Interpretation ID: nht87-2.11

TYPE: INTERPRETATION-NHTSA

DATE: 06/15/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Farrel L. Krall -- Manager, Technical Legislation, Navistar International

TITLE: FMVSS INTERPRETATION

ATTACHMT: 6/15/72 letter from R.L. Carter to Frank and Frank (Std. 113)

TEXT:

Mr. Farrel L. Krall Manager, Technical Legislation Navistar International 2911 Meyer Road P.O. Box 1109 Fort Wayne, IN 46801

This responds to your letter asking about Federal Motor Vehicle Safety Standard No. 113, Hood Latch Systems. You asked whether a design for a front-opening hood you are considering for production would comply with section 54.2 of the standard. According to your letter, the front-opening hood would be a service access feature integrated into the overall design of a rear opening hood system. The latch system would consist of two separate latches, one on each size at the front corner of the access hood. A s discussed below, a front-opening hood with two secondary latch systems would meet the requirements of section S4.2.

By way of background information, the National Highway Traffic Safety Administration ((NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of th e manufacturer to ensure that its vehicles or equipment comply with applicable standard;. The following represents our opinion based on the facts provided in your letter.

Section 54.2 states:

A front opening hood which, in any open position, partially or completely obstructs a driver's forward view through the windshield must be provided with a second latch position on the hood latch system or with a second hood latch system.

You cited an interpretation letter issued in 1972, which stated that while the agency favors a system in which two complete operations are necessary, a system which employs two latches having a single operation will meet the requirements of the standard. You stated that since your design incorporates two separate latches and requires two complete operations to latch the hood, you believe the system meets both the intent and the legal requirements of the standard.

As discussed in the preamble to the final rule, section 54.2 permits the following types of installation; a single latch system with two positions, two separate primary latch systems, or separate primarily and secondary latches. 33 FR 6470-71, April 27, 1968 ( copy enclosed). Thus, designs for front-opening hoods with two separate latch systems were specifically contemplated by the agency in establishing section 54.2 and would comply with that requirement.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

Ms. Erika Z. Jones Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

March 6, 1987

Dear Ms. Jones:

Navistar International Corporation is considering the design and production of a new front opening hood and requests your interpretation as to compliance of the hood latching mechanism with FMVSS-113, Hood Latch Systems. As shown in the attached photogra phs, the front-opening hood in question is a service access feature integrated into the overall design of a rear opening hood system.

Section 4.2 of FMVSS-113 states, "A front opening hood, which in any open position, partially or completely obstructs a driver's forward view through the windshield, must be provided with a second latch position on the hood latch system or with a second hood latch system."

The latch system design for our new front opening hood consists of two separate latches, one on each side at the front corner of the access hood, see example of the latch in the enclosed pictures.

We have researched the interpretation file on Standard 113 and find only one letter from the Agency that seems to be relative, copy enclosed. This letter dated June 15, 1972, concerns a Chevrolet hood latch system wherein the Agency stated that "While... we favor a system in which two complete operations are necessary, a system which employs two latches having a single operation will meet the requirements of the standard."

Our design incorporates two separate latches and requires two complete operations to latch the hood. We therefore believe this system meets both the intent and legal requirements of Standard 113 and would appreciate receiving your formal concurrence. Sin ce this is a priority design issue, we would appreciate an expeditious reply. Please call me if additional information is needed.

Very truly yours,

Farrel L. Krall Manager, Technical Legislation 219/461-1008