Interpretation ID: nht94-3.36

TYPE: INTERPRETATION-NHTSA

DATE: June 9, 1994

FROM: Allan E. McIntyre -- Vice President, Engineering and New Product Development, Sprague Devices, Inc.

TO: Rodney Slater -- Administrator, Federal Highway Administration

TITLE: NONE

ATTACHMT: Attached to 2/3/95 letter from Philip R. Recht to Allan E. McIntyre (A43; Std. 104)

TEXT: Dear Mr. Slater:

The purpose of this letter is to request your office for an interpretation/understanding of FMVSS-104 regarding evaluation procedure or how to undertake ammendment / revision of FMVSS-104.

By way of background please note that Sprague Devices, Inc. of Michigan City, Indiana both designs and markets components for windshield washer systems for trucks, buses and multipurpose vehicles. Secondly, I serve as Chairman of the SAE subcommittee re sponsible for windshield wiping and washer documents specifically SAEJ198 and 1944. I also chair a similar task force under the direction of TMC (The Maintenance Council of ATA).

My specific inquiry is regarding FMVSS-104- S4. 2.2 describing windshield washer requirement for truck, bus and multipurpose vehicles. Document lists SAE recommended Practice J942 of 11/65 (with modification). J942 has been superceded by an "a" and a " b" revision at SAE level. It also pertains specifically to PASSENGER CAR WINDSHIELD WASHER SYSTEMS.

SAE recognized the need of a document specifically addressing commerce vehicles, etc., and had chartered my subcommittee to develop such a document. J1944 is the result of our subcommittee activity and has been both approved and published in SAE Handboo k. (Copy attached). Its purpose is to follow the overall format of the J942 document while recognizing that advancements in technology allow for more strigent requirements, increased performance levels, etc. J1944 is overall a "tougher" document compa red to the J942 series.

Would the above situation allow for documentation of compliance to FMVSS-104 through use of the new J1944 recommended practice or is it necessary to evaluate per J942 as specifically written?

Second inquiry relates to the above also. If it is necessary to evaluate per J942 (both recognizing its' being superceded by "a" and "b" and more recently J1944) how does one petition for a revision in FMVSS-104?

There are other areas in FMVSS documents that are similar in nature to the above and therefore your response to this specific question could in essence respond to the inquiries of many.

Respectfully,

Enclosures

Motor Vehicle Safety Standard No. 104; SAE J1944 - Truck and Bus Multipurpose Vehicle Windshield Washer System

(Text of enclosures is omitted.)