Interpretation ID: aiam4284
Chief Co-ordinator
Technical Administration Department
Daihatsu Motor Co.
Ltd.
1.Daihatsu- cho
Ikeda City
Osaka Prefecture
JAPAN;
Dear Mr. Tsujishita: Thank you for your letter requesting an interpretation of th requirements of three of our safety standards. This letter responds to your questions concerning Standard No. 219, *Windshield Zone Intrusion*. I regret the delay in this response. We will be responding to each of your questions concerning the other two standards in separate letters.; Your questions about Standard No. 219 concerns the requirements of S of the standard. That section provides as follows:; >>>When the vehicle traveling longitudinally forward at any speed up t and including 30 mph impacts a fixed collision barrier that is perpendicular to the line of travel of the vehicle, under the conditions of S7, no part of the vehicle outside the occupant compartment, *except windshield molding and other components designed to be normally in contact with the windshield*, shall penetrate the protected zone template, affixed according to S6, to a depth of more than one-quarter inch, and no such part of a vehicle shall penetrate the inner surface of the portion of the windshield, within the DLO, below the protected zone defined in S6. (Emphasis added.)<<<; Your specific question concerns a situation in which a windshield wipe penetrates the protected zone template during a crash test because, for example, the wiper was pushed rearward by the deformation of the cowl or the wiper switch was contacted by the test dummy during the crash, thus turning on the wiper. You noted the wiper blades are normally in contact with the windshield, but that the wiper arms only contact the windshield through the wiper blades. You asked whether the agency would consider the penetration of the wiper blade and arm into the protected zone template to be a violation of the standard. As discussed below, the answer is no, the penetration of the wiper blade and arm would not be a violation of the standard.; As you observed in your letter, the wiper blade is designed to b normally in contact with the windshield and is thus exempt from the requirements of the standard. While the arm will not be in direct contact with the windshield, the blade attached to the arm does contact the windshield. Also, the wiper arm is a small, light structure which, while not in direct contact with the windshield, is mounted only a fraction of an inch above the surface of the windshield and should pose little or no penetration hazard. Thus, the agency will consider the wiper arm, which is an integral part of the exempted wiper blade, to be exempted as well.; I you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel