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Amendments to FMVSS 118, Power Operated Window, Partition and Roof Panel Systems.

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Oct 2004

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2 min read

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On September 15, 2004 NHTSA issued two separate Final Rules that amend FMVSS 118, "Power Operated Window, Partition, and Roof Panel Systems." These two rulemaking actions revise FMVSS 118 in different ways and have different effective dates. NHTSA says that available fatality and injury data, particularly on small children, continue to occur each year, and even though these fatality and injury incidents are low, there are also low cost design and/or test methods that will help remedy these occurrences.

Docket No. NHTSA 2004-19032

This Final Rules requires that switches for power operated windows, partitions, and roof panel systems be resistant to accidental actuation, which may cause those items to begin to close. Therefore NHTSA is adopting a new requirement that power window switches in new vehicles must pass. This new requirement provides an "accidental actuation test" and requires the use of a new test device, which is a hemisphere with a smooth rigid surface and a 20 mm radius. When this test device is applied to any window switch (or housing surrounding a switch) with a force up to 135 Newtons, the particular window, partition or panel must not begin to close.

NHTSA states that "rocker or toggle" switches are prone to accidental actuation and that "pull up – push down" type switches that must be lifted to close the window are more tolerant to inadvertent actuation. NHTSA also believes that manufacturers could comply with this rule by shielding or recessing their switches, or by designing them so that pressing on them inadvertently will not cause these windows to begin to close.

This new rule applies to all passenger cars, multipurpose passenger vehicles and trucks with a GVWR of 10,000 lbs. or less. NHTSA is allowing a 4-year lead-time until October 1, 2008 for compliance to this new rule. Voluntary compliance is permitted before that date.

Docket No. NHTSA 2004-19076

This Final Rule amends FMVSS 118 by adding new test procedures for a type of non-contact automatic reversal system that accommodates newer technology, which uses infrared reflectance technology. The current test procedures contained in FMVSS 118 are more suited for older technology that uses contact force systems or light beam interruption systems, and are inappropriate for IR-based systems.

For compliance testing of IR based automatic reversal systems, a new test rod has been specified which approximates the dimensions of a small child's hand, arm and/or fingers and also has reflectance values applicable for this purpose.

This new rule applies to all passenger cars, multipurpose passenger vehicles and trucks with a GVWR of 10,000 lbs. or less, and is effective September 1, 2005, with voluntary compliance being permitted before that date.

David Hutton