Mercedes-Benz USA, LLC, Denial of Petition for Decision of Inconsequential Noncompliance, 73395-73398 [2023-23528]
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Federal Register / Vol. 88, No. 205 / Wednesday, October 25, 2023 / Notices
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consider the absence of complaints or
injuries when determining if a
noncompliance is inconsequential to
safety. The absence of complaints does
not mean vehicle occupants have not
experienced a safety issue, nor does it
mean that there will not be safety issues
in the future.4
NHTSA has evaluated the merits of
the inconsequential noncompliance
petition and supplemental materials
submitted by BMW and has determined
that this particular noncompliance is
inconsequential to motor vehicle safety.
Specifically, the Agency considered the
following when making its decision:
In pertinent part, S5.2.5 requires that
each footrest for a passenger other than
an operator fold rearward and upward
when not in use. NHTSA has issued
several interpretations of section S5.2.5.
In a letter dated February 16, 1982, to
American Honda Motor Co., Inc., with
respect to a proposed footboard design,
the then Chief Counsel commented that
‘‘[w]e consider that the purpose of
S5.2.5 is to prevent accidents caused by
rigid footrests contacting the ground in
a banking turn.’’ 5 Various other NHTSA
letters provided the same interpretation
of the footrest requirement in S5.2.5.6
BMW conducted a measurement
analysis for the K1600 GTL Motorcycle
including lean angle to determine the
distance between the passenger footrest
and the ground when other motorcycle
components contact the ground during
a banked turn. The analysis indicated
that the first component that would
35355 (June 12, 2013) (finding noncompliance had
no effect on occupant safety because it had no effect
on the proper operation of the occupant
classification system and the correct deployment of
an air bag); Osram Sylvania Prods. Inc.; Grant of
Petition for Decision of Inconsequential
Noncompliance, 78 FR 46000 (July 30, 2013)
(finding occupant using noncompliant light source
would not be exposed to significantly greater risk
than occupant using similar compliant light
source).
4 See Morgan 3 Wheeler Limited; Denial of
Petition for Decision of Inconsequential
Noncompliance, 81 FR 21663, 21666 (Apr. 12,
2016); see also United States v. Gen. Motors Corp.,
565 F.2d 754, 759 (D.C. Cir. 1977) (finding defect
poses an unreasonable risk when it ‘‘results in
hazards as potentially dangerous as sudden engine
fire, and where there is no dispute that at least some
such hazards, in this case fires, can definitely be
expected to occur in the future’’).
5 https://www.nhtsa.gov/interpretations/
aiam3524.
6 An earlier interpretation from 1973 also to
American Honda stated that S5.2.5 regulates ‘‘only
the direction in which footrests shall retract, so that
if they are inadvertently left down when not in use
they will fold rearward and upward should they hit
an obstacle while the motorcycle is travelling
forward.’’ That interpretation suggests that contact
of the footrests with obstacles other than the ground
or roadway may be a consideration. However, all
other agency interpretations of S5.2.5 focus on
footrest contact with the ground/roadway. See
https://www.nhtsa.gov/interpretations/nht73-622.
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contact the ground would be the rider’s
footrest at 39 degrees lean angle,
followed by other components such as
the engine spoiler that would contact
the ground at 43 degrees. Next,
components including the center stand
would contact the ground at 46 degrees.
The BMW analysis demonstrated that,
as the motorcycle lean angle increases,
all of these components contact the
ground well before the passenger
footrest would make contact with the
ground.
Additionally, BMW conducted a
measurement analysis for the K1600 B
Motorcycle including lean angle to
determine the distance between the
passenger footrest and the ground when
other motorcycle components contact
the ground during a banked turn. The
analysis indicated that the first
component that would contact the
ground would be the rider’s footrest at
39 degrees, followed by other
components such as the engine spoiler
that would contact the ground at 42
degrees. Next, components including
the engine spoiler would contact the
ground at 43.5 degrees. According to
BMW’s analysis, as the motorcycle lean
angle increases, all of these components
contact the ground before the passenger
footrest would make contact with the
ground.
Furthermore, BMW conducted a
measurement analysis for the K1600
Grand America Motorcycle including
lean angle to determine the distance
between the passenger footrest and the
ground when other motorcycle
components contact the ground during
a banked turn. The analysis indicated
that the first component that would
contact the ground would be the rider’s
floorboard at a lean angle of 34.5
degrees, followed by other components
such as the rider footrest that would
contact the ground at 39 degrees. Next,
components including the silencer
would contact the ground at 42 degrees.
As motorcycle lean angle increases, all
of these components contact the ground
well before the passenger footrest would
make contact with the ground.
BMW also conducted real-world test
rides with a K 1600 GTL and with a K
1600 Grand America. On-board videos
were taken to provide a close-up view
of certain components prior to, and at,
contact with the ground. The videos
confirmed the findings from the
measurement analysis.
NHTSA considers the purpose of
S5.2.5 is to prevent accidents caused by
rigid passenger footrests contacting the
ground when a motorcycle is leaned
over in a turn. BMW’s measurement
analysis and real-world testing clearly
demonstrate there is no possibility for
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the passenger footrests to contact the
ground while the motorcycle is under
control in a banked turn because
numerous other components would
contact the ground first, preventing
either passenger footrest from ever
contacting the ground. Therefore, this
noncompliance is inconsequential to
motor vehicle safety.
VII. NHTSA’s Decision
In consideration of the foregoing,
NHTSA finds that BMW has met its
burden of persuasion that the subject
FMVSS No. 123 noncompliance in the
affected motorcycles is inconsequential
to motor vehicle safety. Accordingly,
BMW’s petition is hereby granted, and
BMW is consequently exempted from
the obligation of providing notification
of, and a free remedy for, that
noncompliance under 49 U.S.C. 30118
and 30120.
NHTSA notes that the statutory
provisions (49 U.S.C. 30118(d) and
30120(h)) that permit manufacturers to
file petitions for a determination of
inconsequentiality allow NHTSA to
exempt manufacturers only from the
duties found in sections 30118 and
30120, respectively, to notify owners,
purchasers, and dealers of a defect or
noncompliance and to remedy the
defect or noncompliance. Therefore, this
decision only applies to the subject
motorcycles that BMW no longer
controlled at the time it determined that
the noncompliance existed. However,
the granting of this petition does not
relieve vehicle distributors and dealers
of the prohibitions on the sale, offer for
sale, or introduction or delivery for
introduction into interstate commerce of
the noncompliant motorcycles under
their control after BMW notified them
that the subject noncompliance existed.
(Authority: 49 U.S.C. 30118, 30120:
delegations of authority at 49 CFR 1.95 and
501.8)
Otto G. Matheke III,
Director, Office of Vehicle Safety Compliance.
[FR Doc. 2023–23529 Filed 10–24–23; 8:45 am]
BILLING CODE 4910–59–P
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety
Administration
[Docket No. NHTSA–2020–0064; Notice 2]
Mercedes-Benz USA, LLC, Denial of
Petition for Decision of
Inconsequential Noncompliance
National Highway Traffic
Safety Administration (NHTSA),
Department of Transportation (DOT).
AGENCY:
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ACTION:
Federal Register / Vol. 88, No. 205 / Wednesday, October 25, 2023 / Notices
Denial of petition.
Mercedes-Benz AG and
Mercedes-Benz USA, LLC, (collectively,
‘‘Mercedes-Benz’’ or ‘‘Petitioner’’) have
determined that certain model year
(MY) 2020 Mercedes-Benz GLS 580
motor vehicles do not fully comply with
Federal Motor Vehicle Safety Standard
(FMVSS) No. 118, Power-operated
Window, Partition, and Roof Panel
Systems. Mercedes-Benz filed a
noncompliance report dated May 11,
2020, and subsequently petitioned
NHTSA on June 3, 2020, for a decision
that the subject noncompliance is
inconsequential as it relates to motor
vehicle safety. This notice announces
the denial of Mercedes-Benz’s petition.
FOR FURTHER INFORMATION CONTACT:
Frederick Smith, Office of Vehicle
Safety Compliance, the National
Highway Traffic Safety Administration
(NHTSA), telephone (202) 366–7487,
facsimile (202) 366–3081.
SUPPLEMENTARY INFORMATION:
I. Overview: Mercedes-Benz has
determined that certain MY 2020
Mercedes-Benz GLS 580 motor vehicles
do not fully comply with the
requirements of paragraph S6(a)(1) of
FMVSS No. 118, Power-operated
Window, Partition, and Roof Panel
Systems (49 CFR 571.118). MercedesBenz filed a noncompliance report
dated May 11, 2020, pursuant to 49 CFR
part 573, Defect and Noncompliance
Responsibility and Reports. MercedesBenz subsequently petitioned NHTSA
on June 3, 2020, for an exemption from
the notification and remedy
requirements of 49 U.S.C. Chapter 301
on the basis that this noncompliance is
inconsequential as it relates to motor
vehicle safety, pursuant to 49 U.S.C.
30118(d) and 30120(h) and 49 CFR part
556, Exemption for Inconsequential
Defect or Noncompliance.
Notice of receipt of Mercedes-Benz
petition was published with a 30-day
public comment period, on October 23,
2020, in the Federal Register (85 FR
67604). No comments were received. To
view the petition and all supporting
documents log onto the Federal Docket
Management System (FDMS) website at
https://www.regulations.gov/. Then
follow the online search instructions to
locate docket number ‘‘NHTSA–2020–
0064.’’
II. Vehicles Involved: Mercedes-Benz
stated that it determined that 22 MY
2020 Mercedes-Benz GLS 580 motor
vehicles manufactured between
February 8, 2019, and September 20,
2019, do not meet the requirements of
FMVSS No. 118, S6(a)(1).
III. Noncompliance: Mercedes-Benz
explains that the noncompliance is that
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SUMMARY:
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the automatic reversal systems and
actuation devices for the sunroofs in the
subject vehicles do not fully comply
with paragraph S6(a)(1) of FMVSS No.
118. Specifically, when the vehicle’s
‘‘car wash mode’’ is activated by using
the central touch display in the center
console, the sunroof may close
automatically.
IV. Rule Requirements: Paragraph
S6(a)(1) of FMVSS No. 118 includes the
requirements relevant to this petition.
An actuation device must not cause a
window, partition, or roof panel to
begin to close from any open position
when tested using a stainless steel
sphere having a surface finish between
8 and 4 micro inches and a radius of 20
mm ± 0.2 mm, when the surface of the
sphere is placed against any portion of
the actuation device.
V. Summary of Mercedes-Benz’s
Petition: The following views and
arguments presented in this section are
the views and arguments provided by
Mercedes-Benz and do not reflect the
views of NHTSA. Mercedes-Benz
describes the subject noncompliance
and contends that the noncompliance is
inconsequential as it relates to motor
vehicle safety.
In support of its petition, MercedesBenz offers the following reasoning:
1. Mercedes-Benz alleges that ‘‘due to
their specific operating parameters, even
though the buttons used to activate car
wash mode do not meet the
performance requirement of paragraph
S6(a), the condition does not create an
increased safety risk.’’
2. First, Mercedes-Benz states, ‘‘the
car wash mode feature must first be
activated by the user. Car wash mode is
not automatically enabled unless and
until the operator activates the feature
by affirmatively accepting the option
and turning the feature on. Thus, unless
car wash mode is already active within
the vehicle, the condition described
above cannot occur.’’
3. Mercedes-Benz further states,
‘‘[o]nce the vehicle has initialized car
wash mode, the feature can only be
activated through a series of steps using
either the vehicle’s central touch
display or from a touchpad located in
the center console. Activating car wash
mode is a multi-step process and the
process varies depending on the current
menu contained on the display screen.
For example, if car wash mode has been
programmed by the user inside the
‘‘favorites’’ menu, then a series of two
touches is needed to activate car wash
mode. In all other cases, the operator
would first need to change the display
screen to the vehicle menu first and
from there, navigate to the car wash
mode icon. In either case, car wash
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mode will not become active unless
each of these steps is executed in the
corresponding order. Because of the
complexity involved in navigating
through the required sequence of events
there is an extremely low likelihood of
the car wash mode being inadvertently
activated in the first place.’’
4. Further, Mercedes-Benz claims ‘‘the
sunroofs in the subject vehicles contain
an auto-reverse feature. Upon detecting
an object or obstruction inside the
sunroof, it will automatically stop and
reverse course and fully retract. While
the sunroofs do not meet the
requirements of paragraph S5,
Mercedes-Benz states that they are
certified to the European standard UN–
R–21. The European standard
incorporates many of the performance
features included in the automatic
reversal function contained in FMVSS
No. 118, paragraph S5. The sunroofs in
the subject vehicles will automatically
reverse prior to exerting 100 Newtons of
pinch force, and consistent with the
options provided at paragraph S5.2, the
sunroof will either retract to a position
at least as wide as the initial position
before closing or will allow a 200-mm
rod to be inserted in the gap.’’
5. Mercedes-Benz says that NHTSA
‘‘has previously granted petitions for
inconsequential treatment for FMVSS
No. 118 involving similar circumstances
and vehicle features. NHTSA granted a
petition by General Motors involving a
noncompliance with FMVSS No. 118,
paragraph S4(e), where for 60 seconds
after the vehicles are started, an issue
with the sunroof module would allow
the sunroof to close via the control
button if the engine is turned off and a
front door is opened. In that instance, in
order to activate the sunroof, a series of
specific steps must be taken in order
and the steps must be completed within
a 60-second time frame. See General
Motors Corporation, Grant of Petition
for Decision of Inconsequential
Noncompliance, 73 FR 22459 (April 25,
2008). In granting the petition, the
Agency found that the potential for
entrapment in a power operated sunroof
presented less of a risk of entrapment
than power-operated windows because,
in general, sunroofs are less physically
accessible than power-operated
windows. The decision also focused on
the presence of an auto-reverse feature,
which would reverse the movement of
the sunroof before it exerted a pressure
of 100 Newtons. In granting the petition,
the Agency noted the presence of this
auto-reverse feature as one that would
further reduce the risk of entrapment.’’
6. Mercedes-Benz further asserts that
‘‘much like the conditions present in the
General Motors Corporation vehicles,
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the noncompliance in the car wash
mode feature of the subject vehicles
similarly does not create an increased
safety risk. Assuming that the function
has been initialized by the operator, a
series of specific and coordinated steps
must occur in order to activate car wash
mode. If those steps are not carried out
in the precise order required, then the
car-wash mode program will not be
activated. Even in the unlikely event
that the car wash mode function is
inadvertently activated, there is no
enhanced risk of injury because of the
sunroof auto-reverse feature.’’
Mercedes-Benz concludes by again
contending that the subject
noncompliance is inconsequential as it
relates to motor vehicle safety, and that
its petition to be exempted from
providing notification of the
noncompliance, as required by 49
U.S.C. 30118, and a remedy for the
noncompliance, as required by 49
U.S.C. 30120, should be granted.
VI. NHTSA’s Analysis: The burden of
establishing the inconsequentiality of a
failure to comply with a performance
requirement in a standard—as opposed
to a labeling requirement with no
performance implications—is more
substantial and difficult to meet.
Accordingly, NHTSA has not found
many such noncompliances
inconsequential.1 Potential performance
failures of safety-critical equipment, like
seat belts or air bags, are rarely deemed
inconsequential.
An important issue to consider in
determining inconsequentiality based
upon NHTSA’s prior decisions on
noncompliance issues was the safety
risk to individuals who experience the
type of event against which the recall
would otherwise protect.2 In general,
NHTSA does not consider the absence
of complaints or injuries to show that
the issue is inconsequential to safety.
‘‘Most importantly, the absence of a
complaint does not mean there have not
been any safety issues, nor does it mean
that there will not be safety issues in the
1 Cf. Gen. Motors Corporation; Ruling on Petition
for Determination of Inconsequential
Noncompliance, 69 FR 19897, 19899 (Apr. 14,
2004) (citing prior cases where noncompliance was
expected to be imperceptible, or nearly so, to
vehicle occupants or approaching drivers).
2 See Gen. Motors, LLC; Grant of Petition for
Decision of Inconsequential Noncompliance, 78 FR
35355 (June 12, 2013) (finding noncompliance had
no effect on occupant safety because it had no effect
on the proper operation of the occupant
classification system and the correct deployment of
an air bag); Osram Sylvania Prods. Inc.; Grant of
Petition for Decision of Inconsequential
Noncompliance, 78 FR 46000 (July 30, 2013)
(finding occupant using noncompliant light source
would not be exposed to significantly greater risk
than occupant using similar compliant light
source).
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future.’’ 3 ‘‘[T]he fact that in past
reported cases good luck and swift
reaction have prevented many serious
injuries does not mean that good luck
will continue to work.’’ 4
Arguments that only a small number
of vehicles or items of motor vehicle
equipment are affected have also not
justified granting an inconsequentiality
petition.5 Similarly, NHTSA has
rejected petitions based on the assertion
that only a small percentage of vehicles
or items of equipment are likely to
actually exhibit a noncompliance. The
percentage of potential occupants that
could be adversely affected by a
noncompliance does not determine the
question of inconsequentiality. Rather,
the issue to consider is the consequence
to an occupant who is exposed to the
consequence of that noncompliance.6
These considerations are also relevant
when considering whether a defect is
inconsequential to motor vehicle safety.
NHTSA has reviewed the MercedesBenz inconsequentiality petition and
does not concur with Mercedes-Benz’s
conclusion that the noncompliance is
inconsequential to motor vehicle safety
and is denying Mercedes-Benz’s
petition.
FMVSS 118 S6 sets performance
requirements intended to mitigate the
potential for injury from a window or
sunroof being inadvertently closed
when a person is in its path. Under the
standard, the operating controls may not
allow a window, sunroof or partition to
close when a test sphere (simulating a
child’s knee) is pressed against the
control. Specifically, FMVSS No. 118
3 Morgan 3 Wheeler Limited; Denial of Petition for
Decision of Inconsequential Noncompliance, 81 FR
21663, 21666 (Apr. 12, 2016).
4 United States v. Gen. Motors Corp., 565 F.2d
754, 759 (D.C. Cir. 1977) (finding defect poses an
unreasonable risk when it ‘‘results in hazards as
potentially dangerous as sudden engine fire, and
where there is no dispute that at least some such
hazards, in this case fires, can definitely be
expected to occur in the future’’).
5 See Mercedes-Benz, U.S.A., L.L.C.; Denial of
Application for Decision of Inconsequential
Noncompliance, 66 FR 38342 (July 23, 2001)
(rejecting argument that noncompliance was
inconsequential because of the small number of
vehicles affected); Aston Martin Lagonda Ltd.;
Denial of Petition for Decision of Inconsequential
Noncompliance, 81 FR 41370 (June 24, 2016)
(noting that situations involving individuals
trapped in motor vehicles—while infrequent—are
consequential to safety); Morgan 3 Wheeler Ltd.;
Denial of Petition for Decision of Inconsequential
Noncompliance, 81 FR 21663, 21664 (Apr. 12,
2016) (rejecting argument that petition should be
granted because the vehicle was produced in very
low numbers and likely to be operated on a limited
basis).
6 See Gen. Motors Corp.; Ruling on Petition for
Determination of Inconsequential Noncompliance,
69 FR 19897, 19900 (Apr. 14, 2004); Cosco Inc.;
Denial of Application for Decision of
Inconsequential Noncompliance, 64 FR 29408,
29409 (June 1, 1999).
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73397
S6(a)(1) requires that ‘‘an actuation
device must not cause a window,
partition, or roof panel to begin to close
from any open position when tested
. . . [u]sing a stainless steel sphere
having a surface finish between 8 and 4
micro inches and a radius of 20 mm ±
0.2 mm, place the surface of the sphere
against any portion of the actuation
device.’’
According to the Mercedes-Benz
petition, ‘‘the actuation devices used to
engage car wash mode do not meet the
inadvertent activation provisions of
FMVSS No. 118 S6(a)(1).’’ However,
Mercedes-Benz argues activating carwash mode is a multi-step process and
the process varies depending on the
current menu contained on the display
screen of a particular vehicle. After
considering information provided by
Mercedes-Benz and from online
descriptions of the system, NHTSA
believes there is a minimal level of
complexity involved in navigating
through the required sequence of events
to actuate and close the sunroof. The
controls at issue include those located
on the console between the front seats
where a child could easily stand or
kneel. Given the unpredictable behavior
of an unattended child, inadvertent
selection of the ‘‘Quick Access’’ or
‘‘Favorite’’ hard buttons, where the ‘‘Car
Wash Mode’’ icon can be located, is a
foreseeable and appreciable risk. Car
Wash Mode can be programmed as the
only selectable icon within the
‘‘Favorite’’ menu, increasing its
susceptibility to accidental engagement.
In their petition, Mercedes-Benz
states, ‘‘the sunroofs in the subject
vehicles contain an auto-reverse feature.
Upon detecting an object or obstruction
inside the sunroof, it will automatically
stop and reverse course and fully
retract. While the sunroofs do not meet
the requirements of S5, they are
certified to the European standard UN–
R–21. The European standard
incorporates many of the performance
features included in the automatic
reversal function contained in FMVSS
118, S5.’’ NHTSA acknowledges that the
sunroofs in the Mercedes-Benz vehicles
in question are compliant with UN–R–
21, but Mercedes-Benz concedes they do
not comply with FMVSS 118 S5,
NHTSA’s regulations governing
automatic reversal systems. While UN–
R–21 does provide a level of safety,
FMVSS 118 S5 provides a greater level
of protection from pinching injuries,
particularly to smaller appendages like
a child’s fingers.
Finally, in the petition Mercedes-Benz
claims the circumstances here are
analogous to the circumstances in a
previous NHTSA determination that
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Federal Register / Vol. 88, No. 205 / Wednesday, October 25, 2023 / Notices
noncompliance was inconsequential.
NHTSA considers each petition on its
own merits and the prior decision cited
by the Petitioner has limited
applicability in this case. NHTSA
believes the circumstances for
accidental window/sunroof closure
involved in the cited General Motors
(GM) petition are significantly different
than those required under MercedesBenz current petition. In granting the
GM petition, the agency was persuaded
that the high level of complexity
involved in navigating through the
required sequence of events effectively
eliminated any entrapment risk,
particularly the limited timeframe
within which the events would have to
occur. Specifically, NHTSA stated, ‘‘[i]t
is very unlikely that the entire sequence
of events—starting the engine, turning
the engine off, opening a front door, a
person becoming positioned in the
sunroof opening, and pushing the
sunroof close button—will occur in less
than 60 seconds from the time the
ignition is turned off and the vehicle
operator has exited the vehicle and left
the immediate area.’’ General Motors,
Decision Granting Petition for
Inconsequential Noncompliance, 73 FR
22459 (April 25, 2008). In contrast, the
noncompliance in the Mercedes-Benz
petition does not involve as great a level
of complexity in the required sequence
of events that would lead to sunroof
engagement. The Mercedes-Benz
petition states, in the subject vehicles,
as few as two inputs to the centralized
control devices is sufficient to actuate
and close the sunroof, i.e., with Car
Wash Mode included in the ‘‘Favorites’’
menu. Furthermore, the touch screens at
issue here remain activated indefinitely
until the vehicle is turned off or a user
activates a command. NHTSA therefore
does not agree that the prior
determination in the GM case is
analogous or persuasive here.
Therefore, Mercedes-Benz has not met
its burden of persuasion and for the
reasons described herein NHTSA does
not find that the subject noncompliance
is inconsequential to motor vehicle
safety.
VII. NHTSA’s Decision: In
consideration of the foregoing analysis,
NHTSA finds that Mercedes-Benz has
not met its burden of persuasion that the
FMVSS No. 118 noncompliance at issue
is inconsequential to motor vehicle
safety.
Accordingly, Mercedes-Benz’s
petition is hereby denied and MercedesBenz is consequently obligated to
provide notification of, and a free
remedy for, the noncompliance under
49 U.S.C. 30118 and 30120.
(Authority: 49 U.S.C. 30118, 30120:
delegations of authority at 49 CFR 1.95 and
501.8)
Cem Hatipoglu,
Acting Associate Administrator for
Enforcement.
[FR Doc. 2023–23528 Filed 10–24–23; 8:45 am]
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Electronically via AMIS.
Submission method
lotter on DSK11XQN23PROD with NOTICES1
* This requirement also applies to Applicants’ prospective sub-recipients that are not direct beneficiaries of federal financial assistance (e.g.,
Depository Institutions Holding Company and their Subsidiary Depository Institutions).
Executive Summary: The Small Dollar
Loan Program (SDL Program) is
administered by the Community
Development Financial Institutions
Fund (CDFI Fund). Through the SDL
Program, the CDFI Fund provides (1)
grants for Loan Loss Reserves (LLR) to
enable a Certified Community
Development Financial Institution
(CDFI) establish a loan loss reserve fund
in order to cover the losses on small
VerDate Sep<11>2014
17:01 Oct 24, 2023
Jkt 262001
dollar loans associated with starting a
new small dollar loan program or
expanding an existing small dollar loan
program; and (2) grants for Technical
Assistance (TA) for technology, staff
support, and other eligible activities to
enable a Certified CDFI to establish and
maintain a small dollar loan program.
All awards provided through this Notice
of Funds Availability (NOFA) are
subject to funding availability.
PO 00000
Frm 00090
Fmt 4703
Sfmt 4703
I. Program Description
A. Authorizing Statute: The SDL
Program is authorized by Title XII—
Improving Access to Mainstream
Financial Institutions Act of the DoddFrank Wall Street Reform and Consumer
Protection Act of 2010 (Pub. L. 111–
203), which amended the Riegle
Community Development Banking and
Financial Institutions Act of 1994 (Pub.
L. 103–325) to include the SDL Program
E:\FR\FM\25OCN1.SGM
25OCN1
Agencies
[Federal Register Volume 88, Number 205 (Wednesday, October 25, 2023)]
[Notices]
[Pages 73395-73398]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-23528]
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DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
[Docket No. NHTSA-2020-0064; Notice 2]
Mercedes-Benz USA, LLC, Denial of Petition for Decision of
Inconsequential Noncompliance
AGENCY: National Highway Traffic Safety Administration (NHTSA),
Department of Transportation (DOT).
[[Page 73396]]
ACTION: Denial of petition.
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SUMMARY: Mercedes-Benz AG and Mercedes-Benz USA, LLC, (collectively,
``Mercedes-Benz'' or ``Petitioner'') have determined that certain model
year (MY) 2020 Mercedes-Benz GLS 580 motor vehicles do not fully comply
with Federal Motor Vehicle Safety Standard (FMVSS) No. 118, Power-
operated Window, Partition, and Roof Panel Systems. Mercedes-Benz filed
a noncompliance report dated May 11, 2020, and subsequently petitioned
NHTSA on June 3, 2020, for a decision that the subject noncompliance is
inconsequential as it relates to motor vehicle safety. This notice
announces the denial of Mercedes-Benz's petition.
FOR FURTHER INFORMATION CONTACT: Frederick Smith, Office of Vehicle
Safety Compliance, the National Highway Traffic Safety Administration
(NHTSA), telephone (202) 366-7487, facsimile (202) 366-3081.
SUPPLEMENTARY INFORMATION:
I. Overview: Mercedes-Benz has determined that certain MY 2020
Mercedes-Benz GLS 580 motor vehicles do not fully comply with the
requirements of paragraph S6(a)(1) of FMVSS No. 118, Power-operated
Window, Partition, and Roof Panel Systems (49 CFR 571.118). Mercedes-
Benz filed a noncompliance report dated May 11, 2020, pursuant to 49
CFR part 573, Defect and Noncompliance Responsibility and Reports.
Mercedes-Benz subsequently petitioned NHTSA on June 3, 2020, for an
exemption from the notification and remedy requirements of 49 U.S.C.
Chapter 301 on the basis that this noncompliance is inconsequential as
it relates to motor vehicle safety, pursuant to 49 U.S.C. 30118(d) and
30120(h) and 49 CFR part 556, Exemption for Inconsequential Defect or
Noncompliance.
Notice of receipt of Mercedes-Benz petition was published with a
30-day public comment period, on October 23, 2020, in the Federal
Register (85 FR 67604). No comments were received. To view the petition
and all supporting documents log onto the Federal Docket Management
System (FDMS) website at https://www.regulations.gov/. Then follow the
online search instructions to locate docket number ``NHTSA-2020-0064.''
II. Vehicles Involved: Mercedes-Benz stated that it determined that
22 MY 2020 Mercedes-Benz GLS 580 motor vehicles manufactured between
February 8, 2019, and September 20, 2019, do not meet the requirements
of FMVSS No. 118, S6(a)(1).
III. Noncompliance: Mercedes-Benz explains that the noncompliance
is that the automatic reversal systems and actuation devices for the
sunroofs in the subject vehicles do not fully comply with paragraph
S6(a)(1) of FMVSS No. 118. Specifically, when the vehicle's ``car wash
mode'' is activated by using the central touch display in the center
console, the sunroof may close automatically.
IV. Rule Requirements: Paragraph S6(a)(1) of FMVSS No. 118 includes
the requirements relevant to this petition. An actuation device must
not cause a window, partition, or roof panel to begin to close from any
open position when tested using a stainless steel sphere having a
surface finish between 8 and 4 micro inches and a radius of 20 mm
0.2 mm, when the surface of the sphere is placed against
any portion of the actuation device.
V. Summary of Mercedes-Benz's Petition: The following views and
arguments presented in this section are the views and arguments
provided by Mercedes-Benz and do not reflect the views of NHTSA.
Mercedes-Benz describes the subject noncompliance and contends that the
noncompliance is inconsequential as it relates to motor vehicle safety.
In support of its petition, Mercedes-Benz offers the following
reasoning:
1. Mercedes-Benz alleges that ``due to their specific operating
parameters, even though the buttons used to activate car wash mode do
not meet the performance requirement of paragraph S6(a), the condition
does not create an increased safety risk.''
2. First, Mercedes-Benz states, ``the car wash mode feature must
first be activated by the user. Car wash mode is not automatically
enabled unless and until the operator activates the feature by
affirmatively accepting the option and turning the feature on. Thus,
unless car wash mode is already active within the vehicle, the
condition described above cannot occur.''
3. Mercedes-Benz further states, ``[o]nce the vehicle has
initialized car wash mode, the feature can only be activated through a
series of steps using either the vehicle's central touch display or
from a touchpad located in the center console. Activating car wash mode
is a multi-step process and the process varies depending on the current
menu contained on the display screen. For example, if car wash mode has
been programmed by the user inside the ``favorites'' menu, then a
series of two touches is needed to activate car wash mode. In all other
cases, the operator would first need to change the display screen to
the vehicle menu first and from there, navigate to the car wash mode
icon. In either case, car wash mode will not become active unless each
of these steps is executed in the corresponding order. Because of the
complexity involved in navigating through the required sequence of
events there is an extremely low likelihood of the car wash mode being
inadvertently activated in the first place.''
4. Further, Mercedes-Benz claims ``the sunroofs in the subject
vehicles contain an auto-reverse feature. Upon detecting an object or
obstruction inside the sunroof, it will automatically stop and reverse
course and fully retract. While the sunroofs do not meet the
requirements of paragraph S5, Mercedes-Benz states that they are
certified to the European standard UN-R-21. The European standard
incorporates many of the performance features included in the automatic
reversal function contained in FMVSS No. 118, paragraph S5. The
sunroofs in the subject vehicles will automatically reverse prior to
exerting 100 Newtons of pinch force, and consistent with the options
provided at paragraph S5.2, the sunroof will either retract to a
position at least as wide as the initial position before closing or
will allow a 200-mm rod to be inserted in the gap.''
5. Mercedes-Benz says that NHTSA ``has previously granted petitions
for inconsequential treatment for FMVSS No. 118 involving similar
circumstances and vehicle features. NHTSA granted a petition by General
Motors involving a noncompliance with FMVSS No. 118, paragraph S4(e),
where for 60 seconds after the vehicles are started, an issue with the
sunroof module would allow the sunroof to close via the control button
if the engine is turned off and a front door is opened. In that
instance, in order to activate the sunroof, a series of specific steps
must be taken in order and the steps must be completed within a 60-
second time frame. See General Motors Corporation, Grant of Petition
for Decision of Inconsequential Noncompliance, 73 FR 22459 (April 25,
2008). In granting the petition, the Agency found that the potential
for entrapment in a power operated sunroof presented less of a risk of
entrapment than power-operated windows because, in general, sunroofs
are less physically accessible than power-operated windows. The
decision also focused on the presence of an auto-reverse feature, which
would reverse the movement of the sunroof before it exerted a pressure
of 100 Newtons. In granting the petition, the Agency noted the presence
of this auto-reverse feature as one that would further reduce the risk
of entrapment.''
6. Mercedes-Benz further asserts that ``much like the conditions
present in the General Motors Corporation vehicles,
[[Page 73397]]
the noncompliance in the car wash mode feature of the subject vehicles
similarly does not create an increased safety risk. Assuming that the
function has been initialized by the operator, a series of specific and
coordinated steps must occur in order to activate car wash mode. If
those steps are not carried out in the precise order required, then the
car-wash mode program will not be activated. Even in the unlikely event
that the car wash mode function is inadvertently activated, there is no
enhanced risk of injury because of the sunroof auto-reverse feature.''
Mercedes-Benz concludes by again contending that the subject
noncompliance is inconsequential as it relates to motor vehicle safety,
and that its petition to be exempted from providing notification of the
noncompliance, as required by 49 U.S.C. 30118, and a remedy for the
noncompliance, as required by 49 U.S.C. 30120, should be granted.
VI. NHTSA's Analysis: The burden of establishing the
inconsequentiality of a failure to comply with a performance
requirement in a standard--as opposed to a labeling requirement with no
performance implications--is more substantial and difficult to meet.
Accordingly, NHTSA has not found many such noncompliances
inconsequential.\1\ Potential performance failures of safety-critical
equipment, like seat belts or air bags, are rarely deemed
inconsequential.
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\1\ Cf. Gen. Motors Corporation; Ruling on Petition for
Determination of Inconsequential Noncompliance, 69 FR 19897, 19899
(Apr. 14, 2004) (citing prior cases where noncompliance was expected
to be imperceptible, or nearly so, to vehicle occupants or
approaching drivers).
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An important issue to consider in determining inconsequentiality
based upon NHTSA's prior decisions on noncompliance issues was the
safety risk to individuals who experience the type of event against
which the recall would otherwise protect.\2\ In general, NHTSA does not
consider the absence of complaints or injuries to show that the issue
is inconsequential to safety. ``Most importantly, the absence of a
complaint does not mean there have not been any safety issues, nor does
it mean that there will not be safety issues in the future.'' \3\
``[T]he fact that in past reported cases good luck and swift reaction
have prevented many serious injuries does not mean that good luck will
continue to work.'' \4\
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\2\ See Gen. Motors, LLC; Grant of Petition for Decision of
Inconsequential Noncompliance, 78 FR 35355 (June 12, 2013) (finding
noncompliance had no effect on occupant safety because it had no
effect on the proper operation of the occupant classification system
and the correct deployment of an air bag); Osram Sylvania Prods.
Inc.; Grant of Petition for Decision of Inconsequential
Noncompliance, 78 FR 46000 (July 30, 2013) (finding occupant using
noncompliant light source would not be exposed to significantly
greater risk than occupant using similar compliant light source).
\3\ Morgan 3 Wheeler Limited; Denial of Petition for Decision of
Inconsequential Noncompliance, 81 FR 21663, 21666 (Apr. 12, 2016).
\4\ United States v. Gen. Motors Corp., 565 F.2d 754, 759 (D.C.
Cir. 1977) (finding defect poses an unreasonable risk when it
``results in hazards as potentially dangerous as sudden engine fire,
and where there is no dispute that at least some such hazards, in
this case fires, can definitely be expected to occur in the
future'').
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Arguments that only a small number of vehicles or items of motor
vehicle equipment are affected have also not justified granting an
inconsequentiality petition.\5\ Similarly, NHTSA has rejected petitions
based on the assertion that only a small percentage of vehicles or
items of equipment are likely to actually exhibit a noncompliance. The
percentage of potential occupants that could be adversely affected by a
noncompliance does not determine the question of inconsequentiality.
Rather, the issue to consider is the consequence to an occupant who is
exposed to the consequence of that noncompliance.\6\ These
considerations are also relevant when considering whether a defect is
inconsequential to motor vehicle safety.
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\5\ See Mercedes-Benz, U.S.A., L.L.C.; Denial of Application for
Decision of Inconsequential Noncompliance, 66 FR 38342 (July 23,
2001) (rejecting argument that noncompliance was inconsequential
because of the small number of vehicles affected); Aston Martin
Lagonda Ltd.; Denial of Petition for Decision of Inconsequential
Noncompliance, 81 FR 41370 (June 24, 2016) (noting that situations
involving individuals trapped in motor vehicles--while infrequent--
are consequential to safety); Morgan 3 Wheeler Ltd.; Denial of
Petition for Decision of Inconsequential Noncompliance, 81 FR 21663,
21664 (Apr. 12, 2016) (rejecting argument that petition should be
granted because the vehicle was produced in very low numbers and
likely to be operated on a limited basis).
\6\ See Gen. Motors Corp.; Ruling on Petition for Determination
of Inconsequential Noncompliance, 69 FR 19897, 19900 (Apr. 14,
2004); Cosco Inc.; Denial of Application for Decision of
Inconsequential Noncompliance, 64 FR 29408, 29409 (June 1, 1999).
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NHTSA has reviewed the Mercedes-Benz inconsequentiality petition
and does not concur with Mercedes-Benz's conclusion that the
noncompliance is inconsequential to motor vehicle safety and is denying
Mercedes-Benz's petition.
FMVSS 118 S6 sets performance requirements intended to mitigate the
potential for injury from a window or sunroof being inadvertently
closed when a person is in its path. Under the standard, the operating
controls may not allow a window, sunroof or partition to close when a
test sphere (simulating a child's knee) is pressed against the control.
Specifically, FMVSS No. 118 S6(a)(1) requires that ``an actuation
device must not cause a window, partition, or roof panel to begin to
close from any open position when tested . . . [u]sing a stainless
steel sphere having a surface finish between 8 and 4 micro inches and a
radius of 20 mm 0.2 mm, place the surface of the sphere
against any portion of the actuation device.''
According to the Mercedes-Benz petition, ``the actuation devices
used to engage car wash mode do not meet the inadvertent activation
provisions of FMVSS No. 118 S6(a)(1).'' However, Mercedes-Benz argues
activating car-wash mode is a multi-step process and the process varies
depending on the current menu contained on the display screen of a
particular vehicle. After considering information provided by Mercedes-
Benz and from online descriptions of the system, NHTSA believes there
is a minimal level of complexity involved in navigating through the
required sequence of events to actuate and close the sunroof. The
controls at issue include those located on the console between the
front seats where a child could easily stand or kneel. Given the
unpredictable behavior of an unattended child, inadvertent selection of
the ``Quick Access'' or ``Favorite'' hard buttons, where the ``Car Wash
Mode'' icon can be located, is a foreseeable and appreciable risk. Car
Wash Mode can be programmed as the only selectable icon within the
``Favorite'' menu, increasing its susceptibility to accidental
engagement.
In their petition, Mercedes-Benz states, ``the sunroofs in the
subject vehicles contain an auto-reverse feature. Upon detecting an
object or obstruction inside the sunroof, it will automatically stop
and reverse course and fully retract. While the sunroofs do not meet
the requirements of S5, they are certified to the European standard UN-
R-21. The European standard incorporates many of the performance
features included in the automatic reversal function contained in FMVSS
118, S5.'' NHTSA acknowledges that the sunroofs in the Mercedes-Benz
vehicles in question are compliant with UN-R-21, but Mercedes-Benz
concedes they do not comply with FMVSS 118 S5, NHTSA's regulations
governing automatic reversal systems. While UN-R-21 does provide a
level of safety, FMVSS 118 S5 provides a greater level of protection
from pinching injuries, particularly to smaller appendages like a
child's fingers.
Finally, in the petition Mercedes-Benz claims the circumstances
here are analogous to the circumstances in a previous NHTSA
determination that
[[Page 73398]]
noncompliance was inconsequential. NHTSA considers each petition on its
own merits and the prior decision cited by the Petitioner has limited
applicability in this case. NHTSA believes the circumstances for
accidental window/sunroof closure involved in the cited General Motors
(GM) petition are significantly different than those required under
Mercedes-Benz current petition. In granting the GM petition, the agency
was persuaded that the high level of complexity involved in navigating
through the required sequence of events effectively eliminated any
entrapment risk, particularly the limited timeframe within which the
events would have to occur. Specifically, NHTSA stated, ``[i]t is very
unlikely that the entire sequence of events--starting the engine,
turning the engine off, opening a front door, a person becoming
positioned in the sunroof opening, and pushing the sunroof close
button--will occur in less than 60 seconds from the time the ignition
is turned off and the vehicle operator has exited the vehicle and left
the immediate area.'' General Motors, Decision Granting Petition for
Inconsequential Noncompliance, 73 FR 22459 (April 25, 2008). In
contrast, the noncompliance in the Mercedes-Benz petition does not
involve as great a level of complexity in the required sequence of
events that would lead to sunroof engagement. The Mercedes-Benz
petition states, in the subject vehicles, as few as two inputs to the
centralized control devices is sufficient to actuate and close the
sunroof, i.e., with Car Wash Mode included in the ``Favorites'' menu.
Furthermore, the touch screens at issue here remain activated
indefinitely until the vehicle is turned off or a user activates a
command. NHTSA therefore does not agree that the prior determination in
the GM case is analogous or persuasive here.
Therefore, Mercedes-Benz has not met its burden of persuasion and
for the reasons described herein NHTSA does not find that the subject
noncompliance is inconsequential to motor vehicle safety.
VII. NHTSA's Decision: In consideration of the foregoing analysis,
NHTSA finds that Mercedes-Benz has not met its burden of persuasion
that the FMVSS No. 118 noncompliance at issue is inconsequential to
motor vehicle safety.
Accordingly, Mercedes-Benz's petition is hereby denied and
Mercedes-Benz is consequently obligated to provide notification of, and
a free remedy for, the noncompliance under 49 U.S.C. 30118 and 30120.
(Authority: 49 U.S.C. 30118, 30120: delegations of authority at 49
CFR 1.95 and 501.8)
Cem Hatipoglu,
Acting Associate Administrator for Enforcement.
[FR Doc. 2023-23528 Filed 10-24-23; 8:45 am]
BILLING CODE 4910-59-P