ID: 77-2.8

TYPE: INTERPRETATION-NHTSA

DATE: 04/08/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: American Honda Motor Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your February 23, 1977, request for an interpretation of paragraph S10.1 of Safety Standard No. 111, Rearview Mirrors, which specifies that motorcycle mirrors shall be adjustable "by tilting in both the horizontal and vertical directions." Your letter describes a newly designed motorcycle mirror used on Honda's and asks whether the mirror meets the adjustment requirement of paragraph S10.1 of the standard.

According to your description the mirror is adjusted horizontally by loosening a locknut, positioning the mounting bracket and retightening the locknut. Vertical adjustment is accomplished by rotating the mounting bracket of the mirror (the rotation is at an angle of 35 degrees to the vertical plane).

Standard No. 111 requires passenger car mirrors and motorcycle mirrors to be adjustable "by tilting". The agency interprets this adjustment requirement to mean that the mirror must be adjustable by the driver without the use of tools (for example, a mirror mounted on a universal ball joint). The adjustment requirement for mirrors on trucks, multipurpose passenger vehicles, and buses only specifies that those mirrors be "adjustable in both the horizontal and vertical directions"; there is no requirement that they be adjustable by "tilting". Therefore, mirror adjustment that requires the use of tools is permitted on trucks, multipurpose passenger vehicles, and buses. The basis for the different adjustment requirement is that trucks, multi-purpose passenger vehicles, and buses are generally driven for longer periods of time by the same driver, than passenger cars and motorcycles.

Since the motorcycle mirror you describe is not adjustable by tilting in both the horizontal and vertical directions without loosening and retightening the locknuts, it does not appear that the mirror would comply with the requirements of Standard No. 111.

Sincerely,

ATTACH.

AMERICAN HONDA MOTOR CO., INC.

February 23, 1977

Chief Council -- NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Dear Sir:

This is to request your official interpretation regarding the compliance of a new design for a motorcycle rear-view mirror with the requirements of section S10.1 of FMVSS 111 which becomes effective on February 26, 1977.

Section S10.1 states in part, "The mirror shall be adjustable by tilting in both the horizontal and vertical directions."

The mirror in question is presently used on our model XL100. I am enclosing a brochure which shows the mirror installed on the machine as well as an engineering drawing of the design.

As you will see, the mounting bracket is threaded into the brake or clutch lever mounting and projects outward at an angle of approximately 35 degrees from the horizontal. The mirror holder slips over the end of the bracket and two screws are tightened sufficiently to hold the mirror in place while still allowing it to be adjusted by rotating around the bracket.

The mirror is able to be adjusted horizontally by loosening the locknut, positioning the mounting bracket and retightening the locknut. Vertical adjustment is performed as described above although the mirror does not rotate exactly in the vertical plane but at an angle of approximately 35 degrees to the vertical.

Your earliest response in this matter will be greatly appreciated. If you have any questions or comments please contact me by telephone at (213) 327-8280 extension 372.

Yours truly,

Brian Gill -- Assistant Manager, Safety & Environmental Activities

Enclosure

(Graphics omitted)

ID: 77-2.9

TYPE: INTERPRETATION-NHTSA

DATE: 04/13/77

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Dennis J. Mahr; Attorney at Law

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 23, 1977, letter asking whether Ford Motor Company's record keeping practices conform to the regulations of the National Highway Traffic Safety Administration (NHTSA).

Your letter refers to material allegedly destroyed by Ford pertaining to accident and recall information involving headlamp concealment devices in 1967 Mercury Cougars. The NHTSA is unable to ascertain from the information that you have submitted whether or not Ford's record keeping violates our requirements.

The NHTSA implemented on August 20, 1974, a regulation requiring manufacturers to retain for a period of 5 years records generated or acquired after August 15, 1969, concerning motor vehicle malfunctions that may be related to motor vehicle safety (49 CFR 576, Record Retention). Since the recall to which you refer occurred prior to this regulation, it is possible that the identified records were generated of acquired prior to the promulgation of the regulation, and therefore, the destruction of these records would not necessarily mean that Part 576 was violated.

The NHTSA has a public file concerning the headlamp concealment devices referred to in your letter. This file containing 26 pages of information will be sent to you by our Technical Reference Branch under separate cover.

ID: 77-3.1

TYPE: INTERPRETATION-NHTSA

DATE: 06/15/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Collins Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 28, 1977, letter in which you ask several questions concerning Standard No. 222, School Bus Passenger Seating and Crash Protection, and the definition of school bus.

You first ask whether the seat spacing requirements found in S5.2.1 of the standard are applicable to buses with gross vehicle weight ratings (GVWR) equal to or less than 10,000 pounds. Buses in this weight classification do not have to comply with the mandatory seat spacing requirements. Since these buses are equipped with seat belts, the mandatory seat spacing is not necessary to provide adequate occupant crash protection.

Your second question concerns those areas required to meet the head protection zone requirements. You ask whether the window frame, window supporting structure, and window glass are included within the head protection zone requirements. The NHTSA issued an amendment of the standard (Notice 6, 41 FR 28506) in an attempt to clarify those portions of the bus subject to the head protection zone requirements. In this notice (copy enclosed), we stated that the sidewall, window and door structures were never intended to be included within the zone and are not subject to the requirements for head protection. However, the roof structure, if it falls within the zone, is subject to the requirements. If you need further information to determine the portions of your bus that would be included within the head protection zone requirements, I suggest that you send the agency sketches of your bus interior depicting those areas of concern.

Concerning seat orientation, you question whether the requirement for forward facing seats found in S5.1 of the standard applies to buses with GVWR's of 10,000 pounds or less. S5(b) of the standard lists the paragraphs of the standard applicable to buses in the above-mentioned weight classification. S5(b) does not refer to S5.1 which contains the requirement for forward facing seats. This omission was an oversight that occurred during the drafting of the regulation. The agency intended that seats in all school buses be forward facing, unless designed for handicapped or convalescent passengers as permitted in Notice 6. This intent is obvious since, as you note, we require these seats to comply with forward and rearward performance requirements. The NHTSA will soon issue an amendment of the standard to correct this omission.

Your final question concerns the definition of school bus which excludes common carriers in urban transportation. Your interpretation of this exclusion is correct. These buses are permitted to transport children to and from school but need not comply with the school bus construction standards.

SINCERELY,

COLLINS INDUSTRIES INC.

APRIL 28, 1977

ROGER TILTON NHTSA

THANK YOU FOR YOUR COOPERATION AND THE INFORMATION YOU GAVE ME TODAY BY TELEPHONE. FROM OUR CONVERSATION AND FMVSS 571.222, I UNDERSTAND THAT SEAT SPACING SPECIFICATIONS OF SECTION 5.2, OF THE 222 STANDARDS, DO NOT APPLY TO SCHOOL BUSES AT 10,000 POUNDS OR LESS GVWR. IS THIS INTERPRETATION THE SAME AS THAT OF NHTSA? IS IT NHTSA'S RATIONALE THAT SEAT SPACING CRITERIA OF SECTION 5.2 IS NOT NECESSARY FOR BUSES UNDER 10,000 POUNDS BECAUSE THESE BUSES ARE REQUIRED TO HAVE SEAT BELTS TO RESTRAIN PASSENGERS?

SECTION 5.3.1 OF STANDARD 222 STATES THAT ANY CONTACTABLE SURFACE WITHIN THE SPECIFIED HEAD PROTECTION ZONE (S5.3.1.3) SHALL MEET THE HEAD FORM IMPACT (S5.3.1.2) AND HEAD FORM FORCE DISTRIBUTION (S5.3.1.3) REQUIREMENTS. DOES THIS INCLUDE WINDOW FRAMES? DOES IT INCLUDE WINDOW SUPPORTING STRUCTURE? DOES IT INCLUDE WINDOW GLASS?

FMVSS 222, SECTION 5.1.4, REQUIRES ALL SEATS WITH SEATS BEHIND THEM TO MEET THE FORWARD (SECTION 5.1.3) AND REARWARD (SECTION 5.1.4) SEAT PERFORMANCE SPECIFICATIONS OF STANDARD NUMBER 222?

THE REQUIREMENT FOR FORWARD FACING SEATS, SECTION 5.1 OF STANDARD 222, IS NOT INCLUDED FOR 10,000 POUNDS AND LESS GVWR SCHOOL BUSES. HOWEVER, IN THE DEFINITION OF A SCHOOL BUS PASSENGER SEAT, THERE SEEMS TO BE EVIDENCE THAT THE SCHOOL BUS SEATS MAY NOT NECESSARILY BE FORWARD FACING, BUT MAY BE CANTED AS MUCH AS 45 DEGREES ARE MANUFACTURERS OF SCHOOL BUSES WHICH ARE LESS THAN 10,000 GVW CORRECT IF THEY POSITION THEIR SEATS AT ANY POSITION UP TO 45 DEGREES BETWEEN THE BUS LONGITUDINAL CENTERLINE AND A LINE PASSING ALONG THE FORWARD, UPPER EDGE OF THE SEAT CUSHIONS?

I UNDERSTAND THAT THE DEFINITION OF A SCHOOL BUS IS A MOTOR VEHICLE WITH MOTIVE POWER, EXCEPT A TRAILER, DESIGNED FOR CARRYING 10 PERSONS OR MORE PLUS THE DRIVER, SOLD OR INTRODUCED IN INTERSTATE COMMERCE, FOR PURPOSES THAT INCLUDE CARRYING STUDENTS TO AND FROM SCHOOL OR RELATED EVENTS. COMMON CARRIERS IN URBAN TRANSPORTATION ARE EXCLUDED. IS THIS CONCEPT CORRECT ACCORDING TO NHTSA'S INTERPRETATION?

PLEASE SEND A COPY OF YOUR REPLY TO MR. BYRON CRAMPTON, TRUCK BODY AND EQUIPMENT ASSOCIATION, INC., CHEVY CHASE BUILDING, SUITE 1220, 5530 WISCONSIN AVENUE, WASHINGTON, D.C. 20015.

I AM LOOKING FORWARD TO YOUR REPLY.

JAMES M. BEACH DIRECTOR OF ENGINEERING

cc: BRYON CRAMPTON -- TBEA

ID: 77-3.10

TYPE: INTERPRETATION-NHTSA

DATE: 06/27/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Britax (Wingard) Limited

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of May 5, 1977, requesting clarification of the relationship between paragraph S5.3 of Safety Standard No. 208, Occupant Crash Protection, and Safety Standard No. 216, Roof Crush Resistance. It is your understanding that Standard No. 216 becomes "obsolete and ineffective" after August 15, 1977.

Your interpretation is incorrect. Standard No. 216 is a separate, independent standard from Standard No. 208 and remains effective in its present form regardless of the amendment of Standard No. 208 according to any of the three alternative proposals issued by Secretary Adams (42 FR 15935, March 24, 1977). Standard No. 216 is applicable to all passenger cars except those that conform to the rollover test requirements of paragraph S5.3 of Standard No. 208 by totally passive means.

Under existing Standard No. 208, a manufacturer must meet the rollover requirements of paragraph S5.3 only if he chooses to use option S4.1.2.1 (total passive protection). If the manufacturer chooses this option he can meet the requirements of Standard No. 216 instead of the rollover requirements of S5.3 until August 15, 1977, but not after that date since the alternative then expires. A manufacturer choosing to use either option S4.1.2.2 or option S4.1.2.3 of Standard No. 208 does not have to meet the rollover requirements of paragraph S5.3, at all. As a manufacturer of seat belts, you are undoubtedly aware that a majority of vehicle manufacturers choose to comply with Standard No. 208 by means of option S4.1.2.3.

If Secretary Adams' Alternative proposal I or Alternative proposal III becomes a final rule, Standard No. 208 will remain in the form just described above. The Secretary's Alternative II (mandatory passive restraints) proposes to make the lateral (S5.2) and rollover (S5.3) requirements of Standard No. 208 optional. A manufacturer would be permitted to use a totally passive system (meeting S5.1, S5.2 and S5.3) or to install lap belts and only meet the requirements of S5.1. If Alternative II were made final, most vehicle manufacturers would probably choose to install lap belts rather than to provide passive protection that would satisfy S5.3. As you noted, Alternative II also proposes to extend the option in paragraph S5.3 (complying with Standard No. 216 instead) from August 15, 1977, to August 31, 1980.

You are correct in your statement that the Secretary does not expect to reach a final decision on his alternative proposals until July.

SINCERELY,

MAY 5, 1977

Our ref: TVB/MPJ

Frank Berndt, Acting Chief Counsel, National Highway Traffic Safety Administration

49 CFR Part 571. Docket No. 74 14; Notice 08. March 24th 1977.

I would appreciate any clarification which you can give on the present status of FMVSS 216 and 208 in relation to the document reference on the heading.

On page 15937 of Notice 08 there are proposed three approaches to the amendment of Standard No. 208. Approach I and Approach III do not give us any problems in understanding, but there are certain parts of Approach II where we would be glad of clarification. In Section 2 of Approach II the date of August 15th 1977 would be changed to read August 31st 1980.

We are concerned particularly where this appears in S5.3. As we understand S5.3 in Federal Standard 208, as referenced, the rollover test is not compulsory if testing and conformity to FMVSS 216 has been carried out. Our understanding of S5.3 is that vehicles manufactured on or after August 15th 1977 would have to meet the requirements of S5.3 without the option of alternative certification under Standard No. 216. In other words that Standard 216 would at that date become obsolete and ineffective. Can you please confirm, or otherwise, the following statement:

1. As the Regulations stand at present vehicles manufactured on or after August 14th 1977 would be required to meet S5.3 of Standard 208.

2. As of August 15th 1977 the testing of vehicles to Standard No. 216 becomes irrelevant in all respects.

3. That this situation would stand if either Approach I or Approach III were taken as the amendement to Standard No. 208.

4. That no official decision on the amendement of 208 by means of any of the three approaches will be available before July 1st 1977.

We are not only interested in the applicability of Standard 208 with regard to occupant protection but also from the viewpoint of the use of either Standard 208 or Standard No. 216 in relation to body strength and in particular roof crush, if there is manufacturer or replacement equipment fitment of an opening roof unit.

It appears to us, as mentioned above, that testing for conformity to Standard No. 216 is likely to be irrelevant for any purpose after August 15th this year.

Any clarification you can give would be greatly appreciated.

T.V. Barlow Safety Engineer -- BRITAX (WINGARD) LTD.

ID: 77-3.11

TYPE: INTERPRETATION-NHTSA

DATE: 06/27/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: American Seating Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 24, 1977, letter asking for an interpretation of the requirements for knee contact area in Standard No. 222, School Bus Passenger Seating and Crash Protection, which state that, when impacted, "the resisting force of the impacted material shall not exceed 600 pounds and the contact area on the knee form surface shall not be less than 3 square inches." You ask whether this requirement can be interpreted as meaning that, when impacted, the resisting force of the impacted material shall not exceed 200 pounds per square inch rather than 600 pounds over 3 square inches.

The 600 pound maximum force and the 3 square inch minimum contact area are two distinct requirements. The first specifies an upper bound on the load that will be applied to the upper leg while the latter specifies a lower bound on the knee area over which an impact load must be distributed. To combine the two requirements, as you suggest, tends to relax the contact area requirement for a load which is less than 600 pounds. Such an interpretation would not ensure the level of safety the agency demands for knee contact area. The suggested combination of the two requirements may not provide an adequate distribution of forces over the knee. Accordingly, the agency declines to accept the suggested interpretation of the standard.

SINCERELY,

March 24, 1977

National Highway Traffic Safety Administration

Att: Chief Counsel, Frank A. Berndt

Reference is made to Federal Standard 222, paragraph S5.3.2.2, "When any part on the rear surface of that part of a seat back or restraining barrier within any zone specified S5.3.2.1 is impacted from any direction at 16 feet per second by the knee form specified in S6.7, the resisting force of the impacted material shall not exceed 600 pounds and the contact area on the knee form surface shall not be less than 3 square inches".

We request an interpretation of the requirement for the knee form contact area. The knee recess area of the seat back is the most vulnerable part of the seat not only to vandalism but to hard use by the passenger. This is the area where feet are placed on the back and soles of shoes scuff and damage softer material. Also objects such as briefcases and lunchboxes add to the damage in this area. In fact, in city and inter-city buses this area is normally protected by heavy plastic or stainless steel panels. In the endeavor to provide a more practical surface than the soft vinyl we have been successful in adopting a thin plastic back panel. However, in some areas of the seat back, the resisting force, at 16 feet per second, is only 300 pounds and proportionately the contact area caused by the knee form is about 2 - 2 1/2 square inches.

We question whether the 3 square inches applies to the resisting force of the 600 pound magnitude or if it must extend to the lesser force. If we consider the distribution of the 600 pound force over the 3 square inch area, we are applying 200 pounds per square inch. When we measure the distribution of forces in this manner we meet the 200 pound maximum per square inch.

Under separate cover we are sending you copies of the actual contact areas indicated by the paint imprint. Because your interpretation will have a direct bearing on the construction of the seat as well as performance and economy of maintenance, we would appreciate a response at your earliest convenience.

Chester J. Barecki Vice President - Sales Engineering Transportation Products Division

[Attachments Omitted]

CC: T. HOYT; E. HENEVELD; J. OTT; T. CAMP

ID: 77-3.12

TYPE: INTERPRETATION-NHTSA

DATE: 06/27/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Truck Body and Equipment Association Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your April 6, 1977, letter asking whether two proposed labels satisfy the requirements for certification and information labels found in 49 CFR Part 567, Certification, and Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.

The National Highway Traffic Safety Administration (NHTSA) does not issue advance approval of compliance by manufacturers with motor vehicle safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample labels appear to comply with NHTSA regulations. From the illustrations you present, it appears that you have closely followed the format suggested in our regulations, and therefore, the labels seem to comply with the agency's requirements. Section S5.3(b) of Standard No. 120 permits the use of both labels when affixed in accordance with Part 567.4(b)-(f).

SINCERELY,

TRUCK BODY AND EQUIPMENT ASSOCIATION, INC.

April 6, 1977

Frank Berndt Acting Chief Counsel National Highway Traffic Safety Administration

Dockets 71-19; Notice 06 and No. 75-32; Notice 02 amend FMVSS 120 "Tire Selection and Rims for Motor Vehicles other than Passenger Cars" and Part 567 "Certification" by requiring tire and rim information on or adjacent to a vehicle's certification label.

Effective September 1, 1977, FMVSS 120, S5.3 (b) will allow a final stage manufacturer to use at his option, a "Tire Information Label" in conjunction with his present certification label.

The enclosed sheet depicts Truck Body and Equipment Association's proposed Tire and Rim Information Label for the National Highway Traffic Safety Administration's evaluation.

Are we correct in assuming that our proposed Tire-Rim Information Label when used with, and affixed adjacent to our present certification label (attachment 2) meets the new requirements of FMVSS 120 and Part 567?

Byron A. Crampton Manager of Engineering Services PROPOSED "TIRE-RIM INFORMATION" LABEL

TIRE-RIM INFORMATION

GVWR

GAWR FRONT with tires, rims, at psi cold

GAWR INTERMEDIATE with tires, rims, at psi cold

GAWR REAR with tires, rims, at psi cold

VIN

Notes:

1. Yellow foil with black lettering

2. Label shall meet 567.4(b) through (f) (Illegible Text)

ID: 77-3.13

TYPE: INTERPRETATION-NHTSA

DATE: 06/27/77

FROM: AUTOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Edward J. Flesch

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter to the President dated February 8, 1977, which has been forwarded to our office by the Department of Justice. You are concerned whether there is a Federal law that prohibits the replacement of a single part of a seat belt assembly, as opposed to replacement of the entire assembly.

The National Highway Traffic Safety Administration (NHTSA) issues safety standards and regulations that govern the manufacture of motor vehicles and motor vehicle equipment. Safety Standard No. 209, Seat Belt Assemblies, specifies requirements for seat belt assemblies to be used both as original equipment in passenger cars and as aftermarket replacement equipment. Vehicle manufacturers must certify that their vehicles are in compliance with all applicable safety standards, including Standard No. 209. There is no requirement in Standard No. 209, however, that would preclude the replacement or repair of a broken component in a seat belt assembly.

Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, as amended (15 U.S.C. 1381, et. seq.), provides that no manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. Therefore, none of the persons mentined could replace or repair a component of a seat belt assembly if that action would destroy the compliance of the assembly with Standrad No. 209. Violation of this section of the Safety Act could result in the imposition of civil penalties up to $ 1,000.

Perhaps it is General Motors' policy not to replace or repair a component of a seat belt assembly because of the possibility that the assembly might, thereby, be "rendered inoperative." From the point of view of General Motors, replacement of the entire assembly with a new, certified, assembly might be a safer practice. General Motors is certainly entitled to operate under such a policy. The policy is not, however, a Federal law.

SINCERELY,

February 18, 1977

The President The White House

I have a consumer problem and I don't know just where to go for a solution. I've contacted the following with no result.

Better Business Bureau

Department of Transportation

Consumer Product Safety Commission

General Motors Corporation

District Attorney's Office

Bureau of Consumer Protection

Senator Zorinski's Office

A plastic part that attaches the shroud to the retracting device of the front seat belts on my 1975 Chevrolet Nova has broken. I'm certain that the part should cost somewhat less than a dollar. The Regional Representative for General Motors has told me that a law forbids replacing only this part - that the entire seat belt system most be replaced at a cost of over ten dollars plus labor.

If a law does exist in such language that it must be interpreted that way, it should be changed. The part is easily inserted without effecting the safety function of the seat belt system. Its absence does cause damage to the back of the seat by allowing the shroud to catch on the seat fabric.

I have asked each of those I contacted if instructions can be issued allowing reinterpretation of any regulation or law forbidding the sale of the part. Each Government agency has denied responsibility or the ability to find a solution and referred me to one of the others.

This is a prime example of one of those bureaucratic messes of which you have spoken. I could probably manufacture a "do for it" in my own workship, but it has become much more important to me to unravel this mess than it is to repair the broken shroud. Please let me know what can be done.

EDWARD J. FLESCH

MAY 23, 1977

Edward J. Flesch

Your letter to the President dated February 8, 1977, regarding your complaint concerning General Motors' refusal to replace a part of your seat belt has been forwarded to the Department of Justice for response.

The Consumer Affairs Section contacted the Office of the Chief Counsel for the National Highway Traffic Safety Administration and advised them of your complaint. We were informed by that Office that it has jurisdiction over requirements for seat belt assemblies and anchorages. We are therefore forwarding your correspondence to the Office of the Chief Counsel for their consideration.

We hope this is of assistance to you.

John H. Shenefield Acting Assistant Attorney General Antitrust Division

cc: FRANK A. BERNDT

ID: 77-3.14

TYPE: INTERPRETATION-NHTSA

DATE: 06/28/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin, Jr.; NHTSA

TO: Collins Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 6, 1977, question whether Safety Standard No. 301-75, Fuel System Integrity, is applicable to all school buses or only to school buses with a GVWR greater than 10,000 pounds.

You are correct in your statement that school buses are included in the broader classification, "buses", for purposes of the Federal motor vehicle safety standards, unless otherwise specified in a particular standard. Safety Standard No. 301-75 is applicable to passenger cars, and to multipurpose passenger vehicles, trucks and buses that have a GVWR of 10,000 pounds or less, including school buses under 10,000 pounds. The standard is also applicable to larger school buses, and the distinction is made in the standard since the large school buses are the only vehicles having a GVWR greater than 10,000 pounds that are covered by the standard.

Safety Standard No. 301-75 was made applicable to all school buses pursuant to a mandate under the Motor Vehicle and Schoolbus Safety Amendments of 1974 (15 U.S.C. 1392(i) (1) (A)).

SINCERELY,

COLLINS INDUSTRIES INC.

MAY 6, 1977

FRANK BERNDT ACTING CHIEF COUNCIL

FEDERAL MOTOR VEHICLE SAFETY STANDARDS AND REGULATIONS PART 571.301-7S-1 STATES THAT SCHOOL BUSES WITH GVWR GREATER THAN 10,000 POUNDS SHALL MEET THE REQUIREMENTS OF SECTION 6.5 OF 301. HOWEVER, SCHOOL BUSES BELOW 10,000 POUNDS GVWR ARE NOT SPECIFICALLY MENTIONED IN 301. I UNDERSTAND THAT ALL SCHOOL BUSES MUST MEET THE REQUIREMENTS OF BUSES IN GENERAL UNLESS STATED OTHERWISE IN FMVS STANDARDS. BY DEFINITION, A SCHOOL BUS IS A BUS. IS MY INTERPRETATION CORRECT ACCORDING TO NHTSA?

A REPRESENTATIVE OF ONE OF OUR CHASSIS SUPPLIERS CALLED TO MY ATTENTION THAT ONLY THE LARGE SCHOOL BUSES (OVER 10,000 GVWR) WERE MENTIONED IN 301. HE SEEMED TO BE UNDER THE IMPRESSION THAT THIS COULD BE CONSTRUED TO MEAN SCHOOL BUSES LESS THAN 10,000 GVWR ARE NOT INCLUDED IN 301.

I AM LOOKING FORWARD TO YOUR REPLY AND WILL APPRECIATE ANY INFORMATION YOU GIVE ME.

JAMES M. BEACH DIRECTOR OF ENGINEERING

ID: 77-3.15

TYPE: INTERPRETATION-NHTSA

DATE: 06/30/77

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Matt Kolb

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your April 18, 1977, letter asking whether our regulations pertaining to truck-camper loading apply to trucks designed to haul fifth-wheel trailers.

Truck manufacturers are required to supply information pertaining to the cargo weight rating and longitudinal limits for the center of gravity of those vehicles capable of accommodating slide-in campers (Code of Federal Regulations, Volume 49, Part 575.103, Truck-camper loading). Slide-in camper is defined as "a camper having a roof, floor, and sides, designed to be mounted on and removable from the cargo area of a truck by the user." The purpose of this information requirement is to lessen the possibility of vehicle overloading. Since fifth-wheel trailers do not fall within the definition of slide-in camper, the regulations pertaining to truck-camper loading do not apply to vehicles designed to haul these trailers.

ID: 77-3.16

TYPE: INTERPRETATION-NHTSA

DATE: 07/01/77

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Hon. Clarence D. Long - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of May 9, 1977, to the Federal Trade Commission, on behalf of Mr. Edward L. Armstrong, Sr., Baltimore, Maryland, expressing his concern that new passenger car manufacturers will discontinue supplying spare tires, has been referred to this office of the National Highway Traffic Safety Administration, Department of Transportation, for additional consideration and reply.

We believe that Mr. Armstrong's concern deals with the recently approved "temporary use" spare tire that will be manufactured and used with some of the new 1978 model automobiles. The use of a temporary use spare tire is not a new concept. These tires have been used with compact sport cars, such as Firebird and Camaro, since 1967. The further development of these spare tires has been fostered by the desire of the U.S. automobile manufacturers to produce small, lightweight cars in furtherance of the national energy conservation program. I am sure that you have noticed the new 1977 models by some domestic automobile manufacturers are, in fact, smaller. Of course, the development of these smaller, lightweight, energy-efficient automobiles has resulted in a substantial reduction in usable car trunk space, and therefore, providing a second reason to develop a spare tire which takes less storage space than a conventional tire.

Since this spare tire is designed for use on the nation's highways, it must conform to the minimum performance requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 109, New Pneumatic Tires - Passenger Cars, for strength, endurance and high speed performance. For your information, we have enclosed a copy of this standard.