Interpretation ID: 1983-1.16

TYPE: INTERPRETATION-NHTSA

DATE: 02/08/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Talbott Engineers Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of January 11, 1983, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 104, Windshield Wiping and Washing Systems. The specific question you asked was:

Does S4.1.2 require that multi-purpose passenger cars, trucks, and buses meet the effective wiped area requirements, or does S4.1.2 only apply to passenger cars?

The requirements of section S4.1.2 only apply to passenger cars. Standard No. 104's section S2, Application, provides that the standard applies to passenger cars, multipurpose passenger vehicles, trucks, and buses. The requirements of certain sections of the standard, however, only apply to some of those vehicle types. Section S4.1.2, Wiped Area, provides:

When tested wet in accordance with SAE Recommended Practice J903a, May 1966, each passenger car windshield wiping system shall wipe the percentage of Areas A, B, and C of the windshield. . . . [Emphasis added]

The above language limits the applicability of that specific requirement to passenger cars, and the section does not have any other requirements applicable to other vehicle types.

We would note that your letter used the term "multi-purpose passenger car" rather than multipurpose passenger vehicle, the term used in the standard. We assume that your use of the former term was a typographical error, and we note it only to avoid any possible misunderstanding.

We have enclosed a copy of the most recent revision of Standard No. 104, as you requested.

ENC.

TALBOTT ENGINEERS INC.

January 11, 1983

Legal Counsel NHTSA U.S. Dept. of Transportation FMVSS 104

Dear Sirs:

I would like the legal interpretation of FMVSS 104, S4.1.2, Wiped Area.

Specifically, my question is

"Does S4.1.2 require that multi-purpose passenger cars, trucks, and buses meet the effective wiped area requirements, or does S4.1.2 only apply to passenger cars."

In addition, could you please send the latest revision of FMVSS 104.

I am working in behalf of a concerned client with a large commercial fleet. Expediting your response will be appreciated.

Terry D. Day, P.E.