Interpretation ID: nht92-9.42

DATE: January 22, 1992

FROM: Gordon W. Didier -- Butzel Long

TO: Office of the General Counsel, NHTSA

TITLE: Re: Federal Motor Vehicle Safety Standard No. 118

ATTACHMT: Attached to letter dated 2/14/92 from Paul Jackson Rice to Gordon W. Didier (A39; Std. 118)

TEXT:

We are counsel for a United States manufacturer of automobile sunroofs. Included among our client's production are sunroofs incorporating power operated roof panels which are affected by the amendments to Standard No. 118 to become effective September 1, 1992. Our client is proceeding with development and production of an automobile sunroof product which will comply with the requirements of Standard No. 118 under both Sections S4 and S5 of the Standard, as described below.

The power operated roof panel system of this sunroof incorporates a feature which can be set to automatically close the roof panel when the ignition key is turned to the "off" position. In addition, the sunroof will incorporate a feature which provides for an express close of the roof panel system while the ignition key is in the "on," "start" or "accessory" position upon the one-time activation of actuation control within the interior of the vehicle. During operation of either of these closing methods, the roof panel system will reverse direction when it meets a resistive force of 22 pounds or more as specified in Section S5 of amended Standard No. 118.

In addition to the automatic close and express close features described above, this same sunroof will also incorporate an override feature which provides for closing of the roof panel system upon continuous activation of an actuation control within the interior of the vehicle while the ignition key is in the "on," "start" or "accessory" position. When this feature is in operation and the actuation control is continuously activated, the roof panel system will not reverse direction when it meets a resistive force of 22 pounds or more since the control on the interior of the vehicle will be continuously activated as provided under Section S4 of amended Standard No. 118.

Many owners of sunroof equipped vehicles rely on opening the roof panel systems for ventilation during the winter months. It is important that they be able to close the roof panels as necessary for safety, comfort and security despite any accumulation of ice or snow. This override feature is essential in order to ensure that the roof panel system will be able to be closed after being opened under winter weather conditions when the tracks of the sunroof may become covered with ice or snow. However, the closing force necessary to overcome a resistive force of 22 pounds or more will only be available upon continuous activation of the actuation control within the vehicle while the ignition is in the "on," "start" or "accessory" position.

We have reviewed these design features with technical personnel in the Agency's Office of Crash Avoidance and understand that they believe these features will comply fully with the requirements of amended Standard No. 118. However, we will also appreciate receiving written confirmation from the Agency that these features will be in compliance with the new amendments to Standard No. 118.

Please call me if you have any questions or if I can provide any further information, and I will look forward to your earliest response.