Interpretation ID: nht72-1.5

DATE: 04/05/72

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: U.S. Technical Research Corporation

TITLE: FMVSS INTERPRETATION

TEXT: The questions asked by your letter of March 18, 1972, have been compared with the applicable paragraphs of the Federal Motor Vehicle Safety Standard (FMVSS) No. 164 and the Society of Automotive Engineers Recommended Practice J942.

1. The purpose of paragraphs 2.11 and 4.42b of J942 is to allow the testing of both manual and automatic systems seeing the same procedures. The (Illegible Word) of 4.42b attempts to equalise the usual cleaning cycle of each type of system. It is apparent that the manual system allowed for by 4.42b is one in which a single actuation, if held long enough, would put 15 cc of fluid through the nozzle. The systems you described is not of this type, nor is it the automatic system. You must therefore comply with the intent of the test, which would be to operate your system for 8,000 washer cycles, as stated in paragraph 3.4. Each washer cycle is that which puts approximately 15 cc of fluid through the nozzle. Since your system is not the usual system implied in the standard, the three-record rule would not apply. Time limitation would be dictated by the "Mo./min" column of Table 1 of J942, i.e. two washer cycles per minute.

Therefore, the pump and central switch you described, along with the other parts of the systems, if they meet all other prescribed (Illegible Word), would comply with Federal Motor Vehicles Safety Standard No. 104.

2. An automatic pump cycling device would not be limited by the three-second rule. It would be requested to meet the "Mo./min" column of Table 1 of J942, 1.2., two washer cycles per minute.

3. Paragraph 3.1 does not specify the duration of water spray, member of water sprays, or start time of wiper action. No standard wiper blade, windshield, or mechanism is specified. These are the items which, in conjunction with the washer, must produce an effective wips/wash system.

The National Highway Traffic Safety Administration is concerned that the entire system provide good washing and wiping, and is not concerned with compliance of individual components.

4. "Repeatedly," as used in paragraphs 4.2.2a and b, means the repeated application of the control device (push button, usually) which is designed to cause the water to squirt out of the nozzles. Practically, this reproduces a driver's attempts to activate the system on a cold day, not knowing if it is frozen or plugged. Upon warming up, the systems must not have been damaged, and must still function after removal of the ice or plug. Without this safeguard, many systems would be rendered inoperative on the first cold day by an impatient driver.

5. To our knowledge, there is no reservoir size stated by Federal or State regulations.

Please ask for further information, if needed.