Interpretation ID: nht80-1.33

DATE: 03/18/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mercedes-Benz

COPYEE: JEROME N. SONOSKY

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter forwarded to us by Mr. Jerry Sonosky, requesting an interpretation of the term "overall width" as used in Safety Standard No. 104, Windshield Wiping and Washing Systems. You ask questions: (1) whether overall width means the design width of a vehicle, or whether it means the maximum possible width allowed by design tolerances, and (2) whether overall width includes plastic, splash molding attached to the vehicle body with screws and nuts.

In answer to your first question, overall width means the maximum design width of the vehicle including tolerances.

Safety Standard No. 104 defines "overall width" as the maximum overall body width dimension "W116," as defined in section E, Ground Vehicle Practice, SAE Aero-space-Automotive Drawing Standards, September 1963. The "W116" standard specifies that overall width is measured across the body, excluding hardware and applied moldings, but including fenders when integral with the body. Therefore, the overall width of a vehicle would not include splash molding on the sides of the vehicle.

SINCERELY,

HOGAN & HARTSON

February 14, 1980

Hugh Oates Office of the General Counsel National Highway Traffic Safety Administration

Dear Hugh:

Enclosed is a request for interpretation of Standard 104 which our client, Mercedes-Benz of North America, Inc. asked us to forward directly to you.

Best wishes.

Jerome N. Sonosky

ENC.

CC: PROF. DR. W. REIDELBACH; CRAIG JONES

MERCEDES-BENZ OF NORTH AMERICA, INC.

November 16, 1979

National Highway Traffic Safety Administration

Attn: Office of Chief Counsel

Subject: Motor Vehicle Safety Standard No. 104 - Windshield Wiping and Washing Systems; Request for Interpretation

Dear Madam or Sir:

Your interpretation is requested on the definition "Overall width" as used in Motor Vehicle Safety Standard No. 104 - Windshield Wiping and Washing Systems. Section S 3. of that standard defines "Overall width" as being the maximum overall body width dimension "W116", as defined in section E, Ground Vehicle Practice, SAE Aerospace-Automotive Drawing Standards, September 1963. This second standard contains the statement that "Overall width" is measured across body, excluding hardware and applied moldings, but including fenders when integral with body.

Your interpretation of this definition is requested as follows:

1. Does overall width mean the design width of a vehicle, or does it mean the maximum (or minimum) possible width allowed by design tolerances?

2. Does overall width include plastic, splash molding attached to the vehicle body with screws and nuts. You will note in the attached drawing that this splash trim (cross-hatched) is the widest portion of the vehicle. However it is only an applied molding as shown both in the cross-section view as well as the vehicle photograph.

Should you require additional information on this request do not hesitate to contact Mr. G. M. Hespeler of our Safety Engineering Department - 201-573 2616.

HEINZ W. GERTH

(Graphics omitted)

(Graphics omitted)

(Graphics omitted)