Interpretation ID: aiam0138
Chief Engineer
Trico-Folberth Ltd.
Great West Road
Brentford
Middlesex
England;
Dear Mr. Hadekel:#Thank you for your letter of January 1, 1969 concerning your windshield washer system.#Apparently our letter of October 3, 1968, to Mr. B. C. Johnson was misunderstood. In Mr. Johnson's inquiry of August 23, 1968, he stated 'it is easy to deliver 15 cc's of fluid inside the three seconds specified.' The wording of our reply acknowledged that this performance would be acceptable--it was not intended to be a literal interpretation of our requirements or the SAE Recommended Practice.#We learned that the SAE Windshield Wiping Subcommittee plans to revise J942, Passenger Car Windshield Washer Systems, to clarify the particular points you question. Meanwhile, we think the intent of Section S4.2 of Standard No. 104 is satisfied by the following interpretation of the referenced SAE Recommended Practice:#>>>1. Paragraph 3.1 of J942 requires that 75% of the effective wiped area be cleared in 10 wiper cycles or less. Section S4.2.1 of Standard No. 104 requires that these areas be established in accordance with subparagraph S4.1.2.1 of Standard No. 104.#2. The requirement to wipe 75% clear must also be met within 15 seconds as stipulated in paragraph 4.1.3(c) of J942.#3. A washer cycle is defined in paragraph 2.11 of J942 as 'The system actuation sufficient to deliver approximately 15 cc of fluid to the windshield glazing surface.' Note this definition does not actually define the number of actuations necessary to deliver the 15 cc, although the use of the word 'actuation' *appears* to be singular. It is obvious that the intent of paragraph 4.1.3(c) is that this amount of fluid shall be delivered during the 15 second test period.#4. In paragraph 4.4.2(b) of J942 (under the durability test) the Recommended Practice requires: 'For manual systems a single actuation shall consist of actuation of the control for a period not to exceed 3 seconds.' It is important to note that this specifies the time required for the driver to operate the control--not the total time for the washer system to actuate. It appears this definition refers to a *control actuation*, whereas, the definition for 'washer cycle' refers to a *system actuation*. This is borne out in paragraph 2.2 of J942 which defines 'control' as 'A means for actuating the arresting the windshield washer system. The actuation may be coordinated or semi-coordinated with components of the windshield wiper or may be fully independent.'#5. Note that the following sentence in paragraph 4.4.2(b) states: 'For automatic systems an actuation shall consist of one actuation of the control.' This seems to indicate, by inference, that more than one control actuation is acceptable for manual systems.#6. Therefore, the intent of the referenced SAE Recommended Practice by Section S4.2 of Standard No. 104 is that manual washer systems may be actuated more than once to provide the 15 cc of fluid as long as it does not require the operator more than 3 seconds to operate the control for any single system actuation--and the washer system must deliver 15 cc of fluid to clear 75% of the wiped area within 10 cycles and within 15 seconds.#7. Note that any additional system actuations needed to meet the 15 cc requirement will also require that the manufacturer increase accordingly the total number of control actuations for the durability test in Table I, 'Test Sequence' in J942.<<<#We assume that your windshield washing system meets these requirements based upon your explanation of your manual system. However, we wish to point out our concern that the existing regulations do not adequately define washer system performance requirements, since it is possible under the current regulations for the driver to be needlessly occupied with the washer controls during a period of reduced visibility. Accordingly, we expect to up-grade the washer system performance requirements as soon as practicable.#Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance, Motor Vehicle Safety Performance Service;