Interpretation ID: 1984-3.24
TYPE: INTERPRETATION-NHTSA
DATE: 09/13/84
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: Hino Motors Ltd.
TITLE: FMVSS INTERPRETATION
TEXT: This responds to your recent letter concerning your meeting with Mr. Oesch and Ms. Hom of my staff. As you requested, this letter confirms and clarifies the answers to the questions you asked in your meeting concerning Safety Standard No. 301, Fuel System Integrity.
The answers to all of your questions are based on our understanding that Hino Motors would be furnishing a bare chassis to a final-stage manufacturer who adds a school bus body to complete the vehicle. The answers to your questions are as follows:
1) If Hino Motors is producing an incomplete vehicle, as that term is defined in Part 568.3, then Part 568, Vehicles manufactured in two or more stages, sets forth the requirements Hino must meet. Part 568.4 sets forth the specific information you must provide in an incomplete vehicle document. Part 568 does not require you to certify the incomplete vehicle as complying with the requirements of Standard No. 301. It does require you to make one of the statements set forth in Part 568.4(a)(7).
2) Part 568.4(b) requires each incomplete vehicle manufacturer to provide an incomplete vehicle document. The document must either be attached to the incomplete vehicle or sent directly to a final-stage manufacturer, intermediate manufacturer or purchaser for purposes other than resale to whom the incomplete vehicle is delivered.
3) Part 568.6 requires each final-stage manufacturer to complete the vehicle in such a manner so that it conforms to all applicable standards and to attach the certification label required by Section 567.5 of Part 567, Certification.
4) As an incomplete vehicle manufacturer, Hino Motors need only comply with Part 568. I note that Part 568.7 permits an incomplete vehicle manufacturer to assume voluntarily all of the duties and liabilities imposed by the National Traffic and Motor Vehicle Safety Act on the final-stage manufacturer. If Hino were to assume those duties, then Hino would have to affix the label required by Part 567.5(e).
5) The crash test in Standard No. 301 sets forth the procedures the agency will use in conducting its compliance tests. A manufacturer is not required to conduct crash tests, but may instead rely on such things as engineering analyses or computer modelling to determine if a vehicle complies with a standard.
6) As discussed above, Standard No. 301 sets forth the test procedure the agency will use in its testing. Section 6.5 of the standard provides that the moving barrier test for school buses may be conducted at "any point and angle" on the schoolbus. If a manufacturer is going to do crash testing, the type of testing it uses is left up to the manufacturer. The agency urges manufacturers using crash testing to conduct a test (angle and location of impact) which represents the most difficult test for the vehicle. The maximum speed in the agency's crash test for schoolbuses is 30 mph.
7) At present, there are no pending notices proposing to modify the requirements of Standard No. 301.
B) 1. and 2. The Office of Chief Counsel issues all of the agency's interpretations of the safety standards. Copies of all of our interpretations can be obtained from the Docket Section, Room 5109, 400 7th Street, S.W., Washington, D.C. 20590. Copies of the agency's compliance test reports can be obtained from our Technical Reference Division, Room 5108 at the same address.
Your final questions concern the requirements of S7.1.6(c) of Standard No. 301. You are correct that the test is to be performed on a completed vehicle. If Hino wishes to do crash testing of its chassis, it can be done in the bodyless condition. Since the chassis has no seats, we would suggest you attach the test weight of 120 pounds per designated seating position directly to the chassis.
Mr. Oesch and Ms. Hom have asked me to thank you for sending them a copy of the photograph you took.
Sincerely,
HINO HINO MOTORS, LTD.
Our ref. TUSA-90809
National Highway Traffic Safety Administration Department of Transportation
Attention: Stephen Oesch
Thank you for your kind attentions to us during our recent visit to your place. Many thanks to your sincere reply to our questions concerning FMVSS.
We would like to confirm the content of your reply and make additive questions.
I. Confirmation of the content of your reply on that day.
1. FMVSS No. 301: Concerning Fuel System Integrity
1) In case we supply school bus chassis and the body manufacturer makes the body and completes the vehicle, we must certify this FMVSS in chassis condition (without body).
2) Moreover, we should issue to the Body mfr. "Incomplete Vehicle Document" attached to the vehicle.
3) After this Body mfr. should certify it as a completed vehicle.
4) All we have to do on this regulation is sufficient with this and nothing more is necessary.
5) The requirement of this regulation is to meet the items and value of the regulation, and the actual crash test itself isn't indispensable condition. That is to say, either by calculation or by test, we only have to certify that our vehicle meets the requirements of this regulation.
6) Test condition of Crash Test Concerning crashing speed, point, angle and etc, the manufacturer shall establish the condition judged with basis as the most strict. That is all depends on the idea of Hino. By the way, it is proper to consider that crash speed is the Max. speed; 30 MPH.
7) There is no movement of revision on this regulation for the present.
B. General Item
1) Concerning "Interpretation" and "Test Results", it is possible to read and copy (including request of copy in written form) them. By the way, "Interpretation" and "Test Results" are kept in Room 5109 and Room 5108 respectively.
2) Mr. Berndt: Chief Counsel (Tel 202-426-9511) is the proper person to inquire about FMVSS in written form from now on.
II. Additional questions
1. Judging from S7.1.6.(c) about FMVSS No. 301 S7 Test Condition, this test is supposed to be performed by completed vehicle. Please advise us about the Test Condition when we perform the test by chassis condition. For example,
Is test vehicle in bodyless chassis condition as Hino shipment?
In case the vehicle is bodyless, how will the weight loading condition as the establishment of weight condition 120 lb in design seat position of S7.1.6.(c)?
We will appreciate your early reply.
Please say hello to Ms. Deirdre F. Hom And enclosed please find your photographs taken during our stay in your office as a good memory.
Thanking you again for your kind attentions.
Takabumi Akaboshi Deputy Manager Technical Department Technical Division Overseas Operations