Interpretation ID: nht74-5.50

DATE: 04/22/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of April 5, 1974, requesting interpretations of two sections of Federal Motor Vehicle Safety Standard No. 301 (39 FR 10588).

Your first question was whether dummies are required to be positioned at each front outboard seating position even if such dummies are not specified for testing under Standard No. 208. The answer to your question is yes. Standard No. 301 provides for testing with dummies at each front outboard seating position regardless of the Standard No. 208 testing provisions. Where, however, Standard No. 208 specifies additional test dummies, such dummies are to be included in the vehicle for Standard No. 301 testing.

Your second question was whether the dummies are to be restrained by belt systems until passive restraint systems become mandatory under Standard No. 208. The answer to this question is no. The dummies are to be restrained for testing under Standard No. 301 only by systems that require no action by the vehicle occupant. Therefore, dummies are not to be restrained during testing by belt systems, but only by the passive means, if any, that are employed in the vehicle.

Thank you for your inquiry. Yours Truly,

NISSAN MOTOR CO., LTD

April 5, 1974

Lawrence R. Schneider Chief Council National Highway Traffic Safety Administration

This is to request your interpretation of the FMVSS 301, Fuel System Integrity, issued through the Federal Register on March 21, 1974.

(1) S6.1 Frontal barrier crash which states:

" . . . . at each front cutboard seating position and at any other position whose protection system is required to be tested, by a dummy under the provisions of Standard No. 208 . . . . . . . ".

May we understand from the above requirement that regardless of the provisions of the MVSS 208, we will have to provide the test dummies at each front outboard seating position? And, on the other hand, that it will not be necessary to provide the dummy at the frontal barrier crash test in any other position where installation is not required under the mandatory passive restraint system provided for in the MVSS 208? (See attached figure.) (2) Also, the S7.1.1 which states:

"Each dummy shall be restrained only by means that are installed in the vehicle for protection at its seating position and that require no action by the vehicle occupant".

May we understand from the above that the dummy which is only provided at each front outboard seating position, from our understanding in (1) of the above, shall be restrained by lap and shoulder belts until the proposed effective date of the mandatory passive restraint system under MVSS 208? And, that(Illegible Words) be able to restrain the dummy by lap belt if it will be installed in the front seat to meet the rollover requirement under MVSS 208. (See attached figure.)

Thank you for your attention to our request. We look forward to hearing from you regarding the above.

Tatsuo Kato Staff, Safety

9.1.75 effective date of MVSS 301 9.1.76 proposal effective date of MVSS 208

(Graphics omitted) no dummy for rear seating position no dummy for rear seating position the dummy restrained by lap and shoulder seat belt for front seating position the dummy unrestrained or the dummy restrained by lap belt which is installed to meet the rollover requirement