Document 85xZ69E1Q9J2B0XLOX6O884km
Reproduced by
VACHEt CLECTtlC COtPOtATIO* fto an SAE Fepet (Ju. 1969)
690147
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The Issues of Complying with Federal Motor Vehicle Safety Standards and Other Requirements
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Francis Armstrong
National Highway Safety Sc*:?-. Federal Highway Adrrvmstration. . S. Department of Transportation
Excerpt
Fig. 7 - Relationship between FMVSS and i-.ommal designs
!r is abundan:'; . -_-
no form of statistical sampling
the bureau, no
cleverly conceived, could be
reasonably implerr--t'. r.mdle situation where the
burexr assumed
vr.-.ibilicy for vslidating the manu
facturers' cmiftca:;cr.. "i-cher. the legislation is deaHy
written to exclude .r :rtence, no maser how remote,
chat die govemmen- . r .er.-, in any wey, to the manufac-
turea' certification.
Within this framewr-H: fvr.ctions the compliance activi
ties of the bureau. Cv.-
so to apeak, ia to find the "bad
guys.* It is a we'.'.-'.jww? Axiom in qualify control cirdes
that `you cannot insce-.c Quality into a product.* This ia
particularly tnir in o<i* :uc, mid accetdingly, the bureau's
compliance testing rro,:.vn is better defined as an audit-type
opermion to prorice a treasure of asstnoce that mamrfac*
neers are, chonseiv?.-.. sil igetxly pursuing the type of pro
grams diet sill pror:;.* cooetaner with products thw
meet, as a mimirum.. ;.v.- requirements of the Federal Motor
Vehicle Safety Srs.v -
Having recor~r-: r._- the reqjuremerxe exemplified by
the Federal Mere-
* Safety Standmda ere minimua
remrimnenrr. ir
:J cooclustoo char we do not talk
in tetms of an A* :..
-.Um <pny t--1| relative to
those standards __ -ncr than VXK cornelisnee.
tt'e do. however. pas or the proever--.-
MJL. The ucori^i - '
fust cannot be a high volume a.-v.;
..ze chat induany itaeif must, es -as, think in room of a workable ...and of 'perfection in production' - otisr in the manufacture of such .:er, as the sixoonhUe. But, j$_
i_a|sojusf_ar, Vehicle Safety
' lhw ** > FfdgT<1 Moct
.-y minimum requirements, they
should not be if.tr Fig. 7 is a sin-rv . .
ptoaches iliustrsr::.,. : '
Motor Vehicle Safe.-v:
used as nominal desieo value*. j.-rraysi of three possible ap-
orionahip between FMVSS (Federal aids) and the embtidroem of
nominal design viur
Design value <A) has been established recognizing the ef
fect that normal production variatce would have on the compliance status of the finished product. The nominal de sign value, in this example, exceeds the requirements of the standard to the degree chat all produces mamdaetteed within the normal quality spread attainable in actual ptoJi- tioo would be in compliance with the standard.
Design value (B). while exceeding the mininaan safety performance requirements of the standard, fails to recognize, sufficiently, the effect of noaaal production variance on the compliance status of the finished product. Accoidingly. as pan of the inevitable facta of production life, me measure of noncompliroce eaiat certainly exist.
Design value (Q, on the otha hand, has been established using the federal standard as the mean or central tendency of the name! wiwiewi distribution of quality output issder pro duction conditions. Under these circumstances, the incid ence of noocneqilisncc would, of course, be quite high.
From my earlier marks estsblishina lOOf: compliance as the only ACL acceptable to the bureau, it is obvious rhar only the tsamnle deoictint "nominal design value (A)* ty pifies conditions that could realistically be expected to achieve acceptable compliance performance bv industry. The bwemi is nee concerned with desip) for design's sake. The manufacturer exist, of course, retain complete freedom of
design in meeting die performance requirements of the in
dividual standard!. It i up w the manufacturer to deter mine the degree of ovcrdcsian. relative to the minimum teouiremrots of the standard, necessary to establish and maintain an "in compliance* sranra for his product. The degree of overdesign necessary fee wry one product, be it vdride or equipment, can. arid probably will, vary from manufactures to t^anufsecurer. Certainly, it will be direedy rotated. among ocher things, to the mroufsecurer*' ability a monitor end control his production process.
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