Interpretation ID: nht75-2.27

DATE: 03/11/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Joseph Lucas North America Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 7, 1975, in which you ask whether the control lever/throttle arm of diesel fuel injection equipment is considered part of the pump mechanism or part of the "linkage," i.e. the accelerator control system, within the meaning of Standard No. 124.

The control lever/throttle is similar to the throttle lever referred to in Docket 69-20, Notice 5 (copy attached). In that notice, we established that the throttle lever is not part of the "driver-operated accelerator control system", but rather part of the fuel metering device and therefore does not fall within the ambit of Standard No. 124.

Yours truly,

ATTACH.

February 7, 1975

Fred Schwartz -- Attorney Advisor, Office of the Chief Counsel, National Highway Traffic Safety Admin.

Dear Mr. Schwartz:

FMVSS 124 - Accelerator Control Systems

Joseph Lucas North America Inc. is a subsidiary of Joseph Lucas (Industries) Ltd. of England. Two other subsidiaries, CAV Limited and Simms Motor Units Limited manufacture diesel fuel injection equipment, some of which is exported to the United States fitted to engines, or as sold by Joseph Lucas North America Inc.

A question has arisen concerning the control lever/throttle arm on these pumps. Is this lever/arm part of the pump or it is part of the linkage?

Enclosed are two publications:

1. Publication No. 2067/4 - CAV DPA Distributor Type Fuel Injection Pump with Mechanical or Hydraulic Governor. The Green arrows on pages 2, 66, 67, 68, and 69 point out the item in question.

2. Publication P29E - Simms Mechanical Fuel Injection Pump. The green arrows on pages 2 and 3 point out the item in question.

We feel that this lever/arm is part of the injection pump, and not the linkage. Would you please confirm that our interpretation is correct?

Any help which you could give us in correctly interpreting the definition of such a pump mounted lever/arm would be appreciated, so that we may correctly appraise the arrangements on other such pumps.

Yours truly, JOSEPH LUCAS NORTH AMERICA INC. -- A. J. Burgess, Vice President (Technical)

Enclosures