ID: nht72-3.41

DATE: 02/24/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Lempco Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 18, 1972, on the subject of an automobile dealer's obligations regarding seatbelts in new cars.

Motor Vehicle Safety Standard No. 208 requires seatbelts to be installed at all seating positions. Under the requirements of the National Motor Vehicle and Traffic Safety Act, which we administer, it is a violation of the law to sell a vehicle that does not conform to an applicable standard. A dealer may not, therefore, sell an automobile that does not have the required number of seatbelts.

Although the act does not prevent the purchaser of a vehicle from removing the belts, after he has completed the purchase, we strongly advise him to leave the belts in and to wear them. A dealer who removes the belts after he has sold the vehicle does not violate the law, but he does his customer a disservice.

ID: nht72-3.42

DATE: 11/13/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 14, 1972, on the subject of the test dummy specifications of Standard No. 208. I apologize for our delay in replying.

The alignment procedures of S8.1.11 of the standard cause the head to be aligned so that its vertical axis is almost in the same plane as the dummy's back. The necks on most commercial dummies are made of rubber and are installed at such an angle that, as you have noted, the specified head alignment cannot be maintained. To correct this misalignment, the necks must be adjusted by shims or other means so that the correct alignment can be maintained.

The center of gravity of the upper thorax is approximated by dimensions C and D in Table I and Figure 1 of SAE Recommended Practice J963. The precise location may vary slightly from one dummy model to another due to variances in the distribution of mass in the thoracic area.

ID: nht72-3.43

DATE: 08/02/72

FROM: JAMES E. HOFFERBERTH FOR ROBERT L. CARTER--NHTSA

TO: Peugeot-Renault

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your teletype of July 8, 1972, regarding the question of a manikin's neck. In response to your specific need, and for your general information, I am enclosing a procurement specification for a 50th percentile test dummy recently let out for bid by the National Highway Traffic Safety Administration. This specification represents our present thinking on some of the desirable aspects of a test dummy. We are also working on the development of a proposed regulation that will define the dummy more precisely than standard No. 208 presently does, and, of course, that regulation may differ from the procurement specification.

In the meantime, as we have stated in the Federal Registar, any dummy that meets the requirements of Standard No. 208 may be used by a manufacturer to test its vehicles.

SINCERELY,

DEPARTMENT OF TRANSPORTATION

U.S. COAST GUARD TELECOMMUNICATIONS CENTER

NO 9499 Nov. 7, 1972 10#05

M. BUREAU PEGLEMFNTATION

A. M. ROBERT L CAPTER ASSOCIATE ASMINISTPATOR NHTSA

FOLLOWING PRESSING QUESTIONS ASKED TO MR TOMS AND YOU AT SAE CONFERENCE OF DETROIT IN MAY CONCERNING FMVSS 208 WE HAVE A VERY POSITIVE FIRST ANSWER IN DOCKET 69-7 NOTICE 19

HOWEVER, WE ARE STILL UNABLE TO COMPLETE OUR CONFIRMATION TESTS ON RESTRAINT SYSTEMS FOR 73 MODELS SINCE WE ARE NOT AWARE OF THE EQUIPMENT TO BE PROPOSED FOR DYNAMIC RESPONSE OF MANIKINS' NECK

CAN YOU ALREADY GIVE US SOME MORE DETAILS ON THESE SPECIFICATIONS SINCE OUR HOMOLOGATION SERVICES CANNOT GO ON WITH THEIR WORK

BEST THANKS

N. BUREAU CHIEF REGULATIONS DEPARTMENT AUTOMOBILES PEUGEOT

ID: nht72-3.44

DATE: 05/12/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Kangol Magnet Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your telegram of April 4, 1972, in which you asked whether it is permissible for the engine starting system of a vehicle conforming to the interlock requirements of Motor Vehicle Standard No. 208 to be operable when there are no occupants in the front seats by reaching through an open door or window to turn the ignition key.

Our reply is that the standard does not prohibit a system that operates in this way. Such a system is therefore permissible.

ID: nht72-3.45

DATE: 08/23/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Fairchild Semiconductor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 26, 1972, on the subject of the situations in which S7.4.3 of Motor Vehicle Safety Standard No. 208 permits operation of the engine starting system, notwithstanding the ignition interlock requirements of S7.4.1 of the standard.

Your first question is whether the engine may be restarted if the ignition switch is turned off after the driver has left the seat. Our reply is that restart would not be permitted except within a period of three minutes after the switch has been turned off. There is no sequential relationship between the operation of the switch and the driver's leaving the seat, so that the starting system will have to become inoperable if the driver has left the seat and has turned the ignition off, regardless of whether he turned the switch before or after leaving the seat.

Your second question is whether the engine may be restarted if the ignition switch is turned off, then on, and then the driver leaves his seat. Our reply is again that restart would not be permitted. S7.4.3 refers to operation "if the ignition has not been turned off". Once the ignition has been turned off, turning it on again will not revive the restart mode unless the engine is actually started again and then stopped with the ignition "on".

We have forwarded your check for a Federal Register subscription to the Superintendent of Documents. Enclosed you will find a copy of Notice 20, as you requested.

ID: nht72-3.46

DATE: 03/17/72

FROM: J.E. LEYSATH FOR E.T. DRIVER -- NHTSA

TO: U.M. Electrical Distributers Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 6, 1972, concerning warning buzzers for the automobile industry.

The National Highway Traffic Safety Administration has issued two safety standards which specify warning requirments. These requirements are given in Paragraph S4.4 of Standard 114 and Paragraph S7.3.1 of Standard 208. A copy of these two standards are enclosed for your review and further information.

You will note that these standards do not stipulate minimum requirements for the warning devices, and, at the present time, we have no plans to specify such requirements. The data sheet, however, which you enclosed will be useful to us should we specify such requirements in future amendments to these standards.

We appreciate your writing to us, and if we can be of any further service, please let us know.

ID: nht72-3.47

DATE: 10/13/72

FROM: CHARLES H. HARTMAN FOR DOUGLAS W. TOMS -- NHTSA

TO: Mr. Jesse R. Hollins

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your petition of August 15, 1972, as supplemented by your brother's letter of August 28, 1972, requesting our consideration of your seat belt warning system as a substitute for the warning and interlock systems currently specified in Motor Vehicle Safety Standard No. 208.

As we understand the operation of your system, one of its operating modes resembles the mode presently specified in S7.3.1 of the standard. Your system provides for the operation of a warning signal when the ignition is "on" and the seat belts at occupied front positions have not been operated. Section S7.3.1, considered by itself, would permit such a system, even though that section does not require the warning to operate unless the engine is operating and the vehicle is in a forward gear.

However, your system does not meet the requirement of S7.3.3 that the warning not operate when the vehicle is idling with the transmission in park or neutral position and the belts have not been operated. The argument presented in your brother's letter is that the sudden operation of the warning system when the transmission is placed in a forward gear would be an annoyance to occupants and would result in circumvention of the system.

The NHTSA position is that the convenience of being able to sit unbuckled in a parked car without the warning is such that this "quiet" period should continue to be required. It may be that some occupants will be bothered when the warning begins to sound as they place the car in gear. However, we are persuaded that the current system would be less likely to be circumvented than a system that has no period of non-operation.

The other operating mode of your system has no direct counterpart in Standard 208. As you describe it, returning the ignition to the "off" position will activate the warning system, even after removal of the key, until the belts are returned to their stowed positions. Our letter of August 17, 1972, explained that this will not conform to the requirement of S7.3.2 that the warning must not operate when the belts at occupied front positions have been operated.

We recognize that there are other possible alternative to the required interlock system as a means of encouraging seat belt usage, and several have been suggested. We consider it important, however, that these systems work in a substantially uniform manner, for maximum public safety, acceptance and convenience. On the basis of all the material we have received to date, including yours, we have decided that our present requirements represent the best combination for the alternative to passive restraints in the period 1973-1975. I therefore must deny your petition to substitute your system, or allow it as an alternative, for the interlock system.

ID: nht72-3.48

DATE: 10/18/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. Charles E. West

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of September 18, 1972, to Senator Warren G. Magnuson, Chairman, Committee on (Illegible Words) your automatic seat belt system has been referred to this office for reply.

Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, (copy enclosed) requires complete passive restraint systems in cars manufactured after August 15, 1973. This standard, as well as most of our standards, is written in performance terms and does not require the use of any specific device. Manufacturers are free to employ any system that will meet the requirements of the standard without any voluntary section on the part of the occupant, such as fastening a seat belt.

The National Highway Traffic Safety Administration is not generally engaged in hardware development, but rather, directs its research efforts toward the development of technical data to form the basis for motor vehicle safety performance standards. Perhaps you might care to contact vehicle manufacturers to see if they would be interested in your automatic belt system.

I am placing a copy of your letter in our Public Docket No. 69-7, which contains information relative to occupant restraint systems. We appreciated receiving the description of your system and your interest in motor vehicle safety.

ID: nht72-3.49

DATE: 09/05/72

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 26, 1972, on the subject of the conformity of the Volkswagen shoulder belt/knee bar system to the requirement of Standard No. 208. I apologize for our delay.

Your first question is whether the system would meet the requirements for a fully passive system under S4.1.2.1 and S4.1.3 if it were adjusted automatically and met the frontal and lateral crash protection requirements if S5.1 and S5.2 and if the vehicle conformed to Standard 216. Our reply is that a passive seat belt system of the type you describe would appear to satisfy the requirements of S4.1.2.1 and S4.1.3. It would also, however, be required to meet the requirements of S4.5.3. We cannot determine from your description whether the system is capable of fitting the range of occupants specified in S7.1, as required by S4.5.3.3.

Your second question concerns the possibility that the system could be used, with the shoulder belt either active or passive, to meet the second or third option for passenger cars manufactured between August 15, 1973, and August 15, 1975. You point to two variances between the Volkswagen system and the system contemplated by these options. S4.1.2.2 requires the installation of a Type 1 seat belt, whereas the Volkswagen system contains only a shoulder belt and a knee bar. S4.1.2.3 specifies either a Type 1 or a Type 2 seat belt assembly, neither of which is found in the Volkswagen system. It is our opinion that these variances are such that an amendment of the standard would be required to permit the use of the Volkswagen system under either S4.1.2.2 or S4.1.2.3.

With reference to both the passive system discussed in your first question and a petition for rulemaking in connection with your second, we are particularly concerned with the actual crash performance of a single diagonal belt restraint as opposed to the Type 1 or Type 2 belts permitted in Standard No. 208. The injury criteria presently included in Standard No. 208 may not differentiate between restraint systems with good crash force distribution, such as the air cushion, and those such as the single diagonal belt which could poorly distribute loads on real human occupants. Accordingly, we would appreciate your sending us accident data describing experience with the European type single diagonal belt.

ID: nht72-3.5

DATE: 06/08/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Labelmaster

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of May 11, 1972, submitting sample labels for retreaded tires, the samples which you submit, with the appropriate information properly filled in or clearly indicated by an "X" or other mark, will meet the requirements of S6.2 and S6.3 of Standard No. 117.