Interpretation ID: nht93-9.12

DATE: December 14, 1993

FROM: J. Hulshof -- NEDAP N.V.

TO: Patrick Boyd -- Office for Rulemaking, NHTSA

TITLE: Standard FMVSS 118

ATTACHMT: Attached to letter dated 4/12/94 from John Womack to J. Hulshof (A42; Std. 118)

TEXT:

Referring to our recent telecons we wish to inform you about the following.

We have designed a SCU (Sunroof Control Unit) for a power operated roof panel system where the roof panel can be closed only in the following circumstances:

1. Ignition key activated AND continuous activation of close button 2. Ignition key activated AND short touch of close button (one shot close, close button is released and roof panel moves to closed position) 3. Continuous operation of Central close mechanism, not capable closing the roof panel from a distance of more than 6 meters from the vehicle. 4. Ignition key activated AND continuous operation of a PANIC button

Note: System has no reversal mechanism acc. to the FMVSS 118

Referring to the above mentioned: Does the sunroof comply with the rules as stated in FMVSS 118?

Are there any amendments to the FMVSS 188 in progress?

We look forward to your answer.

Note: For any reactions, our fax nr. in the USA: 815 633 6089 Attn. Bob Cooper, LMS