ID: nht87-3.13

TYPE: INTERPRETATION-NHTSA

DATE: 10/15/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: American Suzuki Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Head, Administration Government Relations Department American Suzuki Motor Corporation P.O. Box 1100 3251 East Imperial Highway Brea, CA 92622-1100

Dear Mr. Petler:

This letter responds to your letter of June 12, 1987, stating that your company wishes to and the following additional language to the Part 567 certification label:

"This vehicle equipped for 800 lb./360kg payload. See owner's manual for additional information.

You further state your understanding that NHTSA has permitted manufacturers to put information on the certification label beyond what Part 567 requires. You include two samples (-A- and -a-) representing certification labels, showing alternative location s on the label for your statement. The sample you designate as -A- shows your statement just above the required vehicle identification number, and just below the statement that your vehicle complies with all applicable Federal motor vehicle safety standa rd. The sample you designate as -B- shows your statement just below all of the information 5567.4 requires a manufacturer to put on the certification label. You ask which sample the agency would find acceptable.

You are correct that the agency his permitted manufacturers to include information on the certification label beyond that which Part 567 requires. There NHTSA has acquiesced in this practice, the additional information appeared after that required under 5567.4(g). Sample B shows the placement of your additional statement after the required Part 567 information. NHTSA finds that Sample B is acceptable so long as your label otherwise complies with Part 567. Sincerely,

Erika Z. Jones Chief Counsel

Erika Z. Jones, Esq. Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Re: Part 561 - Request for Interpretation

Dear Ms. Jones:

On behalf of Suzuki Motor Co., Ltd., of Japan, we are requesting an interpretation of Part 567-Certification, 567.1, as it applies to the placement of additional wording in the form of a statement addressing vehicle payload on the vehicle certification l abel. The additional statement reads:

"This vehicle equipped for 800 lb./360kg payload.

See owner's manual for additional information."

I have attached a drawing showing the statement placed in two different locations as illustrated in samples A and B. Suzuki's preference is sample A with the added statement being placed between the vehicle conformity statement and the VIN. If sample A p lacement is not acceptable to NHTSA. Suzuki would use sample B placement with the added statement appearing below the vehicle type description.

It is our understanding that NHTSA has permitted the use of additional wording or information on certification labels in response to requests like ours from other manufacturers. Suzuki also believes the addition of payload information for this particular vehicle would be of value to the vehicle owner.

Thank you for your assistance in this matter. We look forward to your prompt response to our request for interpretation. Sincerely,

AMERICAN SUZUKI MOTOR CORPORATION

Frederick M. Petler Head, Administration Government Relations Department

FMP:bf

ID: 86-5.26

TYPE: INTERPRETATION-NHTSA

DATE: 09/29/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. William C. Fisher

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. William C. Fisher Product Engineer Parker Hannifin Corporation Parflex Division 1300 North Freedom Street Ravenna, OH 44266

Dear Mr. Fisher:

Thank you for your letter and enclosure regarding the labeling requirements for air brake hose assemblies set forth in Standard No. 106, Brake Hoses. I regret the delay in our response. We have referred the matter to our enforcement division to obtain more information about the assemblies you enclosed. We will return the samples of brake hose assemblies you sent, as you requested, when our examination is completed.

Sincerely,

Erika Z. Jones Chief Counsel

National Highway Traffic Safety Admin. Department of Transportation Office of Chief Council, NOA32 Room 5219 400 Seventh Street, S.W. Washington,D.C. 20590

Attention : Ms. Deirdre Hom, Attorney Advisor

Subject: D.O.T. Safety Standard 106 Section 7.2.3, Parts a and b - Identification of brake tubing assemblies by banding; Section 7.2.3.1 - End fitting marking to D.O.T. regulations.

Dear Deirdre:

Per our recent conversation, I have enclosed samples of the air brake end fittings which we contend are not in compliance with DOT 106 regulations. These assemblies were permanently ". . attached by crimping or swaging. ." a brass collar to the nylon tubing. This would, in our opinion, constitute a permanently attached fitting which is not reusable. In addition, no identification band was found on the coil assembly, and all end fittings lack D.O.T. identification markings.

I request that you review these samples and render a decision on the following questions:

1) Do these samples constitute permanently attached fittings under Section 7.2.3?

2) Is the attachment of a D.O.T. identification band required on brake hose assemblies made with this type of end fitting?

3) Is the end fitting identification marking in compliance with DOT 106 regulations?

I have enclosed for review, a current production sample of a Parker brake coil assembly that complies with DOT 106 regulations.

I request that these samples be returned to me at the Parker Parflex Division upon completion of your study.

Ms. Deirdre Hom Page 2

Your swift attention to this matter will be appreciated. If you have any additional questions, please contact me at (216) 296-2871, ext. 259.

Very truly yours,

William C. Fisher Product Engineer

WCF:dm

Enclosures

1) Unidentified brake hose end fitting (Section Out) 2) Unidentified brake hose end fitting 3) Parker brake coil assembly

cc: William Hertel, Corporate Staff Engineer, Parker Hannifin Corp. Mark Kugelman, General Marketing Mgr., Parker Hannifin Corp. Robert Wiseman, Plant Mgr., Parker Hannifin Corp.

ID: 86-5.35

TYPE: INTERPRETATION-NHTSA

DATE: 10/24/86

FROM: AUTHOR UNAVAILABLE; Erika Z.Jones; NHTSA

TO: Paul Meeker -- Senior Product Designer, Century Products, Inc.

TITLE: FMVSS INTERPRETATION

ATTACHMT: 6/3/85 letter from Jeffrey Miller to Frederick Locker (Std. 213)

TEXT:

Mr Paul Meeker Senior Product Designer Century Products, Inc. 1366 Commerce Drive Stow, OH 44224-1793

This responds to your letter to Mr. Vladislav Radovich of our Rulemaking division, seeking an interpretation of Standard No. 213, Child Restraint Systems (49 CFR S571.213). Specifically, you noted that Collier-Keyworth now sells a child seat with a movable shield that is not spring-loaded. A movable shield that is not spring-loaded will remain in position in front of the child seat occupant, even if the crotch strap attached to the shield is not properly fastened. You stated that your company would like to build a child seat with a movable shield that is not spring-loaded, and stated your opinion that shields need not be spring-loaded to comply with the requirements of Standard No. 213.

Your opinion is correct if read narrowly, because no provision of Standard No. 213 requires or ever has required movable shields on child restraints to be spring-loaded. However, if a child restraint incorporates a movable shield, section S6.1.2.1.2 of Standard No. 213 specifies that the child restraint must be certified as complying with test configuration II. In test configuration II, the child restraints subjected to a 20 mile per hour frontal crash. Section S6.1.2.3.1(c) provides that none of the child restraint must be attached during this test, unless the belts are an integral part of the movable shield. Because of this requirement and the agency's interpretations thereof, child restraints have generally incorporated spring-loaded movable shields. This agency discussed these provisions and their applicability to the Collier-Keyworth non-spring-loaded shields at length in a July 1985, letter to Mr. Frederick Locker. I have enclosed a copy of this letter for your information.

If you have any further questions about this subject after reviewing the letter to Mr. Locker, please contact Mr. Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.

See 6/3/85 letter from Jeffrey R. Miller to Frederick B. Locker

July 31, 1986

Mr. Val Radovitch DEPARTMENT OF TRANSPORTATION

Thank you for taking time to visit with Barbara Kelleher, Bob Quinlin and me on July 30.

Per our conversation, I am enclosing a copy of the Collier "Classic" Car Seat literature which shows its non-spring-load flip-over shield.

As we discussed, Century would like to build a seat with a similar flip-over shield and is concerned about whether it is necessary to spring-load the shield. Our opinion is that this type of shield meets the standard without spring-loading.

Will you comment?

Best Regards,

Paul Meeker Senior Product Designer

PM/dg enc.

ID: 86-5.39

TYPE: INTERPRETATION-NHTSA

DATE: 10/28/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Curtis A. Winston

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Curtis A. Winston Regional Administrator, Region X National Highway Traffic Safety Administration 3140 Jackson Federal Building Seattle, WA 98174

Dear Mr. Curt:

Thank you for your letter of June 27, 1986, asking about how the agency regulations affect the installation of seats and safety belts in used vehicles. You explained that since the passage of a mandatory safety belt use law in Washington, your office has received numerous inquiries about this subject. I hope the following discussion will answer your questions.

I believe it may be helpful to compare how our regulations affect both new and used vehicles. Each manufacturer of new vehicles must certify that each of its vehicles meets all of the applicable Federal Motor Vehicle Safety Standards. The agency has issued the following five safety standards which apply to vehicle seats and safety belts: Standard No. 202, Head Restraints, Standard No. 207, Seating systems, Standard No. 208, Occupant Crash Protection, Standard No. 209, Seat Belt Assemblies, and Standard No. 210, Seat Belt Assembly Anchorages.

After a new vehicle becomes a used vehicle (1.e., when it is sold and delivered to the first purchaser), it may be modified without limitation by its owner, but not by commercial enterprises under the National Traffic and Motor Vehicle Safety Act. Section 108(a)(2)(A) of the Act prohibits commercial enterprises, such as dealers and motor vehicle in compliance with our standards. Thus, in the case of a used vehicle, commercial enterprise cannot remove a safety belt that was originally installed in compliance with Federal safety standards. Violations of section 108(a)(2)(A) can result in Federal civil penalties of up to $1,000 for each violation.

However, in adding equipment to a used vehicle, commercial businesses do not have to comply with the safety standards that would apply if the equipment was installed before the vehicle is first sold. For example, if a commercial business is asked to install a seat in the cargo area of a used van, which did not previously have a seat at that position, the business is not required by the Federal safety standards or section 108(A)(2)(a) to install safety belts for that seat. However, the business may have a duty to install safety belts for that seat under applicable State regulations and courts decisions.

Section 108(a)(2)(A) does not affect vehicle owner, who may themselves alter their vehicles as they please, so long as they adhere to all State requirements. Under Federal law, an owner may remove a safety belt from his or her vehicle. The agency, however, urges vehicle owners not to take such actions. Individual States govern the operational use of vehicles by their owners. Therefore, it is within the authority of the States to preclude owners from removing safety belts or seats from the vehicles.

I hope this information is helpful. Please let me know if you have an further questions.

Sincerely,

Erika Z. Jones Chief Counsel

ID: 86-5.50

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Scott Muirhead

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 2, 1986 to William Smith of this agency, requesting information on which of the agency's regulations would apply to a new product you are considering as an item of original and aftermarket equipment. Your letter was referred to my office for reply. You described the product as a cross-bed seat for use in pickup trucks. The seat would be made of plastic and supported by a fabricated metal frame and be mounted in the front of the truck bed facing the rear. According to your description, the seat would have safety belts. The following discussion explains the application of our regulations to your potential product.

Since your potential product would be used as a seating position in a motor vehicle while the vehicle is in motion, each occupant position on the seat would be considered a designated seating position by the agency. If your product is installed as an item of original equipment on a truck before its sale to its first purchaser, the designated seating positions must conform to the requirements of Standard No. 207, Seating Systems; Standard No. 208, Crash Protection; Standard No. 209, Seat Belt Assemblies; and Standard No. 210, Seat Belt Assembly Anchorages. I have enclosed an information sheet explaining how you can obtain copies of our safety standards.

If your product is sold as an item of aftermarket equipment to be installed by a vehicle owner, it would not be required to comply with Standard Nos. 207, 208, and 210. However, the safety belts provided with the seat would have to comply with Standard No. 209.

Finally, as a manufacturer of an item of motor vehicle equipment, you have a responsibility under section 151 et seq. of the National Traffic and Motor Vehicle Safety Act to conduct a notification and remedy campaign if you or the agency determines that your product contains a safety-related defect or does not comply with an applicable standard. A copy of an information sheet briefly describing those responsibilities is enclosed.

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

Sincerely,

Enclosure

ATTACH.

August 22, 1986

MR. SMITH -- Office of Vehicle Safety Standards, NHTSA Dear Sir:

After having reviewed the various motor vehicle safety standards sent to my attention from your good office. I have concluded that our particular Seating System falls outside the standards regulating inboard multi-purpose passenger vehicle seating.

I am therefore enclosing rough sketches of the seating system our company is developing for both an original and after equipment market. I trust these sketches will enable you to identify any Federal Safety Standards which may be or become applicable to a seating system of this nature.

Thanking you in advance for your attention and kind consideration, I am

Respectfully,

Scott Muirhead -- New Project Manager

Enclosures:

[Graphics omitted]

ID: nht89-1.31

TYPE: INTERPRETATION-NHTSA

DATE: 03/07/89

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: THERESA ROONEY -- ALPINE ELECTRONICS OF AMERICA, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 02/26/87 FROM THERESA ROONEY TO ED GLANCY -- NHTSA, RE FMVSS 101, OCC 1676

TEXT: Dear Ms. Rooney:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. We apologize for the delay in our response. You stated that it is your understanding that any car sound system which is f actory installed must have light intensities that have two values, a higher one for day and a lower one for night; that these two light intensities do not have to be variable; and that any color may be used to illuminate the system. You asked for confir mation of this understanding. As discussed below, Standard No. 101's requirements in this area are somewhat more flexible than suggested by your letter.

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

The requirements of Standard No. 101 that are relevant to car sound systems are set forth in section S5.3.5. That section states:

S5.3.5 Any source of illumination within the passenger compartment which is forward of a transverse vertical plane 4.35 inch (110.6 mm) rearward of the manikin "H" point with the driver's seat in its rearmost driving position, which is not used for th e controls and displays regulated by this standard, which is not a telltale, and which is capable of being illuminated while the vehicle is in motion, shall have either (1) light intensity which is manually or automatically adjustable to provide at least two levels of brightness, (2) a single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or (3) a means of being turned off. This requirement does not apply to buses that are normally operated with the passenger compartment illuminated.

With respect to car sound systems, section S.5.3.5's requirements can be summarized as follows. First, the requirements generally apply to any car sound system that is installed in a motor vehicle before its first sale to a consumer and that includes a source of illumination which is forward of the driver. Second, the section requires that any such source of illumination have either (1) light intensity which is manually or automatically adjustable to provide at least two levels of brightness, (2) a sin gle intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or (3) a means of being turned off. No color requirements are specified for the source of illumination of a car sound system.

I would note that, at the option of the manufacturer, motor vehicles manufactured before September 1, 1989, may comply with the requirements of Standard No. 100 instead of the requirements of Standard No. 101. This provision is of relevance for some, bu t not all, car sound systems, and only for vehicles manufactured before September 1, 1989. If you desire further information about this provision, please contact us.

Sincerely,

ID: nht76-1.28

DATE: 08/06/76

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

TO: Hon. John J. LaFalce - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your correspondence on behalf of Mr. George J. Ciancio, concerning the tires on his 1975 Dodge Van B-100. Prior to responding, this office contacted Mr. Ciancio for additional information.

From the correspondence you submitted to this Administration, Mr. Ciancio did not appear to receive satisfactory responses to the questions he submitted to the Chrysler Corporation concerning the tire problems he was experiencing. We offer the following responses for his consideration:

Question 1 - Stamped on the sidewalls of the original tire the rating is 1400 pounds. Is this maximum load?

Response - Yes. The maximum load rating for an E7815 B passenger car type tire is 1400 pounds. This rating is only applicable when this tire is used for passenger car service. For a van of the type used by Mr. Ciancio, a service factor is applied for "truck service" and the maximum load becomes 1270 pounds.

Question 2 - My registration shows the van weight at 4434 pounds. What is the laden weight of the B-100 van?

Response - Mr. Ciancio was contacted on this point. Our data indicates that the Dodge B-100 van should weigh approximately 3600 pounds depending on the installed equipment. As the Gross Vehicle Weight Rating (GVWR) is 4600 pounds, the approximate laden weight would be about 1000 pounds as indicated by Chrysler. If in fact, the van does weigh 4434 pounds empty, then the laden weight cannot be over 166 pounds, which of course, cannot be correct.

Question 3 - Do I read correctly that my total tire weight allows 5400 pounds, which includes van and load?

Response - No. From page 3 of your Owners Manual, you will note, "The GVW rating of your truck as manufactured is shown on the Safety Certification Label. The GVW rating is the total permissible weight of your truck including driver, passengers, body, and payload." As the GVWR of the B-100 van is 4600 pounds, 4600 pounds is the maximum load.

Question 4 - The axle capacity in the manual front and rear is shown as 2700 pounds. Does this mean with loaded weight?

Response - No. The axle capacity of 2700 pounds is the rating determined by the vehicle manufacturer as the maximum load that should be applied to that individual axle - it does not mean that both axles can take the design capacity for a total of 5400 pounds. Again, the B-100 van is limited to 4600 pounds GVW. Vehicle load on each axle is further limited by the suspension's spring and wheel ratings which reduce actual load carrying capacity to GAWR valves of 2480 front and 2340 rear. These figures indicate the importance of proper load distribution in the vehicle.

Question 5 - Is it true if I increase my tire size from E78-15B to G78-15B, would it make any difference in the load I could carry without jeopardizing the axle weight capacity?

Response - No. By changing the tires on the van from E ratings to G ratings would not change the GVWR of 4600 pounds. The van is still limited to a GVWR of 4600 pounds.

We hope that the responses to these questions will answer some of the concerns of Mr. Ciancio.

ID: nht90-3.27

TYPE: Interpretation-NHTSA

DATE: July 23, 1990

FROM: C.D. Black -- Manager, Product Legislation and Compliance, Jaguar Cars Inc.

TO: Administrator -- NHTSA

TITLE: Re Request for Reconsideration of an Interpretation FMVSS 114 Docket 1-21 Notice 9

ATTACHMT: Attached to letter dated 10-12-90 from P.J. Rice (Signature by K.M. Weinstein) to C.D. Black (A36; Std. 114); Also attached to a copy of 49 CFR Part 571.114 and 55 FR 21868 (May 30, 1990) (text omitted)

TEXT:

Jaguar Cars Ltd of Coventry, England (herein after referred to as Jaguar) request that NHTSA review their interpretation on pages 21872/73 of the Federal Register of the conditions under which a mechanical emergency release may be installed on a transmis sion shift lever interlock.

Jaguar regards the objective of the amendment as fair and reasonable, however, because Jaguar manufacture vehicles for sale worldwide with either manual or automatic transmission, we will continue to install an anti-theft lock operating on the steering c olumn. Jaguar therefore plan to comply with the amended standard by means of a spring-loaded electrical interlock operating on the console-mounted automatic transmission shift lever together with a revision to the steering column lock to prevent removal of the key unless the shift lever is in 'park'. When the ignition is next switched 'on', operation of the brake pedal produces an electrical signal to disengage the interlock and hence allow the shift lever to be moved.

However, as Honda, Mazda, Nissan, Subaru and Toyota have previously stated in the docket, the use of an electrically operated interlock acting on the shift lever could, in the event of a battery or electrical failure, cause problems unless a mechanical e mergency release is provided. If the vehicle is tightly parked, the shift lever placed in 'park' to remove the key, and the battery subsequently discharged, it might then be necessary to "drag" the vehicle on locked wheels to gain access before a charge d battery or jumper leads could be connected to remove it from its disabled position.

Jaguar had anticipated that a manual emergency release which, when required, must be activated against spring pressure with one hand using a tool, while allowing the shift lever to be moved out of 'park' only by a simultaneous movement of the other hand, would maintain the declared intent of the amendment to prevent "rollaway" accidents. The theft protection of any (Jaguar) vehicle so equipped would not be degraded because the steering column lock and ignition/starter system remain immobilized. With t his or a similar combination of equipment there is no merit in requiring the shift lever interlock emergency release to be operable only by the key used to control the vehicle (emphasis added).

Jaguar request your consideration that the total objectives could be met by an interpretation along the following guidelines:

"In the case of an electrically operated interlock on the transmission shift lever, where the primary theft protection is provided by a steering column lock, the emergency release may be operated by a single action requiring the use of the key used to co ntrol the vehicle. Alternatively, a mechanical emergency release is allowable provided that it requires the use of a separate implement or tool and the simultaneous use of two hands to release the shift lever."

In view of the demanding timescale given by the Agency's interpretation on "mechanical override system's" in the final rule, Jaguar respectfully request the earliest consideration of our petition.

ID: nht88-3.42

TYPE: INTERPRETATION-NHTSA

DATE: 09/12/88

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: GEORGE ZIOLO -- DOT PAPERWORK PROCESSOR

TITLE: NONE

ATTACHMT: LETTER DATED 04/20/88 TO ERIKA Z. JONES FROM GEORGE ZIOLO RE HEADLAMP COMBINATIONS-REQUEST FOR CLARIFICATION, FMVSS 108; OCC - 1932;

TEXT: Dear Mr. Ziolo:

This is in reply to your letter of April 20, 1988, asking about the acceptability under Safety Standard No. 108 of modifying imported vehicles so that they are equipped with two Type 2D1 and two Type 1C1 headlamps. You have been informed by the agency's Office of Vehicle Safety Compliance that this is impermissible "because they are 'nonconforming' 'headlight systems'." You disagree because you believe that the minimum requirements of the Standard are satisfied by the Type 2D1 lamps, and that "S4.4 app ears to permit such a combination."

Paragraph S4.4 is not applicable to the situation you present as it refers to combinations of lamps serving different functions; in your discussion, the lamps serve the identical function of headlighting. Given the fact that the Type 2D1 sealed beam 7" diameter headlamps fulfill the headlighting requirements of the Standard, your question must be viewed as whether a supplement to the headlighting system is permissible under Standard No. 108.

Paragraph S4.1.3 of Standard No. 108 permits the addition of nonrequired lighting equipment provided it does not impair the effectiveness of the equipment that the standard requires. The two Type 1C1 5 3/4" diameter sealed beam lamps in a four lamp head lighting system form the major portion of an upper beam headlighting system. The two Type 2D1 lamps in a two lamp headlighting system form the whole of an upper beam headlighting system. Thus, a vehicle furnished with the systems you posit would be equ ipped with more than one upper beam headlighting system. The Type 2D1 system must be designed to conform to the photometric requirements of SAE Standard J579c DEC79 "Sealed Beam Headlamp Units for Motor Vehicles." The SAE Standard establishes at two tes t points, H-V and 4 D-V, maximum allowable candela of 75,000 and 5,000 respectively for each Type 2D1 headlamp. This means that the maximum allowable candela for headlighting systems at these test points is 150,000 and 10,000 candela. The Type 1C1 head lamps will also be designed to conform to SAE J579c. Corresponding maxima at test points H-V and 4 D-V for Type 1C1 systems are 60,000 and 5,000. Thus, a vehicle equipped

with the lamps you have described could emit a total of 270,000 candela at test point H-V (when only 150,000 is permitted), and 20,000 at 4D-V (when only 10,000 is allowable).

Agency research has shown that candela readings in excess of 150,000 greatly increase the potential for glare with little increase in seeing ability. This glare would be visible both to the driver of an oncoming car, and the driver of the modified vehic le itself through creation of a "veiling" glare. The addition of the Type 1C1 headlamps would therefore impair the effectiveness of the Type 2D1 headlighting system, and is forbidden by S4.1.3.

We appreciate your interest in safety.

Sincerely,

ID: 1985-03.22

TYPE: INTERPRETATION-NHTSA

DATE: 07/24/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Richard H. Lucki -- Peugeot, U. S. Technical Research Company

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Richard H. Lucki U.S. Factory Representative PEUGEOT U.S. Technical Research Company 33 Garland Way Lyndhurst, New Jersey 07071

This responds to your letter of March 7, 1985, concerning Standard No. 208, Occupant Crash Protection. I regret the delay in our response. You noted that sections S4.1.2.71(c)(2) and S4.1.2.2(d) of the standard require a seat belt warning system that conforms to S7.3 of the standard to be installed at each front outboard seating position of automatic restraint-equipped cars that have manual belts also at those positions. You pointed out that S7.3, however, only sets requirements for a warning system for the driver's seating position. You asked whether the requirements of S4.1.2.1(c)(2) and S4.1.2.2(d) can be met by providing a warning system conforming to S7.3 at only the driver's seating position. The answer is that those requirements can be met by a warning system for the driver only.

In December 1974 (39 FR 42692), the agency amended Standard No. 208 to establish new safety belt warning system requirements for vehicles manufactured after February 24, 1975. As discussed in the preamble, the agency decided against requiring a warning system at both the driver's seating position and the right front passenger's position. Instead, the agency adopted a requirement in S7.3(a) for a warning system at only the driver's seating position. (In July 1977 (42 FR 34299), the agency renumbered S7.3(a) to become the current S7.3).

In July 1976 (41 FR 29715), the agency proposed language concerning the safety belt warning system in automatic restraint-equipped cars. The proposed language was subsequently adopted, an July 5, 1977 (49 FR 34299), in S4.1.2.1(c)(2) of the standard. The agency explained in the preamble of the July 1976 notice that the proposed safety belt warning system was to parallel the existing requirements for passenger cars. Thus, the intent was to require a warning system for only the driver's position. Requiring a warning system for the driver's position only is also consistent with the separate warning system requirement set in S4.5.3.3(b) for automatic belts. S4.5.3.3(b) requires a warning system only for the driver's position.

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

Sincerely, Jeffrey R. Miller Chief Counsel

March 7, 1985

RE: Federal Motor Vehicle Safety Standard 208 - Request for Interpretation

Dear Mr. Berndt:

Paragraphs 4.1.2.1(c)(2) and 4.1.2.2(d) of Federal Motor Vehicle Safety Standard 208 requires a seat belt warning system which conforms to paragraph 7.3 at each front outboard seating position.

Paragraph 7.3 requires that a seat belt assembly provided at the driver's seating position shall be equipped with a warning system and conditions activation of the audible signal to use of the driver's belt.

We request confirmation that the requirements of S.4.1.2.1(c)(2) and S.4.1.2.2(d) are met by providing a warning system conforming to S.7.3 at the driver's seating position only.

Thank you.

Very truly yours, Richard H. Lucki U.S. Factory Representative PEUGEOT

USTR/RHL/jg/070