Interpretation ID: nht81-3.40
DATE: 11/16/81
FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA
TO: Rolls-Royce Motors
TITLE: FMVSS INTERPRETATION
TEXT: This is in response to your recent letter to the Administrator, regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection, and its related requirements for the comfort and convenience of safety belts.
You stated in reference to paragraph S7.4.4, Latchplate Access, that "the standard as written is design restrictive in not permitting inboard location of the latchplate when stowed by virtue of requiring the latchplate to be located within the outboard reach envelope . . ." You requested that the wording be changed to permit either inboard or outboard reach envelopes.
Paragraph S7.4.4 was not intended to limit the location of latchplates to outboard locations. Latchplates located in the outboard reach must be located within the reach envelopes as specified. However, the requirement would not be applicable to latchplates located inboard, since there should be no difficulty in reaching latchplates in this location. It should also be noted that the requirement is not applicable to automatic belts.
We believe the Agency's response to the petitions for reconsideration of the comfort and convenience requirements will answer your remaining questions. We expect to issue that notice in the very near future.
You requested an early announcement of the final content of FMVSS No. 208 as it would apply to automatic restraints. On October 23, 1981, the Department rescinded that portion of the standard that would require automatic restraints. We have enclosed a copy of the news release pertaining to that action for your information.
Please contact this office if you have further questions.
Sincerely,
ATTACH.
OCTOBER 9, 1981
R. PECK -- ADMINISTRATOR, National Highway Traffic Safety Administration
FMVSS 208 - OCCUPANT CRASH PROTECTION
Dear Administrator,
As a company producing three models of car of wheelbase in excess of 114 inches Rolls-Royce Motors is closely affected by the continuing uncertainty in implementation of the automatic restraint requirements of standard 208. In addition to the uncertainty of introduction date the content of the rule is also subject to debate.
Rolls-Royce is in urgent need of guidance from NHTSA to permit us to use our limited resources in a constructive way to the benefit of our customers.
1. Comfort and Convenience Amendments
During 1979 Rolls-Royce commenced development of automatic restraints for production, both belts and ACRS. Following General Motors' decision late in 1979 to delay introduction of ACRS the Rolls-Royce programme was revised to install automatic belts in all models.
Production lead times dictated that parts for build in September 1981 should be given engineering release by March 1980. This meant that the proposed addition to standard 208 of comfort and convenience requirements were not accommodated in our initial production designs.
When the comfort and convenience amendments were finally adopted in the regulation on the 8th January with an effective date of September 1982 the necessary changes to our installation to ensure compliance were programmed in accordance with that 1982 date.
Amid the statements on regulatory reform announced by the Reagan administration early in 1981 was, on the 6th April a notice of intent to the Federal Register to "eliminate all requirements except belt tension and to defer the effective date for one year". (Actions to Help the U.S. Auto Industry, April 6 1981, NHTSA Action 8) Such action was promised for "on or about July 1". In anticipation of the promised action our programme was again revised. Since that time, over three months ago there has been no official action.
Some sources of information suggest that when the action on comfort and convenience amendments is announced the final ruling will contain accessibility requirements in addition to those for belt contact load. If this is to be the case we request further consideration of the following points concerning S7.4.4 which were not mentioned in the discussion of comments listed in the final rulemaking Docket 74-14 Notice 19.
1.1 The standard as written is design restrictive in not permitting inboard location of the latchplate when stowed by virtue of requiring the latchplate to "be located within the outboard reach envelope . . ." We request the wording be changed to permit inboard or outboard reach envelopes.
1.2 Some commenters requested clarification of the term "unhindered" referring to transit of the test block. In particular, is compression of soft surfaces permissible? In one of our installations compression by the occupant of the seat cushion will pre-empt compression by the test block, except that there is no occupant (dummy) specified for this test. Could you please clarify?
2. Automatic belt warning system
S4.5.3.3.(b)(1)(B) specifies two conditions for determination of the automatic belt being fastened, both requiring switching in the emergency release mechanism. This appears inconsistent with the permissible conditions for determination of a manual belt being fastened, for which S7.3(b) states "either by the belt latch mechanism not being fastened or by the belt not being extended at least 4 inches from its stowed position".
In the case of our design of automatic belt which employs a buckle as an emergency release on the door frame the standard as written at present necessitates routing a cable from the buckle and down the frame. An additional option permitting switching with the belt extended from its stowed position would allow a switch to be fitted in the retractor and wiring to be included in existing loops in that area of the car. The additional option would be of considerable benefit to ourselves.
We believe the only objection to the belt extension option is the possibility that the belt may be withdrawn and knotted to simulate the belt being fastened. This would be less convenient then obtaining a spare latchplate and inserting it in the buckle to disable the warning mechanism by the existing option.
We propose amending the wording of S4.5.3.3.(b)(1)(B) by adding the following wording between ". . mechanism not being fastened" and "or, if the automatic belt is non-separable . .":-
"or by the belt not being extended at least 4 inches from its stowed position".
3. On the 9th April 1981 NHTSA issued an NPRM (49 CFR Part 571 Docket No. 74-14 Notice 22) proposing further amendment to the implementation of automatic restraint requirements in Standard 208. The comment date was 26th May.
In comment on that proposal Rolls-Royce Motors requested "an early announcement of a decision" (BGR/JO DT 19th May 1981, filed in the Docket). Since that comment date over five months ago Rolls-Royce have been unable to commit long term resources to automatic restraints for fear of further change in requirements resulting in wasted money. For manufacturers such as Rolls-Royce who must meet the September 1982 introduction date the long delay in announcing the uncertain outcome of the comments and public hearings mean that production lead times are being eroded. We urgently request an announcement of the final content of Standard 208.
We would be grateful for a quick response to these points.
For and on behalf of Rolls-Royce Motors Limited;
John OSBORNE -- Project Manager - Passive Restraints