Interpretation ID: nht87-1.52

TYPE: INTERPRETATION-NHTSA

DATE: 03/26/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Hisashi Tsujishita

TITLE: FMVSS INTERPRETATION

TEXT:

AIR MAIL

Mr. Hisashi Tsujishita Chief Co-ordinator Technical Administration Department Daihatsu Motor Co., Ltd. l.Daihatsu-cho, Ikeda City Osaka Prefecture JAPAN

Dear Mr. Tsujishita:

Thank you for your letter requesting an interpretation of the requirements of three of our safety standards. This letter responds to your questions concerning Standard No. 219, Windshield Zone Intrusion. regret the delay in this response. We will be resp onding to each of your questions concerning the other two standards in separate letters.

Your questions about Standard No. 219 concerns the requirement of S5 of the standard. That section provides as follows:

When the vehicle traveling longitudinally forward at any speed up to and including 30 mph impacts a fixed collision barrier that is perpendicular to the line of travel of the vehicle, under the conditions of 57, no part of the vehicle outside the occupan t compartment, except windshield molding and other components designed to be normally in contact with the windshield, shall penetrate the protected zone template, affixed according to 56, to a depth of more than one-quarter inch, and no such part of a ve hicle shall penetrate the inner surface of that portion of the windshield, within the DLO, below the protected zone defined in 56. (Emphasis added.)

Your specific question concerns a situation in which a windshield wiper penetrates the protected zone template during a crash test because, for example, the wiper was pushed rearward by the deformation of the cowl or the wiper switch was contacted by the test dummy during the crash, thus turning on the wiper. You noted that the wiper blades are normally in contact with the windshield, but that the wiper arms only contact the windshield through the wiper blades. You asked whether the agency would conside r the penetration of the wiper blade and arm into the protected zone template to be a violation of the standard. As discussed below, the answer is no, the penetration of the wiper blade and arm would not be a Violation of the standard.

As you observed in your letter, the wiper blade is designed to be normally in contact with the windshield and is thus exempt from the requirements of the standard. While the arm Hill not be in direct contact with the windshield, the blade attached to the arm does contact the windshield. Also, the wiper arm is a small, light structure which, while not in direct contact with the windshield, is mounted only h fraction of an inch above the surface of the windshield and should pose little or no penetration h azard. Thus, the agency will consider the wiper arm, which is an integral part of the exempted wiper blade, to be exempted as well.

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

Sincerely,

Erica Z. Jones Chief Counsel

Dec. 24, 1986

Ms. Erika Z. Jones Chief Counsel Office of the Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones:

The purpose of this letter is to respectfully inquire NHTSA's interpretations with regard to the Federal Motor Vehicle Safety Standards (FMVSS) Nos. 101, 201, and 219.

We wish we could have your early and kind response to the questions on the following pages.

We thank you in advance for your kind attention to this matter.

Sincerely yours,

H. Tsujishita Chief Co-ordinator of Technical Administration Dept. Head Office

Enclosure : QUESTIONNAIRE (1),(2),(3)

cc: Mr. R. Busick, Olson Engineering Inc.

QUESTIONNAIRE (3)

FHVSS No. 219 ; Windshield Zone Intrusion Paragraph 55 of FMVSS No. 219 provides When the vehicle .. no part of the vehicle outside the occupant compartment, except windshield molding and other components designed to be normally in contact with the windshield, shall penetrate the protected zone template, ...." In the case that the wi ndshield wiper penetrate the protected zone template ( by some reason such as pushed by the deformed cowl or accidentally turned-on of wiper switch as a result of contact with test dummy), we would like to confirm whether the vehicle is deemed in complia nce or not: (Refer to the illustration below)

We believe the penetration of wiper blades shall be deemed in compliance because the wiper blades are designed to be normally contact with the windshield. The wiper arms, however, only contact with the windshield though the wiper blade. Please advise us about the exemption of wiper arms from this intrusion provision. SEE HARD COPY FOR GRAPHIC ILLUSTRATIONS