Interpretation ID: nht75-3.7

DATE: 11/18/75

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 15, 1975, in which you request an interpretation of paragraph S7.1.3 of Standard No. 301, as to whether it is permissible to stop an electric fuel pump prior to the rollover test.

Paragraph S7.1.3 provides that "If the vehicle has an electrically driven fuel pump that normally runs when the vehicle's electrical system is activated, it is operating at the time of a barrier crash." The static rollover test specified by S6.4 is not a barrier crash, and therefore is not covered by S7.1.3. In the amendments to Standard No. 301 published on October 15, 1975 (40 FR 48352), the addition of the phrase "In meeting the requirements of S6.1 through S6.3" to S7.1.3 clarifies the intent of the agency not to require that an electric fuel pump be operating at the time of the rollover test, because the rollover test is required by paragraph S6.4. Therefore, you may turn off the pump if it is still working at the time of the static rollover test.

SINCERELY,

October 15, 1975

Frank Berndt Office of Chief Council National Highway Traffic Safety Administration

I would like to ask your interpretation of the following phrase which is found in MVSS 301, S.7.1.3 :

"at the time of the barrier crash"

My understanding is that this phrase means that we should turn on the electric system which activates the electric fuel pump before the barrier crash test and leave it on through the subsequent roll over test.

The breakage of the battery and the wiring disconnection, due to the crash, may or may not stop the electric fuel pump, but if it is still working, we should not turn off the switch.

Is my understanding on the above mentioned phrase correct, or may we turn off the pump if it is still working during the roll over test?

Your interpretation on the above will be greatly appreciated.

There may have been a discussion on this matter before. It would be a great help if you could send us the documents on the resolution of that discussion.

Thank you.

NISSAN MOTOR CO., LTD.

Naoyoshi Suzuki

Staff, Safety