Interpretation ID: nht91-3.25

DATE: April 19, 1991

FROM: Andreas Geis -- Robert Bosch GMBH, Automotive Division

TO: U.S. Department of Transportation, NHTSA

TITLE: Re FMVSS 104, Windshield Wiping and Washing Systems, Effective: January 1, 1969. Loading State for developing (VISION) AREAS A,B,C.

ATTACHMT: Attached to letter dated 6-18-91 from Paul Jackson Rice to Andreas Geis (A38; Std. 104); Also attached to letter dated 10-2-90 from Paul Jackson Rice to S. Kadoya

TEXT:

being a manufacturer of windshield wiper systems we are often required to develope the (Vision) Areas A,B,C as defined in FMVSS 104 S4.1.2.1 in conjunction with SAE Recommended Practice J903a, May 1966.

We know from developing other vision areas and it has been recognized by the SAE (see SAE J903c, Nov 1973, para. 3.1.1) that the loading state of the vehicle is not without influence on the position and size of the Vision Areas. Unfortunately neither FMVSS 104 nor the older SAE J903a, which FMVSS 104 refers to, make any mention of the loading state.

May we kindly ask you to inform us how this problem is normally handled? Is there perhaps a newer edition of FMVSS 104 or a preamble or a comment on this subject? Or is it left to the discretion of the manufacturer on which loading state he bases the development of the Vision Areas?

We would greatly appreciate your early reply.