ID: nht88-2.52

TYPE: INTERPRETATION-NHTSA

DATE: 06/20/88

FROM: BYUNG M. SOH -- TARGET MARKETING SYSTEMS, INC, MARKETING DIRECTOR

TO: OFFICE OF CHIEF COUNSEL, NHTSA

TITLE: DOT RULING OR OPINION

ATTACHMT: ATTACHED TO LETTER DATED 9-13-88 TO BYUNG M. SOH FROM ERIKAZ. JONES

TEXT: Please find in enclosuree photocopies pertaining to informations on two devices which we intend to import to U.S.A. Even though these are not well written, I hope that the copies contain enough informations with which you could give us your opinion whet her these devices require approvals from D.O.T.

These are 1. Logical beam: foglight converter 2. C.L.S. system: head-lamp intensity modulator

These devices do not require to change existing lighting devices.

We believe that these devices enhance road safety.

If you require further information, we can be reached at (312)-673-7333 or by fax. (312)-673-7356.

Thank you.

ENC: 1 one set of photocopies of 'logical beam' and 'C.L.S. Systems'

ID: nht88-2.53

TYPE: INTERPRETATION-NHTSA

DATE: 06/20/88

FROM: LEWIS S. BUCHANAN -- NHTSA DRIVER CONTROL PROGRAMS BRANCH OFFICE OF ALCOHOL & STATE PROGRAMS TRAFFIC SAFETY PROGRAMS

TO: LARRY P. EGLEY

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/09/89 FROM STEPHEN P. WOOD -- NHTSA TO LARRY P. EGLEY; REDBOOK A33 [2]; STANDARD 108; LETTER DATED 01/17/89 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 3028; LETTER DATED 05/23/89 FROM LARRY P. EGLEY TO KAT HLEEN DEMETER -- NHTSA; LETTER DATED 09/10/88 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 2530; REPORT DATED 09/10/88 FROM LARRY P. EGLEY, REQUEST FOR EVALUATION / INTERPRETATION OF PROPOSED INVENTION SUDDEN STOP FLASHER [SSF]; REPORT DATED 09/ 07/88 FROM LARRY P. EGLEY, AN APPEAL FOR VARIANT INTERPRETATION OF NHTSA STANDARDS AS THEY RELATE TO BRAKE LIGHTS AND THE SUDDEN STOP FLASHER [SSF]; LETTER DATED 07/13/88 FROM KATHLEEN DEMETER -- NHTSA TO LARRY P. EGLEY; LETTER DATED 06/23/88 FROM LARRY P. EGLEY TO RALPH HITCHCOCK -- NHTSA; OCC 2256; LETTER DATED 06/09/88 FROM LARRY P. EGLEY TO LEWIS BUCHANAN

TEXT: Dear Mr. Egley:

This is in reply to your letter to me regarding your Sudden Stop Flasher.

I do not work in the section of the National Highway Traffic Safety Administration which could appropriately respond to your question. Therefore, I have forwarded your letter to Mr. Ralph Hitchcock, Director, Office of Vehicle Safety Standards with a re quest that his office respond to you. I am certain you will be hearing from someone about your inquiry in the near future.

Thank you for your interest in preventing motor vehicle crashes.

Sincerely,

ID: nht88-2.54

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 22, 1988 EST

FROM: A. L. BRAGG -- LABORATORY MANAGER, TRUCK-LITE CO., INC.

TO: Z. TAYLOR VINSON -- SENIOR STAFF ATTY., NHTSA

TITLE: REQUEST FOR INTERPRETATION OF S4.1.16 AND S4.1.17 IN STANDARD NUMBER 108

ATTACHMT: LETTER DATED NOV. 3, 1988 (EST) TO A. L. BRAGG, LABORATORY MGR., TRUCK-LITE CO., INC., FROM ERIKA Z. JONES, CHIEF COUNSEL, NHTSA

TEXT: Our company currently manufactures several variations of stop, turn, and tail lamps that have a twelve square inch lens. Some particular models of this lamp also incorporate a ring of reflex reflector optics around the outside of the lens. It is our un derstanding that for the purposes of measuring the effective projected illuminated area of the lenses illuminated by an internal bulb, the reflex area (if present) must be subtracted from the total lens area, even though it may appear to transmit light. In the case of our particular lamps, we have a total of twelve square inches, from which we would subtract a four square inch area of reflex reflector which leaves eight square inches of effective projected illuminated lens area.

We note that the current FMVSS-108 document refers to SAE J586c, August 1970 for stop lamps and SAE J588e, September 1970 for turn signal lamps. A close reading of these standards indicates (to us at least) that for vehicles of eighty inches or more in width, an effective projected illuminated area of at least twelve square inches is required when two or more lamps are mounted closer together than twenty-two inches. We would further surmise that if a single stop/turn lamp were used or if two or mor e stop/turn lamps were used but that they were kept at least twenty-two inches or more apart, the twelve square inch rule would not be enforced and that eight square inches of effective projected illuminated area would be sufficient.

This matter is further complicated by the fact that in addition to the SAE standards just mentioned, there is a reference in S4.1.1.7 which seems to indicate that twelve square inches is required for vehicles ove eithty inches in overall width.

Our basic question is in reference to our combination lamp which has four square inches of reflector area and eight square inches of stop, tail and turn area. For vehicles over eighty inches wide can we advise our customers that these lamps may be us ed:

A) Singularly (that is one on each side of the vehicle in the rear) as a stop, turn, tail and reflex reflector?

B) In combination of two's or three's (on each side of the rear of the vehicle), provided that the lamps are separated by at least twenty-two inches?

We would be most grateful for your views and interpretation regarding the above. If we may offer any clarification, please feel free to contact us by letter or telephone.

ID: nht88-2.55

TYPE: INTERPRETATION-NHTSA

DATE: 06/23/88

FROM: LARRY P. EGLEY

TO: RALPH HITCHCOCK -- OFFICE OF VEHICLE SAFETY STANDARDS NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/09/89 FROM STEPHEN P. WOOD -- NHTSA TO LARRY P. EGLEY; REDBOOK A33 [2]; STANDARD 108; LETTER DATED 01/17/89 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 3028; LETTER DATED 05/23/89 FROM LARRY P. EGLEY TO KAT HLEEN DEMETER -- NHTSA; LETTER DATED 09/10/88 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 2530; REPORT DATED 09/10/88 FROM LARRY P. EGLEY, REQUEST FOR EVALUATION / INTERPRETATION OF PROPOSED INVENTION SUDDEN STOP FLASHER [SSF]; REPORT DATED 09/ 07/88 FROM LARRY P. EGLEY, AN APPEAL FOR VARIANT INTERPRETATION OF NHTSA STANDARDS AS THEY RELATE TO BRAKE LIGHTS AND THE SUDDEN STOP FLASHER [SSF]; LETTER DATED 07/13/88 FROM KATHLEEN DEMETER -- NHTSA TO LARRY P. EGLEY; LETTER DATED 06/20/88 FROM LEWIS S. BUCHANAN -- EPA TO LARRY P. EGLEY; OCC 2199; LETTER DATED 06/09/88 FROM LARRY P. EGLEY TO LEWIS BUCHANAN

TEXT: Dear Mr. Hitchcock:

I was advised by Mr. Lewis Buchanan that he had forwarded my letter regarding my "Sudden Stop Flasher" (SSF) to you for response. In the event his letter did not reach you yet, I am enclosing another copy.

I should mention to you that I have conceived of several additional features which I did not mention in my letter to Mr. Buchanan because my intent was to communicate the basic concept only. However, I might briefly mention one of them. This the "Cr ash Lock-up Mode." This feature would cause the system to "lock-up" in the rapid warning flash sequence whenever an "impact-level" deceleration is encountered. When drivers have an accident, they are often confused and disoriented and fail to take measu res to protect themselves, such as turn on the hazard warning flashers. The Crash Lock-up feature would automatically send out a continuous warning when an actual crash occurs, thus possibly preventing yet another crash. Several years ago, I read of a 56-car pile up on a Florida Interstate on a very foggy night. I believe if only a few cars in that string of smashed up vehicles had this feature, that major disaster could have been significantly less severe. The Crash Lock-up would remain actuated un til the ignition switch was recycled.

Please accept my apologies for not addressing my original letter to you instead of Mr. Buchanan. Unfortunately, I was advised by the Kansas City Office that Mr. Buchanan would be the proper recipient.

Thank you very much for your attention.

ID: nht88-2.56

TYPE: INTERPRETATION-NHTSA

DATE: 06/24/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: CHARLEY ERICKSON -- CHARLEY'S OFF ROAD CENTER, INC.

TITLE: NONE

ATTACHMT: MEMO DATED 12-23-87, FROM CHARLEY ERICKSON, TO ERIKA JONES, OCC-1416

TEXT: This responds to your letter asking whether Safety Standard No. 302, Flammability of Interior Materials, applies to the "bikini sun shade," an accessory you wish to sell for both new and used open-body type passenger vehicles. I regret the delay in resp onding to your letter.

Generally speaking, items of motor vehicle equipment are not covered by Standard No. 302 and the bikini shade may be sold to vehicle owners for their installation in their own vehicles without regard to the product's conformance with the standard. Howev er, as explained below, Federal law places limits on the installation of the bikini shade by some commercial businesses.

Standard No. 302 establishes flammability requirements that must be met by new motor vehicles. The requirements apply to particular components within these vehicles, including shades. However, the requirements of the standard apply to a vehicle only un til its first purchase in good faith for purposes other than resale. They do not apply to shades manufactured for aftermarket sale and installation in a a vehicle after its first purchase. It would not violate Standard No. 302 for you to sell aftermark et bikini sun shades that do not comply with the standard.

However, the installation of the shades by certain parties other than vehicle owners could violate the National Traffic and Motor Vehicle Safety Act. Section 108(a) (2) (A) of the Act (copy enclosed) specifies: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render 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 . . ." The f lammability resistance of the original vehicle is an element of design installed in a motor vehicle in compliance with Standard No. 302. That element of design would be rendered inoperative in violation of section 108(a) (2) (A) if a manufacturer, distr ibutor, dealer or motor vehicle repair business installed a bikini sun shade in a new vehicle and thereby caused that vehicle to fail to comply with Standard No. 302

There would also be a rendering inoperative when one of these parties installed the shade in a used vehicle if the shade would have caused the vehicle, when new, to fail to comply with the standard. Section 109 of the Act specifies a civil penalty of up to $ 1,000 for each violation of @108.

You should be aware also of an additional aspect of the Act. All manufacturers of motor vehicle equipment are subject to the provisions set forth in sections 151-159 of the Act concerning the recall and remedy of equipment with defects relating to motor vehicle safety. If it were determined that the bikini shade had a defect relating to motor vehicle safety, you as the shade manufacturer would have to notify all purchasers of the defect and either repair the shade so that the defect is removed, or rep lace the shade with an identical or reasonably equivalent product that does not contain a defect.

To summarize, there is a difference in the application of Standard No. 302 to vehicle equipment such as the bikini sun shade, depending on the identity of the person installing the shade in new and used motor vehicles. If the shade does not afford at le ast as good a level of flammability resistance as that specified by Standard No. 302, the shade cannot be installed in vehicles by any commercial business listed in @108(a) (2) (A) of the Safety Act. Shades that do not meet the standard's flammability r esistance requirements may legally be installed in vehicles by the owners of those vehicles. However, NHTSA discourages owners from installing any item of equipment that would degrade the safety performance of their vehicles. To repeat, you as the shad e manufacturer would still be obligated to recall and remedy shades that are determined to contain a defect relating to motor vehicle safety, even if those shades were installed by vehicle owners themselves.

I hope this information is helpful. Please contact us if you have further questions. ENCLOSURE

ID: nht88-2.57

TYPE: INTERPRETATION-NHTSA

DATE: 06/26/88

FROM: RON MOXHAM

TO: ERICA JONES -- OFFICE OF CHIEF COUNCIL NATIONAL HWY. TRAFFIC SAFETY ADM.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/17/89 FROM ERIKA Z. JONES TO J. JAMES EXON -- SENATE, REDBOOK A33; STANDARD 108, VSA 108(A)(1)(A), VSA 108(A)(2)(A), PART 567.7; LETTER DATED 02/09/89 FROM J. JAMES EXON -- SENATE TO NHTSA; LETTER DATED 01/26/89 FROM RON MOXHAM TO J. JAMES EXON

TEXT: Dear Ms. Jones

Mr. John Massero of your office referred me to you for a technical question. I am in the process of developing an add-on-trunk for mini vans, etc. This would be a detachable box which could be placed on the vehicle when needed. It would attach either to the liftgate bumper, or frame. It would extend 16"-20" beyond the bumper (when in use). See attached drawing.

My question is what highway regulations will I have to comply with? Will the "trunk" have to have a bumper? Will it have to have separate taillights & stoplights? Etc.

I would appreciate any information you can provide regarding this project.

Please let me know if I can provide any further information.

Thank you for your assistance.

Sincerely,

(DRAWING OMITTED)

ID: nht88-2.58

TYPE: INTERPRETATION-NHTSA

DATE: 06/28/88

FROM: KARL H. MAYER -- DR ING H. C F PORSCHE AG RULES AND REGULATIONS PORSCHE

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: REQUEST FOR INTERPRETATION/CLARIFICATION FMVSS 101 AND FMVSS 102

ATTACHMT: ATTACHED TO LETTER DATED 04/03/89 FROM ERIKA Z. JONES -- NHTSA TO KARL H. MAYER, REDBOOK A33 (4), STANDARD 101, STANDARD 102; LETTER DATED 06/28/88 FROM KARL H. MAYER TO ERIKA Z. JONES -- NHTSA, REQUEST FOR CONFIDENTIAL TREATMENT; LETTER DATED 08/25/88 FROM DEAN HANSELL TO KATHLEEN DEMETER -- NHTSA, RE PORSCHE'S JUNE 28 REQUEST FOR REGULATORY INTERPRETATION FMVSS 101 AND 102

TEXT:

Dear Ms. Jones,

In connection with the development of a new vehicle transmission we would like to request your opinion concerning regulatory questions raised by this transmission and its related gear shift mechanism, taking into account Federal Motor Vehicle Safety Stan dards 101 and 102.

We understand that the National Highway Traffic Safety Administration ("NHTSA") does not grant approvals of motor vehicles or motor vehicle equipment. We also realize that, under the National Traffic Motor Vehicles Safety Act, it is the responsibility o f the manufacturer to assure that its vehicles and equipment comply with the applicable standards.

Nevertheless, in our opinion it can at times be helpful and desirable for both the NHTSA and a motor vehicle manufacturer if a candid dialogue can be brought about regarding new technological developments and related regulatory questions. It is the inten t of this letter to create such a dialogue, as needed, in connection with the questions we are presenting.

I. Descriptions of the transmission, its functions and the operation of the gear shift lever

The above mentioned motor vehicle transmission is characterized by two functions -- i.e., a manuel gear shift and an automatic gear shift -- combined in a single unit. The transmission will thus let the driver decide at any time if he wishes to shift manually or transfer that task to the automatic portion of the transmission.

A motor vehicle equipped with such a unit does not have a clutch pedal. Regardless of which of the dual functions is chosen, its operation depends entirely on the position selected for the gear shift lever.

As is customary, the gear shift lever is located in the middle console, where it can be moved along either of two slots which are located essentially parallel to the longitudinal axis of the vehicle. The movement between the two slots corresponds to the change-over from the automatic to the manual function or vice versa. Movement of the lever between the slots can be accomplished while driving the vehicle forward or also while the vehicle is standing still, entirely at the option of the driver.

To accomplish the change from one slot (or function) to the other one, the driver only needs to move the shift lever to the other side across a tranverse connecting slot. As attached drawing 1 shows, this change can only be made from the "D" position on the automatic side to the "M" (manual shift) function on the other side, or vice versa.

When the slot exchange takes place from the automatic to the manual function, at first there is no actual gear shift change; i.e., the vehicle remains in the gear it was in on the automatic side. Only after a further "shift order" is given by the dri ver (by tapping on the shift lever) is the desired gear shift change achieved; i.e., either by shifting up (+) or by shifting down (-). (Shifting on the manual side has a "rocker" characteristic similar to that found with a computer video control, which always returns the gear shift lever to the "M" position after being tapped).

When changing from the manual to the automatic function, at first the gear selected on the automatic side is "taken along" from the one selected by the driver in the manual mode. However, immediately thereafter the automatic speed adaption of the aut omatic function takes over. This adaption, as usual, depends upon the load factor and the engine revolutions as well as the vehicular speed, and corresponds to the conventional functioning of existing automatic transmission units.

II. Questions resulting from the new transmission and Standards 101 and 102

1. We are of the opinion that th s new type of transmission with a dual function is basically permissible under the FMVSS, provided certain requirements are met as per FMVSS 101 and 102. We would like to know whether the NHTSA agrees with this inter pretation of the regulations.

The requirements we have taken into consideration in reaching our conclusion are, among others:

The shift lever can be reached by the driver. FMVSS 101. S5.1. hand operated controls, item (j) of the list.

The shift pattern manufactured as per drawing 1, is continually visible to the driver on the middle console during daylight, FMVSS 101, S5.1 displays, item (c) of the list.

The shift pattern, as per drawing 2, shown in the speedometer, is continually visible to the driver and provided with illumination, which is in accordance with the requirement contained in FMVSS 101, S5.3.1.

If a gauge is listed in column 1 of Table 2, and accompanied by the word "yes" in column 5, then the gauge and its identification required by S5.2.3 shall be illuminated whenever the ignition switch and/or the headlamps are activated. Controls, gauge s, and their identifications need not be illuminated when the headlamps are being flashed.

The above mentioned illumination of the shift pattern is adjustable, in accordance with FMVSS 101, S5.3.3.

In the automatic mode the gear position can be set selectively to P, R, N, D, 3, 2, or 1, clearly readable on the guide display plate of the gear shift on the middle console, as well as clearly marked for the driver by illuminating the corresponding a rrows (arrow) on the shift display in the speedometer.

The engine can only be started if the shift lever is in the P or N position as per FMVSS 102. S3.1.3.

[FOLLOWING PAGE MISSING]

4. The display shown in drawing 3 differs from the mode depicted in drawing 2 only by including the letter "M" on the manual side. The corresponding arrow would be illuminated during use of the manual mode. Additionally the arrow of the selected sh ift position would light up.

Please advise us if the display mode shown in drawing 3 is permissible.

Note: The speedometer depicted in drawings 2 and 3 will have a scale reading in MPH in the version manufactured for the USA instead of a scale in KM.

We are prepared to provide you with any further information that you would need to consider this inquiry, whether by telephone or in writing, or, if you would prefer, in a face-to-face meeting. We have developed a working model of the dual function shif t lever which we are prepared to demonstrate for you, if that would be helpful to you in evaluating these questions.

Your early favorable consideration of these requests would be greatly appreciated so that we can move this technology toward production as soon as possible.

A confidential treatment of this inquiry in accordance with 49 CFR Part 512 ist requested. (See enclosed declaration.)

Very truly yours,

Enclosure

(FIGURE 1-3 OMITTED)

ID: nht88-2.59

TYPE: INTERPRETATION-NHTSA

DATE: 06/30/88

FROM: AUTHOR UNAVAILABLE; ERIKA Z. JONES; EAS-ASE

TO: IRVING GINGOLD, ATTORNEY AT LAW

TITLE: FMVSS INTERPRETATION

TEXT: Irving Gingold, Esq. 529 Nassau Road Roosevelt, NY 11575

Dear Mr. Gingold,

This is in response to your letter of April 27, 1988, asking whether any of the Federal motor vehicle safety standards apply to an airport baggage conveyor. The answer is no.

The National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act) 15 U.S.C. 1381 et seg.), authorizes this agency to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. Conversely, we have no authori ty to regulate vehicles that are not "motor vehicles" or equipment that is not "motor vehicle equipment." Section 102(3) of the Safety Act (IS U.S.C. 1391(3) I defines a motor vehicle as any vehicle driven or drawn by mechanical power manufactured primar ily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.

Under this definition, any vehicle intended and sold solely for off-road use is not considered a motor vehicle under the Safety Act, even if it is operationally capable of highway travel. We have long offered "airport runway vehicles" as an example of ve hicles that are not motor vehicles, because they are sold solely for off-road use. NHTSA has specifically stated that an airport baggage trailer is not a motor vehicle, in a July 11, 1983 letter to D.F. Landers. Since the airport baggage conveyor to whic h you referred in your letter is not a "motor vehicle," none of our safety standards or other regulations would apply to the vehicle. We are not aware of any other Federal agency that has established safety standards applicable to airport baggage conveyo rs.

Sincerely,

Erika Z. Jones Chief Counsel

April 27, 1988

Federal Motor Vehicle Safety Standards U.S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street S.W. Washington, D. C. 20590

Re: Jimmy Knight v. TWA et al My file #1422

Gentlemen:

I represent a client who was seriously injured while riding an airport baggage conveyor on October 9, 1984. I would appreciate it if you could forward to me any and all information pertaining to the safety standards that were applicable to conveyor type of vehicles as our client was operating.

Your cooperation would be appreciated.

Very truly yours,

IRVING GINGOLD

IG:pe

ID: nht88-2.6

TYPE: INTERPRETATION-NHTSA

DATE: 04/22/88

FROM: PAUL SCULLY -- VICE PRESIDENT, PETERSON MANUFACTURING COMPANY

TO: ERIKA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: INTERPRETATION OF "EFFECTIVE PROJECTED LUMINOUS AREA"

ATTACHMT: ATTACHED TO LETTER DATED 08/19/88 TO PAUL SCULLY FROM ERIKA Z. JONES, REDBOOK A32 (2) STANDARD 108

TEXT: Dear Ms. Jones:

The members and counsel of the Transportation Safety Equipment Institute, who met with you on April 14, 1988, requested that I send you a summary of the interpretations which industry has been using regarding the term, "effective projected luminous area" . This relates to an inquiry from Wesbar and the agency's response on the meaning of this term.

On October 28, 1970, the National Highway Safety Bureau issued the following interpretation:

"The effective projected luminous area is that area of the lens measured on a plane at right angles to the axis of the lamp, excluding reflex reflectors, which is not obstructed by an opaque object, such as a mounting screw, mounting ring, or an ornam ental bezel or trim. This allows the area of rings or other configurations (raised portions) molded in the lens to be considered part of the total effective area, even if this area does not contribute significantly to the total light output."

On October 28, 1979, an interpretation was issued by Roger Compton, Director, Office of Operating Systems, Motor Vehicle Programs, to American Motors Corporation which read as follows:

"The effective projected luminous area is that area of the lens measured on a plane at right angles to the axis of the lamp, excluding reflex reflectors, which is not obstructed by an opaque object. This interpretation allows the area of rings, or ot her configurations molded to the lamp to be considered part of the total effective area, even if this area does not contribute significantly to the total light output."

The above interpretations are basically the same. The vehicle lighting industry has been using these definitions, based on opinions from your agency, for about 18 years. Prior to that time, this same basic definition was even used by a number of indivi dual states. Also, the independent testing laboratories throughout the nation, as well as all manufacturers, have been excluding reflex areas in calculating "effective projected luminous area" for well over 40 years.

In 1987, the Society of Automotive Engineers through the SAE Lighting Committee adopted the following language which is now a part of SAE J387-Terminology:

"Effective projected luminous area" is the part of the light emitting surface measured on a plane at right angles to the axis of a lamp, excluding reflex reflectors, (but including congruent reflexes), which is not obstructed by opaque objects such as mounting screws, mounting rings, bezels or trim or similar ornamented feature areas. Areas of optical or other configurations, for example, molded optical rings or markings, shall be considered part of the total "effective projected luminous area" even if they do not contribute significantly to the total light output. The axis of the lamp corresponds to the H-V axis used for photometric requirements."

Again, you will note that the SAE term clearly excludes the reflex reflector areas. A prismatic reflex reflector is constructed to return light from an outside source. In contrast, a lens optic is designed to direct light which originates inside the le ns area. While it is true that a small amount of light escapes through the prismatic reflector area, this light cannot be controlled or directed and provides nothing more than a minimal glow of light.

I confirmed that the vehicle manufacturers in Detroit have also relied on the interpretations issued by your agency and its predecessor as described above.

The letter to Wesbar Corporation, dated March 16, 1988, appears to have been caused by a misunderstanding involving some engineering terms. We respectfully suggest a prompt clarification should satisfy everyone.

Very truly yours,

ID: nht88-2.60

TYPE: INTERPRETATION-NHTSA

DATE: 06/30/88 EST

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: R. H. MADISON

TITLE: NONE

TEXT: This responds to your March 31, 1988, letter asking for our interpretation of Safety Standard No. 207, Seating Systems, as it applies to a seat installed in a multipurpose passenger vehicle and equipped with a safety belt. You attached a sketch of your seat and asked whether the safety belt assembly is considered to be attached to the seat. You asked this question in order to determine whether the seat would be subject to the specified forces of paragraph S4.2(c) of the standard. The answer is that N HTSA considers the assembly to be attached to the seat.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not grant approval of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the m anufacturer to ensure that its vehicles or equipment comply with applicable requirements. The following represents our opinion based on our understanding of the facts provided in your letter. In this regard, I want to note that rendering an opinion in this case was complicated by the fact that your sketch does not show the seat structure and its interrelationship with the vehicle structure and belt anchorage.

In your letter, you refer to a vehicle having a "Belt Attachment Frame" made from steel members attached to the vehicle's structure. You said that,

"(r)esting on the Belt Attachment Frame is a plywood deck . . . The seat cushion rests on but is not otherwise attached to the deck. The seat belt attachments pass through the deck and are secured to the Belt Attachment Frame. Other portions of the s eat or its supporting structure might rest on and contact the Belt Attachment Frame and might extend to or beyond it. However, except for the deck, no part of the seat or its structural members would be attached to the Belt Attachment Frame." (Emphasis added.)

The answer to your question depends on whether the Belt Attachment Frame is considered part of the seat. Based on the information you provide, we

conclude that the Belt Attachment Frame is part of the seat itself. According to your letter, the deck for the seat cushion is attached to and supported by the Belt Attachment Frame; it appears that the Belt Attachment Frame is a necessary and functiona l part of the seat structure. Since we interpret the Belt Attachment Frame to be a part of the seat, and since the seat belt assembly loads will be transferred to the Frame in the event of a crash, we consider the seat belt assembly to be attached to th e seat, for purposes of testing the seat under S4.2(c) of Standard No. 207.

Please contact my office if you have further questions.