Interpretation ID: aiam4887
MA 01854;
"Dear Mr. Chuang: This responds to your letter seeking clarification o recent amendments to Standard No. 118, Power-operated Window Systems (49 CFR 571.118), as published in the Federal Register on April 16, 1991. Specifically, you were interested in new requirements applicable to remote control operations of power windows. You first asked for confirmation of your interpretation of the new requirement in S5(a) that, while closing, remote control-operated power windows automatically reverse direction 'when they meet a resistive force of 22 pounds or more.' You also asked for an interpretation of the term 'daylight opening' as it appears in S5(b) of Standard No. 118. This agency has received several petitions for reconsideration of the recent amendments to Standard No. 118 with respect to the automatic reversal requirements. In response to the petitions, NHTSA is currently reexamining several aspects of this requirement, including those raised in your letter. The agency will publish its response to the petitions for reconsideration in the Federal Register after it has finished its reexamination of the automatic reversal requirement in the April 16 final rule. Please let us know if you have any questions about this new automatic reversal requirement after our response to the petitions for reconsideration has been published and you have had the opportunity to review it. I hope this information is helpful to you. Please contact us if you have further questions. Sincerely, Paul Jackson Rice Chief Counsel";