ID: nht73-6.12

DATE: 06/08/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: RVI Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 18, 1973, concerning a defect notification campaign involving furnaces manufactured by Suburban Manufacturing Company of Dayton, Tennessee, that have been used in recreational vehicles. You ask whether the obligation of the individual vehicle manufacturers under the Safety Act and applicable regulations may be met if the appropriate documents and notices are sent or filed by Suburban Manufacturing.

Suburban Manufacturing Company may prepare and submit to NHTSA or mail to purchasers, on behalf of the individual vehicle manufacturers, the information required by 49 CFR Part 573 "Defect Reports," 49 CFR Part 577, "Defect Notification," and Section 113 of the Safety Act (15 U.S.C. 1402). However, the requirements must be met as they apply to manufacturers of motor vehicles, and not manufacturers of equipment. Moreover, the vehicle manufacturers themselves will still be responsible if any of the documents filed or sent by Suburban Manufacturing Company fail to fully conform to all applicable requirements.

Sincerely yours,

May 18, 1973

Lawrence R. Schneider, Esq. Chief Counsel, NHTSA

Dear Larry:

At present a notification of defect campaign is being carried on in regard to NT32 furnaces manufactured by Suburban Manufacturing Company of Dayton, Tennessee. These furnaces have been sold to many different recreational vehicle manufacturers. We are pleased to note that Suburban Manufacturing Company has indicated a willingness to send all of the notices to purchasers, supply the parts required to repair the defect and bear the entire cost.

The only concern various manufacturers have expressed is that they want to be sure that their obligations under Section 113(d) of the Safety Act and Part 573 - Defect Reports - have been met if the necessary reports are filed by Suburban Manufacturing Company.

It would be appreciated if you would verify our belief that Suburban's reporting will be sufficient. I will undertake to convey your opinion to the RV companies involved.

Sincerely, David J. Humphreys RVI Washington Counsel

cc: Messrs. F. M. Radigan, P. Shrake, A. Spreen and W. Bigelow

ID: nht73-6.13

DATE: 12/13/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Equipment & Body Distributors Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 6, 1973, requesting information on whether vehicle certification labels must be affixed by persons who for their own use install fifth wheels on chassis cabs.

The NHTSA takes the position that vehicles completed by persons for their own use must conform to all applicable motor vehicle safety standards and be certified (by affixing the appropriate label) as conforming. The NHTSA considers the use of these vehicles to be an introduction or delivery for introduction in interstate commerce and subject to the prohibitions of section 108 of the Safety Act. Persons who complete incomplete vehicles are final-stage manufacturers and all other regulations applicable to manufacturers (Parts 566, 573, and 577) apply to them.

November 6, 1973

Richard B. Dyson Assistant Chief Counsel National Highway Traffic Safety Adm.

We have run into a situation in which a trucking firm told us that they had received some information "from Washington" that they did not have to affix Vehicle Certification Labels to the chassis-cabs to which they installed fifth wheels. These truck-tractors would then be placed into their fleet for their own use.

While Section 108 of Public Law 89-563 provides that "no person shall manufacturer for sale, sell, offer to sell or introduce or deliver for introduction in interstate commerce . . . " it would seem that part 568 of the current Certification regulations provides that any vehicle completed must be certified -- regardless of whether the vehicle is for sale or use by the Final-Stage Manufacturer.

We would appreciate your comments on this matter, as well as a statement regarding the Manufacturer Identification Reports and the various parts of the Defect Regulation. We are of the opinion that they have received some erroneous information, and would like to help them set the record straight.

Thank you.

THOMAS S. PIERATT Executive Secretary

ID: nht73-6.14

DATE: 04/10/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Robins Davis & Lyons

TITLE: FMVSS INTERPRETATION

TEXT: (Ilegible Text)

ROBINS. DAVIS & LYONS

March 16, 1973

United States Department of Transportation Federal Highway Administration National Highway Safety Bureau Washington, D. C.

Attn: Office of Performance Analysis

Re: Roste v Ford Our File: S72-0534

Gentlemen:

Our office represents a woman who was badly burned in an automobile accident when the Ford Cortina, in which she was a passenger, exploded upon rear-end impact with another automobile. I am interested in knowing whether or not there have been promulgated any Federal standards or regulations pertaining to the safety of gasoline tanks, appurtenances thereto, fuel tank filler hoses and connections, or the need for a protective fire wall between the fuel tank compartment and the rear of the automobile.

If you can refer me to any information pertaining to these questions or send to me copies of the appropriate data, I would be most appreciative. We will, of course, reimburse you for any costs incurred.

Thank you.

Very truly yours,

John F. Eisberg

ID: nht73-6.15

DATE: 04/09/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Takata Kojyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 24, 1973, to Mr. Francis Armstrong, requesting various interpretations of Standards No. 208 and No. 209, with respect to safety belt systems.

Your first question, referenced to Figure No. 1 of the enclosure with your letter, relates to the required strength of the webbing in the case where two widths are connected together in an upper torso assembly. Under the webbing strength requirements of S4.2(b) of Standard No. 209, both pieces of webbing in the upper torso restraint must, individually, meet a 4,000 pound strength test. Under the assembly performance requirements of S5.3(b) of Standard NO. 209, a common pelvic and upper torso restraint must meet a 3,000 pound strength test. The latter would be true regardless of whether sewing or other means is used to make the belt assembly.

Your second question, referenced to Figure 2 of the enclosure, relates to the bolt strength required in the belt assembly anchorage. Under the provisions of S4.1(f), "equivalent hardware" is permissible in lieu of the 7/16" bolts. In such a case, the tests required under S4.3(c), as prescribed under S5.2(c), would be performed on the entire equivalent hardware, rather than or the individual components (bolts).

With respect to your third question, concerning the acceptability of belts that do not conform to the elongation requirements of Standard No. 209, our reply is that under the present circumstances such webbing would not conform to either Standard No. 208 or

Standard No. 209. As a result of the decision by the United States Court of Appeals for the Sixth Circuit in Ford v. NHTSA, belts installed under Standard No. 208's third option in 1973 (S4.1.2.3) will have to conform to Standard No. 209. Unless Standard No. 209 is amended with respect to its elongation requirements, therefore, energy absorbing webbing of the type you describe will not be permitted in 1974 cars.

TAKATA KOJYO CO., LTD.

February 24, 1973

Francis Armstrong Director, Office of Compliance Motor Vehicle Program National Highway Traffic Safety Administration

Attention to; Mr. J. Gilkey Mr. G. Hunter

This is to request you to enlighten us upon the under-mentioned questions of ours so as to let us manufacture right seat belts assembly conforming to MVSS.

Please note, in this connection, that we have been manufacturing seat belts successfully for many years for installation in the cars destined to the United States.

Question # 1. (Please refer to the Figure # 1)

As shown on the Fig. #1, we made one shoulder belt connecting one webbing of 2" wide with another of 1" wide by pattern-stitching as the Figure. In this case, what breaking strength is required under S4.2(b) of MVSS 209? Is our belt taken as an assemblied webbings in spite of its connection by stitching? In other words, is 3,000 lbs. the required breaking strength for the said belt? How about in case the 2" webbing is connected with the 1"one with hardwares? Please clarify this case too.

Question # 2. (Please refer to the Figure # 2)

In compliance with the request of our customers, auto-manufacturers, we are preparing to use two bolts of smaller diameter than 7/16" for fastening to the anchorage. In this case, is each bolt is required to withstand the breaking strength of 5,000 lbs or more?

Question # 3.

We are planning to use an Energy Absorbent belt for 1974 cars. Our Energy Absorbent belt conforms to the requirement of MVSS 208's S.I. 1,000, but extends more than 40% at 2,500 lbs. In other words, the belt does not conform to MVSS 209. Can our belt be accepted by you, the U.S. authorities when shipped to the U.S. installed in the cars destined to the U.S. markets? Are we right in understanding that MVSS 208 takes precedence of MVSS 209 in this particular case?

Thanking you in advance for your kind guidance at your earliest convenience,

T. Hiramine, DIRECTOR

Enclosed.

(Graphics omitted)

(Graphics omitted)

TAKATA KOJYO CO., LTD.

February 26, 1973

Francis Armstrong, Director

Office of Standards Enforcement National Highway Traffic Safety Administration, Attention to; Mr. J. Gilkey Mr. G. Hunter

Enclosed please find the two copies of sketches numbered as Figure # 1 and Figure # 2.

Kindly take a trouble to check whether the two sheets of copied sketches attached to our letter to you dated February 24, 1973 were numbered as Fig. 1 and Fig. 2, respectively.

We are afraid if we attached two copies of same number by mistake. If so, please replace the wrong ones by the correct ones enclosed herewith. Provided our originally attached ones were correct ones, please just destroy these copies enclosed herein.

Expressing our apologies for inconvenience caused by our oversight,

Sincerely yours

T. Hiramine

Enclosure.

(Graphics Omitted)

(Graphics Omitted)

ID: nht73-6.16

DATE: 02/07/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 31, 1973, in which you asked us to confirm your "understanding that FMVSS No. 121 will not apply to fire-fighting vehicles until 1 September 1976, two years from the effective date." In general, you suggest that "we would expect to comply with FMVSS [for firefighting vehicles] within two years after the effective date or two years from the date of publication of the FMVSS, whichever date occurs later".

You have misread the relevant language of 49 CFR @571.8. That section provides that the effective date of a standard as applied to firefighting vehicles is "either 2 years after the date on which such standard or amendment is published in the Rules and Regulations section of the Federal Register, or the effective date specified in the notice, whichever is later", except as otherwise specified in the standard with reference to those vehicles. The alternatives are thus (a) 2 years after the publication date, or (b) the effective date, whichever is later -- not 2 years after the effective date, as you have read it.

Your reading would not be reasonable; since the effective date cannot be before the publication date, there would be no point to the alternative phrasing.

ID: nht73-6.17

DATE: 04/06/73

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Volkswagen of America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of April 2, 1973, regarding the classification of the Volkswagen Model 181 (The VW Thing) for purposes of the Federal Motor Vehicle Safety Standards.

Based on a review of your letter and its enclosures, we accept your classification of the Model 181 as a Multipurpose Passenger Vehicle.

Sincerely,

VOLKSWAGEN OF AMERICA, INC.

April 2, 1973

Francis Armstrong, Director National Highway Traffic Safety Administration

Re: N41-22GSh

This is in response to your letter of March 19, 1973 directed to Mr. Crawford Shaw in which you requested the submission of satisfactory evidence that would support our classification of the Volkswagen Model 181 (The VW Thing) as a Multipurpose Passenger Vehicle.

Upon receipt of your letter, we arranged for a meeting with you and your staff which was held in your office on March 29, 1973. At this meeting, we presented information relevant to the fact that the VW model 181 is equipped ". . . . with special features for occasional off-road operations . . . . " as is required by the definition of a Multipurpose Passenger Vehicle. The following submission enumerates the features of the VW 181.

VEHICLE HISTORY

This vehicle was originally designed in the early 1960's under contract for the German Government. A major consideration in the design concept was the requirement by the army for rough terrain operation and associated vehicle specifications. The availability of the vehicle was originally limited to the army but subsequently, after sufficient production capacity was gained, availability was extended to the general public in Europe. Most recently, the entire world production has been centralized in Mexico and vehicles are exported back to Europe and also now to the U.S.A.

2

VEHICLE FEATURES

The following is a description of the vehicle including a comparison in some respects to our VW Beetle models so as to differentiate between typical passenger car specifications.

The BODY DESIGN is both rugged and functional, void of cosmetic details, with maximum consideration given to the extremes of hard usage found off road rather than to comfort and decor. The sloping front hood provides excellent forward visibility, an aid in negotiating hill crests. Generous clearance between the fenders and the tires is provided for accommodating extreme suspension travel and preventing entrapment of foreign objects. A folding soft top, removable side curtains and a folding windshield provide for operation in extremes of weather and possibly for negotiating areas of minimal overhead clearance. The folding feature of the rear seats provide a compartment of seventeen cubic feet capacity for cargo carrying.

Special off-road features are:

1. Standard tires of 185 R 14 M & S (Mud and Snow) with tube mounted to a five inch wide rim. The coarse tread profile provides versatility on all surface types. This compares to our normal Beetle tire of 6.00x150, tubeless, mounted to a 4 1/2 inch rim.

2. Ground clearance of 8.1 inches as compared to normal Beetle dimension of 5.9". For additional comparison our VW 412 model has a ground clearance of 5.3" and typical domestic models average approximately 5.0". Ground clearance of competitive off-road vehicles is in the range of 7 to 8".

3. Angle of Approach of 36 degrees and Angle of Departure of 31 degrees gives favorable grade negotiating ability without interference in the area of the vehicle overhang. For both domestic and import passenger cars, the angle of approach is in the range of 17 degrees to 25 degrees and the angle of departure from 11 degrees to 21 degrees.

3

4. An additional specification, unique to this model, is the "Wading or Fording Depth" which is 15.6 inches. This dimension constitutes the water depth through which this vehicle can be driven without danger. Typical passenger cars are not capable of such activity nor is such a dimension specified.

5. An engine protection shield is provided under the vehicle to minimize the chance of damage in the lower crankcase area. Also, an additional shield is provided for the Exhaust Gas Pecirculation filter, a part of the emission control system provided for the U.S.A. model.

6. Towing eyes are provided, mounted in the bumper, two front and two rear, for attachment of a tow line.

7. The overall Transmission/Final Drive gear ratios are lower as compared to the Beetle for improved low speed performance. Hill climbing ability is approximately 15% improved over that of the Beetle, measured on a paved roadway.

8. The chassis employed is a derivative of our platform design, however, reinforcement in the area of the suspension mounting is added. Reinforcement struts from the front torsion tubes to the chassis prevent damage in high load conditions. The front and rear axle loads are respectively 1212/1764 lb. as compared to 1080/1609 lb. of the Beetle.

9. The engine equipped is identical to that of our Beetle model except for minor changes in emission control techniques. However, the air cleaner is a very large capacity oil bath type which aids in reducing dust intake in off-road activities.

Enclosed for your information is a List of Technical Specifications (Exhibit 1) and a copy of the Owner's Manual (Exhibit 2) for the U.S.A. model 181.

4

In our meeting with you, some discussion centered around the providing of four-wheel drive in an off-road vehicle. In the VW 181 with its low curb weight (1995 lb.), rear weight bias, and four-wheel independent suspension, we find no need for four-wheel drive. In our own comparative research, we have in some instances found the 181 to have a distinct advantage over other, much heavier, four-wheel drive vehicles. Also, it is interesting to note that vehicles such as the Chevrolet Blazer, IHC Scout and the Jeep DJ-5 are available with two wheel drive standard and four-wheel drive optional at extra cost.

Additionally of interest, the National Off Road Racing Association (NORRA) is a sanctioning body of many off road race events in the U.S., including that taking place in the Baja area of Lower California. They have clearly recognized the respective capabilities of both two wheel and four wheel drive vehicles by providing competitive classes for both.

Enclosed is a copy of an article that was published in the March 1973 issue of MOTOR TREND Magazine (Exhibit 3). The thoughts of the writers illustrate the capabilities of the vehicle and only illuminate the enthusiasm that has been and will be generated by this vehicle inthe off-road, recreational vehicle market.

In a report of the National Traffic Safety Agency on the development of the initial Federal Motor Vehicle Safety Standard published in Washington, D. C. on March 17, 1967, the Agency set forth the history of its standard setting process and the specific considerations that entered into the selection of the options that were ultimately incorporated into the law. As in many other standard areas, the Agency felt that a number of options were open to it in dealing with the problems presented by special purpose vehicles. The report of March 17 records the discussions within the Agency (Exhibit 4).

It is fair to conclude, in our opinion, that by introducing the definition of MPV, the Agency recognized that some passenger type vehicles present special problem in meeting the passenger car standards and should, therefore, not be required to comply with all of them. The report also makes it clear that the Agency is thinking primarily of jeep and van type vehicle that would fall into that category since both are essentially used as passenger cars but have also features that make them suitable for "carrying of goods" or "cross-country travel over rough terrain."

5

You have also requested clarification of the text of the certification label. We have been informed by the factory that the label text does contain the proper reference to "Gross Axle Weight Rating" and "Gross Vehicle Weight Rating". We do not have a sample of the actual certification label at this time, but will forward one to you shortly. For reference at this time, page two of the enclosed Owner's Manual contains a facsimile of the certification label as it will appear in the vehicle.

In conclusion, the facts set forth herein firmly support our classification of the VW model 181 as a Multipurpose passenger vehicle, in that it is equipped with special features for occasional off-road operations. Competitive vehicles, as Jeeps, Land Rovers, and Broncos may be slightly different from the model 181 in their configurations and offer four wheel drive as an extra cost option, but are very much identical to the model 181 in terms of performance and suitability for off-road use.

We look forward to receiving your early reply and extend the invitation to completely examine an actual vehicle, at your convenience, at our facility in Englewood Cliffs. If any additional questions should arise, please contact me directly by telephone at the number below.

Sincerely yours,

Guenter Storbeck

[Enclosures Omitted.]

ID: nht73-6.18

DATE: 03/02/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Ford Motor Company

COPYEE: J. G. WOMACK; MR. TOMS; MR. HARTMAN; MR. CARTER

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 16, 1973, concerning the safety standard applicable to the sling for the upper torso belt used in Ford's 1974 model restraint system.

The schematic drawing attached to your letter shows that the sling attaches to the roof rail and serves the function of an upper torso belt anchorage. We agree with you that the sling is subject to the requirements of Standard No. 210 and not to the requirements of Standard No. 209. Although the sling is made of fabric webbing, its function is that of an anchorage and it is therefore subject to the anchorage standard.

Yours truly,

Ford Motor Company

February 16, 1973

Douglas W. Toms Administrator National Highway Traffic Safety Administration

Dear Mr. Toms:

An inquiry has been raised by certain of our suppliers with regard to one feature of Ford's 1974 model year restraint system. Ford believes an interpretative statement by the Administration would be desirable to resolve questions that now exist, or may in the future arise, with regard to this type of item.

The attached schematic shows a typical 1974 Ford restraint system. The non-detachable upper torso portion of the restraint system is looped through a "sling" attached to the roof rail of the vehicle. The "sling" is depicted in more detail in View-A of the attached drawing.

This sling is an an anchorage for purposes of Standard No. 210 for several reasons. First, Standard No. 210 defines a seat belt anchorage as the provision for transferring seat belt assembly loads to the vehicle structure. The sling clearly serves this function. Second, as the sling location determines the angle at which the upper torso restraint crosses the occupant's chest, the sling would fall within the acceptable range for upper torso anchorage locations specified in Standard No. 210.

As we have chosen to use webbing in the sling (as opposed to a cable or some such material), the concern expressed involves the question as to whether a potential conflict could arise in interpreting what requirements this sling must meet. If the sling were to be considered by an independent testing laboratory to be part of the seat belt assembly as defined in Standard No. 209, it would apply the

webbing requirements set forth in Section S4.2 of Standard No. 209 to the sling webbing. We would urge that it should not be necessary to meet these webbing requirements as the sling is part of the anchorage and meets the strength requirements of Standard No. 210.

We request, therefore, that the Administration concur in Ford's interpretation that the sling as depicted in the attached schematic is a part of the anchorage and not a part of the seat belt assembly.

Respectfully submitted,

J. C. ECKHOLD

Director

Automotive Safety Office

Attachment

(Graphics omitted)

(Graphics omitted)

FORD-MERCUPY MODEL 65 SHOWN

TORINO-MONTEGO-COUGAR

T-BIRD-MARK IV-LINCOLN

MODELS 65 TYPICAL

ID: nht73-6.19

DATE: 05/22/73

FROM: AUTHOR UNAVAILABLE; James E. Wilson; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: By petition for rulemaking dated November 15, 1973, the Ford Motor Company requested an amendment of Motor Vehicle Safety Standard No. 210 with respect to the strength required of the anchorages for the pelvic portion of a Type 2 seat belt assembly. After considering the merits of the requested amendment, we have decided to deny your petition.

As stated in your petition, the anchorages for the pelvic portion of a Type 2 assembly are presently subject to two strength requirements under Standard 210. Section S4.2.2 provides that, when tested in conjunction with the upper torso anchorage, the pelvic anchorages must withstand a force of 3,000 pounds applied through the seat belt assembly. Section S4.2.1 provides that, when tested separately from the upper torso anchorage, the pelvic anchorages must withstand a force of 5,000 pounds applied through the seat belt assembly.

It is Ford's position that the 5,000 pound requirement of S4.2.1 was intended to be applicable to anchorages used with Type 2 assemblies having detachable shoulder belts, and that it was not intended for use with integral Type 2 assemblies. Although the NHTSA would agree that the most widely used Type 2 assembly at the time of the standard's adoption had a detachable shoulder belt, the agency does not agree that the 5,000 pound requirement should be limited to anchorages used with such belts.

The 1974 model year will be the first in which integral Type 2 belts are installed in all passenger cars. We anticipate that a measurable percentage of persons riding in cars with the new belts will somehow avoid using the shoulder belt, thereby placing

the lap belt under the same potential stress as any other lap belt when used by itself. In light of this possibility, and in consideration of the fact that keeping the pelvic anchorage force at the currently required level of 5,000 pounds will not impose additional manufacturing costs on manufacturers, we do not consider it advisable to grant the requested amendment at this time.

The petition of Ford Motor Company for an amendment of S4.2.1 of Motor Vehicle Safety Standard No. 210 and for a complementary amendment to the test procedures of S5.1 of the standard is therefore denied.

November 15, 1972

Douglas W. Toms Administrator National Highway Traffic Safety Administration

Re: Petition for Amendment of Federal Motor Vehicle Safety Standard No. 210 - Seat Belt Assembly Anchorages

Ford Motor Company, with offices at The American Road, Dearborn, Michigan 48121, as a domestic manufacturer of motor vehicles, hereby submits this Petition for Amendment of Federal Motor Vehicle Safety Standard No. 210 - Seat Belt Assembly Anchorages (hereinafter "the Standard"). This Petition is filed pursuant to Section 553.31 of the procedural rules of the National Highway Traffic Safety Administration.

The purpose of this Petition is to request an amendment to S4.2.1 and S5.1 of the Standard that would eliminate the requirement of applying a 5000-pound force to the anchorages of the pelvic portion of a Type 2 seat belt assembly with a non-detachable upper torso portion. Sections S4.2.2 and S5.2 of the Standard adequately cover the anchorage loading for such a Type 2 seat belt assembly. This 5000-pound test criteria was developed originally for seat belt restraint systems that were independent of upper torso restraints and is still applicable to such systems as well as those that include a detachable upper torso belt system.

Ford Motor Company plans to incorporate non-detachable upper torso straps as required by S4.1.2.3 of Federal Motor Vehicle Safety Standard 208 in its 1974 model vehicles. The present requirements of Federal Motor Vehicle Safety Standard 210 cause the restraint system to be dismantled before it can be tested, resulting in redundant and unnecssary tests and, therefore, are not practicable for this type of restraint system.

Ford test and development programs for these vehicles are now at that point where prototype bodies incorporating 1974 restraint system component designs are available for tests according to Federal Motor Vehicle Safety Standard 210 demonstration procedures to determine that design levels are appropriate for production tooling. We urge your prompt attention to this matter to assure that our current product programs are not affected.

Respectfully submitted,

J. C. Eckhold

Director, Automotive Safety Office

ID: nht73-6.2

DATE: 03/01/73

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

TO: Michigan Law Review

COPYEE: MR. VINSON

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your undated letter to the National Highway Safety Bureau (since December 31, 1970, the National Highway Traffic Safety Administration) concerning Federal motor vehicle safety standards intended to protect the pedestrian and cyclist.

You ask when Standard No. 211 Wheel Nuts, Wheel Discs and Hub caps was proposed and enacted. This standard was one of the Initial Federal standards proposed late in 1966 and issued in late January 1967 effective January 1, 1968, as to original and replacement equipment. This date is almost four months earlier than the date of the accident in Passwaters v. General Motors Corp., 454 F. 2d 1270 (1972) and thus there is no connection between the two. Standard No. 211 derives from a Swedish standard on vehicle exterior protrusions. Eventually we hope to have a definitive standard on exterior protrusions (incorporating Standard No. 211) intended to prevent serious injury to a pedestrian during the initial impact with the vehicle and to control his trajectory to reduce the severity of secondary impacts. The rule would specify impact force distribution and response requirements for exterior vehicle surfaces.

Our initial rulemaking effort in this area was the issuance of an advance notice of proposed rulemaking establishing Docket No. 2-5, published October 14, 1967, (32 F.R. 14278) asking for general comments on size, shape, location, and sharpness of vehicle corners and edges. At the present time, proposals for research to establish threshold-of-injury data and to investigate techniques for reducing injury are being developed. On the basis of this data we will propose a standard on pedestrian protection. Under our current plans, the final standard would be issued late in 1975 with an effective date of September 1, 1990. We also plan to issue a standard on motorcycle rider protection systems around February 1, 1974, with an effective date of January 1, 1975. The agency's standard on motorcycle headgear, under current plans, will be issued around June 1, 1973, with an effective date of September 1, 1974.

ID: nht73-6.21

DATE: 02/15/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 4, 1973, concerning your continuing uncertainties about the intent of sections S4.3.1.1 and S4.3.1.3 of Standard 210.

In your figure 1, assuming the seat is not adjustable, the contact points would be (b) in the first drawing and (c) in the second. However, a rigid attachment of the length shown in the second drawing would appear to violate the intent of S4.3.1.1 that the angle formed by the webbing in passing from the hardware to the seating reference point should be a forward angle.

In your figure 2, if the bracket can be rotated so that an extension of its centerline would pass through the seating reference point, we would consider point (p) to be the nearest contact point for purposes of S4.3.1.1 and S4.3.1.3.

With respect to the proposed used of a flexible wire, as shown in figure 3, the ability of the wire to move with reasonable freedom removes it from the category of rigid hardware. We would consider the points shown as (c) and (f) to be the appropriate contact points for purposes of S4.3.1.1 and S4.3.1.3.

January 4, 1973

Lawrence Schneider National Highway Traffic Safety Administration

Although we have received and appreciated your interpretation of MVSS 210, S4.3.1.1, and S4.3.1.3, Seat Belt Anchorages, this matter remains rather vague to us. Please permit us to restate the situations in question.

We would like to use the seat belt system in which the buckle is attached to the floor panel (tunnel) or seat structure by a rigid bracket as indicated in the enclosed Figure 1. In this situation, please advise us of the correct nearest contact point and angle in each of the attached drawings.

If the rigid bracket with buckle is able to rotate about point "P", as shown in Figure 2, please advise us where we should consider the nearest contact point and angle.

We are also considering using another type of seat belt system, as shown in Figure 3, in which the buckle is attached to the floor panel through the flexible wire. Again, please indicate the exact nearest contact point and angle.

Thank you for your kind assistance.

Tatsuo Kato Engineering Representative Liaison Office in USA Enclosures

The nearest contact point: (A) or (B)?

The angle: 20 degree SEATING REFERENCE POINT

WEBBING

HORIZONTAL LINE

TONGUE

BUCKLE

RIGID BRACKET FIXED TO FLOOR PANEL OR SEAT STRUCTURE

SEATING REFERENCE POINT

THE NEAREST CONTACT POINT: (C), (D) or The angle: 20 degree [Graphics Omitted]

FIGURE 1

RIGID BRACKET

POINT "P"

[Graphics omitted]

FIGURE 3

The nearest contact point: (A), (B) or (C)? The angle: 20 degree SEATING REFERENCE POINT

BUCKLE

FLEXIBLE STEEL WIRE

[Graphs Omitted]

BUCKLE

SEATING REFERENCE POINT The nearest contact point: (D), (E), or (F)? The angle: 20 degree <ODY>