Interpretation ID: nht80-3.21

DATE: 07/21/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mercedes-Benz

TITLE: FMVSS INTERPRETATION

TEXT:

Dear Mr. Gerth:

This responds to your recent letter requesting an inter pretation concerning the term "overall width" as used in Safety Standard No. 104, Windshield Wiping and Washing Systems (49 CFR 571.104). You asked whether passenger car door handles would be included in the measurement of a vehicle's overall width.

Safety Standard No. 104 defines "overall width" as the maximum overall body width dimension "W116," as defined in section E, Ground Vehicle Practice, SAE Aerospace-Automotive Drawing Standards, September 1963. The "W116" standard specifies that overall width is measured across the body, excluding hardware and applied moldings, but including fenders when integral with the body. We would consider passenger car door handles to be vehicle "hardware." Therefore, door handles would not be included in the measurement of overall vehicle width.

Sincerely,

Frank Berndt Chief Counsel

June 5, 1980

Attn: Office of Chief Counsel

Subject: Motor Vehicle Safety Standard No. 104 - Windshield Wiping and Washing Systems, Request for Interpretation

Dear Madame or Sir:

Your interpretation i s requested on the definition of "overall width" as used in Motor Vehicle Safety Standard No. 104 -Windshield Wiping and Washing Systems. Section S3 of that Standard defines "overall width" as being the maximum overall body width dimension "W116" as defined in Section E, Ground Vehicle Practice, SAE Aerospace-Automotive Drawing Standards, September 1963. This second Standard contains the statement that "overall width" is measured across body, excluding hardware and applied mouldings, but including fenders when integral width body.

Your interpretation of this definition is requested as to whether or not the term "hardware" would include passenger vehicle door handles. This would exclude door handles from the measurement of the overall width of a vehicle.

Should you require additional infomation on this request, do not hesitate in contacting Mr. G. M. Hespeler of our Safety Engineering Department, (201) 573-2616. As a point of infomation, your response dated March 18, 1980, to a previous request for interpretation regarding body trim mouldings is also attached for your review.

Very truly yours,

HG:Web