Interpretation ID: aiam3772
z. H. Herrn Mayer/ESV
Postfach 11 40
7251 Weissach
West Germany;
Dear Mr. Mayer: This is in response to your letter of October 13, 983, to Nelso Erickson of this agency, requesting our interpretation of certain requirements in Federal Motor Vehicle Safety Standard (FMVSS) No. 118, *Power-Operated Window Systems*.; A recent amendment to section 3(d) of FMVSS 118 (48 Fed. Reg. 46793 October 14, 1983, copy enclosed) permits power window operation during the 'interval between the time the locking device which controls the activation of the vehicle's engine is turned off and the opening of either of a two-door vehicle's doors or, in the case of a vehicle with more than two doors, the opening of either of its front doors.' As you point out in your recent letter, the opening of the vehicle's front doors would typically be sensed through the interior roof lamp electrical circuit. This circuit would be activaetd when the door is opened 8 to 10 inches from the frame. You ask whether it is permissible under the standard to have power windows remain operable until the door is opened to this point where the roof lamp is activated.; FMVSS 118 is primarily intended to prevent the unsupervised operatio of power windows by children remining in a vehicle. See 48 Fed. Reg. 46793. Paragraph 3(d) was drafted to be consistent with this goal, since it is highly probably that the driver would still be in the vehicle during the specified time interval. Your proposed interpretation is also consistent with the standard's goal, since the driver would not likely be able to leave the vehicle with the door only ajar.; Therefore, we agree that power systems may remain operable unde paragraph 3(d) of FMVSS 118 until the door is opened far enough to permit a small adult to leave the vehicle. The 8 to 10 inch point where the roof lamp is activated appears to be within this permissible range.; Sincerely, Frank Berndt, Chief Counsel