Interpretation ID: 86-3.11

TYPE: INTERPRETATION-NHTSA

DATE: 05/02/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Bob Carlson

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Bob Carlson 8305 29th Avenue, N.W. Seattle, WA 98117

This responds to your January 23, 1986 letter inquiring about Federal motor vehicle safety standards applicable to your projected sale of aftermarket windshield wiper systems for trucks.

Under the National Traffic and Motor Vehicle Safety Act, this agency has issued Federal Motor Vehicle Safety Standard No. 104, Windshield Wiping and Washing Systems, applicable to new motor vehicles. As you note, this standard applies to trucks, as well as other types of vehicles. In your letter, you ask which performance requirements apply to wiping systems for trucks.

Under S4. Requirements, new trucks are required to have a power-driven windshield wiping system that meets the requirements of S4.1.1. The frequency requirements in S4.1.1 apply to trucks, but the wiped area requirements of S4.1.2 apply only to passenger cars. Trucks must also have a windshield washing system that meets the requirements of SAE Recommended Practice J942, November 1965, except that the effective wipe pattern is considered to be "the pattern designed by the manufacturer for the windshield wiping system on the exterior surface of the windshield glazing." Therefore, the vehicle manufacturer establishes the wipe pattern of the system.

If a new truck equipped with your wiper system did not comply with Standard No. 104 due to some aspect of that system, the sale of that truck to the public would be a violation of the prohibition in section 108(a)(1)(A) of the Act against the sale of noncomplying vehicles.

I hope this information is helpful to you.

Sincerely,

Erika Z. Jones

Chief Counsel Chief Legal Counsel National Highway Traffic Safety Administration 400 7th St S W Washington, DC 20590 Mail Code NOA-30

RE: Wiper System Requirements

Gentlemen:

My name is Bob Carlson. I am a salesman for Sea-Tac Ford Truck Sales, Inc; a heavy duty truck store in Seattle, Washington. I am currently developing a new "after market" wiper system for the "L" Series Louisville Ford truck line (literature enclosed).

While I have read FMVSS 104, SAEJ 903A and SAEJ 198, there appears, at least to me anyway, some overlap and confusion as to what test standards will apply to my wiper system developed for use on heavy duty Louisville trucks. therefore request your guidance as to specifically what parts all these federal safety standards will apply. Specifically I will need to know what, if any, a,b,c, zone-wiped area coverages should a person use to check the windshield wiper system. Paragraph S2 in FMVSS 104 states that the standard applies to trucks. However, in Paragraph S 4.1.2, the recommended test procedures and areas specified relate to passenger cars (see tables 1-C FMVSS 104). Now the question becomes. given the fact that you have specified angles in tables 1-4, what then does a person use, if any, for trucks? Do I use the angles specified in the table from J 198 or what?

If the answer is very simple due to the fact that I have misread something or whatever, I would appreciate a phone call either at home or at work using the following numbers:

work: (206) 763 9100; 1-800-426-8305 hours: 8:00 A.m. to 6:00 p.m. PST home: (206) 783 7590 hours: 5:30 a.m. to 7:00 a.m. or 7:00 p.m. to 9:00 p.m. PST

Thank you for your assistance.

Sincerely,

Bob Carlson 8305 29th Ave N W Seattle, WA 98117