ID: nht72-3.49

DATE: 09/05/72

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 26, 1972, on the subject of the conformity of the Volkswagen shoulder belt/knee bar system to the requirement of Standard No. 208. I apologize for our delay.

Your first question is whether the system would meet the requirements for a fully passive system under S4.1.2.1 and S4.1.3 if it were adjusted automatically and met the frontal and lateral crash protection requirements if S5.1 and S5.2 and if the vehicle conformed to Standard 216. Our reply is that a passive seat belt system of the type you describe would appear to satisfy the requirements of S4.1.2.1 and S4.1.3. It would also, however, be required to meet the requirements of S4.5.3. We cannot determine from your description whether the system is capable of fitting the range of occupants specified in S7.1, as required by S4.5.3.3.

Your second question concerns the possibility that the system could be used, with the shoulder belt either active or passive, to meet the second or third option for passenger cars manufactured between August 15, 1973, and August 15, 1975. You point to two variances between the Volkswagen system and the system contemplated by these options. S4.1.2.2 requires the installation of a Type 1 seat belt, whereas the Volkswagen system contains only a shoulder belt and a knee bar. S4.1.2.3 specifies either a Type 1 or a Type 2 seat belt assembly, neither of which is found in the Volkswagen system. It is our opinion that these variances are such that an amendment of the standard would be required to permit the use of the Volkswagen system under either S4.1.2.2 or S4.1.2.3.

With reference to both the passive system discussed in your first question and a petition for rulemaking in connection with your second, we are particularly concerned with the actual crash performance of a single diagonal belt restraint as opposed to the Type 1 or Type 2 belts permitted in Standard No. 208. The injury criteria presently included in Standard No. 208 may not differentiate between restraint systems with good crash force distribution, such as the air cushion, and those such as the single diagonal belt which could poorly distribute loads on real human occupants. Accordingly, we would appreciate your sending us accident data describing experience with the European type single diagonal belt.

ID: nht72-3.7

DATE: 11/14/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 13, 1972, on the subject of S3.5.1(b) of Motor Vehicle Safety Standard No. 201.

The terms "energy absorbing material" and "rigid material", as used in Standard 201, are not rigorously defined. According to your letter, the material used in the arm rest can be depressed to within 1.25 inches of the test surface by an evenly distributed force that does not exceed 100 pounds per square inch. This force does not appear to be excessive, and we would therefore consider the material to be "energy absorbing material".

The "rigid material" with which contact is prohibited at distances greater than 1.25 inches from the test surface would include such components as brackets, channels and braces, most of which are commonly metallic. We do not rule out the possibility that in some instances a metallic component may be used expressly to absorb energy, but in the usual case a metallic part would be considered "rigid material" and contact with it would result in violation of S3.5.1(b).

TRULY YOURS,

NISSAN MOTOR CO., LTD.

September 13, 1972

Lawrence R. Schneider National Highway Traffic Safety Administration

Dear Mr. Schneider:

Subject: Interpretation of MVSS 201; Occupant Protection In Interior Impact

This is to ask your interpretation of MVSS 201; S3.5.1(b) (armrests) which states, "It shall be constructed with energy absorbing material* that deflect or collaspses to within 1.25 inches of . . .without permitting contact with any rigid material. '* is not distinguishable, therefore the following is our own interpretation:

a) If the surface pressure which is calculated from the load equivalent to deflection 1.25 inches on the load-deflection curve measured during the test as shown in Figure 1, is not more than 100 pounds per square inch, we consider the tested material as the energy absorbing material.

b) We consider metalic material as rigid material.

If you feel you could improve upon the above, your prompt reply would be greatly appreciated.

* The underscoring is for your personal reference.

Tatsuo Kato Engineering Representative Liaison Office in USA

[GRAPHICS OMITTED]

ID: nht72-4.20

DATE: 02/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 7, 1972, in which you stated your understanding of how Standard 210 applies to two shoulder belt assembly configurations.

In Figure 1, you show a shoulder belt that passes through a slotted plate (A) bolted to the roof rail. Contrary to the impression you have received, the plate is not a part of the anchorage, but is rather a part of the seatbelt assembly. The anchorage consists of the reinforced roof rail structure, including the bolt hole and any retaining ridges or projections on the roof rail. Plates such as Hardware (A) that bolt onto the roof rail are similar in function to the floor mounted attachment plates that have always been considered as part of the seatbelt assembly, and are similarly treated.

The same remarks apply to the plate shown as (B) in Figure 2. This is also a part of the seatbelt assembly, and not part of the anchorage.

The anchorage strength test should be conducted as you show in Figure 3 and 4, using the complete Type 2 assembly provided with the vehicle.

We regret the misunderstanding about the classification of the attachment hardware and hope that it has not caused you inconvenience.

YOURS TRULY,

NISSAN MOTOR CO., LTD.

February 7, 1972

Lawrence Schneider National Highway Traffic Safety Administration

This is in confirmation of my discussion with Mr. Hunter and Mr. Hitchcock on February 2, 1972, regarding MVSS 210.

Through the above meeting, we understood the following:

1. In the case of Figure 1, the hardware (A) attached on the roof side rail should be treated as an upper torso seat belt anchorage.

2. In the case of Figure 2:

a. The hardware (B) should be treated the same as Figure 1.

b. The intermediate hardware (C) should not be treated as a seat belt anchorage, but handled as a hardware which must conform to MVSS 209 requirement.

3. Seat belt anchorage strength test should be conducted by using the actual Type 2 seat belt set including retractors, and hardware as described in Figure 3 and 4.

NISSAN MOTOR COMPANY, LTD.

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

Fig 1

[GRAPHICS OMITTED]

Fig. 2

[GRAPHIC OMITTED]

FIG 3

[GRAPHIC OMITTED]

ID: nht72-4.4

DATE: 08/25/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Motor Vehicle Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your request of August 7, 1972, for the data used to support the conclusions we announced in Notice 20 of Docket 69-7 concerning the ignition interlock for the center front position and the ability of seat belt systems to meet a 60g, 3-millisecond injury criterion in 1975.

In evaluating the petitions for reconsideration of the center seat interlock requirements, we followed the techniques of cost/benefit analysis adopted in our earlier studies of passive restraints (see General Reference items 42, 43, and 99). The anticipated incremental benefit from an interlock at the center position was $ 9.70 per vehicle, which, when divided by the incremental cost of $ 7.00 supplied by Ford Motor Company (N<16>-69-7-3), produced a favorable ratio of 1.4. Although the analysis was completed, it was used as a rough working paper and was not submitted to the docket. A typed draft of the analysis is being prepared for submission to the docket.

Although we decided to grant interim relief for belt systems from the 60g, 3-millisecond chest injury criterion, several manufacturers submitted data which indicated to us that their present systems were capable of meeting the criterion or that they were close enough that minor modifications would enable them to meet it. The data from your own organization (N<13>-69-7-16) showed that a number of cars were passing the criterion by comfortable margins. The Chrysler data, for example, revealed that in 9 tests no dummy recorded chest accelerations in excess of 50g's. Although General Motors, in its comment, submitted data on subcompacts which indicated a problem with chest accelerations, the data from their larger vehicles ranged between 38 and 52g's. (N<13>-69-7-20). Toyota also submitted test results with most accelerations in the range of 45-50g's, with only one test of a Corolla appearing to show a marginal condition (N<13>-69-7-23).

From our research contracts, a number of sled tests have been conducted at Cornell Aeronautical Laboratory (General Reference No. 135), and most of these produced accelerations of between 30 and 50g's. From other sources have come data indicating that such improvements in belt design as the use of tear seams can produce significantly lower accelerations (see, e.g., General Reference items 161, 166, and 167).

ID: nht73-3.5

DATE: 11/22/73

FROM: AUTHOR UNAVAILABLE; Claude S. Brinegar; NHTSA

TO: Honorable John E. Moss; House of Representatives

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 26, 1973, concerning our estimate of the time required by vehicle manufacturers to meet the adopted and proposed(Illegible Word) to Motor Vehicle Safety Standard No. 301, Fuel System Integrity.

Our basic approach to leadtime analysis in the automotive industry has been along the lines set forth in(Illegible Word) automotive engineering studies prepared in the early days of the highway safety program by Arthur Young and Company, and by Booz, Allen, and Hamilton. Over the years, we have found these studies to be accurate predictors of the time required to make substantial structural modifications to production vehicles.

On the basis of our preliminary crash tests, we concluded that to meet the 30 mile-per-hour, rear moving barrier crash test, the rear-end structure of a typical vehicle would have to be strengthened considerably. To accomplish such strengthening, the manufacturers may have to change the gauge of metal used, the configuration of the underbody and interior panels, and the location and design of interior braces and(Illegible Word). Any changes of this nature will require major tooling modifications, and tool modification has historically occupied a major portion of the leadtime needed to effect a change.

Our leadtime evaluation, based on our usual techniques, indicated that the tooling time and other production planning time required for the structural changes we expect to be necessary to meet the standard

be at least two years. To this time must be added the time required for us to complete the rulemaking process and present the manufacturers with a final standard to which they can design their vehicles. We were, therefore, obliged to conclude that there was not enough time remaining before September 1975 to allow manufacturers to meet the standard with their 1976 models.

In this as in most rulemaking actions, we are working without benefit of information from the manufacturers on their projected expenditures of funds and man-hours. I would like to be able to tell you, to the minute, what those projections are, but the best I can say is that we have no indications that the manufacturers' plans could place conforming cars in production in less than the time specified in our proposal.

I remain committed to the pursuit of this rulemaking action and assure you that it will be completed expeditiously.

ID: nht73-4.18

DATE: 05/08/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: National Tire Dealers & Retreaders Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 21, 1973, in which you ask how retreaded tires are to be tested to the strength requirements (plunger-energy) of Standard No. 117 (S5.1.1, incorporating by reference S4.2.2.4 of Standard No. 109). You appear to believe testing to the requirement is precluded because Standard No. 117 contains no requirement that the cord material be labeled onto the tire, and the plunger-energy requirements specify different performance levels for differing cord materials.

While Standard No. 117 does not require the generic name of the cord material to be labeled onto the retreaded tire, we expect that it will be found on most tire casings and will be available to the retreader on all post "DOT" casings, and on many pre-DOT casings as well. If a retreaded tire is not labeled with its cord material, the strength test can still be conducted. It is not necessary to know the cord material before the plunger-energy values are obtained. Once they are obtained, a sample can be removed from the tire, from which the material can be determined.

March 21, 1973

Mr. Michael Pescoe, Counsel National Highway Traffic Safety Administration

We would like to forward to you a question on Federal Retread Standard 117 raised by one of the companies in the industry: "As specified in S4.2.2.4 Tire Strength, each tire shall meet the requirement for minimum breaking injuries specified in Table 2, when tested in accordance with S5.3 of Safety Standard 109. My question is, the labelling specification S6.3 has no provision for fabric identification. Without cord type the Plunger Energy test, as specified in F.M.V. S.S. 109, cannot be performed because of the different minimum force values for different types of cord. In other words the minimum force is 1650 lbs. for a Rayon tire with a cross section of 6 inches or above. While the specification is 2600 lbs. for Nylon and Polyester cord with the same cross section width. Cord identification is required for testing in compliance with M.V.S.S. 117. What do we do now?"

As soon as we receive your answer, we will forward it on to the company that requested it.

Phillip P. Priedlander, Jr. Director of Communications

ID: nht73-5.23

DATE: 09/20/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Auto Safety Research Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 27, 1973, which requests information on the requirements of Standard 206, Door Locks and Door Retention Components, and suggests that door locking mechanisms should prevent operation of the inside and outside handles latch release controls) of both front and rear doors.

The standard presently requires that engagement of the front-door locking mechanism on passenger cars, multi-purpose passenger vehicles, and trucks render the outside door handle (latch release control) inoperative. On passenger cars and multipurpose passenger vehicles, engagement of the rear-door locking mechanism must render both inside and outside handles inoperative. Your suggestion that inside front door handles also be rendered inoperative was proposed in 1967 as an initial standard, but it was determined at that time that ease of escape in the event of accident made one-step operation of the door more desirable. It was concluded that the vehicle operator would have sufficient control over children in the front seat to permit such override operation.

We are still interested in the best arrangement of locking mechanisms and override at the various seating positions. At the moment, available accident data does not justify further rulemaking. Your comments will be fully considered in the event we decide to take further action.

AUTO SAFETY RESEARCH CENTER

June 27, 1973

U.S. Department of Transportation

Dear Sir;

We were under the impression that, since about 1968, an automobile door, once locked, could not be opened from either the outside or inside, unless it was subsequently unlocked, and that there were Federal regulations to this effect. However, at least on some 1973 cars, the doors can be opened from the inside, even while locked, and a number of people have come to us both surprised and concerned that children and others can open a supposedly locked door.

Please advise us if there is indeed a Federal regulation concerning door lock operation. If there is no regulation to the effect that the door handles, both inside and outside, are rendered inoperative when the door is locked, then may we suggest that, from a safety standpoint, such a regulation should be adopted as soon as possible.

Sincerely,

Delbert A. Russell, Jr. Director

ID: nht73-5.24

DATE: 09/21/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. John Holzer

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 7, 1973, requesting information concerning possible regulatory action involving plastic or gas filters.

Although we have no regulation concerning gasoline filters, the law under which our regulations are promulgated requires that where possible, our standards be based on performance rather than design requirements. This gives the automotive manufacturers maximum flexibility in conforming with the requirements and provides freedom to select whatever design he prefers in order to meet the requirements of the standard.

Our current fuel system requirements are contained in Federal Motor Vehicle Safety Standard No. 301, Fuel Tank Filler Pipes and Fuel Tank Connections, which was effective January 1, 1968. A copy of this standard is enclosed for your information. We have recently issued an amendment to the standard and a proposed amendment which are intended to substantially upgrade fuel systems of motor vehicles between September 1, 1975 and September 1, 1977. Copies of these rulemaking actions are enclosed for your information (38 F.R. 22397 and 22417).

Motor vehicle manufacturers are free to choose the components and designs which they consider most appropriate to their performance requirements. It is quite possible that certain components cannot be used as original equipment because of periodic regulatory actions; for example, a manufacturer may consider a glass fuel filter hazardous when he is attempting the preservation of fuel system integrity incidental to a 30 mile-per-hour, fixed barrier collision.

We would suggest that contact be made with the automotive manufacturers and original equipment manufacturers for a more complete answer to your question.

If we can be of any further assistance, please do not hesitate to contact us.

Sincerely,

September 7, 1973

Department of Transportation National Highway Traffic Safety Administration

Dear Mr. Secretary,

I would like to know if your department has or will propose any motor vehicle safety standards in the area of plastic or glass gas filters.

I am a distributor of these products and I have heard they will be outlawed or restricted in use in 1974. My name and address are,

John Holzer 217-18 64th Ave. Bayside, New York 11364 Sincerely yours,

John Holzer

ID: nht73-5.26

DATE: 10/11/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Robertson Tank Lines, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 30, 1973, requesting a DOT code number for retreaded tires you manufacture. It appears from your letter that the tires you retread are truck tires intended solely for your company's own use.

Any tires retreaded by and solely for use by Robertson Tank Lines are exempt from NHTSA recordkeeping requirements and a code number is not required. As truck retreads are not subject to any Federal motor vehicle safety standard, you are also not required to place a "DOT" symbol on them. If you retread passenger car tires, however, you are required to place a "DOT" symbol on the tire sidewall (indicating conformity to Federal Motor Vehicle Safety Standard No. 117).

ROBERTSON TANK LINES INC.

August 30, 1973

Tire Identification and Recordkeeping Dept. National Highway Traffic Safety Administration

Dear Sir:

The attached form is our request for a tire retread D.O.T. number. Tires produced in our shop will be for our fleet use, with no resale of our tires or services.

Our main office address is:

Robertson Tank Lines, Inc. P.O. Box 1505 Houston, Texas 77002

Retread shop address:

Robertson Tank Lines, Inc. Maintenance Terminal 2401 Battleground Rd. Deer Park, Texas 77536

Thank you for your consideration in handling this matter.

Best Regards,

Donald Gary Hayes

cc: Bob Partain

Date: August 29, 1973

Tire Identification and Recordkeeping National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Gentlemen:

I hereby apply for a Retread Tire Identification Code Mark as a manufacturer of retread tires.

The following information is offered:

Retread Plant

Name:(Illegible Words)

Street:(Illegible Words)

City & State: DEERPARK(Illegible Word)

Zip Code: 77536

Telephone No. 479-3451 EXT 52

Main Office

Name:(Illegible Words)

Street:(Illegible Words)

City & State: Houston, Texas

Zip Code:(Illegible Word)

Telephone No: 623-0000

Types of Tires Retreaded

Truck:

Applicants Signature:(Illegible Words)

ID: nht73-5.33

DATE: 10/26/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: L.E. Haight, Esq., Attorney at Law

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 21, 1973, concerning your desire to disconnect the interlock system on your new car.

The dealer who sold you the car was required to have the interlock working at the time of sale, pursuant to section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)). However, section 108(b)(1) of the Act (15 U.S.C. 1397 (b)(1)), provides that the requirements of 108(a)(1) do not apply after the first purchase of the vehicle for purposes other than resale. As a purchased who intends to use the vehicle, you are therefore not subject to the requirements of the Act and may disconnect the interlock.

Despite the absence of legal sanctions for disconnecting the interlock, we would hope that you could find a way to adjust the belt so that it could be worn without aggravating your bursitis. The physical sanctions for an unbelted person in a crash can be serious indeed.

SINCERELY,

LLOYD E. HAIGHT

ATTORNEY AT LAW

September 21, 1973

National Highway & Traffic Administration

Attention: Bobby A. Boaz

I am writing to you regarding the automobile interlocking seat belt device which has been installed pursuant to your instructions under the National Traffic and Motor Vehicle Act of 1966 and regulations issued thereunder.

For several years, I have suffered with bursitis in my hip joints and I have found that my physical problem is greatly aggravated by being held into an automobile seat by a belt. It seems that the imperceptible vibration of an automobile seat is transmitted into my hip joints to a much greater extend by reason of being locked into a seat by a seat belt. Because of this, I must have periodic treatments from an orthopedic physician.

My purpose in writing to you is to inquire whether or not it is possible, upon presentation of a medical certificate, to obtain an exception to your regulations as to the new seat belt interlocking arrangement. I have just purchased a 1974 automobile and unless I can obtain a release from your agency, I feel I will not do much traveling by automobile.

Your early response would be appreciated.

L. E. Haight