Interpretation ID: 1983-3.28
TYPE: INTERPRETATION-NHTSA
DATE: 11/28/83
FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA
TO: Porsche Aktiengesellschaft
TITLE: FMVSS INTERPRETATION
TEXT:
NOV 28, 1983
DR. ING.h.c. F. Porsche AG z. H. Herrn Mayer/ESV Postfach 11 40 7251 Weissach West Germany
Dear Mr. Mayer:
This is in response to your 1etter of October 13, 1983, to Nelson 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 activated 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 operation of power windows by children remaining in a vehicle. See 48 Fed. Reg. 46793. Paragraph 3(d) was drafted to be consistent with this goal, since it is highly probable 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 under 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
Enclosure
Mr. Nelson Erickson Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh St., S.W.
Washington,D.C. 20590
USA
ESVG-My-re Weissach,October 13,1983
Subject: Request of Clarification of the term "opening" - FMVSS 118
Dear Mr. Erickson,
We kindly ask for clarification of the above mentioned term.
Your early favorable consideration of our request would be greatly appreciated as we presently can not continue to design any further on this matter until we receive an answer from you.
Sincerely yours,
Dr. Ing.h.c.F. Porsche AG -Technical Administration-
Dr.Ing. h.c.F.porsche AG z.H. Herrn Mayer/ESV Postfach 11 40 7251 Weissach WEST GERMANY
Mayer Enclosure
Request of Clarification of the term "opening" in relation with FMVSS 118, Power-Operated Window System
With publication of Docket No. 82-07; Notice 2 (Federal Register Vol. 48, No. 88, Page 20237 of May 5, 1983) Standard 118 was amended to the extent that the use of the power window or partition systems are admissible, pursuant to S 3 (d), which states that: "during the interval between the time a running engine is turned off and the opening of either of a two door vehicle's door or, in the case of a vehicle with more than two doors, the opening of either of "its front doors".
Porsche welcomes this amendment and would like to use this as a future opportunity to improve comfort and still maintain the present safety level.
In design, the interior roof lamp door switch is normally used to signal to the power source of the window regulators if the door is in an "opened" or in a "closed" position.
We now ran into the following problem which we believe to be a basic problem for all the automakers:
In practice it is not common to adjust the door switch or to locate the switch on the carbody in order to function if the door is opened just for a crack, forexample a fraction on an inch.
The building tolerances of the carbody in the area of the door-post are the result of a series of individual tolerances of various parts, including the door switch and is for this reason usually not to small.
Normally this switch actuates when the door is opened between 8" to 10" - the distance between the carbody and the rear end of the door. Even a slim adult will not be able to get out of the car through an opening like this. In our opinion it is admissible and for design necessary to pinpoint the extent of the opening in order to define the difference between the terms "opened" and "closed" in relation to a car door.
Your early favorable consideration of our request would be greatly appreciated since we have stopped designing until we receive an answer from you.
Sincerely yours,
Dr. Ing.h.c. F. Porsche AG -Technical Administration-