ID: nht72-4.14

DATE: 09/08/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 22, 1972, regarding the applicability of the requirements of S5 and S6 of Motor Vehicle Safety Standard No. 208 to trucks and multipurpose passenger vehicles conforming to S4.3.2 and to buses conforming to S4.4.2 of the standard.

Although sections S6.2 and S6.3 have been amended to refer to belt systems, the reference applies only to vehicles that are required by S4 to meet the injury criteria by use of seat belts. Vehicles manufactured under the options of S4.3.2 and S4.4.2 are not required by the terms of those sections to meet either the occupant crash protection requirements of S5 or the injury criteria of S6. Such vehicles are therefore not affected by the amendments to S6.2 and S6.3, and continue to be exempt from compliance with S5 and S6.

ID: nht72-4.15

DATE: 07/05/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 20, 1972, on the subject of the options which may be included in the unloaded vehicle weight of a passenger car under S8.1.1 of Standard 208.

The definition of "unloaded vehicle weight" is intended to include a vehicle equipped with any combination of optional items that are installed by the factory or by the dealer with the factory's authorization. The weight of equipment installed by the dealer without authorization by the manufacturer would not be includable.

To answer your question by use of your example, you must concern yourself with both factory optional air conditioning and with dealer optional air conditioning that is authorized by the factory.

ID: nht72-4.16

DATE: 10/27/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 18, 1972, on the subject of warning system and interlock system operation under Standard No. 208.

The table enclosed with your letter lists all combinations of front seat occupancy and front seat belt usage that are possible in a vehicle with two front seating positions. You ask, as to each of these combinations, whether you have correctly understood the operation of the interlock and warning system. We find that a large majority of the combinations shown in your table are correctly interpreted but that a few are in error or are in need of further clarification.

The primary source of error in the table seems to be confusion as to the effect of the driver's absence from his seat. Under S7.4.1, the conditions under which a failure to operate the belt will require the interlock system to prevent engine operation are specified in S7.4.1(a) and (b). Each of these conditions specifies that the driver's position is occupied, so that if the driver is not in his seat neither condition (a) nor condition (b) is met and interlock system operation is not required.

Applying this interpretation to the matrix in your table discloses that two cases, 18 and 25, are incorrectly interpreted. In each of these cases the driver is not in his seat and the interlock would not be required to operate, even though in both cases the passenger has operated his belt out of sequence and in one case the belt at the vacant driver's position is buckled.

Although interlock operation is not required in cases 18 and 25, a manufacturer would be permitted to design his interlock system to operate in these circumstances. Eighteen and 25 should therefore be treated in the same manner as the other cases in the matrix (11-17, 24) in which interlock operation is shown to be within the manufacturer's discretion.

The warning system, which is required to operate when the ignition is in the start position if the operations required by S7.4.1 to start the engine have not been performed, is on a different footing under conditions where the interlock is permitted, but not required, to operate. Under such conditions, S7.3.5.4 does not require the warning to operate in the start position. We would, however, strongly recommend that the warning system be designed to operate whenever the interlock prevents engine operation, regardless of whether or not S7.4.1 requires operation.

One other case in your table should also be corrected. Under Case 4, you indicate that interlock operation would be within the discretion of the manufacturer. It is our opinion that if the driver has properly operated his belt the interlock and warning system should not operate, even though the belt at the empty passenger's seat has been fastened.

Please advise us if you have further questions.

ID: nht72-4.17

DATE: 02/01/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Borg-Warner Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your request of January 18, 1972, for a letter confirming the written interpretation of Standard 209 concerning automatic locking retractors given to Toyota on November 10, 1971.

We understand from your letter that the "Borg-Warner Maji-Buckle" is identical to the combination buckle and retractor shown us by Toyota. A seat belt with the Maji-Buckle" is, therefore, considered to be equipped with an automatic locking retractor. A retractor is classified according to its operation, not its design, and the "Maji-Buckle" operates in the manner prescribed by Standard 209 for automatic locking retractors.

The comments made to Toyota concerning the test required by S5.3(a)(6) also apply to the "Maji-Buckle."

Please advise us if we can be of further assistance.

ID: nht72-4.18

DATE: 10/24/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Rose Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 19, 1972, to Mr. Francis Armstrong, concerning seat belt model designations.

The intent of paragraph S4.1(k) of Federal Motor Vehicle Safety Standard No. 209 is to require different model numbers for seat belt assemblies that differ in basic design concept. We would not consider belt assemblies that differ only in the size or number of cross threads in the webbing to be separate models. On the other hand, a belt assembly that incorporates a push button type buckle would be considered a separate model from an assembly that incorporates a lift cover type buckle.

If we can be of further assistance, please do not hesitate to contact us.

ID: nht72-4.19

DATE: 11/10/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: British Standards Institution

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 25, 1972, concerning the application of S4.3(c) of Standard No. 209 to an upper torso anchorage bolt used to attach a seat belt assembly that has a continuous length of webbing for upper torso and pelvic restraint.

Our letter of July 20, 1972, to Standard Triumph, to which you refer, did not rule directly on the question of whether a bolt on the upper torso side of a continuous loop assembly would be considered to "secure the pelvic restraint" within the meaning of S4.3(c). It is our opinion that some part of the pelvic force is transmitted to such a bolt and that it is therefore required to conform to S4.3(c). Because the bolt cannot be used for more than one assembly, the applicable force requirement is 5,000 pounds.

ID: nht72-4.2

DATE: 01/28/72

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Docket 69-7

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: CONVERSATION WITH VOLKS WAGEN REPRESENTATIVE

On Tuesday, January 25, 1972, I received a telephone call from Joseph Kennebeck of Volkswagen of America, Inc., concerning the determination of "rated cargo and luggage capacity weight" under section S8.1.1(a) of Standard 208. Volkswagen determines its cargo and luggage capacity by multiplying the number of designated seating positions by the average occupant weight and subtracting this weight from the gross vehicle weight rating. His question was whether the cargo weight determined in this fashion would be the cargo weight used in those tests in which some seating positions are not occupied. In particular, the third option available to passenger cars between January 1, 1972, and August 15, 1973, provides for a test with occupants only at the front outboard positions, (S4.1.1.3.1), and he asked whether the cargo weight would be as indicated above or some larger weight.

I informed him that Volkswagen could use the cargo capacity as determined with a fully occupied vehicle for all tests in which the vehicle is less than fully occupied, as in S4.1.1.3.1.

ID: nht72-4.20

DATE: 02/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 7, 1972, in which you stated your understanding of how Standard 210 applies to two shoulder belt assembly configurations.

In Figure 1, you show a shoulder belt that passes through a slotted plate (A) bolted to the roof rail. Contrary to the impression you have received, the plate is not a part of the anchorage, but is rather a part of the seatbelt assembly. The anchorage consists of the reinforced roof rail structure, including the bolt hole and any retaining ridges or projections on the roof rail. Plates such as Hardware (A) that bolt onto the roof rail are similar in function to the floor mounted attachment plates that have always been considered as part of the seatbelt assembly, and are similarly treated.

The same remarks apply to the plate shown as (B) in Figure 2. This is also a part of the seatbelt assembly, and not part of the anchorage.

The anchorage strength test should be conducted as you show in Figure 3 and 4, using the complete Type 2 assembly provided with the vehicle.

We regret the misunderstanding about the classification of the attachment hardware and hope that it has not caused you inconvenience.

YOURS TRULY,

NISSAN MOTOR CO., LTD.

February 7, 1972

Lawrence Schneider National Highway Traffic Safety Administration

This is in confirmation of my discussion with Mr. Hunter and Mr. Hitchcock on February 2, 1972, regarding MVSS 210.

Through the above meeting, we understood the following:

1. In the case of Figure 1, the hardware (A) attached on the roof side rail should be treated as an upper torso seat belt anchorage.

2. In the case of Figure 2:

a. The hardware (B) should be treated the same as Figure 1.

b. The intermediate hardware (C) should not be treated as a seat belt anchorage, but handled as a hardware which must conform to MVSS 209 requirement.

3. Seat belt anchorage strength test should be conducted by using the actual Type 2 seat belt set including retractors, and hardware as described in Figure 3 and 4.

NISSAN MOTOR COMPANY, LTD.

Satoshi Nishibori Engineering Representative Liaison Office in U.S.A.

Fig 1

[GRAPHICS OMITTED]

Fig. 2

[GRAPHIC OMITTED]

FIG 3

[GRAPHIC OMITTED]

ID: nht72-4.21

DATE: 05/01/72

FROM: AUTHOR UNAVAILABLE; Charles H. Hartman; NHTSA

TO: Rose Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of March 23, 1972, and March 27, 1972, concerning our previous letter to you dated March 10, 1972.

We recognize your contribution to safety and your deep personal involvement in child harnesses. Harnesses, such as yours, offer many desirable features. The child is free to move about, and he is adequately restrained if the harness system is properly adjusted and anchored. Effective harness systems can probably be produced at modest cost.

There certainly can be no objection to the upper torso restraint provided by a good harness system. Indeed, this is a very important feature which is required because of the child's special skeletal structure.

On the other hand, restraints which are anchored to inadequate structures or which allow excessive motion of the child in a crash cannot be condoned. Actual thirty mile-per-hour, sixteen g dynamic sled tests of child harnesses anchored as you recommend have shown that a severe problem exists with the anchorage system. Quoting the University of Michigan Highway Safety Research Institute Report, Child Seat and Restraint Systems Test Program, DOT/MS-000-376, "In the test at 30 mph the adult seat back broke away due to the load imposed by the restraint system tether. This allowed the dummy to move forward far enough to cause potential contact with the vehicle interior." This test was conducted using a heavy duty Bostrom truck bucket seat and utilized only the thrity-pound, three-year-old child dummy, restrained by a Sears small harness. The present typical seat back strengths are, thus, inadequate to support a harness system which depends upon the seat back. It is our intention to encourage improvements in seat back strength for automobile production by future rule making action.

Since your harness is recommended for children up to fifty pounds and since most passenger car seats are not as strong as the test seat, we expect the situation to be even more serious in realistic usage conditions which also normally encounter appreciably higher load levels in thirty mile-per-hour crashes. This is why we object to your system of anchorage. Thus, our position is as stated in our previous letter to you.

We hope that you will consider other methods of anchoring your child harness which will prevent seat back failure and resulting excessive occupant excursions.

We appreciate your sincere interest and concern in this matter. We emphatically do believe that child harnesses play a vital role in child restraints.

ID: nht72-4.22

DATE: 03/17/72

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Electrical Testing Laboratories, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter dated January 19, 1972, to Mr. Eugene Laskin, regarding questions you have reisting to interpretations of demonstration procedure descriptions contained in paragraphs 5.2j and 5.2k of Federal Motor Vehicle Safety Standard (FMVSS) No. 209.

The answers to your questions are as follows:

1. Paragraph S5.2j - The phrase "within a period of 50 milliseconds" refers to the rise time of the acceleration only with the webbing movement measured from start of acceleration to lockup. The movement occurring after lockup due to natural webbing elongation and webbing compaction around the retractor spool is not measured. Webbing movement exclusive of the above-mentioned compaction and elongation can be measured by using a rotary of linear potentimeter reading out on a dual channel oscilloscope or oscillograph along with the readout of the time vs acceleration trace.

2. Paragraph s5.2k - The present standard does not specify any particular sequence for performing the 10,000 lockup cycles on emergency locking retractors as part of the total 50,000 cycles. This office presently has two laboratories performing the compliance tests in the following manner.

Laboratory A - One lockup cycle out of every five using the commercial Carlson cycling apparatus.

Laboratory B - 40,000 cycles of extension and retraction followed by 10,000 lockup cycles.

3. The methods presently employed by our test laboratories in actuating the lockup mechanism is to accelerate the retractor by means of compressed air, thus effecting the lockup.

This method of lockup is employed by our laboratories because a retractor that is sensitive both to vehicle acceleration and tilting would most frequently be locked by acceleration when installed in a vehicle.

This is not to say that you are compelled to cycle your retractors by accelerating them. If the locking mechanism is the name for both modes (e.g. a (Illegible Word)), it may make little difference whether the retractors are accelerated or tilted. However, if our test disclose a cycling failure, you will be obliged to show that your method was, in fact, equivalent to ours.

Should you require any further details or information regarding the test procedure for emergency locking retractors, please contact Mr. R. Jasinski of this office.

Thank you for your interest in auto safety.