Interpretation ID: nht88-2.42
TYPE: INTERPRETATION-NHTSA
DATE: 06/02/88
FROM: STEVEN CROWELL
TO: ELIZABETH DENNISTON -- DIR. OF COMMUNICATIONS; EGON BITTNER COMMISSIONER-WALTHAM, MA.
TITLE: NONE
ATTACHMT: ATTACHED TO LETTER DATED 05/31/90 FROM STEPHEN P. WOOD -- NHTSA TO WILLIAM D. FALCON; REDBOOK A35; STANDARD 201; 202; 205; VSA 108[A][2][A]; LETTER DATED 01/30/89 FROM WILLIAM D. FALCON TO RALPH HITCHCOCK -- NHTSA; OCC 3107; LETTER FROM STEVE C ROWELL; DATED 11/02/88 EST
TEXT: Commission on Accredidation for Law Enforcement Agencies Inc. 4242b Chain Bridge Rd. Fairfax, Va 22030
Dear Ms. Denniston, Mr. Bittner and Mr. Medeiros;
The automobile interior partitions used in all cruisers I have observed seem to lack some legal requirements.
The Motor Vehicle Safety A 49 CFR Ch.V (10/1/86 Edition) ** Sect. 567.7 Requirements For Persons Who Alter Certified Vehicles- A person who alters a vehicle that previously has been certified in accordance with sect 567.4 or 567.5 . . . . shall allow the original certification label to remain on the vehicle , and shall affix to the vehicle an additional label . . . . containing the following information: "This vehicle was altered by (individual or corporate name) in (month and year in which alterations were completed) and as altered it conforms to all appli cable Federal Motor Vehicle Safety Standards affected by the alteration and in effect in (month, year). ** Sect. 571.107 Standard No. 107; Reflecting Surfaces. This standard specifies reflecting surface requirements for certain vehicle components in the driver's field of view. ** Sect 571.111 Standard 111; Rearview mirrors. This standard specifies requirements for the performance and location of rearview mirrors . . . to reduce the number of deaths and injuries that occur when the driver does not have a clear and reasonabl y unobstructed view to the rear. ** Sect. 571.201 Standard No. 201; Occupant protection in interior impact. This standard specifies requirements to afford impact protection for occupants. s3.2 Seat backs-when that area of the seat back that is within the head impact area (head impact area means all nonglazed surfaces of the interior of a vehicle that are statically contactable by a 6.5-inch dimeter spherical head form of a measuring device having a pivot point to "top of head" dimension infinitely adjustable from 29 to 33 inches in accordance with the following proceedure etc.). ** Sect 571.205 Standard No. 205; This standard specifies requirements for glazing materials for use in motor vehicles and motor vehicle equipment. The purpose of this standard is to reduce the injuries resulting from impact to glazing surfaces, to e nsure a necessary degree of transparency in motor vehicle windows for driver visibility, and to minimize the possibility of occupants being thrown through the vehicle windows in collisions. S5.1.1.3 the following locations are added to the lists specifi ed in ANS Z26 in which item 6 and item 7 safety glazing may be used: (k.1.1.2 Interior partitions). Your prompt response to my letter of 1/4/88 is greatly appreciated, however I have noticed a slight oversight in Standard 71.4.1 Transport Equipment. Specifically the mention of wire mesh in this recommendation for the use of a "Safety Barrier". To i dentify an interior partiton (the words used by the D.O.T. for this device) as a "safety barrier" is an oxymoron given the safety hazards inherent in the designs currently being used. Statistics on bodily injury losses occuring in cruisers seem difficult to obtain, but not so for cabs. The graphs enclosed indicate that when and where interior partitions are used in taxis there is enhanced retention of control for the operation of the vehicle accompanied by epidemic increase in accident fatality and bodily injury loss. It seems that the only way to incur more accident fatality in fewer accidents and more injury with less property damage is to introduce occupant impact hazards. It is my belief that enhancement in the design of interior partitions will still afford the safety of enhanced operator retention of control and additionally reduce the likelyhood of injury to occupants (front or rear compartments) in the event of a s udden stop or collision. The economic impact of these hazards in the taxi industry in Boston has been astronomical. Prior to the use of interior partitions in Boston taxis (from 1950-1970) the cost of insurance for taxis was only twice that of the cost for private vehicles i n Boston (given that