ID: aiam0909

Dear Mr. Humphreys: Your letters of September 8 and October 16, 1972, raise a questio concerning the applicability of S4.3 of Standard 207 to certain folding seats in recreational vehicles. Your position is that the typical dinette seat that folds down to form a bed is 'a seat having a back that is adjustable only for the comfort of its occupants' and is therefore excepted from the restraining device requirement of S4.3.; In a letter that we sent to Auto Top, Inc. on September 8, 1972, w distinguished between excepted seats and non-excepted seats on the basis of the degrees of arc through which the back could be adjusted,(sic) A back adjusting only a few degrees would be excepted under this interpretation, while a seat that folded flat to make a bed would not be excepted and would therefore have to have a restraining device. After reconsidering the background of these exceptions, we have decided to modify that interpretation. Although there is likely to be a difference between these seats in the degree of protection they give the occupant, we cannot find that this difference was reflected in the drafting of the S4.3 exceptions.; The S4.3 exceptions were created by a notice of rulemaking publishe April 4, 1967 (32 F.R. 5498). The exception in issue here was adopted in response to a petition by the Rover Company, who requested special treatment for a seat with a back that had a range of adjustment from 77 degrees to the horizontal down to 19 degrees to the horizontal. In granting an exception to the type of seat depicted by Rover, the agency therefore included seats with backs that folded until they were substantially horizontal. We must thus conclude that a seat whose back folds backward with respect to the seat cushion to form a bed is not required under S4.3 to have a device to restrain the backward folding of the seat back.; However, the exemption granted in response to the Rover petition doe not cover the case you have described. A seat having a back that folds for the occupant's comfort but that also folds in another manner is required to have a restraining device for the second folding mode. The usual example of such a seat is a front seat in a two-door sedan that folds forward for entry to the rear and has a back that adjusts through a rearward arc for the occupant's comfort. Such a seat must have a restraining device to prevent forward movement because the adjustment of the back is not 'only' for the occupant's comfort. A dinette seat that has an additional folding or hinging mode must therefore have a restraining device to guard against the effects of the seat's folding in this mode during a crash. For example, a seat whose base is hinged to move the bottom cushion into the space between the dinette seats must be restrained by a device conforming to S4.3.; With specific reference to the type of seat shown in the attachments t your letters, the downward motion of the seat back would be exempt under S4.3, but the motion of the bottom cushion is such that it would have to have a restraining device conforming to S4.3.; As you describe the seat, a restraining device is provided. However without subjecting it to a compliance test under S4.3.2 we are unable to say whether it conforms to S4.3.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: 2845o

Mr. Takashi Ohdaira
Isuzu Motors America, Inc.
21415 Civic Center Drive
Southfield, MI 48076-3969

Dear Mr. Ohdaira:

This responds to your December 16, 1987 letter asking several questions about the applicability of Federal Motor Vehicle Safety Standard No. 207, Seating Systems, to "swivel type front seats" installed in new compact passenger vans. I regret the delay in responding. Swivel seats are not prohibited by Standard No. 207. However, under Standard No. 208, Occupant Crash Protection, a front outboard swivel seat must have lap and upper torso restraints that fit the occupant of the seat in any position in which the seat would be occupied while the vehicle is in motion, including the rearward facing position.

Your letter explains that Isuzu is interested in manufacturing some of its vehicles with swivel seats for the driver and front outboard passenger. The seats can be rotated in any direction and self-locked into either a forward-facing or a rearward-facing direction. A release control is provided allowing the seat to be rotated into a new position. You state that Isuzu tentatively plans to install lap and upper torso belt assemblies with emergency-locking retractors that "meet the requirements applicable to a forward-facing front seat" since the capability of the seats to face rearward is "just a secondary function."

You first ask for confirmation of your understanding that Standard No. 207 does not prohibit the installation of front outboard swivel seats. Your understanding is correct. Our standards do not require seats on vehicles other than large school buses to be forward-facing and thus do not thereby expressly prohibit installation of swivel seats.

Your letter raises the issue of whether the swivel seat installed at the front outboard passenger seating position must comply with the requirements of Standard No. 208 and thus provide lap and upper torso restraints only for the forward-facing position (as opposed to what you term the "secondary" or rearward position). Paragraph S7.1.1 of Standard No. 208 states, in pertinent part:

. . . [T]he lap belt of any seat belt assembly furnished in accordance with S4.1.1 and S4.1.2 shall adjust by means of an emergency-locking or automatic-locking retractor that conforms to 571.209 to fit persons whose dimensions range from those of a 50th-percentile 6-year-old child to those of a 95th-percentile adult male and the upper torso restraint shall adjust by means of an emergency-locking retractor or a manual adjusting device that conforms to 571.209 to fit persons whose dimensions range from those of a 5th-percentile adult female to those of a 95th-percentile adult male, with the seat in any position and the seat back in the manufacturer's nominal design riding position. . . . (Emphasis added.)

The quoted reference to seat "position" in the excerpt from S7.1.1 is not limited to the positions along the vehicle longitudinal centerline to which a seat can be adjusted while forward-facing. We interpret the term as referring also to seat orientation, including the rearward-facing position or any other direction the seat is capable of facing, provided that the seat can be placed in those positions while the vehicle is in motion. Thus, we believe that a front outboard swivel seat must have lap and upper torso restraints that fit the occupant of the seat while the seat is in any position in which it can be occupied while the vehicle is in motion. Starting September 1, 1991, light trucks and multipurpose passenger vehicles with manual safety belts for the driver and front seat passenger seating position will have to meet the requirements of Standard No. 208 in a dynamic crash test. A front outboard swivel seat would have to comply with those requirements with the seat in any position in which it can be occupied while the vehicle is in motion.

We have limited our interpretation to positions in which a seat may be occupied while the vehicle is in motion for the following reasons. The purpose of requiring a seat belt assembly to meet the adjustment requirements of Standard No. 208 with the seat in any position is to ensure that adequate occupant crash protection would be provided to the occupant of the seat regardless of the position he or she chooses for the seat. However, the safety goal of ensuring adequate crash protection for vehicle occupants relates only to positions in which a seat may be occupied when a vehicle is involved in a crash, i.e., the positions in which a seat may be occupied while a vehicle is in motion. If the swivel seat you plan to install for the front outboard seating position can only be used in its forward-facing position while the vehicle is in motion, then it need meet Standard No. 208's requirements only at forward facing positions and need not conform with the standard's requirements at positions facing in other directions.

In your letter, you suggested two possible ways to limit the rearward-facing capabilities of a front outboard swivel seat. First, you suggested that the vehicle could be manufactured with an interlock system that would prevent the vehicle from starting unless the front passenger seat faces forward. In our opinion, this system would not sufficiently ensure that the swivel seat would be used only in its forward-facing position while the vehicle is in motion. An occupant of the seat could swivel his or her seat once the vehicle has started and could thus face rearward without the benefit of lap and upper torso restraints.

Your second suggestion was to manufacture the vehicle such that the front passenger seat could swivel rearward only when the driver seat rotated rearward or when the vehicle was "in park." This would prevent the passenger's seat from facing in any direction other than forward while the vehicle was in motion since the driver must face forward to operate the vehicle. We believe that this alternative could satisfactorily ensure that the front outboard passenger seating position could not face in any direction other than forward while the vehicle is in motion.

In addition to the requirements discussed above, we note also that Standard No. 210, Seat Belt Assembly Anchorages, would require the front outboard swivel seat to have seat belt anchorages for a Type II seat belt assembly. The anchorages would have to meet the standard's strength requirements (S4.2), and those for their location (S4.3) provided that the safety belt will not be dynamically tested pursuant to Standard No. 208's requirements. Anchorages for a front outboard swivel seat that can be occupied in its rearward facing position while the vehicle is in motion could be tested to the requirements of S4.2 by the agency with the seat in either the forward or rearward facing position.

I hope this information is helpful. Please contact us if you have any questions.

Sincerely,

Erika Z. Jones Chief Counsel

ref:207#208#210 d:4/8/88

ID: aiam2572

Dear Mr. Kurre: This responds to your April 1, 1977, letter asking whether the hea protection zone requirements of Standard No. 222, *School Bus Passenger Seating and Crash Protection*, extend to contactable surfaces 30 inches forward of the seating reference point of the front passenger seat behind the driver.; The head protection zone requirements are outlined in S5.3.1.1 of th standard. This section requires that the zone extend 30 inches forward of the seating reference point. The fact that the requirement may extend the head protection zone into the driver occupant space and thus involve contactable surfaces does not diminish the applicability of the requirements to contactable surfaces within that space. Contactable surfaces within that 30-inch zone, as shown on your sketch, must meet the requirements of the standard.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: nht87-2.94

TYPE: INTERPRETATION-NHTSA

DATE: 09/17/87

FROM: WILLIAM E. LAWLER -- INDIANA MILLS AND MANUFACTURING INC

TO: ERICA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 10/14/88 TO WILLIAM E. LAWLER FROM ERIKA Z JONES, REDBOOK A32, STANDARD 208, STANDARD 209

TEXT: Dear Chief Counsel:

We are writing to you to request an official interpretation of portions of FMVSS 208 and 209 with regard to a Type 2 Seat Belt Assembly designed by a customer and ordered by him for installation at a static (non-suspension) driver's seat in a vehicle wit h a GVWR exceeding 10,000 pounds.

The proposed seat belt assembly incorporates an automatic locking retractor to be mounted at the left of the driver's seat and a free-sliding latchplate engineered to remain in view and easy reach when not in use. The webbing is continuous from the retr actor to the anchored end of the upper torso restraint which would be installed above, slightly behind and to the side of the seat occupant. The strengths of all components and the strength of the assembly itself comply with FMVSS 209.

The latter half of 49CFR 571.209 S5.2(i) deals with automatic-locking retractors and their tendency to cinch the seat belt assembly webbing against the occupant while riding on rough roads. In addition, 49 CFR 571.208 S4.2.2, S4.1.2.3, and S7.1, though dealing with lighter vehicles, seem to imply the intent of minimal upper torso restriction. These sections of FMVSS 208 and 209 have been discussed with our customer.

In our opinion, two modifications to the customer's design will convert the continuous webbing feature into separate lap belt and upper torso restraints which will allow his proposed design to comply with the sections of FMVSS 208 and 209 referenced abov e: 1. sew the latchplate to the webbing at a specified location in order to create a standard lap belt 2. place a manual adjusting device in the upper torso restraint.

Our customer has agreed to postpone the order on his original design and use the option we are suggesting until we have received an official opinion from The National Highway Traffic Safety Administration.

If you have further questions, please contact me.

Sincerely,

ATTACHMENT

[DRAWING OMITTED] ALR, 3PT. SYSTEM

ID: nht76-2.9

DATE: 04/26/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Blue bird Body Company's February 13, 1976, question whether 47 described intersections of bus body components qualify as "body panel joints" subject to the requirements of Standard No. 221, School Bus Body Joint Strength. You also ask what test procedures are used in testing joints if the means described in S6.1.1 or S6.1.2 cannot be employed due to the configurations of the intersecting components.

The terms which establish the applicability of the requirements of the standard to a particular section of a school bus body are defined in S4 of the standard. Read together, they establish the following test. If the edge of a surface component (made of homogeneous material) in a bus that encloses the bus' occupant space comes into contact or close proximity with any other body component, the requirements of S5 apply, unless the area in question is designed for ventilation or another functional purpose or is a door, window, or maintenance access panel. Applying this test to the 47 intersections of bus body components you describe, it appears that the arears corresponding to the following numbered paragraphs of your letter are bus body joints and therefore must meet the 60-percent joint strength requirements: 1, 4, 5, 6, 7, 8, 9, 11, 13, 14, 15, 19, 20, 23, 26, 28, 29, 50.

The front and rear headers described in paragraphs 2 and 12 are considered primarily structural and have only an incidental role in enclosing the occupant space and, therefore, are not considered "body panels" for purposes of the requirements.

The wire molding discussed in paragraphs 3 and 10 is considered a maintenance access panel, excluded from the requirements only if a wire is installed behind the molding.

The bumper trim strip described in paragraph 17 is not considered to have a function in enclosing the occupant space and is therefore not considered a body component for purposes of the requirements.

Your assumption that components located entirely below the level of the floor line are not subject to the standard is correct. However, body panels that do "enclose bus' occupant space" because a portion lies above the floor line are subject to the requirements. Thus, the rear center skirt described in paragraph 16, the bumper trim panel described in paragraph 18, and the auxiliary cross members described in paragraph 21 are not subject to the requirements.

The rubrails described in paragraphs 22, 23, 27, 28, and 29 are not themselves considered to have a function in enclosing the occupant space and therefore are not considered body components for purposes of the requirements. For purposes of testing the complex joints to which they are fastened, they should be modified as necessary to prevent them from affecting testing of the underlying joint.

The wheelhousing trim described in paragraph 24 is not considered to have a function in enclosing the occupant space and is therefore not considered a body component for purposes of the requirements.

Because the plywood described in paragraph 25 is attached to a floor panel and is only added to some buses for insulation purposes, it is not considered to have a function in enclosing the occupant space and is therefore not considered a body component for purposes of the requirements.

The extruded aluminum trim described in paragraph 30 is not considered to have a function in enclosing the occupant space and is therefore not considered a body component for purposes of the requirements.

The NHTSA agrees that paragraphs 30 through 36 and 38 through 46 describe joints between maintenance access panels and the bus body. The ventilation duct in paragraph 37 is the type of ventilation space that is not subject to requirements for joint strength.

In many of your requests for clarification, you asked what means would be employed to test joints in which the two body components in question are not flat surfaces in the same or parallel planes. The NHTSA intends to test joints that are not capable of being tested as specified in S6.1.1 or S6.1.2 by determining the nature of the two body components and testing identical materials joined by the same means as is used by the school bus manufacturer. The materials will be flat and conform to the dimensions described in Figure 1, and they will be oriented in the same fashion as described in Figure 1. For example, the 90-degree angle at the joint described in paragraph 20 is ignored for purposes of the NHTSA test procedure by simulating the joint and using opposing forces in the same or parallel planes. In this way, the agency can examine a manufacturer's technique to see if the fastening method constitutes the exercise of due care in complying with the joint strength requirement.

You also asked what procedure would be used in testing joints where more than two panels or body components are joined by one fastener (example in paragraph 29). In these cases, the definition of "body panel joint" in S4 describes several joints, involving one at each intersection area that qualifies as joint. For each pair of components, the tensile strength of the weaker panel is determined, and the joint is required to sustain a load of not less than 60 percent of that tensile strength. For example, in the case of two side panels riveted to a bow, one joint would be between the two lapped panels and 60 percent of the weaker panel would be the test requirement. At the same time, a separate test of the joint between the bow and the panel that contacts the bow would be required, with 60 percent of the weaker component's tensile strength established as the level of strength for testing.

I trust that this discussion will permit a determination of what portions of your products are subject to the requirements of Standard No. 221 and what test procedures are employed in satisfaction of the requirements.

SINCERELY,

BLUE BIRD BODY COMPANY February 13, 1976

Richard B. Dyson Assistant Chief Counsel National Highway Traffic Safety Administration

The purpose of this letter is to request interpretations on whether or not certain portions of our bus body construction are considered to be joints, which are subject to the requirements of FMVSS 221, School Bus Body Joint Strength.

As you can see this is quite a lengthy letter; however, we feel it is necessary because the definitions given in the subject standard leave considerable latitude for interpretation.

We have prepared individual sketches and photographs of each area in question and keyed these sketches to the enclosed isometric drawing #47, Body Construction and Conventional Joint Strength, and photograph #48, Blue Bird All American front section and photograph #49, Blue Bird Conventional front section. These sketches are not necessarily to scale, but are rather intended to communicate the pertinent construction details.

In order to facilitate consideration of these construction areas, I will list them by sequence using the balloon numbers on the isometric drawing and two front end photographs.

1. Upper cowl to cowl. The upper left photograph shows these two members on the left front corner of the body. The upper right photograph shows this same sub-assembly from the inside. The front portion where the body cowl meets the chassis cowl is forward of the windshield area while the rearward portion is aft of the windshield area.

We know of no practical way that this seam can be tested using the procedure outlined in S6 because of the embossed portion of the upper cowl and because of the radius of curvature of these members.

Is this a joint under FMVSS 221 and if so, how should it be tested?

2. Front header to front corner post. The photograph shows the upper right corner of the bus body near the entrance door area looking from inside the bus. The horizontal lower surface of the front header is an exposed panel in the interior body area. However, we know of no practical way to assure 60% joint strength between this panel and the tubular vertical front corner post, which is a structural member; nor do we know of a practical way in which it can be tested using the procedure outlined in S6.

Is this a joint under FMVSS 221, and, if so, how should it be tested?

3. The photograph shows the wire molding, which is installed just above the side window area. The photograph is taken from the opposite side of the body looking up from a seated position. The sketch shows a section of this molding with its attachment to the 14 gauge bow and its function in covering and providing access to the wire harness. The wire molding runs the full length of the bus body on the inside on both right and left. It covers and provides access to the main body wiring harness. However, in some models, the wiring harness is only routed on the left side, but a right side wire molding is still provided.

We are assuming that this wire molding is a "maintenance access panel" as described in S4 and, therefore, not subject to the joint strength requirements.

Is this also a valid assumption on those models in which there is no right side body wiring harness, but the wire molding is still provided?

4. Header to headlining. The photograph shows the header which acts as a lintel above each window and is bolted between the main body posts. The photograph also shows a headlining panel in place looking from inside the bus. The sketch shows details of how the headlining rests on a ledge which is formed into the header. This ledge merely acts as a locater to facilitate installation of the headlining panel during the manufacturing process. The headlining panel is then riveted to the bows. There is no welding or mechanical fasteners between the headlining panel and the header. As shown in photograph #3, this is completely covered by the wire molding and, therefore, in our opinion, does not constitute a "portion of a bus that encloses the bus's occupant space" as referenced in S4, and is, therefore, not subject to the requirements of FMVSS 221. Furthermore, we know of no way to connect the headlining panel to the header to meet the requirements of FMVSS 221 or to test it according to the procedure in S6.

Are we correct in our assumption that this is not a "body panel joint" and, therefore, not subject to the requirements of FMVSS 221?

5. Inside side panel to gusset. The gusset is a formed longitudinal body frame member which runs the full length of the bus body on either side. The formed flange in the gusset is used as a mounting ledge on which the outboard side of the passenger seats is mounted. The inside side panels are shown in the upper portions of the photograph and the gusset is shown in the lower portion of the photograph.

Is the area of contact between the inside side panel and the gusset a "body panel joint"?

6. Gusset to floor. This shows the area of contact between the 14 gauge floor panels and the 16 gauge longitudinal floor gusset which is a formed longitudinal framing member running the full side of the bus body on both right and left. The upper portion of the photograph shows the longitudinal gusset ledge; the mid portion of the photograph shows the vertical portion of the longitudinal gusset; and the lower portion of the photograph shows the 14 gauge floor. Because these members meet each other at right angles, we know of no practical way to test them using the procedure described in S6. Furthermore, the area of contact between these members presents no edge to bus occupants. We are, therefore, assuming that this does not constitute a "body panel joint" as described in S4 and is, therefore, not subject to the requirements of FMVSS 221.

Is this assumption correct?

7. Wheelhouse assembly. The photograph shows a rear wheelhouse assembly which provides tire clearance when the suspension goes into the jounce position. In the finished bus this assembly is covered with floor covering where it meets the floor.

Because of the configuration of this assembly, we know of no practical way to test it according to the procedure defined in S6.

Is this a "body panel joint" and, if so, how should it be tested?

8. Inside side rear vision panel to bow. The photograph shows the rearmost side split sash window and the rubber mounted rear vision glass looking from inside the bus. As seen from the photograph and in the cross section sketch, the joint between the inside vision panel and the bow is completely covered by the extruded aluminum frame around the window.

In our opinion the joint between the inside rear vision panel and the bow does not enclose the bus's occupant space and is, therefore, not a "body panel joint", which is subject to the requirements of FMVSS 221. Is this assumption correct?

9. Side vision header. The photograph shows the left rear inside rear vision panel where it contacts the header, looking from inside the bus with the headlining panel and the wire molding removed. The sectional sketch shows the area of contact between the inside rear vision panel and the header. The upper edge of the inside rear vision panel is completely covered by the wire molding.

We know of no way that the area of contact between the header and the inside rear vision panel can be joined or tested according to FMVSS 221.

We are assuming this is not a "body panel joint" and is, therefore, not subject to FMVSS 221. Is this assumption correct?

10. Wire molding to rear upper inner panel. The photograph shows the longitudinal wire molding where it butts against the rear upper inner panel. This is a butt joint and, in our opinion, the wire molding constitutes a "maintenance access panel".

We are, therefore, assuming this joint is not subject to the requirements of FMVSS 221. Is this assumption correct?

11. Upper emergency door trim. The photograph shows the emergency door opening looking from the outside of the bus with the emergency door open. The purpose of the upper emergency door trim is to provide a door stop and dam against which the rear emergency door weatherstrip can seal. This is strictly a trim part which provides no structural function.

It is our opinion that the area of contact between the rear header and the upper emergency door trim does not constitute a "body panel joint" and is, therefore, not subject to the requirements of FMVSS 221. Is this correct?

12. Rear header to bow. The photograph shows the butt joint between the rear header and rear bow. The rear header goes across the full width of the bus above the rear emergency door. The lower surface of the rear header is an interior panel. We know of no way to join the rear header to the bow or test it according to the requirements of FMVSS 221. We are assuming this is not a "body panel joint" and is, therefore, not subject to FMVSS 221. Is this assumption correct?

13. Upper corner post to bow, belt bar and header. The photograph shows the left rear corner of the bus body looking from inside. The isometric sketch shows the right rear corner of the body looking from outside. The upper corner post acts as an interior panel. We know of no way to join the upper corner post to the bow, belt bar and header or to test it in accordance with FMVSS 221.

We are assuming these are not "body panel joints" and are, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

14. Lower corner post to bow, belt bar and floor panel. The photograph shows the left rear corner of the bus body looking from inside. The isometric sketch shows the right rear corner of the bus body looking from outside. We know of no way to join the lower corner post to the bow, belt bar and floor panel or to test it in accordance with FMVSS 221.

We are assuming these areas of contact do not constitute "body panel joints" and are, therefore, not subject to FMVSS 221. Is this assumption correct?

15. Tag panel to floor. As seen from the sectional sketch, the tag panel meets the floor panel at right angles. We know of no way to test this in accordance with the requirements of S6.

We are assuming this is not a "body panel joint" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

16. Rear center skirt panel to rear emergency door post support. Because of the configuration of these parts, we know of no way to test them in accordance with the procedure of S6. We are assuming this is not a "body panel joint" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

17. Bumper trim strip. As shown from the photograph, this is merely a trim strip to improve the appearance of the rear of the bus where the bumper meets the body. Because of its function and because we know of no way it can be tested in accordance with the procedure of S6, we are assuming the bumper trim strip is not subject to the requirements of FMVSS 221. Is this assumption correct?

18. Bumper trim panel. As can be seen from the photograph, the bumper trim panel serves the purpose of improving the appearance where the bumper meets the outside side panel. It can also be seen that the bumper trim panel is below the floor line and is therefore outside of the occupant space.

We are, therefore, assuming this panel is not subject to the requirements of FMVSS 221. Is this assumption correct?

19. Side and rear vision inside to outside glass opening with rubber. The photograph shows the area of contact between the inside and outside rear vision panel flanges with part of the grazing rubber removed. As can be seen from the sectional sketch, this area of contact is completely covered by the glazing rubber which holds the glass in place. We know of no way to join the inside and outside rear vision panels or test them in accordance with FMVSS 221.

We are assuming this is not a "body panel joint" and, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

20. Floor to floor. As can be seen from the sectional diagram, the testing procedure of S6 would put these fasteners in a tearing mode rather than in shear as was apparently assumed when the testing procedure was developed. The 14 gauge floor panels are covered with rubber floor covering in the finished bus.

We are assuming this is not a "body panel joint" and, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

21. Floor to auxiliary cross member. The photograph shows the bottom side of a floor panel with hat section auxiliary cross members spot welded to the floor panel.

Because these auxiliary cross members are attached to the outside of the occupant space and are below the floor line, we are assuming the area of contact between the auxiliary cross member and the floor is not a "body panel joint" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

22. Rubrail to rubrail overlap. Because rubrails are attached to the exterior skin of the bus body in our opinion they do not "enclose the bus occupant space" and, therefore, do not constitute "body panel joints".

Therefore, we are assuming rubrail overlap joints are not subject to the requirements of FMVSS 221. Is this assumption correct?

23. Side vision side panel. The area of contact between the outside side vision panel and the outside side panel is covered by the rubrail as seen from the sectional diagram.

Is this a "body panel joint" or not, and, if so, how should it be tested; with or without the rubrail in place?

24. Wheelhousing trim to side panel. As seen from the photograph and from the isometric drawing #47, the wheelhousing trim is simply an angular piece of sheet metal to trim the cut edges of the side panels around the wheel opening cutout. This trim provides no structural function and is outside the bus's occupant space.

We are assuming this is not a "body panel joint" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

25. Plywood floor to metal floor. The photograph and sectional diagram show the installation of 5/8" thick plywood which is installed over the 14 gauge steel floor panels as optional equipment for insulation purposes. This option is primarily used in cold climates. The plywood provides no structural strength to the body. It is covered with rubber floor covering on the finished bus. We know no way to join the plywood to the floor or the plywood to itself in accordance with FMVSS 221.

We are assuming the plywood to steel and plywood to plywood are not "body panel joints" and are, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

26. Bow cap to bow. As seen from the photograph and from the sectional sketch, the bow cap is merely a trim part to finish off the exterior of the structural body bow. Because of the configuration of these parts, we know of no way to test them according to the procedure of S6.

We are assuming the area of contact between the bow cap and the bow does not constitute a "body panel joint" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

27. Rubrail to side panel. As seen from the sectional sketch, the rubrail is added to the exterior skin of the bus body and does, therefore, not enclose the occupant space. We are, therefore, assuming that the area of contact between the rubrail and the outside panel does not constitute a "body panel joint" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

28. Side panel rubrail to sill. We know of no way to test the area of contact between the window sill, the outside side panel and the rubrail in accordance with the procedure of S6.

We are assuming these areas of contact do not constitute "body panel joints" and are, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

29. Side panel to side panel. By the definition we understand the area of contact between the outside side panels to be "body panel joints", but two things are unclear. (1) Is our assumption correct that the area of contact below the floor line does not enclose the occupant space and is, therefore, not a "body panel joint"? (2) When this body panel joint is tested, should it be tested with all the members attached which include the rubrail, the two outside overlapping side panels and the body bow?

30. Aluminum trim to roof panel. The aluminum trim shown in the photograph and sectional diagram is used for appearance purposes only when transit type windows are ordered. Because the aluminum trim is added to the exterior skin of the body and does not serve to enclose the occupant space, we are assuming that the area of contact between the aluminum trim and the roof panels is not a "body panel joint" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

The following items are keyed to photograph #49, Blue Bird Conventional Front Section.

31. Fresh air intake. The fresh air intake which is shown in the photograph in our opinion constitutes a "maintenance access panel" and is, therefore, not a "body panel joint". Is this assumption correct?

32. Conventional switch panel. In our opinion this switch panels constitutes a "maintenance access panel" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

33. Conventional left hand heater to bow and cowl. In our opinion the panels and trim enclosing the heater cores and ducting shown in the photograph constitute "maintenance access panels" and are, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct? photograph is covered with a rubber floor covering on a finished bus. In our opinion this panel constitutes a "maintenance access panel" to the transmission and linkage and wiring and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

35. Dash covers and lower dash trim to belt bar. The end dash cover, the center dash cover and lower dash trim provide access to defroster ducting, instrumentation and wiring. In our opinion these constitute "maintenance access panels" and are, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

36. Conventional transmission plate to floor. The transmission plate as shown in the photograph provides access to the transmission and linkage. In our opinion this constitutes a "maintenance access panel" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

37. Heater duct to floor and gusset. The photograph and sectional diagram show the heater duct which is designed for ventilation. It is, therefore, not to the requirements of FMVSS 221. Is this assumption correct?

38. Conventional right hand corner defroster and heater. In our opinion these panels are designed for ventilation purposes and provide maintenance access and, therefore, are not subject to the requirements of FMVSS 221. Is this assumption correct?

The following items are keyed to photograph #48, Blue Bird All American Front Section.

39. All American center grill access to radiator. In our opinion this panel is a "maintenance access panel" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

40. All American switch panel and stationary switch panel. In our opinion these are "maintenance access panels" and are, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

41. Plastic dash to belt bar and angled dash trim to heater panel, All American. In our opinion these panels constitute "maintenance access panels" and are, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

42. All American driver's floor board panels. In our opinion, these are "maintenance access panels" and are, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

43. All American right hand heater. In our opinion these panels provide ventilation and access to the right hand front heater and are, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

44. All American engine hood and ledge. In our opinion these components provide for maintenance access to the engine and are, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

45. All American instrument panel. In our opinion this constitutes "a maintenance access panel" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

46. All American front access panel. In our opinion this constitutes a "maintenance access panel" and is, therefore, not subject to the requirements of FMVSS 221. Is this assumption correct?

The preamble to FMVSS 221, School Bus Body Joint Strength, as it appeared in the Federal Register dated January 27, 1976 said, "It is anticipated that this rule will burden manufacturers only to the extent of requiring the installation of more rivets than are currently used. The NHTSA has reviewed the economic and environmental impact of this proposal and determined that neither will be significant." In light of this, we are assuming that the NHTSA did not intend for major structural changes. We are certain that you understand that many of the areas discussed above would constitute major structural revisions if they were judged by you to be "body panel joints" which are subject to the requirements of FMVSS 221. Obviously, there is not time for such changes between now and October 26, 1976, the effective date for this standard.

We feel that to resolve each of the questions raised above, a meeting is required between NHTSA personnel and Blue Bird personnel. We are hereby requesting that such a meeting be held on February 24, 1976.

Thank you for your consideration of these requests and your early reply.

W. G. MILBY Staff Engineer

[Attachments Omitted]

ID: 571.205--Low Speed Windshield Clarification --Burgess

October 28, 2022

Mr. Dave Burgess
Burgess Consulting
Unit 6, Benford Court
Warwick CV34 5DA
United Kingdom

Dear Mr. Burgess,

I write in response to your email to the National Highway Traffic Safety Administration (NHTSA) asking about federal requirements for windshields in low-speed vehicles (LSVs). Please note that our answer below is based on our understanding of the specific information provided in your initial and subsequent email correspondence.

Background

NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act, 49 U.S.C. Chapter 301) to issue Federal Motor Vehicle Safety Standards (FMVSS) that set performance requirements for new motor vehicles and new items of motor vehicle equipment. The Safety Act requires manufacturers to self-certify that their vehicles and equipment conform to all applicable FMVSS in effect on the date of manufacture. NHTSA also investigates safety-related defects.

Your email correspondence, dated June 17, 2022, laid out several questions relating to LSVs and FMVSS 500, including: (1) whether LSVs must be fitted with a windshield; (2) if fitted with a windshield, whether LSVs must comply with 49 Code of Federal Regulations (CFR)

§ 571.500; and (3) if a fitted windshield is required, what, if any, are the size and position requirements for the windshield?

In response, on July 25, 2022, NHTSA asked via email for further clarification on the number of wheels and maximum capable speed for the specific vehicle referenced in your correspondence. You provided written confirmation to NHTSA that the vehicle at issue has four wheels, is capable of a maximum speed of no more than 25 miles per hour, and subsequently confirmed that the vehicle has a gross vehicle weight rating (GVWR) that is less than 1,361 kilograms (3,000 pounds).

Discussion

49 CFR § 571.3 defines an LSV as a motor vehicle that: (1) is four wheeled; (2) has a speed attainable in 1.6 kilometers (1 mile)1 that is more than 32 kilometers per hour (20 miles per hour) and not more than 40 kilometers per hour (25 miles per hour) on a paved level surface; and (3) has a GVWR that is less than 1,361 kilograms (3,000 pounds). A vehicle must meet all three criteria to qualify as an LSV.

A vehicle that meets the definition of an LSV must be manufactured to conform to 49 CFR § 571.500, which, among other things, requires LSVs to be equipped with a windshield that conforms to paragraph S5.4 of FMVSS No. 205 on glazing materials. Specifically, FMVSS No. 205 applies to glazing installed in motor vehicles prior to first purchase and also to aftermarket glazing for use in motor vehicles. The standard incorporates by reference an industry standard, the “American National Standards Institute American National Standard for Safety Glazing Materials for Glazing Motor Vehicles and Motor Vehicle Equipment Operating on Land Highways-Safety Standard” (ANSI/SAE Z26.1-1996). FMVSS 205 S5.4 specifically notes that windshields of LSVs must meet the ANSI/SAE Z26.1-1996 specifications for either AS-1 or AS-4 glazing.

In summary, if a vehicle qualifies as an LSV under the definition laid out in 49 CFR § 571.3, it must meet the requirements outlined in 49 CFR § 571.500, which include a windshield that conforms to paragraph S5.4 of FMVSS No. 205. Specifically, LSV windshields must meet the ANSI/SAE Z26.1-1996 specifications for either AS-1 or AS-4 glazing. No specific federal requirements exist concerning the size or position of windshields for LSVs.

I hope this information is helpful. If you have any further questions, please feel free to contact Natasha Reed of my staff at this address or at (202) 366-2992.

Sincerely,

John Donaldson
Acting Chief Counsel

Dated: 10/28/22

Ref: FMVSS No. 205

1 See 49 CFR 571.500 S7. Test Procedure, stating that “[e]ach vehicle must meet the performance limit specified in S5(a) under the following test procedure. The maximum speed performance is determined by measuring the maximum attainable vehicle speed at any point in a distance of 1.6 km (1.0 mile) from a standing start and repeated in the opposite direction within 30 minutes.”

ID: aiam1308

Dear Mr. Stolpestad: This is in reply to your letter of October 11, 1973, concerning th 1966 Chrysler you recently purchased from Central Motors in Minneapolis.; As Miss Porter correctly pointed out in her column, the Federal law o odometer fraud enables you to bring a civil action against Central. The amount of recovery in such an action can be substantial. If the court were to accept your estimate of damages of $1490.24, the damages assessable under Federal law would be three times that amount - $4470.72. In no case would damages be less than $1500, a minimum value established by law. In addition, if you are successful, Central must pay your attorney fees as well as all court costs.; I appreciate your concern for the costs of litigation. However, b providing for the payment of attorney fees the odometer law places you in a better position than a personal injury litigant, whose recovery is usually diminished by his attorney's contingency fee. Your best course at this point is therefore to retain counsel if Central persists in its refusal to reimburse you.; By way of advice to your attorney, I would point out that the 'out that Central claims to have taken -- checking the box on the disclosure form that indicates the true mileage is unknown -- was taken too late to be of benefit to them. The Federal regulation governing disclosure requires the disclosure statement to be made 'before executing any transfer of ownership form.' If they mailed the statement the next day, their disclosure was untimely. Moreover, the representations made in the newspaper advertisment (sic) are evidentiary of their representation of 33,000 miles as being the true mileage on the vehicle. Your success in finding the previous owner is also useful in establishing that the actual mileage was greater than shown.; We will be willing to give you or your attorney further advice i questions arise concerning the intent and effect of the Federal odometer law. The enclosed copies of the law and regulations are provided to assist him in representing you.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: 04-003879-2drn

Rod Nash, P.E.
Vice President of Engineering
Collins Industries, Inc.
15 Compound Drive
Hutchinson, KS 67502-4349

Dear Mr. Nash:

This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 222, School Bus Passenger Seating and Crash Protection.You ask how the standard applies to school bus seats that are adjoining, yet have individual sized backs for each passenger" and "unique cushions for each student."You enclosed copies of product literature from Freedman Seating Company that indicates that each seat is 17 inches wide, and that two seats together are 35 inches.

You first ask about the test procedure in S5.1.3, Seat performance forward. S5.1.3 specifies that school bus passenger seats must deflect in a specified manner when force is applied through a loading bar that is centered behind the seat back. The loading bar is described in S6.5 of FMVSS No. 222. S6.5 specifies, "the length of the loading bar is 102 mm less than the width of the seat back in each test. "

You ask whether the "width of the seat back" as stated in S6.5 refers to the width of one seat back or the width of both seat backs together. Our answer is that in this situation the two seats would be considered as a single "seat" for the purposes of FMVSS No. 222. Our answer is consistent with an August 16, 2004, interpretation letter to American Suzuki Motor Corporation, on FMVSS No. 214, Side Impact Protection. In the letter to Suzuki, we noted that the term "bench seats" is not defined in FMVSS No. 214 and stated:"However, seats are commonly considered bench seats when their separate sections are side-by-side, as shown in your photographs, even when they are separately adjustable. "

Therefore, the width of the seat back used in the determination of the length of the loading bar would be the overall width of both seat backs together. The seat back width would be measured on a horizontal plane 406 mm above the seating reference point across both seat backs and the loading bar would be 102 mm shorter than this measurement.

Your second question asks about the correct method of determining the necessary projected surface area of the seat back under S5.1.2 of FMVSS No. 222. S5.1.2 states:

Seat back height and surface area. Each school bus passenger seat shall be equipped with a seat back that, in the front projected view, has a front surface area above the horizontal plane that passes through the seating reference point, and below the horizontal plane 508 mm above the seating reference point, of not less than 90 percent of the seat bench width in millimeters multiplied by 508.

Although your letter asks about "the correct place to determine seat back width," in fact the requirement for projected surface area is based on seat bench width. Thus, the required projected surface area is calculated by multiplying 508 times the seat bench width, which in this case encompasses both adjoining seats, and then multiplying by 0.9. In your example, the seat bench width is 889 mm (35 inches). The projected area is calculated excluding the V-shaped notch area in the back seat in the same manner that the area of the radius of the corners of conventional seat backs is removed (reference TP-222-03).

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:222
d.9/21/904

ID: 06-006236drn

ID: nht87-2.27

TYPE: INTERPRETATION-NHTSA

DATE: 06/29/87

FROM: JONATHAN JACKSON -- COMMERCIAL TESTING CO

TO: DOUG COLE -- NATIONAL VAN CONVERSION ASSOCIATION, INC.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A32, STANDARD 302; LETTER DATED 06/22/87 FROM ROSE M TALISMAN TO DOUG COLE; LETTER DATED 06/08/87 FROM ROSE TALISMAN TO DOUG COLE; LETTER DATED 06/23/87 FROM DOUG COLE T O STEVE KRANTZICE

TEXT: Dear Sir:

When we receive a request for the MVSS 302 test, we use the methodology printed in the Federal Register, Vol. 36, No. 5 - January 8, 1971. It is entitled Motor Vehicle Safety Standard No. 302. The test apparatus is a commercially available Horizonta l Burning Cabinet which we purchased from Custom Scientific Instruments. The burner is fueled with natural gas.

Recently, we did a test for you on a fabric. You questioned the use or non-use of wire supports on this type sample. Paragraph S5.1.3 of the Standard states that a "...specimen that softens and bends at the flaming end so as to cause erratic burning ..." may be supported with wires. The fabric that we tested for you does not fall into that category. It is supported by the tension of the U-frame and does not distort when it burns. The use of wire supports on this type material may give mis-leading results as the wires act as a heat sink.

Our further interpretation of the Standard (paragraph S5.3 (a)), is that a material which is intended for use in a size less than can be supported by the U-frame, the use of wire supports is acceptable. Further reference is made of paragraph S5.2.1 w hich states that the "...maximum available length or width of a specimen is used where either dimension is less than 14 inches or 4 inches respectively."

Our interpretation of the Standard as noted above does not allow use of wire supports on this type material unless the fabric were intended for use in maximum widths of 4 inches.

If you have any questions, please call me.

ENCLOSURE

Sincerely,

FEDERAL REGISTER VOL 36 NO 5, JANUARY 8, 1971 [OMITTED]

MOTOR VEHICLE SAFETY STANDARD NO. 302 FLAMMABILITY OF INTERIOR MATERIALS

PASSENGER CARS, MULTIPURPOSE PASSENGER VEHICLES, TRUCKS, AND BUSES

TEST METHOD

MATERIAL DEVELOPMENT & TESTING LABORATORY

FISHER BODY DIVISION

GENERAL MOTORS CORPORATION

FLAMMABILITY OF INTERIOR TRIM MATERIALS

I. GENERAL DESCRIPTION

THIS PROCEDURE IS USED TO DETERMINE THE BURNING RATES OF MATERIALS USED IN THE OCCUPANT COMPARTMENTS OF AUTOMOBILES.

II. EQUIPMENT AND/OR MATERIAL REQUIRED

A. THE TEST IS CONDUCTED IN A METAL CABINET TO PROTECT THE TEST SPECIMENS FROM DRAFTS. THE INTERIOR OF THE METAL CABINET IS 381 MM LONG, 203 MM DEEP AND 355 MM HIGH. IT HAS A GLASS OBSERVATION WINDOW IN THE FRONT AND A CLOSABLE OPENING TO PERMIT IN SERTION OF THE ALUMINUM[Illegible Word] SPECIMEN HOLDER. FOR VENTILATION, IT HAS A 13 MM CLEARANCE SPACE AROUND THE TOP OF THE CABINET, TEN 19 MM DIAMETER HOLES IN THE BASE OF THE CABINET AND LEGS TO ELEVATE THE BOTTOM OF THE CABINET BY 10 MM.

1. THE TEST SPECIMEN IS INSERTED BETWEEN TWO MATCHING U-SHAPED FRAMES OF ALUMINUM STOCK 25 MM WIDE AND 10 MM HIGH. THE INTERIOR DIMENSION OF THE U-SHAPED FRAMES ARE 51 MM WIDE BY 330 MM LONG. ALL SPECIMENS ARE KEPT HORIZONTAL WITH HEAT RESISTANT .2 5 MM CHROMEL WIRE SPANNING THE WIDTH OF THE U-SHAPED FRAME UNDER THE SPECIMEN AT 25 MM INTERVALS.

2. AN ALUMINUM STAND IS USED TO SUPPORT THE U-SHAPED FRAME WHICH LOCATES THE TEST SPECIMEN IN THE CENTER OF THE CABINET.

3. A BUNSEN BURNER WITH A TUBE OF 10 MM INSIDE DIAMETER IS USED. THE GAS ADJUSTING VALVE IS SET TO PROVIDE A FLAME WITH THE TUBE VERTICAL OF 38 MM IN HEIGHT. THE AIR INLET TO THE BURNER IS CLOSED.

NOTE: SEE FISHER DRAWING NO. EQ 199 FOR DETAILS REGARDING ALL ABOVE EQUIPMENT.

B. A CONTROLLED TEMPERATURE AND HUMIDITY CHAMBER OR EQUIVALENT.

C. CLICKER DIE 100 MM X 355 MM FOR CUTTING TEST SPECIMENS.

FLAMABILITY TEST VARIABLES THAT AFFECT THE BURN RATE WHEN PERFORMING FISHER BODY TM 32-12

1. ALWAYS CLEAN THE U-SHAPED FRAMES BEFORE STARTING EACH BURN TEST (RESIDUE OILS, CARBON, ETC., FORM ON THE U-SHAPED FRAME AFTER EACH TEST)

2. MAKE SURE THE .25 MM CHROMEL WIRES ARE PERFECTLY STRAIGHT (HORIZONTAL). SAGGING WIRES WOULD ALLOW CERTAIN TEST SPECIMENS TO SAG.

3. MAKE SURE THE DOOR ALWAYS FITS FLUSH TO THE TEST CABINET. (FROM TIME TO TIME, HEAT CAUSES THE DOOR NOT TO FIT SMUGLY CAUSING OR ALLOWING A DRAFT).

4. ALWAYS EXCHANGE THE AIR INSIDE THE TEST CABINET WITH FRESH AIR. (AFTER EACH TEST SMOKE WILL STAY INSIDE THE CABINET UNLESS BLOWN OUT). FISHER BODY USES AN AIR JET TO EXCHANGE AIR.

5. KEEP THE FLAMMABILITY TEST CABINET AS NEAR ROOM TEMPERATURE AS POSSIBLE BEFORE STARTING EACH TEST. (SPARE CABINET LIDS, SPARE U-SHAPED FRAMES COMPRESSED AIR ARE USEFUL OPTIONAL ITEMS).

6. LEAD FLAME (FLAME THAT FLASHES FORWARD OF THE MAIN BURNING AREA) USUALLY OCCURS ON VINYL COATED FABRICS AND MUST BE OBSERVED VERY CAREFULLY BY THE OPERATOR.

7. CORRELATION DIFFICULTY - IF PERFORMING DUPLICATE TESTS, ALWAYS CUT SPECIMENS IN THE SAME AREA CONSIDERING THICKNESS, WIDTH, RIBS IF PLASTIC PARTS, ETC.

8. FLAT BLACK INTERIOR CABINET FINISH - A SHINY INTERIOR TENDS TO RADIATE (REFLECT) HEAT INSIDE THE CABINET; ALSO, CAUSES A CLEANING PROBLEM AFTER EACH TEST.

9. VENTILATION HOLES - KEEP OPEN. BURNING MATERIALS AND BLOWN MATERIALS WILL COVER THESE HOLES AND WILL PREVENT AIR CIRCULATION WITHIN THE CABINET.

10. SPECIMEN IDENTIFICATION - BE CAREFUL WHEN MARKING SPECIMENS FOR IDENTIFICATION SINCE ENAMELS, INKS, ETC, COULD AFFECT YOUR TEST RESULTS.

THE SPECIMEN IS PRODUCED BY CUTTING THE MATERIAL IN THE DIRECTION THAT PROVIDED THE MOST ADVERSE TEST RESULTS. THE SPECIMEN IS ORIENTED SO THAT THE SURFACE CLOSEST TO THE OCCUPANT COMPARTMENT AIR SPACE FACES DOWNWARD ON THE FRAME.

MATERIAL WITH A NAPPED OR TUFTED SURFACE IS PLACED ON A FLAT SURFACE AND COMBED TWICE AGAINST THE NAP WITH A COMB HAVING SEVEN TO EIGHT SMOOTH ROUNDED TEETH PER 25 MM.

PRIOR TO TESTING, EACH SPECIMEN IS CONDITIONED FOR 24 HOURS AT A TEMPERATURE OF 21 DEGREES C + 1.5 DEGREES C AND A RELATIVE HUMIDITY OF -0.0

50% + 0.0. TO FACILITATE HANDLING, SEVERAL PIECES MAY BE TAKEN - 5%

FROM THE HUMIDITY CHAMBER AND PLACED IN A POLYETHYLENE BAG TO RETAIN MOISTURE UNTIL THEY ARE TO BE BURNED.

V. TEST PROCEDURE

A. MOUNT THE SPECIMEN SO THAT BOTH SIDES AND ONE END ARE HELD BY THE U-SHAPED FRAME AND ONE END IS EVEN WITH THE OPEN END OF THE FRAME. WHERE THE MAXIMUM AVAILABLE WIDTH OF A SPECIMEN CANNOT BE HELD IN THE U-SHAPED FRAME, PLACE THE SPECIMEN IN POSIT ION ON WIRE SUPPORTS AS DESCRIBED IN 11A.1., WITH ONE END HELD BY THE CLOSED END OF THE U-SHAPED FRAME. SPECIMENS SHORTER THAN 355 MM MAY BE POSITIONED ON THE WIRE SUPPORTS AND ALIGNED WITH THE OPEN END OF THE FRAME FOR IGNITION PURPOSES.

B. PLACE THE MOUNTED SPECIMEN IN A HORIZONTAL POSITION IN THE CENTER OF THE CABINET.

C. WITH THE FLAME ADJUSTED ACCORDING TO II A.3, POSITION THE BUNSEN BURNER AND SPECIMEN SO THAT THE CENTER OF THE BURNER TIP IS 19 MM BELOW THE CENTER OF THE BOTTOM EDGE OF THE OPEN END OF THE SPECIMEN.

D. EXPOSE THE SPECIMEN TO THE FLAME FOR 15 SECONDS.

E. BEGIN TIMING (WITHOUT REFERENCE TO THE PERIOD OF APPLICATION OF THE BURNER FLAME) WHEN THE FLAME FROM THE BURNING SPECIMEN REACHES A POINT 38 MM FROM THE OPEN END OF THE SPECIMEN.

F. MEASURE THE TIME THAT IT TAKES THE FLAME TO PROGRESS TO A POINT 38 MM FROM THE CLAMPED END OF THE SPECIMEN. IF THE FLAME DOES NOT REACH THE SPECIFIED END POINT, TIME ITS PROGRESS TO THE POINT WHERE FLAMING STOPS.