Interpretation ID: aiam0656
U.S. Resident Engineer for CITROEN S.A.
U.S. Technical Research Corporation
801 Second Avenue
New York
NY 10017;
Dear Mr. Belier:#The questions asked by your letter of March 10, 1072 have been compared with the applicable paragraphs of the Federal Motor Vehicle Safety Standard (FMVSS) No. 104 and the Society of Automotive Engineers Recommended Practice J942.#1.>>>The purpose of paragraphs 2.11 and 4.4.2b of J942 is to allow the testing of both manual and automatic systems using the same procedure. The wording of 4.4.2b attempts to equalize the usual cleaning cycle of each type of system. It is apparent that the manual system allowed for by 4.4.2b is one in which a single actuation, if held long enough, would put 15 cc of fluid through the nozzle. The system you described is not of this type, nor is it an automatic system. You must therefore comply with the intent of the test, which would be to operate your system for 8,000 washer cycles, as stated in paragraph 3.4. Each washer cycle is that which puts approximately 15 cc of fluid through the nozzle. Since your system is not the manual system implied in the standard, the three-second rule would not apply. Time limitation would be dictated by the 'No./min' column of Table 1 of J942, i.e., two washer cycles per minute.#Therefore, the pump and control switch you described, along with the other parts of the system, if they meet all other prescribed parameters, would comply with Federal Motor Vehicle Safety Standard No. 104.<<<#2.>>>An automatic pump cycling device would not be limited by the three-second rule. It would be required to meet the 'No./min' column of Table 1 of J942, i.e., two washer cycles per minute.<<<#3.>>>Paragraph 3.1 does not specify the duration of water spray, number of water sprays, or start time of wiper action. No standard wiper blade, windshield, or mechanism is specified. These are the items which, in conjunction with the washer, must produce an effective wipe/wash system.#The National Highway Traffic Safety Administration is concerned that the entire system provide good washing and wiping, and is not concerned with compliance of individual components.<<<#4.>>>'Repeatedly,' as used in paragraphs 4.2.2a and b, means the repeated application of the control device (push button, usually) which is designed to cause the water to squirt out of the nozzles. Practically, this reproduces a driver's attempts to activate the system on a cold day, not knowing if it is frozen or plugged. Upon warming up, the system must not have been damaged, and must still function after removal of the ice or plug. Without this safeguard, many systems would be rendered inoperative on the first cold day by an impatient driver.<<<#5.>>>To our knowledge, there is no reservoir size stated by Federal or State regulations.<<<#Please ask for further information, if needed.#Sincerely, E. T. Driver, Director, Office of Operating Systems, Motor Vehicle Programs;