitting surface" as defined in SAE J387, and ask for confirmation.

According to Standard No. 108 (SAE J586), "to be considered visible, the lamp must provide an unobstructed view of the outer lens surface of at least 12.5 square centimeters measured at 45 degrees to the longitudinal axis of the vehicle." SAE Information Report J387 Terminology - Motor Vehicle Lighting OCT88 defines "light emitting surface" as "all or part of the exterior surface of the transparent or translucent lens that encloses the lighting or light signalling device and allows conformance with phot ometric and calorimetric requirements."

We believe that it would be appropriate to substitute the definition of "light emitting surface" for "outer lens surface" in SAE J586. The "outer lens surface" of J586 appears to mean the same as "the exterior surface of the transparent or translucent l ens" of J387. Thus, stop lamp visibility conformance would require an unobstructed view of the light emitting surface of at least 12.5 square centimeters.

As always, Taylor will be happy to answer any further questions you may have on this matter (202-366-5263).

ID: 0854

Mr. Lance Tunick
Vehicle Science Corporation
P.O. Box 1015
Golden, CO 80402-1015

Dear Mr. Tunick:

This is in reply to your letter of April 14, 1995, to Taylor Vinson of this Office asking for an interpretation of Motor Vehicle Safety Standard No. 108.

Specifically, you are concerned with the meaning of the words "outer lens surface" that appear in SAE Standard J586 Stop Lamps for use on Motor Vehicles Less Than 2032 mm in Overall Width FEB84, an SAE standard incorporated by reference in Standard No. 108. These words appear as part of the visibility specifications under the installation requirements. You point out that "outer lens surface" as not been defined either by the SAE or by NHTSA. You believe that the phrase within the context of SAE J586 can mean "light emitting surface" as defined in SAE J387, and ask for confirmation.

According to Standard No. 108 (SAE J586), "to be considered visible, the lamp must provide an unobstructed view of the outer lens surface of at least 12.5 square centimeters measured at 45 degrees to the longitudinal axis of the vehicle." SAE Information Report J387 Terminology - Motor Vehicle Lighting OCT88 defines "light emitting surface" as "all or part of the exterior surface of the transparent or translucent lens that encloses the lighting or light signalling device and allows conformance with photometric and calorimetric requirements."

We believe that it would be appropriate to substitute the definition of "light emitting surface" for "outer lens surface" in SAE J586. The "outer lens surface" of J586 appears to mean the same as "the exterior surface of the

transparent or translucent lens" of J387. Thus, stop lamp visibility conformance would require an unobstructed view of the light emitting surface of at least 12.5 square centimeters.

As always, Taylor will be happy to answer any further questions you may have on this matter (202-366-5263).

Sincerely,

John Womack Acting Chief Counsel ref:108 d:5/3/95 9

ID: 22497-5ogm

Mr. Takashi Yoshie
General Manager
Toyota Technical Center, USA
1850 M Street, NW
Washington, DC 20036

Dear Mr. Yoshie:

This in response to your letter dated December 21, 2000, regarding the provisions of Federal Motor Vehicle Safety Standard No. 201, Occupant protection in interior impact, as they relate to determining the proper vertical approach angle to be used when testing targets located on safety belt anchorages.Specifically, you are concerned about how to determine the maximum vertical approach angle when testing a target located on a seat belt anchorage on a vehicles B-pillar. We regret any inconvenience that our delay in responding may have caused.

It is your companys view that in the case of a safety belt anchorage located on the B-pillar, the proper amount of downward rotation used to determine the maximum vertical approach angle for testing is ten degrees.This is the amount of rotation that the standard specifies for B-pillar targets. You are concerned, however, that some independent laboratories are interpreting the standard to specify that the amount of downward rotation is five degrees. This is the amount of rotation that the standard specifies for targets on safety belt anchorages. As discussed below, we interpret Standard No. 201 to specify that, in the case of a safety belt anchorage projecting above the surface of the B-pillar, the amount of downward rotation used to determine the maximum vertical approach angle for testing is five degrees. However, if the anchorage does not project above the surface of the B-pillar, the maximum vertical approach angle for testing is ten degrees.

As you know, Standard No. 201 establishes performance requirements for certain areas of vehicle interiors. These performance requirements are intended to reduce the risk of occupant head injury by ensuring that vehicle interiors have certain impact characteristics. Compliance with these performance requirements is tested through the use of a specially designed impactor, the free motion headform (FMH).The FMH, which is instrumented to collect impact data, is projected into certain target zones in the vehicle.

Standard No. 201 does not require that all areas of the upper interior of a vehicle be subject to compliance testing. The Standard sets forth a number of discrete target areas that are to be impacted by the FMH. All of these target areas may be impacted by the FMH provided that the FMH is directed at the target within a certain range of angles. These angles are referred to in Standard No. 201 as approach angles.

S8.13.4 of the standard specifies a range of permissible horizontal and vertical approach angles that constrain the direction of the FMH when approaching particular types of targets. The approach angle limits are specified in Table 1. That table separately lists, among other targets, the left B-pillar, right B-pillar, and seat belt anchorages.

If an approach angle for a particular target is within the range of permissible approach angles, that angle may be used in testing a target area. To allow a determination of the maximum vertical approach angle for a particular target, S8.13.4.2(b)(1) and S8.13.4.2(b)(2) provide specific directions for determining the maximum vertical approach angle used.S8.13.4.2(b)(1) - which applies to all targets except B and other pillar targets - specifies that the maximum vertical approach angle is determined by rotating the FMH downward by 5 degrees while keeping the forehead impact zone in contact with the target circle.In the case of B and other pillars other than A-pillars, S8.13.4.2(b)(2) applies. S8.13.4.2(b)(2) directs that the FMH be rotated downward by 10 degrees with the forehead impact zone remaining in contact with the target circle if the target is on any pillar except an A-pillar. If the maximum vertical angle derived from the use of S8.13.4.2(b)(1) and S8.13.4.2(b)(2) is within the range of permissible vertical approach angles outlined in S8.13.4, a test may be conducted with respect to the target area in question.

It is your companys view that where a target is on a safety belt anchorage located on the B-pillar, the amount of downward rotation used to determine the maximum vertical approach angle for testing is ten degrees. This contention is based on the inclusion of safety belt anchorages as component parts of pillars in the definition of "pillar" within Standard No. 201. According to your argument, seat belt anchorages are part of a pillar under this definition and Target BP2 - which is any seat belt anchorage on a B-pillar - is not a safety belt anchorage target but is more properly a pillar target. You therefore believe that the degree of downward rotation used when establishing the maximum vertical approach angle should be ten degrees and not five degrees.

In reviewing your letter, we note that while you are correct that the standards definition of pillar includes attached components such as safety belt anchorages, it does not specify that the angle specifications for testing targets on pillars should take precedence over the angle specifications for testing targets on seat belt anchorages.

To resolve this issue, we have considered the policy reasons behind specifying special angle requirements for pillars other than A-pillars, and whether those reasons are relevant to seat belt anchorages located on such pillars.

In specifying that when calculating the vertical approach angles for B and other pillar targets there is a required offset of ten degrees of downward rotation, the National Highway Traffic Safety Administration sought to delay chin contact with the vehicle to allow appropriate HIC calculations. As the agency explained in the preamble to the August 1995 Final Rule (60 FR 43031, 43036, August 18, 1995), ten degrees of downward rotation was determined to be an appropriate amount for determining the maximum vertical approach angle for B - pillar and other pillar targets.However, five degrees of downward rotation was determined to be the appropriate amount for seat belt anchorage targets.

In the case of seat belt anchorages mounted on the B-pillar, the amount of offset required to delay chin contact would depend, in large part, on the configuration of the particular anchorage.In those instances where a belt anchorage projects above the surface of the B-pillar, a ten degree offset would be unnecessary.In cases where the anchorage design results in BP2 being on or below the surface of the B-pillar, the same degree of offset used for other B-pillar targets - ten degrees - would be appropriate to prevent early chin contact.

Accordingly, we interpret the standard to specify that, in the case of a safety belt anchorage located so that it does not project above the surface of pillars other than A-pillars, the amount of downward rotation used to determine the maximum vertical approach angle for testing is ten degrees. In the instance of anchorages that project above the surface of the pillar, the amount of downward rotation used to determine the maximum vertical approach angle for testing is five degrees.

I hope that this is responsive to your inquiry. If you have any questions or comments, please contact Otto Matheke of this office at (202) 366-5253.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:202
d.10/15/02

ID: nht76-1.45

DATE: 06/21/76

FROM: AUTHOR UNAVAILABLE; T. W. Herlihy for S. P. Wood; NHTSA

TO: NTDRA Dealer News

TITLE: FMVSS INTERPRETATION

TEXT: I am writing to point out an error in an article that appeared in the May 24-31, 1976, issue of NTDRA Dealer News (Vol. XXXIX, No. 15). The article summarized a recent Federal Register notice (41 FR 18659; May 6, 1976; Docket No. 71-19; Notice 4) that delayed certain effective dates of Federal Motor Vehicle Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.

The error appears in the paragraph of the article that reads:

Section 5.1.1 says that rims used must be those designated by the tire manufacturer. The effective date has been changed from March 1, 1977 to September 1, 1979.

One requirement of S5.1.1 is that a vehicle be equipped with rims that have been designated by the manufacturer of the vehicle's tires as suitable for use with those tires. The effective date of this requirement was originally established as September 1, 1976, and was not delayed by Notice 4. Another requirement of S5.1.1 is that a vehicle be equipped with rims that comply with the standard, i.e., with rims that are marked according to S5.2, Rim Marking. Only the effective date of this vehicle requirement was changed from March 1, 1977, to September 1, 1979.

A clarification of these effective dates in a forthcoming issue of NTDRA Dealer News would be much appreciated.

Yours truly,

ATTACH.

Federal Register Lists Changes In Standard #120

WASHINGTON, D C -- The Department of Transportation has announced several changes in Standard #120. The Selection and Rims for Motor Vehicles Other Than Passenger Cars.

The changes are

Section 5.1.1 says that rims used must be those designated by the (Illegible Word) manufacturer. The effective date has been changed from March 1, 1977 to September 1, 1979.

Section 5.2 concerned with rim markings will be made effective August 1, 1977 rather than August 1, 1976

Section 5.3 concerning the certification label will apply to vehicles made on or after September 1, 1977 rather than 1976 When the Standard was issued on January 23, 1976, DOT told passenger car manufacturers that descriptive labels placed on new cars must make reference to the weight to be carried and to specify the tire size to be used and at what air pressure. The notice to new car makers had an effective date of September 1, 1976. It has been changed to September 1, 1977.

ID: aiam3951

Dear Mr. Adams: This is in response to your letter of May 16, 1985, regarding th National Highway Traffic Safety Administration's (NHTSA's) opinion regarding the manner in which an odometer disclosure statement should be completed.; You indicate that, as an insurer of auctions, you expect that you ma purchase and re-market certain automobiles which have inaccurate or rolled back odometer readings. The Odometer Disclosure regulations, 49 CFR Part 580, provide for the inclusion of two sets of certifications on Odometer Disclosure Statements. Of the first set, you indicate that you will check the third statement, indicating that the odometer reading does not reflect the actual mileage of the vehicle.; You correctly point out, however, that none of the three statements i the second set provides for this situation. In your letter, you request an exception which would permit you to check the first statement, and cross out the last line which reads, 'and I have no knowledge of anyone else doing so'.; NHTSA grants you this exception, provided this last line, thoug crossed out, can still be read. We believe it is essential that a consumer understand that which the transferor is *not* certifying as well as that which he is. Alternatively, NHTSA would have no object if you wrote in and checked a fourth statement which would read:; >>> I hereby certify that the odometer of said vehicle was no altered, set back, or disconnected while in my possession.<<<; If written in, this statement must be included on the odomete statement itself. To avoid the possibility of its being separated from the statement, it may not be attached on a separate piece of paper.; If you have any further questions, please do not hesitate to let u know.; Sincerely, Kathleen DeMeter, Assistant Chief Counsel for General Law

ID: nht79-3.44

DATE: 12/28/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Toray Industrie, Inc.

COPYEE: HELENE B. TEKULSKY -- TECHNICAL DEVELOPMENT CENTER, MITSUI & CO. (USA), INC.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to a letter we received from Mitsui & Company asking questions concerning the "resistance to light" test in paragraph S5.1(e) of Safety Standard No. 209, Seat Belt Assemblies, as it applies to polyester seat belt webbing. You asked whether it is true that this paragraph will not be enforced for dacron and polyester webbing until an appropriate test method can be incorporated in the standard, and whether such a test method is being developed.

In a July 23, 1976, letter to the Celanese Fibers Marketing Company the agency stated that the Standard No. 209 test procedure for resistance to light was developed to test nylon webbing and that the procedure does not give meaningful results for the new polyester webbings. Therefore, Celanese was informed that the requirement would not be enforced for polyester webbing until a new procedure could be developed. This letter was placed in our public docket for the benefit of all interested parties (in our "Redbook" interpretations file). The agency does not intend to place an announcement of this interpretation in the Federal Register, however, since the standard will soon be amended to incorporate an appropriate test procedure for dacron and polyester webbing.

The new test procedure was developed for the National Highway Traffic Safety Administration by the Narrow Fabrics Institute and the Society of Automotive Engineers Task Force on Webbing. The new procedure would require the use of a plain glass filter instead of the Corex B filter currently required. The agency anticipates rulemaking to incorporate this new procedure sometime early next year, depending on rulemaking priorities.

I am enclosing a copy of our 1976 letter to Celanese for your information.

Sincerely,

ENC.

JULY 23, 1976

John Turnbull -- Celanese Fibers Marketing Company

Dear Mr. Turnbull:

This responds to your March 19, 1976, recommendation that paragraph S5.1(c) of Standard No. 209, Seat Belt Assemblies, be amended to clarify that the temperature specified in the "resistance to light" test procedure is intended to be "black panel" temperature rather than "bare bulb" temperature.

The procedures outlined in Standard No. 209 for the "resistance to light" test were adopted from the Bureau Standards's procedures for testing seat belts. The standard was developed by an industry and government group, which included Celanese Fibers, as a simplification and improvement of the A.S.T.M. Designation E42-64 procedure. The "resistance to light" test was-established to test nylon webbing, which was the standard material used in seat belt webbing at that time.

We recognize, however, that the industry now uses dacron and polyester materials in seat belt webbing, and that the Standard 209 test procedure developed to test nylon does not give meaningful results for these new materials. Therefore, the National Highway Traffic Safety Administration does not enforce the requirements of paragraph S5.1(e) of Standard No. 209 in the case of seat belt webbing made of dacrons and polyesters, and will not until appropriate testing procedures can be developed and incorporated in the standard for these new materials.

Procedures for testing systems containing materials other than nylon are under development and we plan to initiate rulemaking to incorporate these procedures into standard 209. You should understand that our commencement of a rulemaking proceeding does not signify that the rule in question will be issued. A decision as to the issuance of the rule is made on the basis of all available information developed in the course of the rulemaking proceeding, in accordance with statute criteria.

We would appreciate any data you may be able to provide regarding colorfastness tests for fabrics other than nylon.

Sincerely,

HERLIHY FOR Stephen P. Wood -- Assistant Chief Counsel, NHTSA

November 16, 1979

HUGH OATES, ESQ. -- Office of the Chief Counsel, National Highway Traffic Safety Administration

Dear Mr. Oates:

We have been in contact with Mr. William Smith at NHTSA for the past two years regarding the enforcement of paragraph S5.1(e) of Standard No. 209, Seat Belt Assemblies, "resistance to light test" for polyester seatbelt webbing.

It is our understanding that an amendment to the above standard had been suggested as meaningful results for seatbelt webbing of dacrons and polyesters could not be ascertained from the test as it stands. We further understand that, until an appropriate testing method is devised, paragraph S5.1(e) of Standard 209 will not be enforced for dacron and polyester webbings.

What we would like to know is whether an announcement to the above effect will appear in the Federal Register, whether an alternative testing method is being developed, and if this is the case when the new method is expected to be adopted by NHTSA and incorporated into Standard 209.

We would appreciate it if you would send your written reply to our questions to the following gentleman and a copy of the letter sent to us.

Mr. Katsufumi Mitsui General Manager Industrial Textile Department Toray Industries Inc. 2-2, Nihonbashi-Muromachi, Chuo-ku, Tokyo, Japan

Should you have any questions, please feel free to give me a call at (212) 973-4880 to discuss them.

We look forward to hearing from you soon.

Very truly yours,

MITSUI & CO. (USA), INC.;

Helene B. Tekulsky -- Technical Development Center

cc: K. Mitsui;

W. Smith;

Mitsui - Tokyo