Interpretation ID: nht71-2.2

DATE: 02/05/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Century Products, Inc.

COPYEE: C. DIETRICH -- BOLT BERANEK AND NEWMAN; D. SCHRUM -- ELECTRICAL TESTING LABS.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 28, 1971, requesting an interpretation of Motor Vehicle Safety Standard No. 213. Although your letter-refers to S4.11(d) as the paragraph with which you are concerned, it appears from the test of your letter that you are requesting an interpretation of paragraph S5.1(d).

S5.1 of the standard specifies the test procedure that will be used by NHTSA to determine whether the child(Illegible Word) system meets the force resistance requirements specified in S4.1 of the standard. S5.1(d), the passage in question, rends as follows:

"Apply an increasing load to the torso block in a forward direction, not more than 15 degrees and not less than 5 degrees above the horizontal., until a loud of 1,000 pounds is achieved. The intersection of the lead application line and the back surface of the torso block, at the time that the force removes the slack from the lead application system, shall not be more than 8 inched or less than 6 inches above the bottom surface of the torso block. Maintain the 1,000-pound load for 10 seconds."

Your question is whether the angle at which the force is applied, even though initially between 5 degrees and 15 degrees above the horizontal, may above outside that range during application of the specified force.

The answer to your question is no. The relevant wording of the standard, that the force is to be applied in a forward direction "not more than 15 degrees and not less than 5 degrees above the horizontal, until a load of 1.000 pounds is achieved," clearfly requires that the direction of the test force remain within the specified angular limits throughout the period of force application.

Please write if you have further questions.