Interpretation ID: nht87-2.40

TYPE: INTERPRETATION-NHTSA

DATE: 07/09/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Thomas Baloga

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Thomas Baloga Safety Engineering Mercedes-Benz of North America, Inc. P.O. Box 350 Montvale, NJ 07645

Dear Mr. Baloga:

Thank you for your letter of May 28, 1987, to Stephen Oesch of my staff concerning the requirements of Standard No. 301 Fuel System Integrity. You noted that there is a conflict in the standard about the correct ground clearance of the contoured impact s urface used in the school bus impact test of the standard. You noted that S7.5.1 of the standard refers to the dimension between the ground to the lower edge of the impact surface as 5.25 + 0.5 inches, while Figure 2 of the standard shows dimension is 5. 25 + 0.5 inches.

The agency adopted the use of the contoured barrier in a final rule issued on April 16, 1975. The preamble to the final rule stated that "The contoured barrier would incorporate the moving barrier specifications of SAE Recommended Practice J972a (March 1 973). However, the impact surface of the barrier would be at a height 30 inches above provision. Studies have shown that a 30-inch test height is more representative of actual collisions. This would be a typical engine height of vehicles that might impac t a schoolbus." Thus, in S75.1 of the standard, the agency adopted the ground clearance as 5.25 inches + 0.5 inches to ensure that the top of the barrier would be 30 inches from the ground. In Figure 2, the agency apparently incorporated the barrier dime nsions directly from the SAE Recommended Practice J972a, without changing the ground clearance dimension.

We will publish an amendment to the standard that will correct the ground clearance dimension set out in Figure 2 of Standard No. 301.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

May 28, 1987

Mr. Steve Oesch Legal Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Subject: FMVSS 301 "Fuel System Integrity" Printing Error

Dear Mr. Oesch:

Mr. Bob Williams, Office of Rulemaking, has verbally confirmed that a printing error exists in Figure 2 of the subject standard. Specifically, Dimension D in Figure 2 should be 5.25 (inches) instead of 12.25. The correct 5.25 inch dimension is stated in the text within paragraph S7.5.1. Would you be so kind and confirm this printing error in writing; perhaps it can be incorporated into our other request concerning a printing error in FMVSS-208.

Thank you very much for accommodating our requests.

Sincerely,

Thomas Baloga Safety Engineering (201) 573-2622

TCB/Wdo-M/A18