ID: nht72-3.4

DATE: 02/16/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Alabama Tire Dealers and Retreaders Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your three letters, dated December 1, 1971, December 27, 1971, and January 11, 1972, concerning Motor Vehicle Safety Standard No. 117.

In your letter of December 1, 1971, you enclose a booklet that you have recently made available which contains your interpretation of Standard No. 117, and ask us to review it. As your letter was written before the amendment of December 23, 1971 (36 F.R. 24814), and the suit in Chicago, it does not, and our reply will not, deal with the changes made by that amendment or the "stay" ordered by the Court of Appeals. We believe your summary of the standard is correct, but we would recommend that you include in the requirements of paragraph S5.1.1 of Standard No. 117 the treadwear indicator requirements found in S4.2.1(d) of Standard No. 109. This fact is apparently being overlooked by some retreaders, and you may wish to point it out more clearly.

Your letter of December 27 asks whether exposure of cord that has occurred on casings because of "chipping" would prevent the casing from being retreaded under S5.2.1. As presently written, S5.2.1 would preclude the retreading of such a casing if what is exposed is ply cord. However, if it is actually "chafer" fabric, which is a special fabric placed only around the bead, then exposure is permitted.

Finally, with regard to your letter of January 11, I regret that, as you have been told, Mike will not be able to attend the Missalaga Conference. He has told me that your organization has done a very responsible job with regard to not only Standard No. 117 but other areas of tire safety as well, and we appreciate your efforts.

ID: nht72-3.40

DATE: 08/04/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: General Motors Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of July 11, 1972, raises two substantive questions concerning the belt system requirements of Motor Vehicle Safety Standard No. 208.

The first question concerns S7.4.1, which provides that the engine starting system shall not be operable "unless the belt system at each occupied front position is operated after the occupant is seated". You ask whether a system that you submitted for our inspection, which does not use electronic logic circuits, would conform to this requirement.

The belt system in question is designed to make it quite difficult to enter the vehicle if the belt system is fastened. The occupant is thus forced to unfasten the belt (if it has been left fastened) to enter the vehicle, then to fasten it in order to start the engine. The system employs an inboard-mounted shoulder belt with the outboard attachment point for the lap and shoulder belts mounted in the door. The ignition system employs a buckle switch, so that the belt must be buckled for the engine to start. Upon entering the vehicle, an occupant may find that the belt is either buckled or unbuckled, depending on the action of the previous occupant, but if it is buckled, he will find entry difficult if he does not first unbuckle it. After evaluating the system, we have concluded that the occupant is essentially compelled to operate the belt system after being seated in order to start the car. The system therefore conforms to the requirements of S7.4.1.

In view of the lack of logic circuits, we urge that the design of the buckle be given careful attention, to prevent defeat of the system by the insertion of objects into the buckle.

Your second question concerns the acceptability of belts which require "some action during normal vehicle entry or egress" under the requirements for passive belts. As presently drafted, S4.5.3 does not permit such belts to be classified as passive belts. We will treat your request for amendment of this requirement as a petition for rulemaking and give it prompt consideration.

ID: nht72-3.41

DATE: 02/24/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Lempco Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 18, 1972, on the subject of an automobile dealer's obligations regarding seatbelts in new cars.

Motor Vehicle Safety Standard No. 208 requires seatbelts to be installed at all seating positions. Under the requirements of the National Motor Vehicle and Traffic Safety Act, which we administer, it is a violation of the law to sell a vehicle that does not conform to an applicable standard. A dealer may not, therefore, sell an automobile that does not have the required number of seatbelts.

Although the act does not prevent the purchaser of a vehicle from removing the belts, after he has completed the purchase, we strongly advise him to leave the belts in and to wear them. A dealer who removes the belts after he has sold the vehicle does not violate the law, but he does his customer a disservice.

ID: nht72-3.42

DATE: 11/13/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 14, 1972, on the subject of the test dummy specifications of Standard No. 208. I apologize for our delay in replying.

The alignment procedures of S8.1.11 of the standard cause the head to be aligned so that its vertical axis is almost in the same plane as the dummy's back. The necks on most commercial dummies are made of rubber and are installed at such an angle that, as you have noted, the specified head alignment cannot be maintained. To correct this misalignment, the necks must be adjusted by shims or other means so that the correct alignment can be maintained.

The center of gravity of the upper thorax is approximated by dimensions C and D in Table I and Figure 1 of SAE Recommended Practice J963. The precise location may vary slightly from one dummy model to another due to variances in the distribution of mass in the thoracic area.

ID: nht72-3.43

DATE: 08/02/72

FROM: JAMES E. HOFFERBERTH FOR ROBERT L. CARTER--NHTSA

TO: Peugeot-Renault

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your teletype of July 8, 1972, regarding the question of a manikin's neck. In response to your specific need, and for your general information, I am enclosing a procurement specification for a 50th percentile test dummy recently let out for bid by the National Highway Traffic Safety Administration. This specification represents our present thinking on some of the desirable aspects of a test dummy. We are also working on the development of a proposed regulation that will define the dummy more precisely than standard No. 208 presently does, and, of course, that regulation may differ from the procurement specification.

In the meantime, as we have stated in the Federal Registar, any dummy that meets the requirements of Standard No. 208 may be used by a manufacturer to test its vehicles.

SINCERELY,

DEPARTMENT OF TRANSPORTATION

U.S. COAST GUARD TELECOMMUNICATIONS CENTER

NO 9499 Nov. 7, 1972 10#05

M. BUREAU PEGLEMFNTATION

A. M. ROBERT L CAPTER ASSOCIATE ASMINISTPATOR NHTSA

FOLLOWING PRESSING QUESTIONS ASKED TO MR TOMS AND YOU AT SAE CONFERENCE OF DETROIT IN MAY CONCERNING FMVSS 208 WE HAVE A VERY POSITIVE FIRST ANSWER IN DOCKET 69-7 NOTICE 19

HOWEVER, WE ARE STILL UNABLE TO COMPLETE OUR CONFIRMATION TESTS ON RESTRAINT SYSTEMS FOR 73 MODELS SINCE WE ARE NOT AWARE OF THE EQUIPMENT TO BE PROPOSED FOR DYNAMIC RESPONSE OF MANIKINS' NECK

CAN YOU ALREADY GIVE US SOME MORE DETAILS ON THESE SPECIFICATIONS SINCE OUR HOMOLOGATION SERVICES CANNOT GO ON WITH THEIR WORK

BEST THANKS

N. BUREAU CHIEF REGULATIONS DEPARTMENT AUTOMOBILES PEUGEOT

ID: nht72-3.44

DATE: 05/12/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Kangol Magnet Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your telegram of April 4, 1972, in which you asked whether it is permissible for the engine starting system of a vehicle conforming to the interlock requirements of Motor Vehicle Standard No. 208 to be operable when there are no occupants in the front seats by reaching through an open door or window to turn the ignition key.

Our reply is that the standard does not prohibit a system that operates in this way. Such a system is therefore permissible.

ID: nht72-3.45

DATE: 08/23/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Fairchild Semiconductor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 26, 1972, on the subject of the situations in which S7.4.3 of Motor Vehicle Safety Standard No. 208 permits operation of the engine starting system, notwithstanding the ignition interlock requirements of S7.4.1 of the standard.

Your first question is whether the engine may be restarted if the ignition switch is turned off after the driver has left the seat. Our reply is that restart would not be permitted except within a period of three minutes after the switch has been turned off. There is no sequential relationship between the operation of the switch and the driver's leaving the seat, so that the starting system will have to become inoperable if the driver has left the seat and has turned the ignition off, regardless of whether he turned the switch before or after leaving the seat.

Your second question is whether the engine may be restarted if the ignition switch is turned off, then on, and then the driver leaves his seat. Our reply is again that restart would not be permitted. S7.4.3 refers to operation "if the ignition has not been turned off". Once the ignition has been turned off, turning it on again will not revive the restart mode unless the engine is actually started again and then stopped with the ignition "on".

We have forwarded your check for a Federal Register subscription to the Superintendent of Documents. Enclosed you will find a copy of Notice 20, as you requested.

ID: nht72-3.46

DATE: 03/17/72

FROM: J.E. LEYSATH FOR E.T. DRIVER -- NHTSA

TO: U.M. Electrical Distributers Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 6, 1972, concerning warning buzzers for the automobile industry.

The National Highway Traffic Safety Administration has issued two safety standards which specify warning requirments. These requirements are given in Paragraph S4.4 of Standard 114 and Paragraph S7.3.1 of Standard 208. A copy of these two standards are enclosed for your review and further information.

You will note that these standards do not stipulate minimum requirements for the warning devices, and, at the present time, we have no plans to specify such requirements. The data sheet, however, which you enclosed will be useful to us should we specify such requirements in future amendments to these standards.

We appreciate your writing to us, and if we can be of any further service, please let us know.

ID: nht72-3.47

DATE: 10/13/72

FROM: CHARLES H. HARTMAN FOR DOUGLAS W. TOMS -- NHTSA

TO: Mr. Jesse R. Hollins

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your petition of August 15, 1972, as supplemented by your brother's letter of August 28, 1972, requesting our consideration of your seat belt warning system as a substitute for the warning and interlock systems currently specified in Motor Vehicle Safety Standard No. 208.

As we understand the operation of your system, one of its operating modes resembles the mode presently specified in S7.3.1 of the standard. Your system provides for the operation of a warning signal when the ignition is "on" and the seat belts at occupied front positions have not been operated. Section S7.3.1, considered by itself, would permit such a system, even though that section does not require the warning to operate unless the engine is operating and the vehicle is in a forward gear.

However, your system does not meet the requirement of S7.3.3 that the warning not operate when the vehicle is idling with the transmission in park or neutral position and the belts have not been operated. The argument presented in your brother's letter is that the sudden operation of the warning system when the transmission is placed in a forward gear would be an annoyance to occupants and would result in circumvention of the system.

The NHTSA position is that the convenience of being able to sit unbuckled in a parked car without the warning is such that this "quiet" period should continue to be required. It may be that some occupants will be bothered when the warning begins to sound as they place the car in gear. However, we are persuaded that the current system would be less likely to be circumvented than a system that has no period of non-operation.

The other operating mode of your system has no direct counterpart in Standard 208. As you describe it, returning the ignition to the "off" position will activate the warning system, even after removal of the key, until the belts are returned to their stowed positions. Our letter of August 17, 1972, explained that this will not conform to the requirement of S7.3.2 that the warning must not operate when the belts at occupied front positions have been operated.

We recognize that there are other possible alternative to the required interlock system as a means of encouraging seat belt usage, and several have been suggested. We consider it important, however, that these systems work in a substantially uniform manner, for maximum public safety, acceptance and convenience. On the basis of all the material we have received to date, including yours, we have decided that our present requirements represent the best combination for the alternative to passive restraints in the period 1973-1975. I therefore must deny your petition to substitute your system, or allow it as an alternative, for the interlock system.

ID: nht72-3.48

DATE: 10/18/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. Charles E. West

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of September 18, 1972, to Senator Warren G. Magnuson, Chairman, Committee on (Illegible Words) your automatic seat belt system has been referred to this office for reply.

Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, (copy enclosed) requires complete passive restraint systems in cars manufactured after August 15, 1973. This standard, as well as most of our standards, is written in performance terms and does not require the use of any specific device. Manufacturers are free to employ any system that will meet the requirements of the standard without any voluntary section on the part of the occupant, such as fastening a seat belt.

The National Highway Traffic Safety Administration is not generally engaged in hardware development, but rather, directs its research efforts toward the development of technical data to form the basis for motor vehicle safety performance standards. Perhaps you might care to contact vehicle manufacturers to see if they would be interested in your automatic belt system.

I am placing a copy of your letter in our Public Docket No. 69-7, which contains information relative to occupant restraint systems. We appreciated receiving the description of your system and your interest in motor vehicle safety.