Interpretation ID: nht95-4.52

TYPE: INTERPRETATION-NHTSA

DATE: October 11, 1995

FROM: Gerald R. Stewart -- Office of Safety Performance Standards, Crash Avoidance Division, NHTSA

TO: Office of the Chief Counsel, NHTSA

TITLE: Request for Interpretation for Safety Grooves

ATTACHMT: Attached to 11/13/95 letter from Samuel J. Dubbin to Borje Kukka (A43; Std. 104; Std. 205)

TEXT: MEMORANDUM:

At a recent meeting I received a video tape and brochures on safety grooves which are used in Finland and other countries to help keep windshields and wiper blades clean in adverse weather. Mr. Borje Kukka from Helsinki Finland asked for help with regar d to which vehicle safety standards, if any, would be applicable to safety grooves.

I have sent Mr. Kukka a letter with most of the information he needs; however Mr. Felrice suggested that I request an interpretation from Chief Counsel to be sent to Mr. Kukka so that he has a complete understanding of whether safety grooves are consider ed an item of vehicle equipment or not.

I am submitting the video tape, brochures, and a copy of my letter to Mr. Kukka. Please prepare an interpretation letter for Mr. Kukka. If you have questions contact me at 366-5268 or Mr. Kukka at the following:

Borje Kukka Humalistonkatu 5 00250 Helsinki Finland

Phones: 011 358 0 493 013 private 011 358 02 419 820 Fax 011 358 0 407 315 cellular 011 358 49 414 727

Attachment

Mr. Borje Kukka Humalistonkatu 5 00250 Helsinki Finland

Dear Mr. Kukka,

Thank you for inviting me to your meeting with Mr. Nitze to review the safety groove principles and video tape. I was impressed with the simplicity of the process for grinding the grooves into a vehicle windshield and also with the performance of the gr ooves on keeping the windshield and wiper blades clean during adverse conditions.

I contacted the Office of Chief Counsel and a search of interpretations produced an example for a device which cleans windshield wipers. A copy is attached along with some general information which will help you. As I said in the meeting, it is importa nt for you to understand the term "render inoperative" as it refers to our Federal Motor Vehicle Safety Standards 205 and 104. Copies of these are attached. At the meeting I gave you a copy of the ANS 226 document which is referenced by Standard 205.

At this point, it is important for you to know whether the safety grooves would be considered by our agency as an item of motor vehicle equipment or not. I have provided your video tape and brochures to the Chief Counsel Office with a request for an int erpretation of the question of which vehicle safety standards, if any, are applicable to your safety grooves. An answer should be available within 60 days.

Thank you again for giving me an opportunity to learn about a simple process that can improve a driver's ability to drive safely. I hope this information is helpful to you. If you have questions or need more information please do not hesitate to call m e at 202-366-5268.