Interpretation ID: nht74-2.32

DATE: 02/06/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Kar-Kraft, Inc.

COPYEE: PESKOE; COMPTON

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter dated December 6, 1973, in which you ask whether there is a distinction between the reference to the "lowest seating position" for motorcycles in S5.1.2.1 of Motor Vehicle Safety Standard No. 205, and the reference to "lowest seating surface" in proposed "Fields of Direct View" (Docket No. 70-7; Notice 2; 37 FR 7210, April 12, 1972). You also request an explanation for the difference between the reference to 15 inches above the seating surface in Standard No. 205, and 18 inches in Docket No. 70-7.

The notice in Docket No. 70-7, as you may know, has been withdrawn (38 FR 6194, March 7, 1973). However, we would consider the phrase "lowest seating position" to be synonymous with "lowest seating surface" with respect to these particular items. The 18-inch requirement proposed in Docket No. 70-7 represented a more recent evaluation than the 15-inch requirement in Standard No. 105 of the minimum desirable area for motorcycle visibility. Had that requirement become effective the agency would have taken steps to ensure that the requirements were consistent with each other.

Yours truly,

ATTACH.

December 6, 1973

Richard B. Dyson -- Office of the Chief Council, N. H. T. S. A.

Dear Mr. Dyson:

In a recent conversation with your Mr. Peskoe, I asked a question relative to FMVSS 205 which Mr. Peskoe advised would best be asked in written form to which your office would make a prompt reply.

Accordingly, my question is this:

In FMVSS 205, Glazing Materials, at S5.1.2.1 "Safety plastic materials . . . may be used in a motor vehicle only in the following specific location at levels not requisite for driving visibility.

(b) Motorcycle windscreens below the intersection of a horizontal plane 15 inches vertically above the lowest seating position."

Additionally, in Docket 70-7, Notice 2, Paragraph S10.1 it says: "There shall be no obstructions forward of the forwardmost point of the driver's seat that are above a horizontal plane 18 inches above the lowest seating surface of the driver's seat . . ."

Specifically, what is the definition of the "lowest seating position" in FMVSS 205 and lowest seating surface in Docket 70-7 and what accounts for the difference in the 15 inch and 18 inch dimensions?

We look forward to your prompt reply in this matter.

Sincerely,

KAR-KRAFT, INC.;

L. A. Volberding -- Administrative Manager