ID: nht71-1.41

DATE: 12/29/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson, Assistant Chief Counsel; NHTSA

TO: L. E. Needham

TITLE: FMVSS Interpretation

TEXT: Your letter of November 4, 1971, concerning the compliance of two dual rear door locking system with Standard 206, has been forwarded to this office for reply.

Both systems consist of

". . . a primary locking system which when engaged renders the outside rear door handle and the inside rear door handle inoperative and a special locking device accessible from the door shut face, which when engaged renders the inside door handle inoperative but does not affect the outside door handle."

The systems differ is that engagement of the special locking device in the first system prevents the engagement of the primary locking systems, while engagement of the special device in the second system does not have this effect.

As stated in the preamble to the April 27, 1968 amendment (33 F.R. 6465) to the standard. S4.1.3 does not preclude the installation of a special locking mechanism in addition to the required locking mechanism. However, the required locking mechanism must be engageable or disengageable regardless of whether any additional locking mechanism is engaged or disengaged. If the special locking mechanism does not interfere with the operation of the required locking mechanism, it will not constitute a failure to comply with the standard.

Under these criteria, the first dual system would not comply with the standard since engagement of the special locking mechanism would interfere with the operation of the primary locking mechanism.

The second dual system would comply if engagement of the special locking mechanism would prevent neither the engagement nor the disengagement of the primary locking mechanism.

Please write if I can be of any further assistance.

ID: nht71-1.42

DATE: 07/22/71

FROM: E. T. DRIVER -- NHTSA OFFICE OF OPERATING SYSTEMS MOTOR VEHICLE PROGRAMS

TO: LOUIS C. LUNDSTROM -- DIRECTOR, AUTOMOTIVE SAFETY ENGINEERING GENERAL MOTORS ENVIRONMENTAL STAFF

TITLE: NONE

TEXT: Dear Mr. Lundstrom:

This is in reply to your letter of July 12, 1971, to Mr. Douglas W. Toms, Acting Administrator, concerning replacement equipment covered in FMVSS No. 108, effective January 1, 1972.

The requirements for original and replacement equipment in FMVSS No. 108 cover those items listed in Tables I and III, namely: Headlamps Turn signal operating units Tail lamps Turn signal flashers Stop lamps Vehicular hazard warning signal License plate lamps operating units Reflex reflectors Vehicular hazard warning signal Parking lamps flashers Side marker lamps Identification lamps Backup lamps Clearance lamps Turn signal lamps Intermediate side marker lamps Intermediate reflex reflectors

In addition the requirements cover the following items specified in the text of the standard:

School bus warning lamps

Headlamp beam switching devices

Headlamp upper beam indicator lamps

Turn signal pilot indicator lamps

Hazard warning signal pilot indicator lamps

Plastic lenses

Sincerely,

ID: nht71-1.43

DATE: 07/16/71

FROM: ROBERT L. CARTER -- NHTSA MOTOR VEHICLE PROGRAMS

TO: LOUIS C. LUNDSTROM -- DIRECTOR AUTOMOTIVE SAFETY ENGINEERING GENERAL MOTORS ENVIRONMENT ACTIVITIES STAFF

COPYEE: C.R. SHARP

TITLE: NONE

TEXT: Dear Mr. Lundstrom:

This is in response to your request of June 14 for an interpretation of several provisions of Standard No. 101, Control Location, Identification and Illumination.

You asked first whether "redundant" controls must be identified, such as the windshield washer control that is located in the end of the column mounted shift lever. The standard does not distinguish between required and redundant controls, and redundant controls must be identified. As this agency observed of controls designed to be operable by touch "their function is not clear to a operator unfamiliar with the vehicle in which they are installed, and their identification is necessary" (36 F.R. 8297, May 4, 1971).

Secondly, you pointed out to us the virtual impossibility of requiring identification of intermediate positions in rocker-type and push-pull type heating and air conditioning system controls. We agree with your point, and I enclose an order of the Administrator amending paragraph S4.2 to exclude intermediate positions on these types of controls from the identification requirement.

Finally, you ask whether the identification requirement in S4.2 for "manually operated" controls extends to a floor mounted windshield washer control. Since a manually operated control is, by definition, a control that is operated by hand, a foot-operated control need not be identified.

Sincerely,

Enclosure

DEPARTMENT OF TRANSPORTATION

National Highway Traffic Safety Administration

[Docket No. 1-18; Notice 5]

Summary Statement

MOTOR VEHICLE CONTROLS STANDARD - amendment of motor vehicle controls standard (Standard No. 101), to clarify control identification and illumination requirement and control location test condition, effective January 1, 1972, and September 1, 1972.

Title 49 - TRANSPORTATION

Chapter V - National Highway Traffic Safety Administration Department of Transportation

PART 571 - FEDERAL MOTOR VEHICLE SAFETY STANDARDS Control Location, Identification, and Illumination

The purpose of this notice is to amend Motor Vehicle Safety Standard No. 101 to clarify control identification, and illumination requirements, and the control location test conditions.

Standard No. 101, Control Location, Identification, and Illumination, was amended on January 14, 1971 (36 F.R. 503) and, as a result of reconsideration petitions, was amended again on May 4, 1971 (36 F.R. 8296). General Motors Corporation has asked for a clarification of the requirement in S4.2 that "Each position of . . . a heating or air conditioning system control shall be identified." It points out the virtual impossibility of identification of intermediate positions for rocker-type and push-pull-type switches. The NHTSA agrees that intermediate positions for these types of switches are difficult to identify, and consequently has amended S4.2 to exclude them from the identification requirement.

Ford Motor Company has petitioned for a clarification of the requirement in S4.3 that ". . . A control shall be provided to adjust the intensity of control illumination variable from an 'off' position to a position providing illumination sufficient for the vehicle operator to readily identify the control under conditions of reduced visibility." Specifically, Ford wishes an interpretation

that a simple on-off switch is a sufficient variable control.

The NHTSA has determined that a motor vehicle operator should be able to set control illumination levels according to his own, eye comfort and the specific condition of reduced visibility that requires control illumination. Additionally, it is important for a driver to reduce control illumination when the illumination is reflected in the windshield creating a glare condition. The NHTSA intended in the January 14 issuance that a continuously variable "rheostat"-type control be provided, and is amending S4.3 to reflect this intention.

The NHTSA is also amending the restraint test condition of S5.2 to correspond with the recent amendment to Standard No. 208, Seat Belt Installations, (36 F.R. 9869) that requires Type 1 seat belt assemblies in, among other vehicles, walk-in van-type trucks, and multipurpose passenger vehicles with a gross vehicle weight rating of more than 10,000 pounds.

In consideration of the foregoing, 49 CFR 571.21, Federal Motor Vehicle Safety Standard No. 101, Control Location, Identification and Illumination, is amended as follows:

1. The third sentence in Paragraph S4.2 is amended to read: "Each position of an automatic vehicle speed control and a heating and air conditioning system control, other than an intermediate position of a rocker-type or push-pull-type control, shall be identified."

2. The last sentence of Paragraph S4.3 is amended to read: "A control shall be provided to adjust the intensity of control illumination, continuously variable from an 'off' position to a position providing illumination sufficient for the vehicle operator to readily identify controls under conditions of reduced visibility."

3. Paragraph S5.2 is amended to read: "The person seated at the controls of a multipurpose passenger vehicle or truck with a gross vehicle weight rating of more than 10,000 pounds, convertible, open-body type vehicle, walk-in van-type truck, or bus is restrained by a nonextending pelvic restraint fastened so that there is no slack between the lap belt and the pelvis."

Effective date: January 1, 1972, Paragraph S4.2 for passenger cars; September 1, 1972, Paragraph S4.2 for vehicles other than passenger cars, Paragraph S4.3 and Paragraph S5.2.

This amendment is issued pursuant to sections 103 and 119 of the National Traffic and Motor Vehicle Safety Act of 1966, and the delegation of authority from the Secretary of Transportation to the National Highway Traffic Safety Administrator, 49 CFR 1.51.

Issued on JUL 9 1971

Douglas W. Toms

Acting Administrator

ID: nht71-1.44

DATE: 03/04/71

FROM: D. FERGUSON -- NHTSA MOTOR VEHICLE PROGRAM

TO: EISUKE NIGUMA -- TOYO KOGYO COMPANY LIMITED

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 9/23/77 (EST) FROM ROBERT L. CARTER -- NHTSA MOTOR VEHICLE PROGRAMS TO ROBERT K. DORNAN -- MEMBER U.S. CONGRESS; LETTER DATED 7/29/77 FROM WILLIAM B. STOVER TO BRIAN YOUNG OF CONGRESSMAN DORNAN'S OFFICE

TEXT: Dear Mr. Niguma:

This is in reply to your letter of January 23, 1971, to Mr. Rodolfo A. Diaz, regarding attachment bolts used to secure seat belt assemblies to a motor vehicle.

The intent of the requirement in paragraph S4.3(c)(l) of Standard 209 is to assure that inadequate attachment bolts will not be used to attach seat belt assemblies to the vehicle. This paragraph does not require that the specific models of vehicles be listed on the label. It provides that if a seat belt assembly is designed for use in specific vehicles in which only one end of a belt assembly can be attached by a single belt, then the bolt need only have a breaking strength of 5,000 pounds.

It should be noted, however, that paragraph S4.1(l) of the Standard requires the(Illlegible Words) assemblies for aftermarket use to furnish an instruction(Illegible Word) stating whether the assembly is for universal installation or for installation only in specifically stated meter vehicles. (Illegible word) as you state, the seat belt assemblies used in MAZDA vehicles are designed exclusively for specific models, such models must be listed on the installation instruction sheet.

Please contact us if we can be of further assistance.

Sincerely,

ID: nht71-1.45

DATE: 12/02/71

FROM: ROBERT L. CARTER -- NHTSA ACTING ASSOCIATE ADMINISTRATOR MOTOR VEHICLE PROGRAMS

TO: LOUIS C. LUNDSTROM DIRECTOR, AUTOMOTIVE SAFETY ENGINEERING GENERAL MOTORS TECHNICAL CENTER

TITLE: NONE

TEXT: Dear Mr. Lundstrom:

This is in reply to your petition of September 10, 1971, requesting that Motor Vehicle Safety Standard No. 302, "Flammability of Interior Materials," be amended by (1) substituting a 12-inch-per-minute burn rate for the 4-inch-per-minute burn rate presently specified in the standard and (2) making certain specified changes in the test cabinet and test procedure. For the reasons stated below, your request for a 12-inch-per-minute burn rate is hereby denied.

The arguments you offer as a basis for your petition are stated below, and are followed by our responses. Generally, your position is that while you admit that "the available data may provide justification for a standard on flammability," you claim there is no evidence in the docket that supports the basis for, or establishes any safety benefit of, a 4-inch-per-minute burn rate. You argue also that the number of non-fuel fires is too small to warrant a 4-inch-per-minute burn rate. Finally, you claim that using materials having a 4-inch-per-minute burn rate would add an average retail cost of $ 10 to vehicles you manufacture, which cannot be justified under your analysis of the safety need. You indicate, however, that your present materials will or can be made to meet a 12-inch-per-minute burn rate.

"The 4-inch-per-minute burn rate was incorporated into the standard as a result of the agency's determination that it provided a flammability rate sufficiently low to provide adequate escape time from a vehicle in the event fire should occur." At no point in your petition do you present any data that shows that the 4-inch-per-minute burn rate is unreasonable or excessive from a safety standpoint. Moreover, despite your statement to the contrary, the Administration believes there is sufficient data on the number and degree of non-fuel fires in motor vehicles to justify the 4-inch-per-minute rate.

Much of the argument in your petition concerns a variability in the burn rate of materials you have tested. You apparently maintain that the variability makes it difficult for a manufacturer to know whether or not the material he uses in fact complies with the standard. The Administration realizes that the burn rate of any particular material may vary. This fact will be taken into account, along with the frequency and extent of any test failures, in assessing whether a manufacturer has exercised due care. It would not be appropriate, however, to respond to the problem of variability by raising the overall burn rate requirement. Such an action would probably result simply in manufacturers choosing cheaper and less safe materials.

You also argue that, under the specified test procedure, there may also be variations in burn rate results caused by inconsistencies of interpretation.

You provide data showing that GM and its suppliers obtained different results using adjacent material on the same roll. We find this argument to be without merit. General Motors is completely free to specify to its suppliers the method which it considers satisfactory under the standard to measure burn rates, or to test the materials themselves. This is no less than NHTSA itself does when it monitors test laboratories that are contracted to perform compliance tests.

You also provide data showing the effects of aging on a specific fire retardant additive. The evidence available to the NHTSA does not, however, indicate that it is necessary to use flame-retardant treatments that display these undesirable characteristics in order to comply with the standard.

Finally, while you present arguments against the retention of a 4-inch-per-minute rate, your petition lacks significant substantive arguments for the 12-inch-per-minute rate you wish to substitute. At no point do you show how a 12-inch-per-minute burn rate will allow sufficient time for the driver to stop the vehicle, and if necessary for occupants to leave it, before injury occurs. Based on the Administration's findings, such a 12-inch-per-minute rate will not provide the necessary escape time.

Your request for changes in the test cabinet and test procedure is presently being evaluated, and you will be notified when a decision concerning them has been made.

Sincerely,

ID: nht71-1.46

DATE: 01/01/71 EST

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: L. R. Walders, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: RE: REQUEST FOR INTERPRETATION OF FMVSS NO. 108

In your letter of December 23, 1970, you asked on behalf of the Japan Automobile Manufacturer's Association whether a motorcycle manufactured prior to January 1, 1973, must comply with the location requirements for turn signal lamps if the vehicle is so equipped.

This will confirm your interpretation that "the location requirements for turn signal lamps do not apply to motorcycles manufactured before January 1, 197, and no change would be required for the location of turn signal lamps on motorcycles manufactured before that date".

ID: nht71-1.47

DATE: 01/08/71

FROM: R. H. COMPTON -- NHTSA; SIGNATURE BY CHARLES A. BAKER

TO: A. Hammerstein

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 23, 1970, to the U. S. Department of Tranportation concerning the time when stop lamps will be required to meet Class A photometrics.

The conflict between the requirements of paragraphs S4.1.1.6 and S4.1.1.7 has already been called to our attention, and will be clarified in an amendment to Standard No. 108 scheduled to be published in the Federal Register in the near future.

It was not intended for the stop lamps to meet the Class A photometric values, nor are they required to, until January 1, 1973.

ID: nht71-1.48

DATE: 01/20/71

FROM: R.A. DIAZ -- NHTSA; SIGNATURE BY HAROLD M. JACKLIN

TO: Bus and Truck Supply Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 30, 1970, requesting an interpretation of Motor Vehicle Safety Standard No. 205, "Glazing Materials," as it applies to the forward-facing window above the windshield of a particular bus, a picture of which you enclosed.

Because the window in question is a forward-facing window, we cannot conclude that it is an "opening in the roof" under the standard. We apologize for the inconvenience caused by any implication to the contrary that you may have been given on your visit here.

Based upon the picture submitted, and your statement that the window "is not adjacent to passenger seating," we conclude that this location is one that is not specifically designated by the standard. As such, the use of AS2 glazing, which you indicated you plan to use, or alternatively AS1, AS3, AS10, or AS11 glazing, would be appropriate.

If you have further questions, we will be happy to answer them for you.

ID: nht71-1.49

DATE: 01/22/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Bolt Beranek and Newman, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters, both dated December 16, 1970, concerning Motor Vehicle Safety Standard No. 213, "Child Seating Systems." One of these letters enclosed a request for clarification of two provisions of Standard No. 213. This request is presently under review and you should be hearing from the agency concerning it in the near future. You also enclosed in this letter a copy of a page from the 1970 Sears, Roebuck & Co. catalogue showing a child harness that is advertised as "not a safety harness," and ask whether this type of harness is exempt from the requirements of Motor Vehicle Safety Standard No. 209. The agency considers these types of harnesses to fall within the purview of Standard No. 209 and they are required to comply with the requirements for Type 3 seat belt assemblies as specified in S4. of that standard. Enforcement procedures are currently in progress in this area to eliminate those child harnesses that do not comply with the standard.

Your second letter requests that a study conducted by the University of Michigan Highway Safety Research Institute (Contract No. FR-11-6962), entitled "Integrated Seat - Restraint and Child Systems," be placed in the public docket, and further request that the "data films of the dynamic sled test be made available through the Docket." The report to which you apparently refer has been placed in the general reference section of Docket 2-15. It is entitled "Child Seat and Restraint Systems Test Program" but bears the same contract number as the one you request. With reference to your request for data films, these films are presently available for examination by the public through the agency's Research Institute, and information to this effect has been placed in the Docket.

ID: nht71-1.5

DATE: MAY 28, 1971

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Boise Cascade Recreational Vehicles

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 14, 1971, on the subject of the effective date of the requirements for seat belts and seat belt anchorages in multipurpose passenger vehicles.

You have been correctly informed by RVI that the seat belt installation standard (No. 208), and the seat belt anchorage standard (No. 210) are effective July 1, 1971, with respect to trucks and multipurpose passenger vehicles. The amendment to Standard No. 208 issued September 30, 1970, required seat belts effective July 1, 1971. That standard will be superseded by the new occupant crash protection standard on January 1, 1972, but it is in full effect from July 1, 1971, to January 1, 1972. We regret any confusion that may have arisen as the result of the issuance of the occupant crash protection standard.

The requirements for seat belt anchorages have not been affected in any way by the occupant crash protection rule and it is therefore suprising to find that the effective date of the anchorage standard has also been misunderstood. We would hope that the changes in procurement schedule to which you refer would not result in inability to conform to the standard by July 1, 1971.

On the basis of the information presently available to us there does not appear to be sufficient cause to postpone the effective dates of Standards No. 208 and 210.