ID: nht73-3.41

DATE: 03/08/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mrs. Gussie Peer

TITLE: FMVSS INTERPRETATION

TEXT: Your recent letter to the National Transportation Safety Board concerning bus window glass has been referred to me for reply.

Safety glazing in buses is regulated by Federal Motor Vehicle Safety Standard No. 205. In general, the windows in the vicinity of passengers may be either laminated safety glass or tempered safety glass, or rigid plastics, if the windows are readily removable. Hence, the Federal standard does not prohibit manufacturers from using glazing materials that perform as you suggest.

In the past few years, manufacturers have expressed interest in providing passengers with protection from missiles thrown at buses. I expect to see an increase in the use of materials that conform with your suggestion.

I am enclosing a summary of the Federal Motor Vehicle Safety Standards for your information.

ID: nht73-3.42

DATE: 03/08/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Wiggins & Christian

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of February 27, 1973, concerning the application of the new Federal Odometer Disclosure Requirements to transfers between dealers.

The Federal requirements apply, with certain exceptions, to each transfer of ownership of a motor vehicle. Some types of vehicles, such as heavy trucks and antique vehicles, are exempt. Passenger cars and lighter vehicles, however, are exempted only in the case of transfers of new vehicles from a manufacturer or a distributor to a dealer or from one dealer to another. The transfer of a used car or light truck, whether from dealer to dealer, dealer to wholesaler, or dealer to customer, must be accompanied by a disclosure statement.

ENC.

ID: nht73-3.43

DATE: 03/16/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Toyota Motor Sales, USA, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 9, 1973, concerning the application of Standard 209 to emergency locking mechanisms that Toyota intends to use in its 1974 models. Mr. Susuki of your staff presented Toyota's problem at greater length in a meeting with NHTSA on March 2, 1973, and the following response serves to confirm the opinion given him at that time.

Both the central G-sensing device (with its computer) and the individual(Illegible Word) on the retractors are considered to be seat belt assembly hardware for purposes of Standard 209. We do not find that the central position of the G-sensor is a sufficient reason to exclude it from the requirements of the standard applicable to hardware, including the corrosion requirements. However, any corrosion testing of the G-sensor would be performed with the sensor's(Illegible Word) in place. If the covering is imperious to water, as Mr. Susuki stated, there should be little difficult in passing the test.

A second question was raised by Mr. Susuki concerning the testing of the upper torso retractor. It is our opinion that the retractor should be subjected to the environmental tests in its installed condition, with its cover in place.

A final question presented by Mr. Suzuki concerns the allowable width for that portion of the upper torso belt that does not contact the occupant. As we informed him the August 1972 petition by JAMA on this subject is still open and we anticipate that the agency's action will be favorable.

ID: nht73-3.44

DATE: 03/22/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Monsanto Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reference to a question that has been raised in telephone conversations, by Monsanto, as to whether the NHTSA allows a manufacturer of newly developed tires to run them on the public roads before they are certified as conforming to Standard 109.

The answer is no. We have, to the best of our knowledge, allowed no exception to the requirement that all tires to which a motor vehicle safety standard is applicable must conform to the standard and be certified as such.

ID: nht73-3.45

DATE: 03/23/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Seminole Trailer Manufacturing Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 6, 1973 to this agency asking whether it is permissible under Standard No. 108 to locate boat trailer identification lamps on the first crossmember forward of the rearmost crossmember. You believe that the identification lamps will have a longer life span in this location.

The general locational requirement that a lamp be "on the front" or "on the rear" was never intended to specify that it be at the extreme front or rear of a vehicle. Clearance and identification lamps required to be "on the front" are generally mounted on a truck cab or body, for instance. Therefore your proposed location is acceptable to meet the requirements of Table II of the Standard. However, identification lamps, wherever located, must meet the visibility requirements of paragraph S4.3.1.1, and if they do not meet them in your proposed location the trailer will not comply with Standard No. 108.

ID: nht73-3.46

DATE: 03/12/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Harnischfeger Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 25, 1973, to Gordon Lindquist, Regional Administrator, NHTSA, asking whether Federal standards require the installation of seat belts on certain vehicles you manufacture. According to brochures you have submitted, these vehicles are your RH 25 3-cu. yd. heavy duty hydraulic shovel, R-150-1 15-ton hydraulic crane, W-350 35-ton hydraulic swinger crane, and T-150 15-ton fully hydraulic truck crane.

With reference to the first three vehicles, the RH 25, R-150-1, and W-350, the NHTSA does not consider these vehicles to be manufactured primarily for use on the public roads. Therefore, they are not "motor vehicles" subject to regulation under the National Traffic and Motor Vehicle Safety Act of 1966. We view them as construction equipment whose use of the public roads is incidental to their primary work-performing purpose.

The NHTSA believes, however, based on the information you have submitted, that the T-150 hydraulic truck crane is a motor vehicle under the Safety Act, and a "truck" under the motor vehicle safety standards. We base this determination on the vehicle's speed capability, that its manufacturer classifies it as a "truck crane", and that its overall appearance appears to be that of a vehicle designed to be used on the highway. As a truck, the vehicle is required to be equipped with seat belts as specified in Motor Vehicle Safety Standard No. 208, Occupant Crash Protection (49 CFR 571.208, copy enclosed). It is required also to conform to safety requirements specified in other safety standards and regulations. Copies of the standards can be obtained as described in the enclosed, "Where to obtain Motor Vehicle Safety Standards and Regulations".

Our decision as to whether this vehicle is a motor vehicle is based only on that information which you have provided us. Other relevant factors which can be taken into consideration are set forth in the enclosed interpretation regarding mini-bikes. If you have further information which you believe we should also consider we will be glad to review it.

ENCLS.

ID: nht73-3.47

DATE: 03/30/73

FROM: AUTHOR UNAVAILABLE; Mike Pescoe, Attorney; NHTSA

TO: Mr. William Goldberg

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 14, 1973, forwarding to me a copy of the preface to your forthcoming paper on the development of Standard No. 213, and asking a few questions which we have already discussed over the phone.

With respect to the preface, it is essentially accurate, at least sufficiently so for the purpose for which it is intended.

The questions you've asked are repeated below, followed by our answers.

1. What gives credibility to and what reduces credibility of comments filed with Docket 2-15? Are the comments of some organizations given more credence than others?

Each comment to the docket is assumed to be of equal credibility, that is, we assume each is offered in good faith, and based upon the writer's legitimate beliefs and interests. The agency evaluates each submission on its own merits.

2. Do non-separating 3-point belts present a problem for usage of current child restraint systems?

Our understanding is that child seats can be used with 3-point belts. These belt systems do utilize one member that is essentially similar to the traditional lap belt. We understand the shoulder portions of these belts can be adjusted so as not to prevent installation of the child seat, by either placing that belt section in front of or behind the child seat. We have not received any information from the public that these belts are in fact difficult to use with child seats. If we do we will certainly look into the matter thoroughly.

3. Has NHTSA or will NHTSA be cooperating with JPMA on some kind of market survey?

The NHTSA has forwarded a list of suggested questions, which are also in the docket. We do not expect our contribution to include more than recommending that these questions be asked.

4. To what extent is rulemaking determined by comments and by internal direction?

This certainly depends on the issues involved. For the most part, initial decisions are made by the agency, with modifications resulting from comments received. However, comments may affect some issues more than others. In Standard No. 213, for example, much impetus for a dynamic test has been created by comments.

We've recently amended the standard, based on two outstanding notices (September 30, 1970; April 10, 1971). In case you haven't seen the amendments, I have enclosed a copy.

ENCLS.

ID: nht73-3.48

DATE: 04/03/73

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: The Flexible Co.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 21, 1973, requesting that you be permitted to affix the Certification label for buses manufactured by your company on the right side of the dash panel, as illustrated in a picture (your serial #B72-4375-2) you have enclosed.

As pictured, the label in the location you have chosen is easily readable without moving any part of the vehicle except an outer door, as required by section 567.4(c) of the Certification regulations, and your request that you be permitted to affix the label for these vehicles in that location is hereby approved.

ID: nht73-3.49

DATE: 04/04/73

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Wagner Electric Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 16, 1973, requesting an interpretation of paragraph S5.4.1 of Federal Motor Vehicle Safety Standard No. 105a.

Answers to your questions are as follows:

1. The reservoir configuration in your Sketch No. 1 would meet the requirements of S5.4.1 for compartmentalized reservoire. We have provided a similar interpretation to General Motors Corporation on this point, which is enclosed for your reference.

2. Since the configuration of your Sketch No. 1 conforms to S5.4.1, a single fluid level sensing device is acceptable.

3. The configuration shown in your Sketch No. 2 would not comply with volumetric requirements of S5.4.2 since your "reserve" fluid volume plus "protected" fluid compartments "A" and "B" volumes would not be equal to the total volume required by S5.4.2. S5.4.2 requires a volume for each reservoir equal to the fluid displacement resulting when all-wheel cylinders or calipor pistons serviced by the reservoir move from a new lining, fully retracted position (etc) to a fully worn, fully applied position. Thus, if this final condition existed on both subsystems, one subsystem would not have the specified fluid available.

4. The configuration depicted in your Sketch No. 3 would meet the requirements of S3.4.1 and S5.4.2 as well as S5.3.1(b) assuming the indicator lamp would be activated at or above the 25 percent level of fluid volume.

5. The configuration shown in your Sketch No. 4 would meet the requirements of S5.4.1 and S5.4.2 as well as the requirements of S5.3.1(b) with the same assumption that the lamp would be activated at or above the 25 percent fluid volume level.

ENC.

ID: nht73-3.5

DATE: 11/22/73

FROM: AUTHOR UNAVAILABLE; Claude S. Brinegar; NHTSA

TO: Honorable John E. Moss; House of Representatives

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 26, 1973, concerning our estimate of the time required by vehicle manufacturers to meet the adopted and proposed(Illegible Word) to Motor Vehicle Safety Standard No. 301, Fuel System Integrity.

Our basic approach to leadtime analysis in the automotive industry has been along the lines set forth in(Illegible Word) automotive engineering studies prepared in the early days of the highway safety program by Arthur Young and Company, and by Booz, Allen, and Hamilton. Over the years, we have found these studies to be accurate predictors of the time required to make substantial structural modifications to production vehicles.

On the basis of our preliminary crash tests, we concluded that to meet the 30 mile-per-hour, rear moving barrier crash test, the rear-end structure of a typical vehicle would have to be strengthened considerably. To accomplish such strengthening, the manufacturers may have to change the gauge of metal used, the configuration of the underbody and interior panels, and the location and design of interior braces and(Illegible Word). Any changes of this nature will require major tooling modifications, and tool modification has historically occupied a major portion of the leadtime needed to effect a change.

Our leadtime evaluation, based on our usual techniques, indicated that the tooling time and other production planning time required for the structural changes we expect to be necessary to meet the standard

be at least two years. To this time must be added the time required for us to complete the rulemaking process and present the manufacturers with a final standard to which they can design their vehicles. We were, therefore, obliged to conclude that there was not enough time remaining before September 1975 to allow manufacturers to meet the standard with their 1976 models.

In this as in most rulemaking actions, we are working without benefit of information from the manufacturers on their projected expenditures of funds and man-hours. I would like to be able to tell you, to the minute, what those projections are, but the best I can say is that we have no indications that the manufacturers' plans could place conforming cars in production in less than the time specified in our proposal.

I remain committed to the pursuit of this rulemaking action and assure you that it will be completed expeditiously.