Interpretation ID: nht74-4.24

DATE: 05/10/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of April 16, 1974, requesting an interpretation of the test procedure specified in Standard No. 301 (Docket 73-20; Notice 2) concerning the operation of the vehicle's fuel pump during testing.

Paragraph S7.1.3 of the standard requires that electrically driven fuel pumps be in operation during the barrier crash tests if they normally operate with the activation of the vehicle's electrical system. If the pump is incapable of functioning with the independent activation of the electrical system and requires the operation of the vehicle's engine, then the pump should not be running during the barrier crash tests.

Once the barrier crash tests have been completed, if the fuel pump was operating it may be desctivated, as the standard only requires that it operate during the crashes.

Thank you for your inquiry.

Volvo of America Corporation

April 16, 1974

Lawrence Schneider, Chief Counsel National Highway Traffic Safety Administration

Volvo of America Corporation hereby requests an interpretation of the test procedure specified in ammended Federal Motor Vehicle Safety Standard No. 301, published March 21, 1974, 39 Federal Register 1050 (Docket No. 73-20; Notice 2). Section S7.1.3 of that standard specifies conditions under which electrically driven fuel pumps must be operating at the time of the barrier crash. Volvo requests an interpretation on the operating condition of the fuel pump after the barrier crash.

The electric pump used by Volvo normally ceases to operate when the engine speed drops below 70 RPM. On the basis that the engine is unlikely to remain running after a 30 MPH barrier crash, and that no condition is specified in FMVSS 301, Volvo requests that post-crash evaluation and testing be performed with the fuel pump de-activated.

Volvo thanks you for your consideration of this matter and requests a reply as soon as practical.

Rick Shue Product Safety Engineer

cc: E. Skarin