Interpretation ID: aiam4329
Manager
Technical Legislation
Navistar International
2911 Meyer Road
P. O. Box 1109
Fort Wayne
IN 46801;
Dear Mr. Krall: This responds to your letter asking about Federal Motor Vehicle Safet Standard No. 113, *Hood Latch Systems.* You asked whether a design for a front-opening hood you are considering for production would comply with section S4.2 of the standard. According to your letter, the front-opening hood would be a service access feature integrated into the overall design of a rear opening hood system. The latch system would consist of two separate latches, on each side at the front corner of the access hood. As discussed below, a front-opening hood with two separate latch systems would meet the requirements of section S4.2.; By way of background information, the National Highway Traffic Safet Administration (NHTSA) 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 manufacturer to ensure that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.; Section S4.2 states: >>>A front opening hood which, in any open position, partially o completely obstructs a driver's forward view through the windshield must be provided with a second latch position on the hood latch system or with a second hood latch system.<<<; You cited an interpretation letter issued in 1972, which stated tha while the agency favors a system in which two completed operations are necessary, a system which employs two latches having a single operation will meet the requirements of the standard. You stated that since your design incorporates two separate latches and requires two complete operations to latch the hood, you believe the system meets both the intent and the legal requirements of the standard.; As discussed in the preamble to the final rule, section S4.2 permit the following types of installations: a single latch system with two positions, two separate primary latch systems, or separate primary and secondary latches. 33 FR 6470-71, April 27, 1968 (copy enclosed). Thus, designs for front-opening hoods with two separate latch systems were specifically contemplated by the agency in establishing section S4.2 and would comply with that requirement.; Sincerely, Erika Z. Jones, Chief Counsel