ID: nht73-1.49

DATE: 08/30/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Physicians for Automotive Safety

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 12, 1973, concerning children's car harnesses and car seats.

In response to your inquiry about the "Auto-babe" car harness, it is our opinion that the harness is a Type III seat belt assembly under Standard No. 209 and we presently are investigating the product as an apparent noncompliance with the standard.

The next stage in the rulemaking on child restraints will be reached this fall with a notice of proposed rulemaking on dynamic test requirements. We will be interested to have your comments on this proposal when it is issued.

Yours truly,

PHYSICIANS FOR AUTOMOTIVE SAFETY

July 12, 1973

James Wilson -- Acting Administrator, NHTSA, U.S. Dept. of Transportation

Dear Mr. Wilson:

I am enclosing a brochure describing a child auto harness, and would very much like to know 1. does the device meet requirements of Standard 209, Type II, and 2. if not, what action will be taken to prevent manufacture of the device and recall of those still in the stores.

I should also like to receive information with respect to the date a proposal for the upgrading of Standard 213 can be expected.

Your help in this matter would be very much appreciated.

Sincerely,

Seymour Charles, M.D.

President

Enclosure

(Graphics omitted)

ID: nht73-1.5

DATE: 02/22/73

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

TO: Toyo Kogyo Co., Ltd. USA Rep. Ofc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 8, 1973 concerning the operating point of a hand-operating parking system (Standard No. 105a).

We intend to specify an operating point in the response to petitions for reconsideration of Standard No. 105a. This notice should be published not later than May 1, 1973.

Yours truly,

Richard B Dyson -- Assistant Chief Councel, National Highway Traffic Safety Administrator U.S. Government of Transportation

Dear Mr. Dyson

Re; Operating Point of Hand Parking System

Would you inform us your opinion regarded with 90 lb force applied to hand-operated parking system in MVSS 105A Docket No. 70-27 Notice 5 Section 5.2.

In this regulation we cannot find the operating point.

We would like to consider it on the middle finger in following figure.

Your kind reply will be high appreciated,

Sincerely yours,

ID: nht73-1.50

DATE: 08/20/73

FROM: Richard B. Dyson; NHTSA

TO: Takata Kojyo Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 31, 1973, concerning the meaning of the term "75 percent extension" as used in S5.2(j) of Motor Vehicle Safety Standard No. 209.

The 75 percent extension point used in 85.2(j) is intended to represent the belt's extension during its use in a vehicle. The measurement of extension is therefore begun with the webbing retracted as fully as the design of hardware and the size of the retractor permit. It may be that when the belt is retracted to this point a considerable amount of webbing remains outside the retractor, as shown in Figure 2 of your letter. The measurement of extension nonetheless begins at this point, so that "75 percent extension" is 75 percent of the incremental webbing length between this point and the point of fullest extension.

To refer to the figures accompanying your letter, the measurement technique shown in Figure 2 is correct. That shown in Figure 1, which is based on 75 percent of the total length of the belt, is incorrect.

ID: nht73-1.6

DATE: 09/11/73

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

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 8, 1973, to Mr. Schneider asking for confirmation of your interpretation of two sections of Standard No. 105a.

You ask first whether S5.3.1 requires that the activation of an indicator lamp upon application of 50 pounds of force be instantaneous, or whether a minimal time lag is permissible. You indicate that in a "panic stop" there is a time lag of approximately 100 milliseconds between application of 50 pounds of force and lamp activities in the VW system. Since, as you state, it is "humanly impossible" to discern such a minimal time lag, we consider that the VW system complies with S5.3.1, and that the lamp is activated upon application of 50 pounds of force.

You are also correct in your interpretation of S5.2.1 that the 5-minute requirement applies only to vehicles that do not exceed the limit of traction on a 30 percent grade.

Sincerely,

VOLKSWAGEN OF AMERICA, INC.

August 8, 1973

Lawrence R. Schneider -- Chief Counsel, National Highway Traffic Safety Administration

Dear Mr. Schneider:

This letter is a request for interpretation of certain language in S5.3.1 and S5.2.1 of FMVSS 105a, Hydraulic Brake Systems.

In regard to this matter a meeting was held on August 6, 1973 with personnel of the NHTSA and Volkswagen representatives. In attendance were Messrs. Taylor Vincent, E. Driver, C. Baker and V. Bloom of the NHTSA, and Messrs. G. Riechel, J. Kennebeck and K.H. Ziwica of Volkswagen of America.

1. S5.3.1 provides that "an indicator lamp shall be activated when the ignition (start) switch is in the "on" (run) position and whenever any of the following conditions occur: (a) a pressure failure in any part of the service brake system, other than a structural failure of a housing that is common to two or more subsystems, before or upon application of either (1) . . . or (2) 50 pounds of control force upon a fully manual service brake".

In the above mentioned meeting with the NHTSA, VW representatives described the conditions under which the brake failure system used by Volkswagen actuates if a failure in one of the subsystems has occurred. By using a normal or slow force application rate as shown in example "d" of attachment I, the failure indicator lamp will be activated before 50 pounds of control force are reached. By using a very fast application rate as shown in example "b" of attachment I, the indicator lamp will be activated with a certain time lag from the point where 50 pounds are reached. This characteristic is further illustrated in attachment II containing test data of a very slow control force application, and in attachment III for a panic brake force application.

In the discussion with the NHTSA representatives there was agreement that in regard to a fast control force application the wording in S5.3.1(a) "upon application of 50 pounds" does not mean that the failure indicator light must be activated instantaneously if a 50 pound control force is reached, but rather a certain time lag would be permissible before the warning light illuminates. For the panic brake situation, a time lag of approximately 100 ms, after 50 pounds control force are reached, was considered reasonable.

Based on the above mentioned discussion, we would appreciate it if you would provide us with written confirmation indicating that with a fast control force application the wording "upon application of 50 pounds" in S5.3.1(a) does not prohibit a reasonable time lag before the failure indicator lamp is activated. We want to emphasize that this interpretation would not detract from the safety intent of the requirement for failure indicators, as it is humanly impossible to discern such a minimal time lag.

2. According to S5.2.1, a parking brake system of a passenger car "shall be capable of holding the vehicle stationary (to the limit of traction of the braked wheels) for five minutes".

It is our understanding from the aforementioned discussion with the NHTSA personnel that the five minute requirement only applies to a vehicle which is able to be kept stationary by its parking brake at 30% inclination. A vehicle which slides down the 30% inclination with wheels locked by the parking brake is not required to meet the five minute requirement.

We also would appreciate receiving your written confirmation to this interpretation of S5.2.1 of FMVSS 105a.

Thank you for your cooperation in this matter.

Sincerely,

J.W. Kennebeck --

Manager,

Safety and Development

(Graphics omitted)

Attachment B

Broke Pedal applied very fast failure induced in rear circuit

ID: nht73-1.7

DATE: 09/14/73

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

TO: U.S. Technical Research Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 24, 1973, asking for an interpretation of several aspects of Standard No. 105a.

You have asked the following questions

"1. Paragraph S.5.1.2. 'Partial failure.'

It is required that '. . . the remaining portion(s) of the service brake system shall continue to operate . . .' What is the exact meaning of 'continue to operate'? Does it mean that the remaining portion of the brake system must be permanently fed or does it mean that it is required to have temporary braking with the operative portion reserve capability? In this latter case, how many brake applications are required?"

"Continue to operate" means that the portion of the brake system that has not failed continues to operate indefinitely, i.e., to the point that it wears out or until a second failure occurs in the brake system. It requires a permanent feed and does not depend upon the reserve capability of operative portion of system.

"2. Paragraph S.5.1.3.3 'Brake power units':

What exactly constitutes the power source? On the Citroen D and S models, the front brake circuit is fed by the pressure prevailing in the rear suspension. The brake accumulator and the rear suspension are fed from the high pressure source (which includes an HP pump, a pressure regulator and a main accumulator) . . . What is meant by 'inoperative brake power unit'? Does that mean that the high pressure pump only is inoperative or also the other components of the power source (main accumulator and regulator)?. . . What is meant by 'when the inoperative unit is depleted of all reserve capability' (paragraph S.5.1.3.3.(ii))? Are we correct in assuming that it means that only the main accumulator is depleted of reserve capability? (It is obvious that if one considers that not only the main accumulator, but also the brake accumulator and the rear suspension are depleted, no braking is possible)."

The power source consists of pumps, accumulators and/or back up systems such as a separate electric or hydraulic pumps, etc. A primary power source would be the pump, while the accumulators would constitute a secondary source and would be the portions used in optional test. A high pressure source would include the pump, regulator and, in Citroen's case, the main accumulator.

"Inoperative brake power unit" could mean that the (1) main pump is out, but the accumulators are functioning, (2) the main pump is operating, but only one brake accumulator is operating, (3) the pump and brake accumulator are operating, but the suspension accumulator is out, (4) the pump or accumulator is out, and the system is operating on reserve or backup pump. This list is meant to be illustrative rather than exhaustive.

"When the inoperative unit is depleted of all reserve capability" means that one of the units (pump, accumulator, etc.) is completely non-functional, e.g., the pump has failed, the accumulator has failed, the check valve has failed, etc.

"3. Paragraph S.7.10.2 'Optional procedures'

We believe that subparagraph 'b' (vehicles with brake power unit) applies to our vehicles.

The test procedure mentioned in paragraph S.7.10.2(a) cannot be applied to our vehicles since, if the system is depleted of 'any residual brake power reserve capability', it is obvious that no braking is possible. We believe that the power source only should be depleted of any residual reserve (HP pump inoperative, main accumulator depleted), but not the entire brake system. Since, by definition, a 'brake power unit' is a unit where the operator action consists 'only of modulating the energy application level,' but not of supplying energy to the system, it is obvious that no braking is possible if all internal residual energy left in the brake system is depleted (since, in this case, there would be no energy available for braking from either the HP source, the driver or the system).

S7.10.2(b) does apply to Citroen. Your comments on S7.10.2(a) are correct.

Yours truly,

July 24, 1973

National Highway Traffic Safety Administration

Attention: Chief Counsel

Gentlemen:

In relation to Motor Vehicle Safety Standard No. 105a "Hydraulic Brake System", as published in the Federal Register vol. 38 No. 96 of May 18, 1973, we would like clarification of the following points.

1. Paragraph S.5.1.2 "Partial failure."

It is required that ". . . the remaining portion(s) of the service brake system shall continue to operate . . ." What is the exact meaning of "continue to operate"? Does it mean that the remaining portion of the brake system must be permanently fed or does it mean that it is required to have temporary braking with the operative portion reserve capability? In this latter case, how many brake applications are required?

2. Paragraph S.5.1.3.3 "Brake power units":

- What exactly constitutes the power source? On the Citroen D and S models, the front brake circuit is fed by a brake accumulator while the rear brake circuit is fed by the pressure prevailing in the rear suspension. The brake accumulator and the rear suspension are fed from the high pressure source (which includes an HP pump, a pressure regulator and a main accumulator). (see enclosed sketches)

We understand that the high pressure source is constituted by the HP pump, the pressure regulator and the main accumulator only. Are we correct?

- What is it meant by "inoperative brake power unit"? Does that mean that the high pressure pump only is inoperative or also the other components of the power source (main accumulator and regulator)?

We believe it should be considered that several failures cannot simultaneously happen to the same system. (as it is considered in equivalent European regulations).

- What is it meant by "when the inoperative unit is depleted of all reserve capability" (paragraph S.5.1.3.3.(ii))? Are we correct in assuming that it means that only the main accumulator is depleted of reserve capability? (It is obvious that if one considers that not only the main accumulator, but also the brake accumulator and the rear suspension are depleted, no braking is possible).

3. Paragraph S.7.10.2 "Optional procedures"

We believe that subparagraph "b" (vehicles with brake power unit) applies to our vehicles.

The test procedure mentioned in paragraph S.7.10.2(a) cannot be applied to our vehicles since, if the system is depleted of "any residual brake power reserve capability", it is obvious that no braking is possible. We believe that the power source only should be depleted of any residual reserve (HP pump inoperative, main accumulator depleted), but not the entire brake system. Since, by definition, a "brake power unit" is a unit where the operator action consists "only of modulating the energy application level," but not of supplying energy to the system, it is obvious that no braking is possible if all internal residual energy left in the brake system is depleted (since, in this case, there would be no energy available for braking from either the HP source, the driver or the system.)

We remain, of course, at your disposal should you need more information on the operation of our braking system, and, awaiting your answer, we are,

Very truly yours,

By Bernard Belier -- U.S. Resident Engineer for CITROEN S.A.

Enclosures: 1 print "Citroen SM braking"; 1 sketch "Citroen high pressure source"; 1 sketch "Citroen brake system"; 1 sketch "Suspension"; 1 plate No. 21 "Citroen brake accumulator"

ID: nht73-1.8

DATE: 08/20/73

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

TO: Renault, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 1, 1973, asking for clarification of S5.2.1 and S6.9 of Standard No. 105a.

You interpret the parking brake test as allowing "the vehicle to slide down the 30% incline (because of its weight) as long as the wheels remain locked". The parking brake must hold the vehicle on a 30% grade for 5 minutes. If vehicle weight distribution is such that the limit of traction is exceeded and the vehicle slides down the incline, no noncompliance would be indicated unless the parking brake failed to lock the wheels.

No skid number is specified for the "clean, dry, smooth, portland cement concrete" incline surface specified in S6.9.

Yours truly,

August 1, 1973

Lawrence R. Schneider -- Chief Counsel, Nat. Highway Traffic Safety Admins.

SUBJECT: FMVSS 105a - Docket 70-27, Notice 8

Dear Mr. Schneider:

Regie Nationale des Usines Renault would like to request a clarification regarding section S.5.2.1. and S.5.2.2.1 of the above Docket.

It is our understanding that in order for the parking brake to comply with these paragraphs, the wheels of the vehicle must remain locked, but the vehicle may slide down the 30% incline (because of its weight) as long as the wheels remain locked.

We would appreciate receiving a written confirmation of our interpretation.

In addition, we would appreciate the NHTSA informing us of the skid number of the "clean, dry, smooth, Portland cement concrete" referred to in paragraph S.6.9.

Thank you for your cooperation and consideration.

Very truly yours,

RENAULTINC --[Illegible Words] for Francois Louis, Manager, Technical Standards Dept.

ID: nht73-1.9

DATE: 10/29/73

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

TO: T. N. O'Leary, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of October 8, 1973, to the Department of Transportation you ask whether it is true that DOT requires trailer braking systems to have stainless steel conduits rather than copper ones.

Neither the Federal motor vehicle safety standards nor the regulations of the Bureau of Motor Carrier Safety contain such a requirement, and we are unaware of any Federal regulation of this nature.

Yours truly,

October 8, 1973

Office of the General Counsel -- Department of Transportation

Gentlemen:

We have been informed that there is a Department of Transportation regulation to the effect that trailers hauled behind motor vehicles must have stainless steel, as opposed to copper conduits for their gravitational braking systems. As I understand it, the idea behind the gravitational braking system is that when the car puts on its brakes, the trailer naturally exerts forward pressure on the hitch, and this pressure in turn activates the conduits or braking system in such a way that brake fluid flows through the conduit and puts the brakes on the crailer in action.

If there is, in fact, such a regulation, I would appreciate your pointing it out to me. Thank you.

Yours very truly,

PAIN & JULIAN --

Thomas N. O'Leary

P.S. Also, I would appreciate knowing the reasons behind such a regulation and the evidentiary effect, if any, in a Court of Law for such a rule.

ID: nht73-2.1

DATE: 07/09/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Jeep Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 24, 1973, concerning the procedure for testing seat belt attachment bolts specified in section S5.2(c)(1) of Motor Vehicle Safety Standard No. 209.

The attachment bolts that you describe have extremely long shoulders and are installed in the vehicle by being passed through a hat section before entering the floor pan. Your question is whether(Illegible Word) test procedure of S5.2(c)(1) permite the hat section to be used in conjunction with the test fixture shown in Figure 3. It is our opinion that section S5.2(c)(1) permits some discretion in the manner in which the Figure 3 test fixture is to be used and that a hat section duplicating the section used in the vehicle would be permitted as part of the test apparatus. We therefore confirm your impression that you may use the hat section in testing your bolts.

Sincerely,

May 24, 1973

Lawrence R. Schneider-- Chief Counsel, National Highway Traffic Safety Administration, U.S. Department of Transportation

Dear Mr. Schneider:

Jeep Corporation is requesting your concurrence with our interpretation with regard to FMVSS No. 209, "Seat Belt Assemblies" More specifically, we refer to paragraph S5.2(c)(1) which pertains to the demonstration procedure for verifying the strength of seat belt attachment bolts. This paragraph contains, by reference, a drawing (Figure 3) which shows a test fixture into which the seat belt attachment bolt is threaded. In addition, the angle of pull is specified with respect to the axis of the bolt as well as the number of threads that must remain exposed, etc. We would particularly like to point out that paragraph S5.2(c)(1) states that attachment bolts can be tested "in a manner similar to that shown in Fig. 3." We interpret this to mean that the geometry of the attachment bolt "environment" as it exists in an actual vehicle can be simulated on the strength testing machine when the tensile strength of the bolt is verified. The following information explains our problem in more detail.

In one of our future model Jeep vehicles the attachment bolt "environment" is considerably unlike that portrayed in Fig. 3 of FMVSS No. 209. Our Figure 1, attached to this letter, shows a side view of the installation in this Jeep vehicle. It should be noted that the long shank of the bolt goes through a sheet metal "hat section" before being threaded into the anchorage nut. This "hat section" supports the shank of the bolt and prevents an excessive amount of bending as would occur if the long shank were fully exposed without the "hat section" being there. The anchorage plate with its attached nut is on the underside surface of the floor pan of the vehicle.

In verifying the strength of the attachment bolt we will therefore mount a section of floor pan complete with the "hat section" on the test fixture which is shown in Fig. 3 of FMVSS No. 209. Our adaptation of the floor pan section to the text fixture is shown in our attached sdetch, Figure 2. Naturally, in our strength test the attachment bolt will be "backed out" so as to expose two full threads as required in FMVSS No. 209. Also, we will obviously delete the sound insulation material which is used in the actual vehicle since it offers no lateral support whatsoever. Thus, the bolt shank would be supported in exactly the same way it is in the actual vehicle since we would be using the same thickness of metal for the floor pan and "hat section" as used in production. Finally, the diameter of the hole(s) in the "hat section" through which the attachment bolt passes would be the same as in the actual vehicle.

Your confirmation of our interpretation would be greatly appreciated.

Sincerely,

F.A. Stewart-- Vice President Safety & Reliability, JEEP CORPORATION

Att:2

(Graphics omitted)

(Graphics omitted)

ID: nht73-2.10

DATE: 09/25/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Sebring Vanguard Inc.

TITLE: FMVSR INTERPRETATION

TEXT: We have received your letter of September 7, 1973, to Mr. Vinson with its enclosures and appreciate your providing them.

In your "memo" on purchase orders you state that Sebring Vanguard "has decided that our vehicles are multi-purpose vehicles." The Vanguard, however, is not for purposes of the safety standards a multipurpose passenger vehicle, defined as "a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation." (In a recent notice, copy enclosed, we have proposed a change in this definition that would make it more restrictive.)

The Vanguard as we understand it is a "passenger car", defined as a vehicle designed for carrying 10 passengers or less, other than a multipurpose passenger vehicle, motorcycle, or trailer. Vehicle design, rather than actual usage, is the definitional determinant, and the fact that some purchasers of a Vanguard may use it off-road or as a replacement for MPV's does not change its category.

ENC.

SEBRING VANGUARD INC.

September 7, 1973

Taylor Vinson, Attorney NHTSA

In our continuing effort to keep N.H.T.S.A. informed of our development program concerning the VANGUARD line of electric vehicles, enclosed please find some new data.

You will note our initial vehicle, the CitiCar, does not resemble the fifty VANGUARD Sport Coupes that have been merrily humming around the nation. We will shortly petition the N.H.T.S.A. for an amendment to standards 204, 206 and 208. As I mentioned on the phone today, we also intend to petition for the commencement of the writing of new standards more appropriate for light-weight vehicles in connection with structural strength and crush distance.

You and your associates are cordially invited to our display at the National Transportation Defense Associations Conference at the Washington Hilton starting Sunday, 23 September through Noon of the 26th. We will be happy to provide you with additional new information at that time.

Sincerely, Robert G. Beaumont President

Encls.

(Graphics omitted)

September 7, 1973

TO: Taylor Vinson

FROM: Robert G. Beaumont

SUBJECT: Copies of Purchase Orders enclosed in the letter of 9/7/73

After careful determination our company has decided that our vehicles are multi-purpose vehicles.

Hawaiian Electric Co. . . This vehicle is used at the Waiau Guard House for security in and around the penal institution's site.

Smithtown High School . . . These two vehicles will be used strictly off-road by security guards for patrol at the two high school complexes.

Post Office Dept. . . . Information concerning this bid has come to us that indicates for a varity of reasons that we will be awarded it. Specific usage of these vehicles will be postal security both on-the-road and off-road, inside the Jersey City complex and outside the complex.

Department of Commerce . . . (see attached letter from Test and Evaluation) This is a reorder, clearly specified on the Purchase Order "special purpose." As the letter indicates, it is replacing a jeep which is a multi-purpose vehicle.

Modern Metal Magazine, August 1973. Please read exciting article on electric cars.

U.S. DEPARTMENT OF COMMERCE National (Illegible Word) and Atmospheric Administration

August 14, 1971

Robert C. Beaumont -- Vanguard Vehicles, Inc.

Dear Mr. Beaumont:

Here's the answer to your question on vehicle replacement:

The Vanguard electric car we purchased last December has been used in place of a jeep (4 wheel drive, 4 cylinder, (Illegible Words) He returned the jeep to our vehicle group with the recommendation it be junked.

The other two Vanguards we expect to get this month will replace (Illegible Words) from the General Services Administration. One is a Ford (Illegible Words) other is a Ford station wagon which will be (Illegible Words) special project requiring many trips on high speed highways.

I know you're aware that I can't publicly endorse a product by (Illegible Word). I can say however with no problem that your vehicle meets our requirements better than any we have found so far. For the many short trips our 35 people make around our (Illegible Words) have tried pick-up trucks, (Illegible Words) bicycles, in addition to jeeps, vans and station wagons. (Illegible Words) has come so close to meeting our need (Illegible Words) (Illegible Lines)

ID: nht73-2.11

DATE: 08/28/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: British Leyland Motors Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of August 21, 1973, in which you inquire whether British Leyland Motors Inc. may add to the consumer information leaflets for prospective purchasers, required by NHTSA regulations, the consumer information required by the Environmental Protection Agency.

As long as the information required by NHTSA is presented in conformity with 49 CFR 575, we have no objection to the inclusion within the same covers of additional information relative to EPA requirements. This would permit any format which include:EPA information without detracting from the clear and unconditional presentation of tabular information required under @ 575.6(a) of Part 575.