Interpretation ID: nht68-3.2
DATE: 02/20/68
FROM: AUTHOR UNAVAILABLE; H.M. Jacklin, Jr; NHTSA
TO: Toyo Kogyo Company, Limited
TITLE: FMVSS INTERPRETATION
TEXT: Thank you for your letter of November 30, 1968 (your reference No. CSAI-25) requesting information to a number of questions related to the Federal Motor Vehicle Safety Standard. I(Illegible Word) that we did not receive your October 5, 1968 letter and that the(Illegible Word) of work has delayed my answer to your most recent letter.
I am glad to send you the following information:
a.(Illegible Word) No. 112 - Headlight Concealment Devices.
1. It is stipulated in 3.4.5 that "each headlamp concealment device shall, within an ambient temperature range of -70 to +120 degrees F., be capable of being fully opened in not(Illegible Line) described in S.4.3." With regard to the temperature condition at the time of a test, if only the(Illegible Word) temperature satisfied the cold temperature conditions, is it all right to try no regard to other conditions, such as the sticking of frost, ice, etc.?
ANSWER: It is only necessary that the ambient temperature conditions (-20 to +120 degrees F.) be(Illegible Word) at the time of the test.
b.(Illegible Word) No. 114 - Thoft Protection.
1. With regard to the regulation in s.4.2 that "The prime cause for deactivating the csr's engine or other main source of motive power shall not activate the(Illegible Word) required by S4.11(b)," we have provided the ignition switch with four stages as shown in the batch below; our key-locking system is of the(Illegible Word) that the system does not activate(Illegible Line)(Illegible Line)
ANSWER: The system as you describe it appears to conform to(Illegible Line)(Illegible Line) with this requirement to the responsibility of the individual manufacturer.
2. With reference to the stipulation in S.4.1. "Each passenger car shall have a key-locking system that, whenever the key is removed, will prevent ----.", we would like to know whether or not we must provide such a mechanism as the key can be removed only at the stage "Lock" and cannot at the stage "Off".
ANSWER: A locking system having such a position that the key may be removed without activating either the cars' steering lock or its self-mobility lock would not conform to the standard in its present form, since paragraph S4.1 of the standard requires each car to have a key locking system that, whenever the key is removed, will prevent either steering or self-mobility of the car, or both.
c. MVSS No. 201 - Occupant Protection in Interior Impact 1. With regard to the interpretation of the stipulation in S.3.1 " , the deceleration of the head form shall not exceed 80 g for more than 3 milliseconds," when the deceleration wave -- shown in the chart below -- is obtained.
in case DELTA t[1] < 3 milliseconds, we interpret that the standard is satisfied even when delta t[1] +="Sigma" t[2] t[3] t[i] milliseconds.
Is our interpretation correct? (Illustration omitted)
ANSWER: Your interpretation is correct. The standard permits more than one peak that exceed 80g which, cumulatively, may add to more than 3 milliseconds. No single peak may continuously exceed 80g for more than a 3 millisecond duration.
2. When the areas stipulated in S.3.1.1.(d) -- "Areas outboard of any point of tangency on the instrument panel of a 6.5 inch diameter head form tangent to an inboard of vertical longitudinal plane tangent to the inboard edge of the steering wheel," -- are illustrated, which of the following hatched portions in the figures below is in conformity to the stipulation? (Illustration omitted)
ANSWER: Figure (a) is correct for the inboard side. Present requirements do not apply to the area outboard of the steering wheel on the instrument panel.
d. MVSS No. 207 - Anchorage of Seats.
S.3.3 Folding and hinged seats. Except for folding auxiliary seats and seats with backs which are adjustable for occupant confort only.
1. Is it correct to interpret that the underlined part is referring to seats with backs reclining mechanism enabling to adjust the angle of the back?
ANSWER: Yes.
2. Or, should we interpret that the seats with reclinable backs come under the hinged seats?
ANSWER: No.
3. a. In the case of car with four doors, if the front seats are those with reclinable backs, these are presumed to be the ones corresponding to (1). Is this interpretation correct?
ANSWER: Yes.
b. In the case of a car with two doors, we would like to interpret that only the reclinable seat backs with folding mechanism enabling the passenger on the rear seat to get in and out are in conformity to (2). Is our interpretation correct?
ANSWER: Yes.
S.3.3.1 The release control shall be readily accessible to the occupant of that seat and to the occupant of any seat immediately behind that seat.
1. The above stipulation is presumed to be laid down for the egress of the passengers on the rear seat. Therefore, when the reclining seats are installed in a four-door car, we would like to consider it unncessary to pay regard to the underlined part. Is this interpretation correct?
ANSWER: Yes.
2. In the case of a two-door car, if the control which can be easily operated by passengers on the rear seat is installed only on one side (the right side), the passengers on the rear seat can operate the control by moving to the right side. Consequently, we consider it sufficient to install only on the right side the control which is easily accessible to the passengers on the rear seat. Is this interpretation correct?
ANSWER: In the case of a two-door car, for a split back or bucket seat arrangement, where both seat backs fold, a release control should be provided on the outboard side of each folding seat back. If the seat back is split and only one seat back folds, only one release control is required on the outboard side.
e. MVSS No. 210 - Seat Belt Assembly Anchorages
1. We judge that the fastening strength of the seat belt anchorage will change, depending on the shape of the eye bolt attaching the seat belt to the seat belt anchorage point.
If an anchorage is tested by using our designed seat belt assembly and the strength of the anchorage can be assured, we understand that the anchorage fully conforms to the standard, and also understand that it is not necessary to guarantee the owners of Mazda vehicles if they attach a seat belt assembly other than the one designated by us. Is our interpretation correct?
We, of course, will specify in our Operation Manual that the seat belt assembly designated by our company must be used.
ANSWER: Under Paragraph S.5.1 of Federal Motor Vehicle Safety Standard No. 210, anchorages are to be tested by using a Type 1 or Type 2 seat belt assembly as defined in FMVSS No. 209. If you follow this procedure, using a belt which complies to No. 209, and your anchorages meet the requirements of Standard No. 210, then you are in compliance with this standard.
I must point out that this Bureau does not issue approvals on items of equipment or on vehicle designs. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the Standards.