Interpretation ID: nht74-5.48

DATE: 05/17/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Renault, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 3, 1974, requesting an interpretation of the test procedure specified in Standard No. 301 (Docket No. 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.

Thus, the interpretation of the requirement expressed in your letter is correct.

YOURS TRULY,

May 3, 1974

Mr. Lawrence R. Schneider Chief Counsel -- NHTSA

SUBJECT: REQUEST FOR CLARIFICATION - FMVSS 301-75

We would appreciate receiving a confirmation that our interpretation of @ S.7.1.3 of FMVSS 301-75 (Docket No. 73-20; Notice 2) is correct.

@ S.7.1.3 says, "If the vehicle has an electrically driven fuel pump that normally runs when the vehicle's electrical system is activated, it is operating at the time of a barrier crash".

Our understanding is that while the ignition switch is in the "ON" position, the engine is stopped since the fuel tank is filled with an ASTM type 1 solvent. However, some vehicles equipped with an electrically driven fuel pump include a switch device that shuts off the fuel pump after 1.5 seconds, should the engine stop for any reason.

This means that during the test at the time of the crash the fuel pump will not be running even though the ignition key is turned "ON".

Thank you for your assistance in this matter.

Francois Louis Manager Technical Standards Department