Interpretation ID: nht68-3.6

DATE: 06/07/68

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA

TO: Toyota Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 25, 1968, concerning Federal Motor Vehicle Safety Standards Numbers 111, 291, and 206. I hope these interpretations will answer your questions:

Standard No. 111:

Question 1. Your interpretation is not entirely correct. Your Figure 1 shows only six directions the 90-pound force can be applied; whereas, the force may be applied from any intervening location from within the solid wedge in the 180 degrees forward are inserted within the six lines you show in your Figure 1. S3.1.2.2 requires that the mirror is to be subjected to this test force. This may be applied to the center of the mirror or to any other location on the mirror surface.

Question 2. The test force may be applied as shown in your Figures 2(a), (b), and (c) but not as shown in Figure 3. As stated above, the test force must be applied to the mirror itself, not to the mirror support.

Question 3. As stated above, the 90-pound force may be applied as shown in your Figure 2(c) since it would not be possible, in this case, to obtain the maximum 45 degrees angle due to design of the mirror system.

Standard No. 201:

Since S3.4.2(b) of Standard No. 201 does not specifically state the thickness of energy-absorbing material required to cover the folding armrest, the armrest shown in your sketch on page 5 appears to be permissible. It does seem advisable, however, in future designs to either provide a greater thickness of energy-absorbing material or increases the potential area of contact with the underlying steel support by providing a wider flange and turning the edge inward.

Standard No. 206:

The inertia lond requirements of S3.3.3 refer to S3.3 - Door Latches only, and do not include the lock. Door lock requirements are specified separately in S3.1. Therefore, the door latch system requirements must be met without a lock engaged.

April 25, 1968

Dr. William Haddon, Jr., Director

National Highway Safety Bureau

We have questions on interpretation of Standards No. 111, No. 201, and No.

206.

Your kind cooperation would be very much appreciated if you answer the following questions.

Standard No. 111 S3.1.2.2

Question 1.

S3.1.2.2 specifies that " when the mirror is subjected to a force of 90 pounds in a forward or sideward direction in any plane 45 degrees above or below the horizontal". We interpret that direction of a force which should be applied to the mirror means any one of the six directions shown in Fig. 1, and that the force should be applied to a universal joint of the mirror or to a center of the mirror. Is this interpretation right?

Question 2.

As actual procedures of applying a force we use methods shown in Fig. 2 and 3, whether we use Fig. 2 method or Fig. 3 method depends on vehicle models. We think Fig. 2 method simulates actual application of a force better than Fig. 3 method, although direction of a force applied to the mirror by a head form will be different from 45 degrees (less than 45 degrees) when a head form approaches the mirror in Fig. 2 (a). If we use Fig. 3 method, we can always apply 45 degree force. Are those Fig. 2 and 3 methods permissible?

Question 3.

In applying a force using a head form, in some cases, it is impossible to apply 45 degree force due to shape of the mirror and mirror support. In this case, is it permissible to apply a force of as big as possible but less than 45 degree direction as shown in Fig. 2 (c)?

Standard No. 201 S3.4.2 (b)

We need clarification of "covered with energy absorbing material." In Fig. 5 and 6 we show a structure of folding armrest of Toyota Crown model. In Fig. 4, if force F is applied to the armrest as shown, fixtures of the armrest as shown A is comparatively easily deformed. However, a portion encircled in Fig. 5 BB crossection has only 5 mm thick cover of urethane foam rubber. Is this structure permissible?

Standard No. 206 S3.5.3

Is it permissible to lock the door latch system before we apply an inertia force of 30g to the door latch system?

Thank-you,

Toyotaro Yamada Manager

Fig. 1 (Graphics omitted)

Fig 2(a) Downward applied Force (Graphics omitted) Fig 2(b) Upward applied Force (Graphics omitted)

Fig 2(c) Downward applied Force. (Graphics omitted)

Fig 3 (Graphics omitted)

Fig 5 Armrest Installation (Graphics omitted)

Fig 6 Armrest Structure (Graphics omitted)

crossection CC. (Graphics omitted)

crossection AA (Graphics omitted)

crossection BB (Graphics omitted)