Interpretation ID: 1984-2.9
TYPE: INTERPRETATION-NHTSA
DATE: 06/13/84
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: Volkswagen of America Inc.
TITLE: FMVSS INTERPRETATION
TEXT:
Mr. Dietmar K. Haenchen Executive Engineer Vehicle Regulations Volkswagen of America, Inc. P.O. Box 3951 Troy, Michigan 48007-3951
Dear Mr. Haenchen:
This is in reply to your letter of April 25, 1984, asking two questions with respect to the humidity test for replaceable bulb headlamps specified in Motor Vehicle Safety Standard No. 108.
With reference to paragraph S6.8, you mention the relative humidity figure of 90 +/- 10%, and your interpretation that the six-hour cycle of the test should be run at 90% and that the 10% tolerance "is intended to cover any drift in the instrumentation, controls and the process of generating the humidity." We concur that this is a reasonable interpretation of this requirement.
You have also asked when the headlamp must be inspected after the humidity test, as paragraph S4.1.1.36(d)(7) is silent on this point. It is your interpretation that this inspection must occur directly following the test, and before the photometrics of the lamp are measured, even though, in your view, it would be more convenient to check it after the photometric test. Your interpretation is correct; this inspection must occur within the 9 to 11 minutes specified for beginning the photometric test after completion of the humidity test.
Sincerely,
Frank Berndt Chief Counsel
25 April, 1984
Office of the Chief Counsel National Highway Traffic Safety Administration Nassif Building 400 Seventh St., S.W. Washington, D.C. 20590
Re: Request for Interpretation -- FMVSS 108
Dear Sir:
With the Federal Register publication of June 2, 1983, environmental tests are now specified for replaceable bulb headlamps. We have two interpretations regarding the humidity test for these lamps for with we ask your concurrence.
1. Humidity Specification -- The humidity test, S6.8, requires that the lamp be subjected to 20 consecutive six-hour cycles at a relative humidity of 90 +/- 10% and then soaked for 1 hour in lower temperature and humidity. It is Volkswagen's interpretation that the six-hour cycle portion of the humidity test should be run at 90% and that the tolerance of +/- 10% is intended to cover any drift in the instrumentation, controls and the process of generating the humidity.
2. Inspection - Sections 4.1.1.36(d)(7) requires that after the humidity test in accordance with S6.8, that "the inside of the headlamp show no evidence of delamination or moisture, fogging or condensation", and the lamp must meet the photometric requirements. The section does not, however, specify exactly when the inspection is to take place.
It is Volkswagen's interpretation that the regulations require the inspection to take place immediately after the completion of the final one hour portion (30% relative humidity) of the humidity cycle and before the photometric measurements. This is not very practical (because of the 10 +/- 1 minute limitation on beginning the photometric tests), and inspection after the photometric measurement would be much more convenient, however we have reached this conclusion based upon our reading of the regulatory language.
Your prompt response to this request will be appreciated.
Very truly yours,
VOLKSWAGEN OF AMERICA, INC.
Dietmar K. Haenchen Executive Engineer Vehicle Regulations
JPS/bLc
TYPE: INTERPRETATION-NHTSA
DATE: 06/18/84
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: John C. Bobak -- President, Crest Industries, Inc.
TITLE: FMVSS INTERPRETATION
TEXT:
John G. Bobak President Crest Industries, Inc. 3841 13th Street Wyandotte, MI 48192
This responds to your letter of May 9, 1984, regarding the application of Federal motor vehicle safety standard No. 212, Windshield retention and standard No. 216, Roof crush resistance to aftermarket windshield adhesives. Your specific question concerned a statement made by Kent Industries that its urethane windshield adhesive "meets and exceeds" those two standards.
You are correct in your understanding that Standards Nos. 212 and 216 only apply to newly manufactured motor vehicles. The standard establish a certain level of performance for those vehicles and do not set specifications for such individual vehicle components as windshield adhesive. In addition, neither of these standards apply to item of motor vehicle equipment, such as windshield adhesive, sold as aftermarket products.
If you have any further questions please let me know.
Sincerely Original Signed By Frank Berndt Chief Counsel LETTER FROM JOHN G. BOBAK IS NOT LEGIBLE.