ID: nht71-5.15

DATE: 12/07/71

FROM: AUTHOR UNAVAILABLE; F. Armstrong; NHTSA

TO: Ernest Holmes Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 2, 1971, to Mr. George Shifflett of my staff, in which you ask questions relating to clearance lamp locations on your wrecker bodies.

I am concerned with your statement that "there is no record of your department's approval on the clearance lamp corner mounting on the 750 and 850 bodies." The National Highway Traffic Safety Administration does not "approve" vehicles or equipment subject to the Federal motor vehicle safety standards. Conformance, and certification of that fact, are the manufacturer's responsibility under section 108(a) of the National Traffic and Motor Vehicle Safety Act of 1966. We are glad, however, to provide informal interpretations of the standards when requested to do so by manufacturers such as yourself.

Your first question is, "Does the (low) location of the rear clearance lamp meet the position requirements?". Paragraph S4.3.1.5 of Federal Motor Vehicle Safety Standard No. 108 (effective January 1, 1972), permits a deviation in mounting height: "When the rear identification lamps are mounted at the extreme height of a vehicle, rear clearance lamps need not meet the requirement of Table II that they be located as close as practicable to the top of the vehicle." Thus, if the identification lamps are mounted at the extreme height of the vehicle, Standard No. 108 permits a location of clearance lamps at any height less than the extreme height of the vehicle. This does not change the requirement currently in effect (Table II).

Your second question is, "Does the front clearance lamp location (on the body corner radius) on our 750 and 850 model bodies meet position requirements?". Standard No. 108 currently requires front clearance lamps to be located "as near as practicable to the upper left and right extreme edges of the vehicle." The requirement

effective January 1, 1972, is that these lamps be located "to indicate the overall width of the vehicle . . . as near the top thereof as practicable." It appears from the photographs you enclosed that the front clearance lamps should be mounted higher on the body front, unless you have a good reason for determining that it is not "practicable" to do so.

I trust this will answer your questions.

ID: nht71-5.41

DATE: 12/27/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: By letter of December 6, 1971, you have asked our opinion as to how S6.1 of Standard 208 applies to two hypothetical situations. S6.1 requires that "all portions of the test device shall be contained within the outer surfaces of the passenger compartment throughout the test."

Your first situation involves a vehicle in which the impact of the dummy's head causes the windshield to bulge beyond its original location but does not penetrate the windshield. It is our opinion that in this case the vehicle has contained the occupant and would conform to S6.1.

In your second situation, the dummy's head pushes the windshield loose its base and opens a gap between the windshield and the vehicle. It is our opinion that this drawing also shows the dummy to be satisfactorily contained.

In either situation, however, a manufacturer would have to assure himself that the windshield behaviour shown in the drawings would be consistent and would not lead to failure in tests in which the test dummy strikes it in a different manner.

NISSAN MOTOR CO., LTD.

December 6, 1971

Lawrence R. Schneider Chief Counsel National Highway Traffic Safety Administration

Re: Interpretation of MVSS 208

If possible, could you give us your opinions on the following two cases, we would like to know whether such cases meet MVSS 208, S.6.1.:

After frontal barrier crash test, the head of the anthroponorphic test device is contained within the outer surface of the windshield glass, which, (case 1.) was deformed as shown in Fig. 1. (case 2.) was remved in part as shown in Fig. 2. by the head impact on the windshield glass. Although the test devices' head is out of the original outer surface of the vehicle passenger compartment.

Your kind cooperation and assistance in this matter would be greatly appreciated.

Satoshi Nishibori Engineering Representative Liaison Office In U.S.A.

Attachments

(Graphics omitted) (Graphic omitted)

ID: nht72-4.5

DATE: 03/10/72

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Dockets

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: Conversation with Jensen Motors representative on Monday February 7, 1972

Howard D. Panton, Chief Designer for the Jensen Motors Company, met with representatives of NHTSA to discuss rulemaking actions of concern to his company. Representing the NHTSA were Robert Crone, Office of Crashworthiness, and John Womack, Office of Chief Counsel.

The major areas of concern to Jensen are Standard 206, 208 and 214, and the proposed rulemaking on Standard 201.

Standard 206 bears on Jensen's plans to develop a car with gull-wing doors. Their problems with the test procedure are similar to those expressed by Mercedes and they were invited to submit suggestions for changes in the test procedure.

Standard 214 also affects the gull-wing car, which would have a very high sill. The company feels that a test with the ram five inches above the bottom of the door would require then to have an unsatisfactory height for the door structure, with corresponding reduction in the glass area. It was indicated that Jensen's problem could not be met by an interpretation of the standard, and that they would have to seek an amendment of the procedure. Panton indicated that the company would consider doing this.

Standard 208 is of particular concern due to the apparent need for impact testing of several cars. This is said to be a serious problem for a small company (1000 cars a year) with a high cost per car ($ 10,000 plus). The NHTSA representatives indicated that the agency was aware of the problem. On the question of exemption authority, which Jensen considered to be a possible remedy, they were told that the agency no longer has exemption authority but that if such authority were returned to the agency it might be used to give the smaller manufacturers additional time on complex standards if they can establish the need for delay.

The current proposal on Standard 201 concerns Jensen in several ways, most notably with respect to the proposed changes in the windshield header location. They were advised that this requirement is undergoing careful review and that any detailed comments they could make would be welcome.

ID: nht72-6.26

DATE: 05/12/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: CITROEN

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 24, 1972, in which you posed questions about the operation of the seat belt warning system under Standard 208 and about the intent of the headlamp adjustment requirement under Standard 215.

Your questions on Standard 208 deal with the requirement in S7.3.3 that the warning system in a vehicle with an automatic transmission must not operate when the engine is operating and the gear selector is in the "Park" position. In answer to your first question, if the two conditions for non-operation exist, the warning system must not operate, regardless of the position of the hand brake lever. If either condition does not exist, e.g., the transmission is in "Park" but the engine is not operating, it would be permissible to have the system operate, and its operation could be controlled by the hand brake so long as the hand brake circuitry does not interfere with the mandatory operation of the system under S7.3.1 and S7.3.5.

If the shift lever is in the neutral position, as stated in your second question, you are free to choose whether to have the system operate or not, since S7.3 does not require either operation or non-operation when the transmission is in neutral.

In response to your last question on Standard 208, an "operating engine" is an engine that is rotating. It is permissible to have a system in which the warning operates when the transmission is in "Park" and the ignition is "On", but the warning must shut off when the engine begins to operate.

Your question on Standard 215 is whether the headlamps must be adjustable after the tests "so as to permit restoration of normal lighting" or whether it is sufficient for the lamps to be adjustable +4 degrees vertically and horizontally whether or not this restores normal lighting. Our reply is that the requirement is intended to provide for the safe operation of the lamps after impact and that the lamps must therefore be adjustable in a manner that restores normal lighting.

ID: nht73-3.29

DATE: 02/16/73

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of December 28, 1972, concerning the application of Standard 124, "Accelerator Control Systems", to a particular Nissan design.

Prior to our receipt of your letter, Nissan representatives met with representatives from our Office of Operating Systems. At this meeting, Nissan representatives explained their questions and left a carburetor with NHTSA staff engineers as an aid to understanding the matters in question. Your company's concern is with the failure of a spring, designated as spring C, which in the event of severance or disconnection, would allow the secondary throttle plate to stay open slightly and thereby increase normal idle speed by approximately 300 rpm. Since spring C only returns the secondary throttle plate to idle position, spring C could not be considered as a return energy source under S5.1 of the standard, and, the failure of Spring C would not fall under the same requirements as a failure of either A or B. Further, spring C is not a part of the "driver-operated accelerator control system" but is part of the "fuel metering device", and as such, severance or disconnection of spring C would not fall within the purview of S5.2.

You also presented a drawing of an accelerator control system and asked which point of severance or disconnection along the system is appropriate when conducting tests for the standard. Since the standard requires that the return to idle time must be met when "any one component of the accelerator control system disconnected or severed", you ask if this would apply to bolts holding together mounting brackets, or just those components which move in relation to foot-pedal actuation. The components intended to be tested under severance or disconnection in the standard are those which are strictly defined in S4.1. "Driver-operated accelerator control system". Accordingly, those components which move in accomplishing the regulation of engine speed would be tested, while fixed parts such as brackets and bolts depicted by the drawing you submitted would not be tested.

The carburetor your representatives left with us is being returned to Nissan under separate cover. Your letter and the attached photographs of the carburetor with labeled springs will be placed in Docket 69-20.

ID: nht73-3.35

DATE: 03/01/73

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: E.T.R.T.O.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your submission No. 65/109 of January 23, 1973, petitioning that temporary exemption from Motor Vehicle Safety Standard No. 109 be provided for European tire manufacturers who manufacture high speed tires. Your petition points out that Standard No. 109 does not allow the manufacture of high speed tires designed to be inflated to relatively high inflation pressures, but which do not have commensurate load-carrying ability at those pressures. You indicate that such tires are commonly used in Europe for high speed passenger cars, and have not produced safety problems.

The temporary exemption regulations (49 CFR 555, copy enclosed), in accordance with the statutory authority under which they were issued (P.L. 92-548), apply only to manufacturers of motor vehicles. They do not apply to manufacturers of motor vehicle equipment, and the relief which they provide is accordingly not available to tire manufacturers.

The NHTSA is of the opinion that the requirements of Standard No. 109, emphasizing the load-carrying as well as the high speed capability of passenger car tires, should be suited to driving conditions which predominate in the United States. Despite the facts, as you mention, that it is possible for motorists to exceed posted speed limits, and that areas do exist where speed limits are not posted, the NHTSA believes the high speed requirements of Standard No. 109 are sufficient to guard against tire failures under these conditions. At the same time, the NHTSA will consider petitions to amend Standard No. 109, submitted pursuant to NHTSA procedural rules (49 CFR 553.31, .33), and E.T.R.T.O. is free to petition to amend the standard to include requirements for European-type high speed tires. Your petition should contain full supporting data for the amendments requested. We would expect you as well to include possible performance requirements for such tires.

You refer briefly in your letter to the performance of these tires when tested pursuant to the planned Uniform Tire Quality Grading regulation. The NHTSA plans to publish in the very near future a revised notice of proposed rulemaking regarding this regulation, and we will be pleased to receive your comments to that proposal when it is published.

ID: nht73-3.6

DATE: 01/03/73

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Office of Operating Systems

TITLE: FMVSS INTERPRETATION

TEXT: Your memorandum of November 27, 1972, concerning non-tabulated values for tire inflation pressures.

In response to the above-captioned memorandum, we, in coordination with the Chief Counsel's office, have concluded that Standard No. 110 does not preclude the use of odd-numbered tire inflation pressures on the placard required by S4.3 of Standard No. 110, and that the standard does not prohibit interpolation of the load values of the Standard No. 109 tables for purposes of compliance testing.

The relevant language of Standard No. 110 is in paragraphs S4.3 and S4.3.1:

S4.3 Placard. A placard, permanently affixed to the glove compartment door or an equally accessible location, shall display the --

(c) vehicle manufacturer's recommended cold tire inflation pressure for maximum loaded vehicle weight and, subject to the limitations of S4.3.1 for any other manufacturer-specified vehicle loading condition . . .

S4.3.1 No inflation pressure other than the maximum permissible inflation pressure may be specified unless --

(b) The vehicle loading condition for that pressure is specified; and

(c) The tire load rating from Table 1 of @ 571.109 for the tire at that pressure is not less than the vehicle load on the tire for that vehicle loading condition.

There is nothing in the standard which specifically requires the inflation pressure to be one actually listed (even-numbered) in the Tables of Standard No. 109. While paragraph S4.3.1(c) of Standard NO. 110, in referring to the load rating found in the table, arguably implies such a requirement, we cannot, without more specific language, read into the standard that recommended inflation pressures must be even-numbered. The mere fact that the specific tire load rating will not be printed in the table, however, does not preclude enforcement of the placard requirement. Because interpolation of values in a table is accepted engineering practice, we conclude that it is reasonable to interpolate such values in the Tables of Standard No. 109, for purposes of enforcing Standard No. 110, where manufacturers have specified odd-numbered inflation pressures.

ID: nht73-4.43

DATE: 08/08/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: DPD Mfg. Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 31, 1973, in which you asked our opinion as to the effect of Standard 208 upon your vehicle air conditioner installations.

Standard 208, Occupant Crash Protection, for the next few years allows manufacturers the option of providing either seat belts or passive protection systems, of which the air cushion is presently the most widely considered, in various combinations. The decision as to when passive protection would become mandatory has not yet been made.

The passive protection requirements of Standard 208 are measured with instrumented dummies, and the standard does not specifically regulate the method by which manufacturers provide the protection in the various crash tests. The way a manufacturer chooses to meet the standard, including the arrangement of the components of the vehicle interior, is thus left to his own discretion and the NHTSA does not offer opinions as to particular vehicle designs.

The "vacuum advance system" you refer to evidently refers to the air pollution control programs of the Environmental Protection Agency. That agency's address is Washington, D.C. 20460.

Yours Truly,

dpd mfg. co., inc.

July 31, 1973

The Office of the Chief Counsel National Highway Traffic Safety Administration

We manufacture air conditioners for small cars imported into the United States Accordingly, we are interested in providing units which will not interfer with vehicle safety devices.

Our 1973 air conditioners are usually installed under the dash or in center console. See attached photos of our air conditioners installed and the vehicle without air conditioning.

We have heard that a vacuum advance system may be under consideration and the air-bag protection system would definitely bear on our future design of air conditioners. Also, we need your opinion as to the effect of Law 208 upon our air conditioners.

The above information is most urgently requested since we are proceeding rapidly with the 1974 air conditioners.

Thanking you in advance for an early reply.

O. D. Hunter Director of Training and Publications

Enclosures

ID: nht73-4.5

DATE: 04/10/73

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Toyo Kogyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 3, 1973, in which you ask two questions regarding your company's practice of maintaining records on replacement parts for vehicles you manufacture. You appear to be under the impression that the retention of such records is necessary for purposes of certification to the Federal motor vehicle safety standards.

There are no requirements for the certification or replacement vehicle parts, unless the parts themselves are subject to a safety standard. At present, Standards Nos. 106, 108, 109, 116, 117, 205, 211, and 213 apply to items of motor vehicle equipment, and it is only with respect to replacement equipment subject to these standards that certification is required under Section 114 of the National Traffic and Motor Vehicle Safety Act.

Moreover, the NHTSA does not have specific requirements that manufacturers maintain records as to those equipment items that must be certified. Of course, good manufacturing practice would dictate that manufacturers maintain sufficient records to show that "due care" was exercised in manufacturing the items to conform to the standards. This is the legal standard applicable to manufacturers under the Safety Act. But it is for each manufacturer to determine for himself the extent to which such records should be maintained.

It is possible that any replacement equipment item, whether or not subject to a standard, may be found to contain a safety-related defect. The discovery of a defect by either the

manufacturer or the NHTSA will result in the manufacturer notifying purchasers of whom he has knowledge. (Section 113 of the Safety Act, 15 USC 1402) Here again, good manufacturing practice would require a manufacturer to maintain sufficient records that if a defect is found, the manufacturer will be able to determine the extent of his production in which the defect may exist. A manufacturer who has such records will be able thereby to minimize his burden of notification. However, as in the case of certification, the NHTSA does not have requirements for record retention that manufacturers must follow. It is for the manufacturer to determine the extent to which he should maintain records for these purposes.

ID: nht73-5.20

DATE: 01/15/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 14, 1972, concerning the acceptability, under S7.4 of Standard 208, of a time delay device in a belt interlock system.

As described in your letter, the delay device would permit an occupant who has operated the belt in the correct sequence to lift off the seat while buckled for a brief period before attempting to start the vehicle. Under S7.4 as presently constituted, this action by the occupant would result in the belt's being buckled before the seat is occupied. The occupant would therefore have to unbuckle the belt and rebuckle before starting the car. A time delay device, in short, would not be allowable.

We make no comment that this situation is desirable or undesirable, but it is, however, required by the language of S7.4.

NISSAN MOTOR CO., LTD.

December 14, 1972

Lawrence R. Schneider National Highway Traffic Safety Administration

This is to request your interpretation of MVSS 208, S7.4, Belt Interlock System.

QUESTION 1

Would a belt interlock system utilizing a time delay device, which works as shown in the enclosed illustration, in order to avoid the following situation meet MVSS 208, S7.4?

SITUATION

If a front seat occupant, after buckling his seatbelt, were to move in such a way as to lift himself from the seat for any reason before starting the engine, that person would be required to unbuckle and rebuckle in order to start the engine. This situation is not only inconvenient to the customer but also may alarm him as he may not realize why the engine does not start although he has done the proper process.

QUESTION 2

Should the abovementioned interlock system meet MVSS 208, how many seconds (3 or 5) delay ("t" see illustration) will be acceptable?

Due to a very short lead time a prompt reply would be greatly appreciated.

Satoshi Nishibori Engineering Representative Liaison Office in USA

FUNCTION OF TIME DELAY DEVICE

(Graphics omitted)