ID: nht72-4.23

DATE: 05/12/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: United States Testing Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 5, 1972, in which you suggested that S4.3(d)(3) of Motor Vehicle Safety Standard No. 209 is not appropriate for buckles located between the front seats.

Although you are correct in saying that the requirement was originally developed to guard against the buckle's being opened by the pressure of the steering wheel, there is a chance that compressive forces will also affect buckles located between the seats. Even though the tests may be more difficult to administer, these buckles are not exempt under the present version of the standard, and it is not correct to say that the requirement is not applicable to them.

We do not suggest by this that the requirement could not be changed in response to an adequately supported petition. However, the requirement as it now stands applies to all buckles, wherever located.

ID: nht72-4.24

DATE: 07/20/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Standard-Triumph Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 28, 1972, in which you requested formal confirmation of the interpretation of S4.3(c) of Motor Vehicle Safety Standard No. 209 given you informally on June 22.

The requirements of S4.3(c) apply to bolts used to secure the pelvic restraint of a seat belt assembly. They do not apply to bolts used to secure the upper torso restraint. Bolts for the upper torso restraint are therefore regulated with respect to their strength only by the assembly performance requirements of S4.4(b).

The reference to "shoulder bolts" in S4.3(c) relates to the design of the bolt and not to the manner of its use. Pelvic restraints are often attached to the vehicle by such bolts, hence the reference to them.

ID: nht72-4.25

DATE: 09/18/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: British Standards Institution

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of July 26, 1972, concerning the seat belt retractor test protector test procedures of section S5.2(k) of Motor Vehicle Safety Standard No. 209.

In our initial reply of August 21, we stated that the belt was to be retracted completely during the cycling, even though some vehicle installations might prevent complete retraction. After further examining the consequences of this position, we have concluded that it is in error.

The intent of the cycling sequence is to reflect the normal use of the belt over time. If the belt is designed to be installed in a vehicle in such a manner that during normal cycling a part of the webbing cannot be wound onto the retractor, a compliance test should employ the same restrictions of movement. We therefore conclude that you are correct in considering a belt to be fully retracted for purposes of Standard No. 209 when it is retracted as fully as the geometry of its installation permits.

Sincerely,

L R Schneider -- Chief Counsel, US Department of Transportation, National Highway Traffic Safety Administration

July 26, 1972

Dear Sir

F M V S S 209

We are writing as a National Test Laboratory concerned with automotive safety testing and, in particular, seat belt assemblies to your specifications. Some parts of the specification are open to interpretation and we are, of course, concerned that we should operate our test procedure in the accepted manner.

In particular, we would request that you confirm our test methods in connection with Clause S5.2(k) "Performance of retractor". In the case of emergency locking retractors, we proceed as follows:-

1) Corrosion test.

2) Manual withdrawal retraction for 25 cycles.

3) 2500 cycles from full extension to full retraction with an application of 20 lbs force at full extension.

Note (i) As this force is dynamically applied, the mass concerned is less than 20 lbs.

(ii) Full retraction is assumed to mean the full possible retraction of the assembly when installed in a motor vehicle. This will be less than the capability of the retractor, but reflects the practical conditions providing the installation data is obtained from the belt submittor.

4) Temperature resistance test.

5) 2500 additional cycles as (3)

6) Dust test.

7) Manual withdrawal and retraction for 25 cycles.

8) For emergency locking retractors, 45000 cycles operated between the limits of 50% extraction and 100% extraction.

Note (i) The stroke will therefore be half of that applied for the initial 5000 operations and will fully extract the webbing on each occasion.

(ii) Because full extraction occurs, the 20 lbs force will be applied during the 45000 operations as well as the previous 5000 operations.

9) During the initial 5000 operations, 1000 locking operations occur and during the final 45000 operations, 9000 locking operations occur. The locking operations are applied at any point between 50% extraction and 100% extraction.

10) The 20 lbs force is applied on every cycle including the locking cycles.

We should be grateful for your assistance in this matter as a considerable quantity of test work is awaiting clarification of this particular test procedure.

Yours faithfully for Director, RAC DANDY --Senior Engineer Head of Mechanical Section

ID: nht72-4.26

DATE: 03/16/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Wingard Limited

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 10, 1972, regarding interpretation of certain parts of Federal Motor Vehicle Safety Standard No. 209, Seat Belt Assemblies.

In regard to your question on performance of retractors, the standard specifies that "an emergency-locking retractor or a non-locking retractor attached to upper torso restraint shall be subjected to 45,000 additional cycles of webbing withdrawal and retraction between 50 and 100 percent extension." This requirement applies to all emergency-locking retractors whether attached to the pelvic or upper torso restraint and only to those non-locking retractors that are attached to the upper torso restraint.

In regard to the 45,000 additional cycles, one cycle consists of extending the webbing from 50 to 100 percent extension and return to 50 percent.

Please do not hesitate to contact us if we can be of further assistance.

ID: nht72-4.27

DATE: 01/01/72 EST.

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: British Standards Institution

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 26, 1972, on the subject of seat belt retractor testing under S5.2(k) of Motor Vehicle Safety Standard No. 209.

Your outline of the emergency locking retractor test procedure is essentially correct. During the initial 5,000 cycles, however, the belt is to be retracted completely, even though some vehicle installations may prevent complete retraction. The assumption in (3)(ii) of your letter is therefore incorrect.

The remaining points in your interpretation are correct.

Sincerely,

ATTACH.

British Standards Institution

L R Schneider -- Chief Counsel, U S Department of Transporatation, National Highway Traffic Safety Administration

JULY 26, 1972

Dear Sir

F M V S S 209

We are writing as a National Test Laboratory concerned with automotive safety testing and, in particular, seat belt assemblies to your specifications. Some parts of the specification are open to interpretation and we are, of course, concerned that we should operate our test procedure in the accepted manner.

In particular, we would request that you confirm our test methods in connection with Clause S5.2(k) "Performance of retractor". In the case of emergency locking retractors, we proceed as follows:-

1) Corrosion test.

2) Manual withdrawal retraction for 25 cycles.

3) 2500 cycles from full extension to full retraction with an application of 20 lbs force at full extension.

Note (i) As this force is dynamically applied, the mass concerned is less than 20 lbs.

(ii) Full retraction is assumed to mean the full possible retraction of the assembly when installed in a motor vehicle. This will be less than the capability of the retractor, but reflects the practical conditions providing the installation data is obtained from the belt submittor.

4) Temperature resistance test.

5) 2500 additional cycles as (3).

6) Dust test.

7) Manual withdrawal and retraction for 25 cycles.

8) For emergency locking retractors, 45000 cycles operated between the limits of 50% extraction and 100% extraction.

Note (i) The stroke will therefore be half of that applied for the initial 5000 operations and will fully extract the webbing on each occasion.

(ii) Because full extraction occurs, the 20 lbs force will be applied during the 45000 operations as well as the previous 5000 operations.

9) During the initial 5000 operations, 1000 locking operations occur and during the final 45000 operations, 9000 locking operations occur. The locking operations are applied at any point between 50% extraction and 100% extraction.

10) The 20 lbs force is applied on every cycle including the locking cycles.

We should be grateful for your assistance in this matter as a considerable quantity of test work is awaiting clarification of this particular test procedure.

Yours faithfully for Director

R A C DANDY -- Senior Engineering; Head of Mechanical Section

ID: nht72-4.28

DATE: 03/08/72

FROM: JOHN G. WOMACK FOR RICHARD B. DYSON -- NHTSA

TO: Volvo, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 23, 1972, in which you posed three questions concerning the test procedures of Standard 209.

Your first question concerns the passage in S5.2(j) which states that the retractor is subjected to an acceleration of 0.70 within a period of 50 milliseconds. . . . ' Your question is whether the measurement of withdrawal begins at the caset of acceleration or at the point at which an acceleration of 0.70 is achieved. Our answer is that the measurement begins at the onset of acceleration. The withdrawal that occurs within the 50 millisecond rise time will be included in determining whether the 1 inch limit has been exceeded.

Your second question concerns the sequence in which the retractor locking mechanism will be activated under S5.2(k). It is your understanding that the 10,000 locking cycles will be evenly distributed among the total 50,000 cycles. Because the standard is silent as to the sequence of testing, an even distribution is not the only test method that could be used. At the present time, the agency has one contractor who is testing in this manner and one who is testing with 40,000 cycles of extension and retraction followed by 10,000 lockup cycles. If it should prove that the latter method is more severe, however, due to the excessive wear on the same spot that you anticipated, we would (Illegible Word) to use that method and conduct our tests by evenly distributing the lockup cycles.

Your third question concerns the manner in which lockup is to be achieved during the cycling test for retractors that lock either by acceleration or by tilting. The intent of the cycling procedures is to duplicate the usage actually encountered by a retractor in a vehicle. If the retractor is sensitive to webbing withdrawal and to the acceleration of the vehicle, then the lockup mode that would be (Illegible Word) often stressed over the retractor's lifetime would be the webbing withdrawal mode and the 10,000 cycles would be cycles of lockup through webbing withdrawal. If the retractor is sensitive only to vehicle acceleration and to tilting,the most frequent cause of lockup would be vehicle acceleration and our tests will be conducted by accelerating the retractor. This is not to say that you are compiled to cycle year retractor by accelerating them. If the locking mechanism is the same for both modes (e.g. a pendulum), it may make little difference whether the retractors are accelerated or tilted. However, if our tests disclose a cycling failure, you will be obliged to show that your method was in fact equivalent to ours.

ID: nht72-4.29

DATE: 09/12/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Cody Chevrolet Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 1, 1972, to the attention of Mr. Jerome Palist of our White Plains, New York Office, concerning certification requirements for a vehicle which you describe and indicate will be used by a college to transport ball teams and school personnel, but will not be equipped with flashing lights or other special school bus equipment. You apparently wish to know whether you must consider this vehicle as a school bus for purposes of certification to Federal requirements.

"School bus" is defined in the motor vehicle safety standards to mean a bus "designed primarily to carry children to and from school, but not including buses operated by common carriers in urban transportation of school children" (49 CFR 571.3). Based upon the description you provide, the NHTSA would not consider the vehicle you describe to be a school bus. For purposes of certification to Federal requirements (49 CFR Parts 567 and 568), therefore, "gross vehicle weight rating" should not be computed under the minimum values specified for school buses. In addition, the requirement that vehicle type be inserted on the certification label should be met by inserting, "BUS."

This letter should not be construed to mean that the NHTSA takes a position as to whether this vehicle need, under State law, conform to requirements for school buses. The State must determine the scope and application of its own laws.

ID: nht72-4.3

DATE: 09/20/72

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Docket 69-7

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: Interpretation of Dummy Placement for Crash Test Requirements of S4.1.2.3.1(d) and (e).

A Ford Motor Company representative has informally noted that Docket 69-7, Notice 16, published February 24, 1972, does not clearly indicate whether, in S4.1.2.3.1(d) and (e), three dummies are simultaneously placed in all front seating positions for a single crash test, or whether two separate crashes are conducted, with two dummies in the outboard front seats for a S4.1.2.3.1(d) crash and a single dummy in the center front seat for a S4.1.2.3.1(e) crash.

Although a manufacturer may choose, for reasons of convenience, to conduct a combined crash test or individual crash tests for S4.1.2.3.1(d) and (e), the test intended by S4.1.2.3.1 is a combined test and the NHTSA will therefore conduct its compliance tests with dummies simultaneously placed in all front seating positions.

ID: nht72-4.30

DATE: 11/02/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Fordyce; Mayne; Hartman; Renard; & Stribling

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 10, 1972, requesting information on requirements applicable to the trucking industry regarding the reporting of numbers of vehicles produced. You also ask whether a person who adds a fifth wheel to complete a truck is a manufacturer who is subject to the requirements.

Section 573.5(b) of NHTSA "Defect Reports" regulation (49 CFR Part 573) requires manufacturers of motor vehicles to report, on a quarterly basis, the total number of the manufacturer's vehicles by make, model, and model year, if appropriate, produced or imported during that quarter. This requirement applies to all manufacturers of complete or incomplete motor vehicles, including manufacturers of trucks. A person who adds a fifth wheel to an incomplete vehicle and completes the vehicle is considered to be a manufacturer under section 573.3 of the regulation, and is required to report production figures as part of his quarterly reports.

ID: nht72-4.31

DATE: 10/01/72 EST

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Chesapeake Marine Products

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of September 21, 1972, you ask, "are there any "partial built" certification standards which would govern our operation as a boat trailer distributor?"

I enclose a copy of 49 CFR Part 567, Certification, and Part 568, Vehicles Manufactured in Two or More Stages, for your review as to their applicability to your operations. They apply to manufacturers who initiate or complete the manufacturer of motor vehicles. They do not, however, impose an obligation upon a distributor of boat trailers who does not alter the vehicle he receives from a manufacturer in a manner that affects compliance with applicable standards.