Interpretation ID: 1984-1.49

TYPE: INTERPRETATION-NHTSA

DATE: 05/09/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: MMC Services

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter inquiring about the test specifications of Safety Standards 203 and 204 and the New Car Assessment Program. You specifically asked about the positioning of a tilting steering wheel for each of those tests. The answers to your questions are as follows.

Standard No. 203 incorporates by reference Society of Automotive Engineers Recommended Practice J944, December 1965. SAE J944 provides that a steering wheel is to be mounted at the angle specified by the manufacturer's "package drawing." Therefore, a tilting steering wheel would be placed at the nominal design position set by the manufacturer.

Standard No. 204 does not specify the positioning of a tilt wheel. In Standard No. 204 compliance testing, our Office of Vehicle Safety Compliance positions adjustable steering columns and wheels at the midpoint of the tilt and telescope adjustments. In the case of your particular tilting steering wheel, there is no midpoint. Thus, we would test the vehicle with the steering wheel in the position which is closest to the geometric center of the steering column. Based on the sketch enclosed in your letter, it appears that tilt positions 2 and 3 of your wheel are at an equal distance from the geometric center of the steering column. Therefore, your tilt tilt steering wheel should be capable of complying when tested in either of those positions.

The New Car Assessment Program does not use the Standard No. 208 test procedures, but instead uses its own set of test procedures. Those procedures specify that an adjustable steering wheel is to be positioned at the midpoint of its tilt adjustment. Since there is no midpoint for your wheel, the wheel would be set at the position closest to the gometric center of the steering column. As discussed above, the agency would use either position 2 or 3 for your tilt wheel.

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

SINCERELY,

MMC SERVICES INC.

February 10, 1984

Frank Berndt Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation

Subject: Test Conditions of FMVSS 203, 204 and NCAP Dear Sir:

This is to inquire about the test specifications of FMVSS 203, 204 and NCAP (New Car Assessment Program) regarding tilt steering.

1. Our interpretations are as follows:

(1) FMVSS 203 (SAE J944)

The height of the steering wheel shall be adjusted to the manufacturer's design reference point.

(2) FMVSS 204

No description of the adjusting method for the tilt steering.

(3) NCAP

The NCAP's test is conducted according to FMVSS 208; S8.1.4 which states "Adjustable steering controls are adjusted so that the steering wheel hub is at the geometric center of the locus it describes when it is moved through its full range of driving positions.

2. Tilt Steering Mechanism

Our tilt steering for the future model is only adjusted at four (4) positions by the gear, and therefore, the steering wheel hub is not set at the geometric center of the locus as required in FMVSS 208. (See the figure on the following page)

(Graphics omitted)

3. Questions

(1) Are our interpretations as mentioned above correct? If not, please let us know of your interpretations.

(2) When performing the 35 mph frontal collision test, at which gear position do we set the steering wheel hub?

(3) At which gear position shall we set the steering wheel hub for the following respective tests?

(a) FMVSS 203

(b) FMVSS 204

Masakatsu Kano Executive Vice President

MMC SERVICES, INC.