Interpretation ID: nht95-3.96

TYPE: INTERPRETATION-NHTSA

DATE: August 22, 1995

FROM: SABURO INUI -- VICE PRESIDENT, TOYOTA MOTOR CORPORATE SERVICES OF NORTH AMERICA, INC.

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Request For Interpretation FMVSS 114 Theft Prevention, Final Rule Vehicle Rollaway Test Procedure [Docket No. 1-21; Notice 13]

ATTACHMT: ATTACHED TO 10/13/95 LETTER FROM JOHN WOMACK TO SABURO INUI (A43; STD. 114)

TEXT: Dear Mr. Womack;

Toyota would like to request an official interpretation concerning the automatic transmission park position test procedure outlined in the in the FMVSS 114 final rule, as given in the June 7, 1995 Federal Register.

Subsequent to publishing the final rule, NHTSA issued an interpretation to General Motors describing the test procedure as a "static" test, i.e. dynamic body motions were not to be included in the overall measurement of vehicle motion. It is also our un derstanding that the measurement is to be taken beginning at the moment before the service brake is released. Sections S5.2(e) and S5.3(b) both describe the test procedure as follows; (step numbers are added for clarity)

NHTSA procedure

Step 1. Drive the vehicle forward up a 10 percent grade Step 2. Stop the vehicle with the service brake Step 3. Apply the parking brake (if present) Step 4. Move the shift mechanism to the "park" position Step 5. Apply the service brake Step 6. Release the parking brake Step 7. Release the service brake Step 8. Verify that the vehicle movement was less than or equal to 150 mm.

As written, step 2 of this procedure requires application of the service brake and step 5 requires the same. But there is no action to release the service brake. We believe the intention of the procedure either requires a release of the service brake b etween steps 2 and 5, or step 5 should be eliminated (meaning the service brake is only released to begin the measurement).

Therefore, we are proposing the following revised procedure;

Toyota's Proposed Procedure

Step 1. Drive the vehicle forward up a 10 percent grade Step 2. Stop the vehicle with the service brake Step 3. Apply the parking brake (if present) Step 4. Release the service brake Step 5. Move the shift mechanism to the "park" position Step 6. Apply the service brake Step 7. Release the parking brake Step 8. Release the service brake Step 9. Verify that the vehicle movement was less than or equal to 150 mm

Obviously, if the vehicle is not equipped with a parking brake, Steps 4, 6, and 7 of Toyota's procedure (or Steps 5 and 6 of NHTSA's procedure) would be eliminated.

Therefore, we request an interpretation of whether Toyota's proposed procedure fulfills the intention of NHTSA's test requirement.

Should you have any further questions, please contact Mr. Chris Tinto of my staff at (202) 775-1707.