Interpretation ID: nht79-4.7

DATE: 04/11/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Sheller-Globe Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of February 15, 1979, concerning the definition of "forward control" vehicle contained in 49 CFR 571.3. Your specific concern is how to measure a vehicle's length to determine if "the steering wheel hub is in the forward quarter of the vehicle length."

Overall vehicle length should be determined by measuring the maximum longitudinal distance between the foremost point on the front bumper face bar and the rearmost point on the rear bumper face bar. In the context of the Part 581 Bumper Standard (49 CFR 581), the agency considers bumper guards to be part of the bumper face bar if they are contacted by the impact ridge of the pendulum test device used in compliance testing (43 F.R. 20804, May, 15, 1978). For the purposes of determining vehicle length, the agency will consider bumper guards as a part of the vehicle bumper face bar and thus included in the measurement of vehicle length. Components such as a permanent or fold-down step which are not associated with the bumper system's function are not considered part of the bumper face bar for the purposes of Part 581 Bumper Standard (43 F.R. 40230, Sept. 11, 1978). Therefore, the agency will not consider a permanent or fold-down step as a part of the bumper face bar for the purposes of determining vehicle length.

I have enclosed for your information a notice of proposed rule-making which would extend Standards No. 201, 203 and 204 to forward control vehicles. The notice also states the agency's intention to eliminate the forward control exemption found in other Federal motor vehicle safety standards.

If you have any further questions, please let me know.

SINCERELY,

SHELLER-GLOBE CORPORATION Vehicle Planning and Development Center

February 15, 1979

Office of Chief Counsel National Highway Traffic Safety Administration

Dear Sir:

The purpose of this letter is to request interpretation relating to the NHTSA definition of "forward control."

In determining the front quarter of the vehicle length we need to know what is included in the measurement.

Example would be if the bumper guards on the front bumper are included in the measurement.

Although the vehicle we receive from the manufacturer as a completed vehicle is not certified as a forward control, if we add a step either permanent or fold-up behind the original rear bumper, can this increase in length dimension be used to determine the front quarter of the vehicle?

Your prompt reply will be appreciated.

R. M. Premo - Director Vehicle Safety Activities