Interpretation ID: nht92-9.43

DATE: January 22, 1992

FROM: Cliff Chuang -- President, Prospects Corporation

TO: Dorothy Nakama -- Legal Counsel, Chief Counsel Office, NHTSA

TITLE: Re: Request of An Interpretation

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

TEXT:

We have reviewed the FMVSS 118 rule published on April 16, 1991. It gives car manufacturers and automotive suppliers with substantial design flexibility to improve the vehicle power window and sunroof operation.

Prospects Corporation has developed a window/roof system (AEM: Automobile Environment Management) that provides many useful new features to help consumers to solve several of their automotive problems. One of the features is that the system can close all windows in a parked vehicle when unexpected rain occurs to avoid water damage.

Prospects is currently marketing this system to automobile manufacturers. The initial reception in the OEM market is very positive. However, a few OEM customers have asked a question regarding the AEM system complying with the FMVSS 118 rule. Their concern is that there is no "automatic" word in the section S5 (a) of the FMVSS 118 rule. In order for them to feel comfortable using the AEM system, a written interpretation from your office is necessary to clarify the AEM rain sensing close with pressureless anti-pinch safety feature complies with FMVSS 118.

The AEM system has a PRESSURELESS infrared anti-pinch safety protection feature. If the obstruction is detected before the automatic close, the system will refuse to activate the close operation. If an obstruction is detected while the window or roof is in closing operation, the system will stop and reverse open the window at least 200 mm immediately. If the safety sensing mechanism malfunctions, the system will disable the rain close feature. Because of the photo sensing technology, there is no pressure force is applied on the objection, therefore, the resistive force will be much less than 22 pounds, and in most cases, there is no extra resistive force.

The section S5 (a) of FMVSS 118 says: ".... may close: (1) Upon the one-time activation of a locking system on the exterior of the vehicle, (2) Upon the one-time activation of any remote actuation device, or (3) Upon continuous activation of any remote actuation device capable of closing the power window, partition or roof panel from a distance of more than 20 feet from the vehicle."

From the function definition, the AEM rain sensing close feature falls in the S5 (a)(1) description. Assuming a vehicle is equipped with the AEM system, and the driver decided to close the windows if unexpected rain occurs on a hot summer day during parking, so that he selected the Automatic Mode of AEM (the locking system, its control switch is on the dashboard or door panel). When rain drops triggered the AEM moisture sensor, the system closed the

windows with one-time activation. In this case, we interpret that this driver is CLOSING the vehicle windows by using a "locking system" (AEM) on the exterior of the vehicle, per S5 (a) (1) of FMVSS 118.

The AEM system brings an innovation to benefit consumers: they now have a choice of venting the hot air out of their cars in the appropriate parking environment, and close the windows when it becomes necessary (rain occurs). Because of the requirement for clarification from our OEM customers, we need your office to provide a written reply as soon as possible. Your earliest reply will significantly help this innovation become available to public consumers.

I am looking forward to your written reply.

Attachment

PROSPECTS CORPORATION AEM System Active Infrared Sensing Safety Protection Mechanism

September 20, 1991

The AEM system provides a safety feature that will ensure the vehicle window close operations: - Automatic close due to rain sensing; - Security close when the ignition key is removed; - "l-touch" express close while driving.

The safety mechanism includes several infrared sensors and emitors that will detect the upper window frame areas for obstructions just before and during the above close operations.

Before the AEM system commands the windows to do one of the above three close operations, the infrared device will perform the obstruction detection function. If an object is detected between a particular window frame and the window glass, the AEM system will not issue the close operation common to that window.

If the pre-checking has passed, the windows will begin to express close. The infrared devices will continue to work during the window closing process. Any point, if an object is detected between an upper window frame and the upward moving window glass, the AEM system will immediately stop that window and reverse it to open 200mm regardless of whether the window glass reaches the object or not.

If for any reason the infrared safety devices malfunction, the AEM system has the capability to perform a diagnostic test. It will detect the device malfunction on the particular window(s) and then disable the Express close, Security close, and Automatic close functions for that window(s). Therefore, the potential injury will be completely eliminated with this strict safety algorithm.

The same principle is being applied to the sunroof operation to eliminate the potential safety liability from the manufacturer.

Attached are 5 drawing diagrams to detail the method and mechanism that will ensure the safe operation with the advanced AEM system.

** (Prospects Corporation has filed a U.S. patent application for this device)

(Drawings, photos and text omitted.)