Interpretation ID: nht75-3.11

DATE: 11/25/75

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 22, 1975, posing several questions relating to Standard No. 302, 49 CFR 571.302. We are sorry for the delay in responding, but unfortunately your letter was filed in the docket as a response to a notice of proposed rulemaking concerning Standard No. 302.

Your first question relates to the requirement that the surface of the specimen closest to the occupant compartment air space face downward on the test frame. This requirement is now found in S5.2.2 of Standard No. 302, as published on September 16, 1975 (40 FR 45746). Through error, S5.2.2 was not amended when the standard was first amended on March 31, 1975 (40 FR 14318). This requirement applies to all test samples regardless of their thickness.

Your second question lists five components and asks whether they are included within Standard No. 302 as amended by Docket No. 3-3, Notice 7, and whether they would be included within Standard No. 302 if the amendment proposed by Notice 8 is adopted. Our answers follow:

1. The wiring harness illustrated in your letter need not currently meet the requirements of the standard, but would have to meet the requirements if it was located within 1/2 inch of the surface of the floor covering and Notice 8 was adopted as presently proposed.

2. The roof lamp need not currently meet the requirements of the standard, but would have to meet these requirements if Notice 8 was adopted as proposed.

3 and 4. The door lock and door handle knobs need not meet the requirements of the standard, but would have to if Notice 8 was adopted.

5. The floor grommets need not currently meet the requirements of the standard, but would have to meet these requirements if Notice 8 was adopted and they were within 1/2 inch of the surface of the carpet.

You are correct, therefore, in your analysis of the effect of Notice 8 as stated in your letter.

Your third question relates to whether the air space located behind the instrument panel and underneath the seat will be considered as part of the occupant compartment air space if Notice 8 is adopted. Assuming that the air behind the instrument panel is sealed off from the passenger compartment, it would not be considered part of the occupant compartment air space. The air under the seat cushion would be considered part of the occupant compartment air space unless it too is sealed off from the passenger compartment.

We trust these answers will be helpful to you.

YOURS TRULY,