ID: nht75-4.24

DATE: 07/22/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: RVIA

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 22, 1975, in which you request an interpretation which excludes roof vent covers in recreational vehicles from the coverage of Motor Vehicle Safety Standard No. 205.

The National Highway Traffic Safety Administration (NHTSA) has received an identical request from Richards, Watson, Dreyfuss & Gershon on behalf of Hehr International, Inc. In response to that request, we have determined that roof vent covers should be included within the scope of Standard No. 205, but also concur that roof vent covers manufactured by the injection molding process are not susceptible to testing under the procedures found in USAS Z26.1. Consequently, we intend to issue in the near future proposed rulemaking which would establish surrogate testing procedures for this type of roof vent cover. Until such time as the new procedure is adopted, it is the intention of the NHTSA to take no action against manufacturers who do not certify that their injection molded roof vent covers meet the requirements of Standard No. 205 which incorporate the requirements of USAS Z26.1.

ID: nht75-4.25

DATE: 08/12/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Daniel W. Lang

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 15, 1975, in which you inquire as to the applicability of the National Traffic and Motor Vehicle Safety Act and the regulations promulgated thereunder to your client, Star Vision, as a manufacturer and installer of see-through fiberglass replacement tops.

Section 108(a)(2)(A) prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. This means that the installation of the top by Star Vision must not take a vehicle out of compliance with Safety Standard No. 216 or any other applicable safety standard. You should note that the requirements of section 108(a)(2)(A) apply to modifications of vehicles following their sale to a purchaser for purposes other than resale. It appears from the literature accompanying your letter that the tops are not installed on vehicles prior to their first sale. If they are, then Star Vision is subject to the notification, remedy, certification, and recordkeeping requirements of section 108(a)(1).

There is no specific requirement for testing the replacement tops in order to determine compliance with Standard No. 216. However, since the Act prohibits knowingly rendering inoperative any vehicle or part of a vehicle in compliance with an applicable safety standard, Star Vision is under an obligation to test its product if it has reason to believe that installation of the tops will substantially degrade the performance of the vehicle roofs. If the company has no reason to believe that installation will affect the safety characteristics of the vehicle, it is not obligated to conduct compliance tests.

The replacement tops appear to be subject to Safety Standard No. 205, Glazing Materials (49 CFR 571.205). As a result, Star Vision must certify the tops in accordance with section 114 of the Act (15 U.S.C. @ 1403).

If the tops do not comply with Standards Nos. 205 or 216 or any other applicable safety standard, or if they contain a malfunction or defect related to motor vehicle safety, the company will be obligated by sections 151-60 of the Act to notify the purchasers of the kits and to remedy the defect or noncompliance without charge. In addition, section 108(c) of the Act provides that compliance with the Act will not exempt a person from common law liability.

We trust that this information will be of assistance.

SINCERELY,

July 15, 1975

James Gregory National Highway Traffic Safety Administration Attention: Office of Chief Counsel

Re: "Star Vision See Thru Tops"

This office represents Star Vision, a division of Etanter Enterprises, of Los Angeles, California.

Star Vision, as the enclosed literature indicates, sells a see-through fiberglass replacement top for most makes of automobiles, both domestic and foreign. Installation requires the cutting of a hole in the roof of a vehicle. The top may be purchased in a kit for home installation or installed by a Star Vision distributor who purchases tops from the company. Star Vision occasionally in the past has installed a top itself.

I would appreciate your consideration in answering the following questions:

1. Does @108 of the 1966 Act or @103 of the 1974 Act control the activities of the company;

2. Does the company have to test its product to determine whether or not it complies with Safety Standard #216;

3. If yes, how, where, and when can a product be tested in a manner acceptable under the law;

4. What responsibilities does the company have as a manufacturer only; as a manufacturer-installer;

5. What responsibility does the company have under the law to a do-it-yourself purchaser of a home installation kit?

The company is most anxious to be adequately informed about any standards or requirements that might affect their business. A prompt reply will help us greatly.

Daniel W. Lang Additional notes and hints to aid the installation of the STAR VISION rooftop kit.

Some cars come equipped with a beam across the roof under the headliner. Make sure that when you lay out the panel that you leave enough clearance about 1 1/2". If the panel supplied for your car should clear all beams or bars. If for any reason it does not, do not proceed with the installation, measure the space that is available, ship us back the panel that you have with the size that you need and we will ship you the proper size.

BEFORE cutting or laying out the area to be cut, carefully feel around the headliner for any obstructions. Be careful that your car does not have a double roof, such as some late model GM cars. (Illegible word) Be sure to leave room near the windshield, some cars such as some Toyotas will have about 3" of extra support so stay back from that as you will not make a clean installation.

Stay back from the sun visors but as far as possible to the front of the car. The Star Vision roof kit is most beneficial as far forward as possible than over or behind the drivers head.

We have installed our STAR VISION rooftop kit in almost every kind of car. If you have any problems with your particular car do not hesitate to contact us, we will research the problem free of charge and forward you the help that you seek.

BE SURE TO READ ALL THE INSTRUCTIONS CAREFULLY. PROCEED WITH CARE, PATIENCE AND PRIDE.

STAR VISION

TRANSPARENT ROOF TOP KITS

Your STAR VISION Transparent rooftop kit will add years of enjoyment to your driving pleasure. The installations is simple, the following instructions will help you achieve professional results.

Lay the piece of transparent panel flat on the roof of your car. DO NOT remove the protective paper until last. Place the material as for forward as possible with out interfering' with the windshield mouldings and framework. (usually about 4 to 6 inches.) Measure the distance on both sides to ensure an even fit. Now measure the distance from the edges left and right to ensure that the panel is centralized. Use some masking tape to prevent the panel from moving once the exact position has been arrived at.

Use a crayon pencil to trace out the outline of the panel. The line should be 3/8 inch away from the panel to leave room for the moulding. Drill four (4) 5/16" holes thru the roof of your car at each corner of the panel. Drill thru the headliner. Now get in the car and note the four holes. Using a single edge razor blade cut out the headliner using the holes as reference points. (NOTE some cars such as Porsche 914 and Fiat X 1/9 do not have a headliner)

NOTE: If your car has thin metal bars suspended across to hold up the headliner, cut them in the middle and remove them completely. On older cars the headliner may be brittle and subject to tearing, use extreme caution in those cases. Before going to them next step check out the total travel of your jigsaw blade, make sure that when you start to cut out the panel, that the blade will not tear into the remaining headliner. You can shorten the blade by merely breaking of the tip about one inch. Use a soft cloth on the side of the jigsaw foot that is going over the part of the roof that will remain so that it will not scratch the surface.

Using a Jig saw with a 32 tooth per inch blade cut out the outlined panel. When completed use masking tape to adhere headliner to the roof so when the molding is applied the headliner will neatly tuck away. Adhere only about 1/4 inch to the headliner and adhere the rest to the roof see illustration.

When installing the molding always use the wooden tools supplied to "Lip" over the rubber. Should your hand slip, these tools will not scratch the plexiglass or paint. Also use the blunt end of the tool to pry apart the locking slot to insert the "lock" use a weak soap solution to aid installation.

Now you are ready to install the panel. First install the rubber molding as in illustration #2. Note that the molding has two different sides to accommodate different roof thicknesses. Any side can be used for the panel. Install the molding with the "lock" side up. After the panel is in place install the "lock" to ensure leak proofing. Note that your supplied with a few extra inches of molding. Trim excess to fit, but leave extra inch. Compress this extra inch, this will expand and make a leakproof seal. If for any reason your top leaks, use the tool supplied to lift up the molding and apply any commercial windshield sealer under the molding. Wipe away any excess. Use non abrasive cleaners only!

(Graphics omitted)

Eatanter Products presents another quality product, completely new in style, and guaranteed to enhance the appearance of your car.

Our transparent 'STAR VISION' roof top kit adds a whole new feeling of freedom and comfort to your driving pleasure, experience all the skies and sights under any weather condition.

To complement the appearance of your automobile, we are offering several tints to suit your personal car.

NEW!

STAR VISION

TRANSPARENT ROOF TOP KITS

VOLVO

Ford

FIAT

CHEVROLET

Mazda

VW

LOW COST FUN!

EAST DO IT YOURSELF

your car or ?.....?

12" x 24" $ 43.95 15" x 30" size $ 64.95 15" x 40" size $ 74.95

SHIPPING NOT INCLUDED.

We accept BANKAMERICARD.

Easy Do-it yourself!!!

Complete illustrated instructions in every kit. Also HELPFUL hints & TOOLS.

Enjoy all the skies and sights under all weather conditions with our new 'STAR VISION' rooftop kit. Our 'STAR VISION' rooftop kit is a low cost practical method to add prestige and value to your automobile. Our 'STAR VISION' is a full time accessory unlike the $ 450 to $ 800 'moonroofs' and sunroofs that can only be used under ideal weather conditions. Our roofkit is in use ALL THE TIME.

On the coldest nights or downpour rainfalls, when other sunroofs and tops are unusable, our rooftop kit is in use. Our kit is a permanent installation. There are no parts to wear out, no pulleys to crank, only pure enjoyment of great views and a whole new world of new sights, previously unattainable. Our STAR VISION rooftop kit is available in SMOKE, BLUE, GREEN, AMBER and clear. The kits are designed for easy installation and come complete with a set of thorough instructions. The only tools that are not supplied are a sabre saw, and a hand-drill. Average installation time is two hours.

ID: nht75-4.26

DATE: 06/10/75

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

TO: Hickman Hampel Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 10, 1975, petitioning the National Highway Traffic Safety Administration to authorize the use of tempered glass for motorcycle windscreens.

As you know, Standard No. 205 and USAS Z26.1 prohibits the use of tempered glass in motorcycle windscreens. The rationale for this requirement is that tempered glass when impacted either shatters, showering the operator with glass pellets, or crazes, thereby obscuring the operator's vision. Consequently, while there are definite safety advantages to the use of windshield wipers, it is our view that they do not offset the dangers cited above. Your petition, therefore, is denied.

We trust you will be able to find a laminated glass or acrylic which meets both your requirements and our standard, and wish you success in this endeavor.

Sincerely,

ATTACH.

March 10, 1975

Guy Hunter -- Safety Standard Engineer, National Highway Safety Traffic Administration

Re: Petition for Approval of Tempered Glass for Motorcycle Windscreens

Dear Mr. Hunter:

Thank you for your offer of prompt evaluation and assistance. I do hope, based on the overall improvement in safety for the motorcycle rider, you will permit the use of tempered glass in a motorcycle windscreen. My conversations with suppliers of laminated and tempered glass have convinced me tempered glass is probably the best product available for our needs. It apparently will take a great deal of physical abuse, has good transparency, and will tolerate the action of a windshield washer and wiper without undue scratching.

During our phone conversation, you mentioned the energy absorbing characteristic of laminated glass is the main reason it is exclusively specified for the windshields of closed vehicles. On a motorcycle, a windscreen made of acrylic, polycarbonate, or tempered glass can be fastened to the supporting fairing with breakable nylon bolts. The largest fairing manufacturer, Vetter, emphasises this safety feature. All their acrylic windscreens are fastened with nylon bolts which will break if a rider is thrown forward and impacts heavily against the windscreen. My windscreens will all be fastened with identical or comparable nylon bolts.

Please send me a letter giving me approval, at least on an interim experimental basis, to use tempered glass. Also, please initiate action which will hopefully result in formal approval of tempered glass under Code 205 and ANS Z 26.

Very truly yours,

John S. Hickman, President -- HICKMAN HAMPEL CORP.

ID: nht75-4.27

DATE: 10/17/75

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

TO: Mercedes-Benz of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter dated May 7, 1975, regarding an apparent conflict between the inertia load requirement of Standard 206, Door Locks and Door Retention Components, (49 CFR 571.206, S4.1.1.3) and the test procedure incorporated by S5.1.1.2, Paragraph 5 of SAE Recommended Practice J839b. I regret the delay in responding; your letter was mistakenly routed to our Docket Section and only recently came to our attention.

The answer to your question is that the requirement of S4.1.1.3 controls. It is sufficient that the door latch system withstand a 30g load only in the transverse and longitudinal directions. The system is not required to withstand this load in "any direction."

You asked further about the acceptability of centrifuge testing to demonstrate compliance with the inertia load requirement of Standard 206. Although S5.1.1.2 mentions "approved tests," NHTSA has consistently refused to approve or supervise the methods manufacturers use to test to the standards. Any government inertia load compliance testing will be done in accordance with paragraph 5 of SAE Recommended Practice J839b. Mercedes-Benz, of course, may employ any method it chooses to ensure compliance with this and other safety standards, as long as the product complies. We recognize that centrifuge testing may be highly useful in a variety of applications, and I do not by any means want to discourage innovations in developmental or compliance testing.

Yours Truly,

MERCEDES-BENZ OF NORTH AMERICA. INC.

May 7, 1975

National Highway Traffic Safety Administration

Subject: Request for Clarification; Federal Motor Vehicle Safety Standard No. 206 - Door Locks and Door Retention Components

Paragraph 4.1.1.3 (Inertia Loading) in the above Standard requires that the door lock may not disengage when a longitudinal or transverse load of 30g is applied to the door lock system.

SAE Standard J839b, May 1965, referenced in paragraph 5.1.1.2 requires that compliance with the previous paragraph be demonstrated by approved tests or in accordance with paragraph 5 of the SAE Standard. SAE J839b, paragraph 5.2 requires that the door lock system must withstand a 30g inertia loading in any direction.

Clarification is hereby requested on the directional loading requirements of FMVSS 206. Specifically, shall the loading be applied in any direction as specified in the SAE Standard, or in only the longitudinal and transversal directions as specified in the subject Standard.

We would also appreciate being advised as to the acceptability of loading the lock mechanism in a centrifuge for demonstration of compliance as opposed to dynamic inertial loading of the lock. Dynamic loading on a lock, as it occurs in an accident, would last only approximately one-tenth of a second, whereas centrifugal load testing subjects the test samples to the requirements for approximately one minute.

Should you require additional information concerning this request, do not hesitate in contacting this office.

Heinz W. Gerth Assistant Vice President

ID: nht75-4.28

DATE: 07/30/75

FROM: Z. TAYLOR VINSON FOR RICHARD B. DYSON -- NHTSA

TO: Truck Body and Equipment Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 3, 1975, forwarding a copy of an earlier letter that evidently was never received by us. You asked whether a garbage truck that contained an auxiliary driver's position on the right side of the vehicle, with a separate set of controls, needs to have a seat at the auxiliary position, and whether access to such controls as the heater, wipers, and lights from this position is required.

We consider the standards relating to the driver's position as relating to the normal position, and not to an auxiliary driving position. The answer is no, therefore, to both of the above questions.

Yours Truly,

TRUCK BODY AND EQUIPMENT ASSOCIATION, INC.

July 3, 1975

Richard Dyson, Assistant Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Enclosed please find a copy of a letter submitted to the NHTSA Office of Chief Counsel on May 19, 1975. In addition to the original cover letter, there were sales documents, a vehicle performance analysis, and several other pieces of background information.

We are still waiting to receive an interpretation on the vehicle in question.

If I can be of any help in expediting this matter please feel free to contact me.

Byron A. Crampton Manager of Engineering Services

TRUCK BODY AND EQUIPMENT ASSOCIATION INC.

May 19, 1975

James Schulz Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Recently a member of TBEA's Refuse Body Division raised several questions concerning the applicability of certain Federal Motor Vehicle Safety Standards to a specific vocational vehicle.

The vehicle in question is a relatively new concept in a solid waste removal vehicle (Garbage Truck) designed for optimum manpower utilization. From the enclosed sales literature the basic operating configuration is apparent - a one man operation. The projected cost savings associated with this design are achieved by the reduction in the number of people required to operate these vehicles during the collection cycle. Aside from the cost savings benefits appreciated through this side loading type of collection vehicle, additional benefits are achieved in the area of operating safety. The one man side loading unit has been proven to be substantially safer to operate than the conventional rear loading unit.

The vehicle's construction is as unique as its operation. The conventional truck cab is partitioned off into two separate areas. The left hand section, equipped with (1) designated seating position, is conventionally controlled to allow for normal road operation to and from landfill areas. The right hand section of the cab is altered by removing the door, lowering the floor and installing an additional set of hand operated driver controls. This modified section then becomes a convenient stand-up curbside work station. The 500 to 600 stops per day require constant movement in and out of the vehicle and this curbside/curb level operating position allows the driver to easily move and load the collection vehicle. As stated earlier, there is no door, door hardware, or seating system located at the curbside control position.

With these facts in mind, are we correct in assuming that no seating system and corresponding hardware is required for this auxillary control position? In addition, is control accessibility required (i.e. heater, wipers, lights) for this auxillary control position?

Should any clarification be required, please feel free to contact me.

Byron A. Crampton Manager of Engineering Services

ID: nht75-4.29

DATE: 03/27/75

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

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to General Motors' January 14, 1975, request for confirmation that a Type II seat belt assembly demonstrated to Messrs. Carter, Detrick, Hofferberth, Burgett, Hitchcock, and Herlihy of the NHTSA on December 17, 1974, satisfies the requirements of S7.1.1 of Standard No. 208, Occupant crash protection, that the lap belt portion "adjust by means of an emergency-locking or automatic-locking retractor." You describe the seat belt assembly as of the single retractor, continuous loop type, with a B-pillar-mounted "window shade" emergency-locking retractor, and a one-way frictional "D ring" buckle tongue which limits return of webbing to the lap belt portion from the torso portion when the belt assembly is in use. At the December 17 demonstration you specifically asked if the "D ring" frictional characteristics satisfy the criterion established in a September 25, 1972, letter to Renault, Inc. (copy enclosed), that "the friction in the buckle is low enough that the normal motion of the occupant against the shoulder belt cinches up the lap belt."

Section S7.1.1 requires adjustment of the lap belt portion "by means of an emergency-locking or automatic-locking retractor" and adjustment in most cases of the upper torso portion "by means of an emergency-locking retractor." The language permits some single retractor, continuous loop systems as long as the single retractor does "automatically adjust" the tension of the lap belt portion to prevent excessive belt slack. Because of the submarining danger of a slack lap belt, the NHTSA has restricted the acceptability of continuous loop systems under S7.1.1 in two areas.

One restriction was set out in the Renault letter and it is the basis for your question whether the GM "D ring" has a sufficiently low level of friction to qualify the lap portion as "automatically adjustable."

We would like to clarify that letter by emphasizing that, to conform to the requirements, the assembly must be designed by the manufacturer with a sufficiently low level of friction to qualify the lap portion as "automatically adjustable." Thus it is the manufacturer who determines whether or not the particular belt is designed to satisfy the requirements of the standard. In your December 17 demonstration we saw no evidence of design deficiency in limited use of that continuous loop system.

The other restriction was set out in a March 9, 1973, letter to General Motors (copy enclosed). It limits the use of "comfort clips" on the upper torso portion of continuous loop systems. The letter distinguishes continuous loop systems from systems that have separate lap and shoulder belt retractors. It concludes that "a comfort clip would be acceptable under S7.1.1 of the standard, so long as the shoulder belt is otherwise capable of adjustment as required by S7.1.1."

This restriction has since been the subject of an NHTSA proposal (Docket 74-32; Notice 1) which would restrict the use of "a device used to limit retractive action of an emergency-locking retractor for the comfort of the occupant" to seat belt assemblies that have "an individually adjustable lap belt." General Motors' response to that proposal and its anticipated use of a "window shade" device in future continuous loop systems assume that NHTSA intends to permit "belt tension relief" devices on all continuous loop systems. I would like to point out that this issue is outstanding in Docket 74-32.

Pursuant to your request for confidential treatment of this question on a new seat belt assembly, this letter will be made public only after the introduction of the new vehicle in question.

ID: nht75-4.3

DATE: 08/28/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Dennis Replansky

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent request for a discussion of what constitutes the manufacture of a new trailer when used components from an existing trailer are utilized. As you are aware, a newly-manufactured air-braked trailer must, in all but a few cases, be equipped with an air brake system that conforms to Standard No. 121, Air Brake Systems.

The use of new components in combination with used components to assemble a complete vehicle is a common practice in both truck and trailer operations. The National Highway Traffic Safety Administration (NHTSA) has recognized this commercial practice by establishing that the use of a new body on a used "chassis" that has already been certified does not constitute the manufacture of a new vehicle. In contrast, placing a used body on a new chassis that has never been certified as a vehicle has been determined to create a newly-manufactured vehicle that must be certified. This distinction did not present difficulty to trailer manufacturers in the past, when they were only required to meet the lighting requirements of Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

Since implementation of Standard No. 121, however, manufacturers have had to determine whether the particular assembly they undertake contains a used "chassis" which would not be required to meet the air brake standard. As a general matter, the NHTSA has stated that, as a minimum, the running gear (the axles, wheels, suspension, and related components sometimes known as a bogie) and main frame of the existing vehicle must be used to qualify as a used "chassis". However, the many different types of trailer construction make it difficult to determine what constitutes the main frame of some configurations. The NHTSA has concluded that the load-bearing structural member(s) which run the length of the vehicle and support the trailer will be considered to be the "main frame".

In the case of monocoque van construction, the trailer side walls which constitute the main load-bearing members through the length of the vehicle must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.

In the case of container chassis, the box frame that consitutes the main load-bearing member through the length of the vehicle must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle.

In the case of a platform trailer, the main frame members which run the length of the trailer must be reused in addition to the running gear, or else the rebuilding operation will constitute manufacturer of a new vehicle.

In the case of a platform trailer, the main frame members which run the length of the trailer must be reused in addition to the running gear, or else the rebuilding operation will constitute manufacturer of a new vehicle.

In the case of a tank trailer in which the tank serves the purpose of and replaces frame rails, the tank must be reused as the main frame in addition to the running gear, or else the rebuilding operation will constitute manufacture of a new vehicle. If a separate frame serves as the load-bearing member through the length of the vehicle, the tank could be replaced without the operation constituting the manufacture of a new vehicle. An inner tank may be replaced without certification as a new vehicle if the inner tank does not serve as a main load-bearing member.

Modifications of existing trailers to increase or decrease volumetric capacity or vehicle length are generally permitted without recertification. For example, the barrel of a tank trailer may be lengthened in response to the new weight limits without recertification of the vehicle.

In closing, it should be noted that Bureau of Motor Carrier regulations may differ on modification or rebuilding of vehicles in interstate commerce.

SINCERELY,

BLANK, ROME, KLAUS & COMISKY

July 24, 1975

James C. Schultz, Esquire Chief Counsel U. S. Dept. of Transportation - NHTSA

A number of our clients in the motor vehicle industry have raised questions concerning the applicability to rebuilt trailers of Federal Motor Vehicle Safety Standards, especially Standard #121, Air Brake Systems. Unfortunately, Standard #121 does not define "manufacture" for purposes of determining applicability.

The following factual situation has arisen most often:

A manufacturer's customer presently has trailers, commonly called "chassis", which are used solely for hauling containers. The equipment represents a considerable investment. At present, the customer's trailers are obsolete because they cannot carry the new I.S.O. containers. The customer has asked the manufacturer to modify the old trailers to permit them to use the new I.S.O. containers. The manufacturer will do this by taking the customer's old axle assembly (composed of the axles, brakes, wheels, drums, rims, tires and certain connecting parts) and adding to that a new structural frame, namely a box frame and fittings, to permit each trailer to carry the new I.S.O. containers.

Does Standard #121, Air Brake Systems, apply to such rebuilt trailers?

We would appreciate your guidance.

DENNIS REPLANSKY

CC: TAD HERLIHY

ID: nht75-4.30

DATE: 09/05/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Takata Kojyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Takata Kojyo's July 29, 1975, question whether Standard No. 208, Occupant Crash Protection, or Standard No. 209, Seat Belt Assemblies, prohibits on a "continuous loop" three-point belt system the use of a clip between the outboard attachment point of the lap belt portion and the sliding buckle tongue which engages the inboard attachment hardware. The clip is used to prevent the sliding buckle tongue from falling to the floor when the belt system is retracted after use.

Standard No. 209 contains no provision which prohibits use of the clip. Section S7.1.1 of Standard No. 208 requires adjustment of the lap belt portion of seat belts "by means of an emergency-locking or automatic-locking retractor." In continuous loop systems, the single retractor must meet this adjustment requirement as well as that for the upper torso portion. At this time, the NHTSA has interpreted S7.1.1 to permit the use of clips which restrict movement of the webbing, but a proposal is outstanding that would restrict the use of certain clips to seat belt assemblies that have "an individually adjustable" lap belt. The language of that proposal is intended to strictly limit the use of clips which restrict webbing movement. In any case, Standard No. 208 does not at this time prevent use of the clip you describe.

It is noted that the clip could be misadjusted so that slack is introduced in the lap belt, permitting submarining in the event of a crash. This problem could be avoided by permanently attaching the clip at a low enough position so that the belt would be automatically adjustable even for a 50th percentile 6 year old child without possibility of misadjustment. This permanent location could presumably still be high enough on the belt to provide for convenient stowage of the belt tongue after use.

SINCERELY,

July 29, 1975

James Gregory Administrator National Highway Transportation Safety Administration Department of Transportation

Re: Question of a part especially assemblied in a safety seat belt

May we ask your permission directly to ask a underneath question?

Regarding a model of Type II of safety seat belt sketched in an enclosed sheet -- a looped type with a jointless webbing --, as you see in it, there is a "CLIP" provided on the harnessing side of webbing of the seat belt, the CLIP of which is for preventing slipperily falling of "THROUGH TONGUE" along the webbing in unused case of the belt.

The present rules FMVSS 208 & 209 have both no inspections or descriptions concerning the CLIP. So we would ask you if providing or using such a clip on a seat belt is out of the Rule or the Spec, or is regarded being allowed.

We are sincerely looking forward your kind instruction.

Mitsuru Masada Chief of Development & Control Department for Takata Kojyo Co., Ltd.

SASH GUIDE

THROUGH TONGUE

WEBBING

CLIP

RETRACTOR

(Graphics omitted)

ID: nht75-4.31

DATE: 11/21/75

FROM: AUTHOR UNAVAILABLE; G. G. Mannella for James B. Gregory; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of November 11, 1975, requesting confirmation that a 1976 Ford Motor Company "deluxe continuous-loop seat belt system" satisfies the requirements of Section 7.1.1 of Standard No. 208, Occupant Crash Protection.

Section 7.1.1 requires adjustment of the lap belt portion of a front outboard seat belt assembly "by means of an emergency-locking or automatic-locking retractor" and adjustment in most cases of the upper torso portion "by means of an emergency-locking retractor." The language permits some single retractor, continuous loop systems as long as the single retractor does "automatically adjust" the tension of the lap belt portion to prevent excessive slack. Because of the submarining danger of a slack lap belt, the National Highway Traffic Safety Administration (NHTSA) has restricted the acceptability of continuous loop systems under S7.1.1 in two areas.

In the NHTSA's September 25, 1972, letter to Renault to which you refer, the level of friction in the tongue is discussed and our position is stated that it must have a sufficiently low level to qualify the lap belt portion as "automatically adjustable." In your recent demonstration of the tongue frictions in the Ford 1976 "standard" and "deluxe" continuous loop seat belt systems to NHTSA personnel, we saw no evidence of design deficiency in limited use of those systems.

The other restriction concerns the use of manual and automatic tension relieving devices on the upper portion of continuous loop systems. In our letters of March 9, 1973, and March 27, 1975 (to General Motors), June 13, 1975 (to Chrysler Corporation), and September 5, 1975 (to Takata-Kojyo), the NHTSA has limited the use of tension relieving devices to the upper torso portion of seat belt assemblies that have "an individually adjustable lap belt." It is our view that the 1976 Ford deluxe continuous loop system does not have "an individually adjustable lap belt" within the meaning of Standard No. 208. In this system slack which is introduced into the continuous loop by the "window shade" tension relief device on the upper retractor is directly transferred to the lap belt, thus increasing the risk of submarining if a crash should occur. I would like to point out that issues related to tension relief devices are, however, still outstanding in an NHTSA proposal (Docket 74-32, Notice 1).

I am enclosing a report on "Comfort and Convenience Analysis of Advanced Restraint Systems" of August 1975. This study, conducted by the NHTSA Safety Research Laboratory on a number of different safety belt designs concludes that: "Several aspects of the systems caused difficulties or confusion, but the single-loop 'window-shade' feature most frequently produced problems." In light of our mutual desire to improve safety belt usage levels, I should also like to again recommend to your attention the results of the earlier NHTSA sponsored study "Sources and Remedies for Restraint System Discomfort and Inconveniences" by Man Factors, Inc., that I sent to your company in January 1975.

SINCERELY,

Ford Motor Company

November 11, 1975

Dr. James B. Gregory Administrator National Highway Traffic Safety Administration

Re: Request for Interpretation of FMVSS 208 with regard to the Performance Requirements for a 1976 Ford Motor Company Deluxe Continuous-Loop Seat Belt System

Reference 1: September 25, 1972 letter from Richard B. Dyson (NHTSA) to Mr. Francois Louis (Renault, Inc.)

Reference 2: March 27, 1975 letter from Robert L. Carter (NHTSA) to David E. Martin (General Motors)

On October 23, 1975 we met with you and members of your staff to review and discuss the subject deluxe seat belt system which is contained on the driver side of one of the two 1975 Pinto vehicles that we left for your further review. This continuous-loop belt system incorporates many customer convenience and comfort features which we believe would result in increased belt usage. We also believe we have interpreted correctly the performance requirements of Section 7.1.1 of Standard 208 in light of the two subject references. However, Ford would appreciate receiving assurance that the Administration agrees with our interpretation.

It is the interpretation of the Ford Motor Company, based on the referenced documents, that we as a manufacturer have designed the subject seat belt system to provide:

1. Excellent fit of the lap strap with "automatic adjustment" while donning, due to the constant stored position of the free sliding tongue as specified in Reference 1, which states:

"The characteristic to be avoided is the tendency of the buckle to trap an excessive amount of webbing on the lap belt side of the buckle. This tendency is overcome . . . if the buckle slides down of its own weight while the assembly is stored on the B-pillar so that the next occupant must lengthen the lap belt as he fastens the buckle".

2. A belt system having a tension reliever which, during normal usage of the belt system, will not result in "excessive slack" in the lap strap.

In most instances an intentional, overt act on the part of the user is required to transfer any slack from the shoulder strap to the lap strap without cancelling the tension reliever. Such cancelling permits the retractor spring to "automatically adjust" the lap strap. However, in the unlikely event that occupant action would force "excessive slack" into the lap strap without cancellation of the tension reliever, it would be expected that a conscientious user of seat belts would recognize that he has loosened the lap strap and would readjust the belt system by a simple manual cancellation of the tension reliever.

Ford will provide on the visor sleeve and in the owner's manual instructions to customers indicating the possibility of a loose lap strap and what to do to correct it, such as:

Avoid a loose lap strap; if for any reason you have created slack in your lap strap, lean forward to cancel the tension reliever which will permit the shoulder strap retractor spring to snug the lap strap automatically. Your normal motions while driving will then again activate the tension reliever.

Hence, our belt system with the tension reliever, if used as instructed ("during normal usage"), will, as specified in Reference 2, "automatically adjust the tension of the lap belt portion to prevent excessive belt slack".

Ford also emphasizes that the free-sliding tongue overcomes many customer inconvenience items found in other systems by providing:

* convenient and consistently positioned parking of the tongue for easy access,

* freedom of movement without lock-up to extend webbing during donning due to the free sliding action,

* improved stowage of webbing since the retractor spring does not have to lift the tongue,

* no interference with seat adjustment.

An early response to this letter is urgently requested since this improved belt system is planned for production as a running change during the 1976 model year.

R. E. KIMBALL FOR

J. C. Eckhold Director Automotive Safety Office

ID: nht79-3.31

DATE: 09/11/79

FROM: AUTHOR UNAVAILABLE; Joan Claybrook; NHTSA

TO: Hon. T. F. Eagleton - U.S. Senate

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 23, 1979, letter asking whether brakes installed in vehicles in compliance with Standard No. 121, Air Brake Systems, can be modified or disconnected.

Your question asks whether these brake systems can be rendered inoperative. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.) states that --

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or an item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . . .

Whether a portion of the air brake system can be rendered inoperative depends, therefore, upon whether that part of the brake system was installed in or on the vehicle in compliance with an applicable safety standard.

The National Highway Traffic Safety Administration (NHTSA) has concluded that portions of the braking systems installed in compliance with the sections of Standard No. 121 that were invalidated by the court were not installed in compliance with an applicable safety standard. Accordingly, these devices can be disconnected by a commercial facility. In general, this means that the antilock devices installed on trucks and trailers may be disconnected or removed. However, other components of the braking system that were installed in compliance with the remaining applicable sections of the standard may not be rendered inoperative by a commercial facility. Therefore, entire braking systems cannot be removed from trucks and trailers. The NHTSA recommends that any modification of the braking systems be undertaken only after consulting with the manufacturer about the safest configuration of the particular vehicle.

In a related question, you ask who will bear the cost of disconnecting the braking systems, the manufacturer or the purchaser. We believe that the cost of modifying the braking system, depending on the circumstances, is a matter that may be negotiated between the parties.

SINCERELY,

United States Senate COMMITTEE ON APPROPRIATIONS

August 23, 1979.

Joan Claybrook Administrator National Highway Traffic Safety Admin. Department of Transportation

Dear Ms. Claybrook: A constituent of mine has written inquiring as to the guidelines for dealing with operative 121 brake systems in view of the recission of the regulation. He is concerned that continued operation of the brakes could be hazardous, but understandably he is reluctant to disconnect the brakes without some assurance he would not be libel.

A related question has to do with the cost of disconnecting and modifying 121 brakes. Does the manufacturer bear this responsibility or is it left to the purchaser of the vehicle?

I'd appreciate having your comments on these questions at the earliest time.

Thomas F. Eagleton United States Senator