ID: nht72-1.45

DATE: 03/10/72

FROM: JAMES E. WILSON FOR CHARLES H. HARTMAN--NHTSA

TO: Rose Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 1, 1972, concerning the National Highway Traffic Safety Administration (NHTSA) pamphlet, "What to Buy in Child Restraint Systems."

While you approve generally of the pamphlet, you state that you consider certain statements in it to be incorrect. Particularly, you disagree with two statements appearing on the page of the pamphlet discussing child harnesses. Those statements were: "Give preference to those which attach under the seat back, not over it."; and, "Give preference to those which either attach directly to the vehicle floor, or to the vehicle seat belt, not to the seat back." We do not agree that either of these statements is incorrect.

The NHTSA position is that child harnesses that attach over or directly to the vehicle seat back increase the chance of seat back failure, a hazard which you recognize in your letter. Our dynamic test data have shown that affixing a child harness in either of these ways can cause the inertial load of the child to be applied to the seat back excessively deforming or failing the seat back, thereby allowing excesive occupant excursion and increasing the chance of injury to the child. In short, these configurations increase rather than, as you seem to argue, decrease the chance of seat back failure.

With regard to the statements concerning compressive forces being applied to the child during a crash, while we agree in principle that such forces are undersirable, it is not clear from your letter how their application is prevented by having the child harness attach over the top of the vehicle seat. In any event, it is preferable, in our view, for some force to be applied to the child's torso, as long as it is evenly distributed, than to have the child flung into hostile surfaces within the vehicle.

We also do not agree with the statement on page 2 of your letter that harnesses can safely be attached to a vehicle seat back, as the seat back is ". . . in turn securely attached to the car floor." Our experience has been quite the opposite; vehicle seat backs are merely attached to the seat frame and are quite susceptible to collapse in crash situations.

Finally, we do believe the pamphlet, in its recommendation that a child should not stand on the front seat of the vehicle when the harness is attached, is consistent with the design of your harness in that both seek to reduce the danger of whiplash injury,

I hope this clarifies our position for you.

SINCERELY,

rose manufacturing co.

February 1, 1972

Douglas W. Toms Administrator National Highway Traffic Safety Administration U.S. Department of Transportation

Dear Mr. Toms:

Please permit us to congratulate you on the excellent pamphlet, entitled "What to buy in Child Restraint Systems".

Also, however, please permit us to question some statements in this pamphlet which we consider to be, in effect, erroneous and dangerous.

We refer to the next-to-the-last page regarding child restraint harnesses. The first drawing on this page illustrates a restraint harness essentially similar to the one we manufacture, and market under the "Sears" and other trade names. Your first statement in red ink states: "Give preference to those which attach under the seat back, not over it". We submit that any such harness which is attached solely under the seat back, and not also over it, is subject to two vicious hazards. First, it would in case of a crash permit the seat back to move forward to crush the child against the seat cushion. This might result from the folding forward of a hinged seat back or the breaking loose of a fixed one.

The second hazard is more prevalent and just as vicious. An adult lap belt is normally attached under the seat back, and is safe when thus attached. In a crash it puts the impact loading on the hips and pelvic region--the strongest parts of the body with no vital organs to be affected. This is positively not true of any belt or harness which places any restraint on the shoulders or upper torso. All adult 3-point belts are required to have the upper torso restraint attached at some point above the shoulder. Some such safety should also be required in the child harness. It must not be permitted to apply any compressive pressure to the shoulders and downward along the spine, in case of a crash.

Your second statement in red reads: "Give preference to those which either attach directly to the vehicle floor, or to the vehicle seat belt, not to the seat back". This, again provides the same two hazards, the crushing, forward-moving seat back, and the linear forces compressing the spine.

We wish to emphasize that these two hazards are definitely and completely eliminated in the belt which we make, and which is partially indicated in your drawing, but without explanation or comment.

Our harness is not attached directly to the car floor. It is attached directly to the seat back, which in turn is securely attached to the car floor. This holds the seat back securely in its place in a crash, and it also eliminates the linear spinal pressure. The child harness is free to slide up and down along the anchor strap which extends vertically at the front of the seat back. This provides two important safety features. First, it assures that the impact force will always be restrained from a point horizontal to the position of the body at the instant of impact, whether this position is standing, sitting or lying down. Not only will this restraining force be applied directly linear to the impact force but the construction and attachments of our harness assures that such restraint force will be applied to the front of the child and never at the side or rear which might cause neck or spinal injury.

The other, and very important safety feature of our harness is the complete and instantaneous freedom of movement of the child. A child of 2 or 3 years cannot be forcibly restricted to a single sitting position during a long ride without venement and justifiable protest, and consequent distraction of the driver's attention.

This brings us to the last of your statements on that page, viz. "Caution: Parents are warned not to allow a child to stand on the front seat of the vehicle when utilizing a harness restraint, or this may happen". The accompanying drawing indicates a typical whiplash injury situation. To eliminate this hazard, and still provide the maximum safe freedom of movement, our harness includes a positive but adult-adjustible stop on the vertical anchorage strap, and our instructions include a positive warning to keep this stop adjusted to a point which will not permit the child to stand in any seat, front or rear, under any conditions which permits his head to extend to a point higher than the top of the seat back.

We very strongly feel that, in your sincere efforts to educate the public and save the lives of children, you should see to it that these erroneous implications are promptly corrected and that such corrections be given as wide publicity as the original pamphlet.

We shall be awaiting your reply with interest.

C. W. Rose Chairman of the Board

ID: nht72-1.46

DATE: 06/12/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Peterson Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 24, 1972, inquiring whether Standard No. 213 requires head rests, arm rests, and shields of certain Peterson child seats to be covered with nonrecovery, or slow-recovery energy absorbing material.

Paragraph S4.10.3 of Standard No. 213 exempts the contactable area of a rigid side of a child seating system from the requirement that it be covered with deformable, nonrecovery, or slow-recovery energy absorbing material (S4.10.1 and S4.10.2), when the contactable area of the side that is higher than the system's seating surface is at least 24 square inches. We would consider head rests, arm rests, and shields of the Peterson child seats in question to be within the exemption of S4.10.3 if their contactable area above the child seating surface is 24 square inches or more.

I point out, however, that the proposal of September 23, 1970 (35 F.R. 14786) would alter this result, as the exemption would no longer extend to any components contactable by the head.

ID: nht72-1.47

DATE: 12/14/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Kettler of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: A review of correspondence we sent you on October 6, 1972, (in response to your letter of September 26, 1972, concerning child seating systems you plan to import), has revealed that one statement we made should be clarified.

In the second paragraph of our letter we stated that each "seat must be labeled or tagged with a certification that it conforms to all applicable Federal motor vehicle safety standards." Standard No. 213 (49 CFR 571.213), which applies to child seating systems, does require each child seating system to be labeled with information regarding its safe use, and we refer you to the standard for these requirements. However, with respect to certification, manufacturers are not limited to the method specified in our October 6, 1972, letter (viz., attaching a label to the seat), but may certify in other ways as well. For example, Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), on which the certification requirement is based, states that the certification may also be placed on the outside of the container in which the item is delivered.

We regret that our former letter was incomplete in this regard.

ID: nht72-1.48

DATE: 03/10/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Irvin Industries Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 23, 1972, in which you list information you wish to label on child seats you will manufacture, and ask whether the information as presented will comply with Motor Vehicle Safety Standard No. 213. You state that a label containing the model number, date of manufacture, and the company's name and place of business will be permanently affixed to the product, while a separate legend, containing other information, will be molded on the bottom of the seat in raised letters at least 3/32 inches high.

The labeling scheme you wish to use would conform to paragraph S4.1 ("Labeling") of Standard No. 213, providing, of course, the blank spaces for model number and date of manufacture are appropriately filled in. We would suggest, however, that that part of the molded legend beginning" . . . and there is a minimum of 19 inches vertical clearance between this seating . . .", to the end of that provision be simplified to be more understandable to an ordinary consumer.

WE ARE PLEASED TO BE OF ASSISTANCE.

ID: nht72-1.49

DATE: 02/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Cosco Household Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 8, 1972, requesting information pertaining to reclining type child seating systems. You describe these seats in your letter as those which allow the child to ride in a semi-recumbent posture by moving the seating surface forward while maintaining the upper back in a more or less fixed location. You state the hip of the child moves forward as a result, while the head remains in roughly the same place.

The questions you asked regarding this type of child seat are repeated below, followed by our responses.

1. Is NHTSA now testing, or does it intend to test, reclining car seats in both the upright and reclining configurations?

Paragraph S4.11.1(b) of Standard No. 213 requires that each child seating system in which the attitude of the child is adjustable meet the performance requirements of the standard when placed in each designed adjustment position. Consequently, reclining child seats must meet these requirements in both reclining and upright positions.

2. Is the allowed twelve-inch excursion to be measured from the reference point of the semi-recumbent dummy, or from the location of this point were the seat assumed to be upright?

The allowable forward movement of the dummy reference point is to be measured using the reference point of the semi-recumbent dummy, and the forward movement must not exceed 12 inches when measured from that point.

3. Does the NHTSA intend to make a specific statement on the requirements of reclining car seats . . .?

We believe the language of paragraph S4.11.1 of the standard to be sufficiently explicit regarding this requirement.

ID: nht72-1.5

DATE: 04/05/72

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: U.S. Technical Research Corporation

TITLE: FMVSS INTERPRETATION

TEXT: The questions asked by your letter of March 18, 1972, have been compared with the applicable paragraphs of the Federal Motor Vehicle Safety Standard (FMVSS) No. 164 and the Society of Automotive Engineers Recommended Practice J942.

1. The purpose of paragraphs 2.11 and 4.42b of J942 is to allow the testing of both manual and automatic systems seeing the same procedures. The (Illegible Word) of 4.42b attempts to equalise the usual cleaning cycle of each type of system. It is apparent that the manual system allowed for by 4.42b is one in which a single actuation, if held long enough, would put 15 cc of fluid through the nozzle. The systems you described is not of this type, nor is it the automatic system. You must therefore comply with the intent of the test, which would be to operate your system for 8,000 washer cycles, as stated in paragraph 3.4. Each washer cycle is that which puts approximately 15 cc of fluid through the nozzle. Since your system is not the usual system implied in the standard, the three-record rule would not apply. Time limitation would be dictated by the "Mo./min" column of Table 1 of J942, i.e. two washer cycles per minute.

Therefore, the pump and central switch you described, along with the other parts of the systems, if they meet all other prescribed (Illegible Word), would comply with Federal Motor Vehicles Safety Standard No. 104.

2. An automatic pump cycling device would not be limited by the three-second rule. It would be requested to meet the "Mo./min" column of Table 1 of J942, 1.2., two washer cycles per minute.

3. Paragraph 3.1 does not specify the duration of water spray, member of water sprays, or start time of wiper action. No standard wiper blade, windshield, or mechanism is specified. These are the items which, in conjunction with the washer, must produce an effective wips/wash system.

The National Highway Traffic Safety Administration is concerned that the entire system provide good washing and wiping, and is not concerned with compliance of individual components.

4. "Repeatedly," as used in paragraphs 4.2.2a and b, means the repeated application of the control device (push button, usually) which is designed to cause the water to squirt out of the nozzles. Practically, this reproduces a driver's attempts to activate the system on a cold day, not knowing if it is frozen or plugged. Upon warming up, the systems must not have been damaged, and must still function after removal of the ice or plug. Without this safeguard, many systems would be rendered inoperative on the first cold day by an impatient driver.

5. To our knowledge, there is no reservoir size stated by Federal or State regulations.

Please ask for further information, if needed.

ID: nht72-1.50

DATE: 11/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Pride Products Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 23, 1972, requesting information on the use of sample testing for determining conformity to Motor Vehicle Safety Standard No. 213. You ask if there are sampling provisions to which manufacturers should currently be adhering.

There is no specified sampling provision for manufacturers to follow in testing their products for conformity to Standard No. 213. The National Traffic and Motor Vehicle Safety Act requires each item of motor vehicle equipment (for example, each child seat) to conform to the applicable safety standard in effect on its date of manufacture. It is the manufacturer's responsibility to decide what type of testing program is necessary to be reasonably certain that each item complies. The extent of his sampling should depend on such factors as the margin by which typical samples pass the performance requirements, the amount of variation in production that is present, and the degree to which substandard items can be detected by non-destructive techniques.

ID: nht72-1.6

DATE: 06/13/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: FMC Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 25 inquiring about compliance of your planned motorhome with Federal Motor Vehicle Safety Standards Nos. 101 and 104.

Standard No. 101 requires certain controls to be illuminated. We interpret this to mean sufficiently illuminated that the control identification, if verbal, can be read, or if pictorial, can be understood. Therefore, illumination from any course is satisfactory as long as the basic requirement of comprehension is met.

Standard No. 104 does not describe the type of windshield wiping system that must be used to meet its requirements. It is the manufacturer's responsibility to insure, whatever system is used and whatever configuration of windshield is employed, that the wiped and washed area requirements are met.

ID: nht72-1.7

DATE: 07/27/72

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

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 20, 1972, to Mr. Toms concerning general reference material in support of the proposals contained in Docket No. 70-27. Hydraulic Brake Systems. You ask that the NHTSA place in the file "The supporting data upon which the test sequence is based as well as the data used to determine the performance values based on the sequence."

The proposed test sequence is based primarily upon the test sequence of standard No. 105, which is that of SAE Recommended Practice J937 incorporated by reference. Parking brake lightly loaded vehicle, inoperative brake power assist unit, and partial failure tests not included in J937, were placed in the sequence in the order that appeared, in the judgment of agency personnel, most likely to provide realistic and undistorted results. The sequence, of course, is subject to revision on the same basis in the forth-coming final rule. General reference material in the Docket includes data from braking tests of eighteen 1970 automobiles, NBS Technical Note 557, "The Brake Pedal Forces Capability of Adult Females," and SAE 720032, "Evaluation of the Use of Automotive Braking Systems During a 7300 Mile Cross-Country Trip."

ID: nht72-1.8

DATE: 04/11/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: GGO Group, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 3, 1972, to Mr. Schneider asking whether your Gemini Tow Control System would come under our regulations, and whether you would be considered a brake manufacturer.

The Federal motor vehicle safety standard covering vehicle hydraulic brake systems, Standard No. 105, applies only to passenger cars (not directly to equipment manufacturers), and does not cover the hydraulic braking relationship between towing and towed vehicles. For that reason the Gemini system would not be regulated by Standard No. 105. There are no Federal standards applicable to a tow control system per se.

We would, however, view you as a "manufacturer," and the product you have described as "motor vehicle equipment," within the remaining of the National Traffic and Motor Vehicle Safety Act of 1965.