Pasar al contenido principal

Los sitios web oficiales usan .gov
Un sitio web .gov pertenece a una organización oficial del Gobierno de Estados Unidos.

Los sitios web seguros .gov usan HTTPS
Un candado ( ) o https:// significa que usted se conectó de forma segura a un sitio web .gov. Comparta información sensible sólo en sitios web oficiales y seguros.

NHTSA Interpretation File Search

Overview

NHTSA's Chief Counsel interprets the statutes that the agency administers and the standards and regulations that it issues. Members of the public may submit requests for interpretation, and the Chief Counsel will respond with a letter of interpretation. These interpretation letters look at the particular facts presented in the question and explain the agency’s opinion on how the law applies given those facts. These letters of interpretation are guidance documents. They do not have the force and effect of law and are not meant to bind the public in any way. They are intended only to provide information to the public regarding existing requirements under the law or agency policies. 

Understanding NHTSA’s Online Interpretation Files

NHTSA makes its letters of interpretation available to the public on this webpage. 

An interpretation letter represents the opinion of the Chief Counsel based on the facts of individual cases at the time the letter was written. While these letters may be helpful in determining how the agency might answer a question that another person has if that question is similar to a previously considered question, do not assume that a prior interpretation will necessarily apply to your situation.

  • Your facts may be sufficiently different from those presented in prior interpretations, such that the agency's answer to you might be different from the answer in the prior interpretation letter;
  • Your situation may be completely new to the agency and not addressed in an existing interpretation letter;
  • The agency's safety standards or regulations may have changed since the prior interpretation letter was written so that the agency's prior interpretation no longer applies; or
  • Some combination of the above, or other, factors.

Searching NHTSA’s Online Interpretation Files

Before beginning a search, it’s important to understand how this online search works. Below we provide some examples of searches you can run. In some cases, the search results may include words similar to what you searched because it utilizes a fuzzy search algorithm.

Single word search

 Example: car
 Result: Any document containing that word.

Multiple word search

 Example: car seat requirements
 Result: Any document containing any of these words.

Connector word search

 Example: car AND seat AND requirements
 Result: Any document containing all of these words.

 Note: Search operators such as AND or OR must be in all capital letters.

Phrase in double quotes

 Example: "headlamp function"
 Result: Any document with that phrase.

Conjunctive search

Example: functionally AND minima
Result: Any document with both of those words.

Wildcard

Example: headl*
Result: Any document with a word beginning with those letters (e.g., headlamp, headlight, headlamps).

Example: no*compl*
Result: Any document beginning with the letters “no” followed by the letters “compl” (e.g., noncompliance, non-complying).

Not

Example: headlamp NOT crash
Result: Any document containing the word “headlamp” and not the word “crash.”

Complex searches

You can combine search operators to write more targeted searches.

Note: The database does not currently support phrase searches with wildcards (e.g., “make* inoperative”). 

Example: Headl* AND (supplement* OR auxiliary OR impair*)
Result: Any document containing words that are variants of “headlamp” (headlamp, headlights, etc.) and also containing a variant of “supplement” (supplement, supplemental, etc.) or “impair” (impair, impairment, etc.) or the word “auxiliary.”

Search Tool

NHTSA's Interpretation Files Search



Displaying 10401 - 10410 of 16517
Interpretations Date

ID: nht74-5.30

Open

DATE: 04/03/74

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

TO: MAZDA

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 8, 1974, which requests a review of your new accelerator system to determine compliance with Standard No. 124, "Accelerator Control Systems."

The NHTSA does not provide a technical review of a manufacturer's product nor certify that a particular design meets the requirements of a standard. That is the manufacturer's responsibility. We will interpret or clarify the meaning of the standard in response to specific questions.

We understand your question to be whether two springs surrounding a spring guide and separated by a washer meet the stipulation in S5.1 of Standard No. 124 for ". . . at least two sources of energy . . ." This arrangement of springs would be considered "two sources of energy" within the meaning of the standard.

As you requested, the technical description has been held confidential as a "trade secret" and we are returning it to you herewith.

ENC.

ID: nht74-5.31

Open

DATE: 04/12/74

FROM: AUTHOR UNAVAILABLE; A. G. Detrick; NHTSA

TO: Harley-Davidson Motor Company Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reference to your defect notification campaigns NHTSA No. 73-0094, concerning fork lower brackets, and NHTSA No. 73-0215, concerning frame reinforcement and tail lamp wiring.

It has been brought to our attention that some dealers have not been able to obtain all the parts required for campaign 73-0094, and to a lesser degree, campaign 73-0215. Although it appears that Harley Davidson is attempting to provide parts as rapidly as production permits, this parts shortage has the unfortunate effect of tending to discourage owners from having their vehicles corrected. It is reasonable to assume that some owners may have abandoned their attempts to get their vehicles corrected after having been repeatedly told for several months that parts are not available.

Part 577.4 (49 CFR) of the Defect Reports Regulation requires that whom the manufacturer offers to repair the defect through his dealers without charge to the purchaser, the notification letter shall include the manufacturer's estimate of the day by which his dealers will be supplied with parts and instructions for correcting the defect. The letters which you have sent(Illegible Words) first purchasers did not contain a firm date for parts availability as required by Part 577, although they did imply that the necessary parts were available when ordered by a dealer. Since, in actuality, parts were not always available, it becomes necessary to inform owners of the date by which the necessary parts will be available.

It is therefore necessary that you revise the owner notification letters for both campaigns and include in each letter your estimate of the day by which dealers will be supplied with the necessary parts, as required by Part 577. Copies of both letters must be sent to this office and a copy of the applicable letter shall be sent to each owner who has not yet had his vehicle corrected.

If you desire further information, please contact Messrs. W. J. Reinhart or James Murray at this office (202) 426-2840.

ID: nht74-5.32

Open

DATE: 04/12/74

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

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 13, 1974, request for confirmation that the intake manifold connector and the brake booster check valve used in connecting the engine intake manifold and the vacuum power brake booster are not subject to Standard 106, Brake hoses.

A brake hose end fitting is defined in Standard 106 as "a coupler, other than a clamp, designed for attachment to the end of a brake hose." As pictured in your schematic, the couplers are the clamps, and the intake manifold connection and brake booster check valve are engine components to which the brake hose has been attached by the clamp couplers. Therefore your interpretation is correct that neither component is subject to Standard 106.

SINCERELY,

March 13, 1977

Elwood T. Driver Director, Office of Operating Systems National Highway Traffic Safety Administration

Re: Docket 1-5; Notice 10 Amendment to MVSS 106 Brake Hoses

Chrysler Corporation requests confirmation of the informal interpretation provided to us by a member of your staff concerning the recently amended requirements of MVSS 106 (39 F.R. 7435) as they apply to the hook-up between the engine intake manifold and the vacuum power brake booster. To make this hook-up one end of a section of vacuum brake hose is slipped onto the intake manifold connector and the other end is slipped onto the brake booster check valve as shown in the attached schematic of this system. The hose is held secure at each end by a spring type hose clamp.

In accordance with that conversation it is our understanding that the vacuum hose used to connect the intake manifold to brake booster is a brake hose within the meaning of the standard. However, since this hose is secured by clamps, it is not a brake hose assembly under the standard and, therefore, the intake manifold connector and the brake booster check valve are not subject to the requirements of MVSS 106. This is in keeping with the amendment to the definition of brake hose assembly deleting the reference to "clamps."

In view of the short time period allowed for compliance with the new requirements, prompt confirmation of our interpretation is requested.

R. O. Sornson Manager Environmental and Safety Relations (Graphics omitted)

BRAKE BOOSTER CHECK VALVE

VAC BRAKE HOSE

VAC HOSE CLAMP

INTAKE MANIFOLD CONNECTOR

ENGINE MANIFOLD

ID: nht74-5.33

Open

DATE: 04/09/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Bruce J. Motyka

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of March 11, 1974, asking for suggestions regarding problems you have experienced with your pickup truck-camper unit.

It appears from your letter that no violations of Federal requirements have occurred. Motor Vehicle Safety Standard No. 126 and its companion Consumer Information requirement (49 CFR @ 575.103) about which we wrote to you through Senator Percy's office did not become effective until January 1, 1973, well after the time you bought your vehicle. Moreover, it is not correct to characterize the dealer who sold you the unit as a "final-stage manufacturer." Under NHTSA requirements a pickup truck is a completed vehicle, and a person who installs a slide-in camper into the cargo area of a truck does not become a manufacturer. While this is not the case with chassis-mount campers, it is with respect to slide-in campers.

I suggest that if you wish to proceed further you consult an attorney, who would be able to best assess your chances of success in civil litigation. The dealer's employee who told you that the "GVW plate meant nothing" was mistaken. The weight ratings provided on the plate represent the manufacturer's representation of the maximum safe weight of a fully loaded vehicle.

You might wish to examine the labels attached, pursuant to Standard No. 126 and 49 CFR @ 575.103, to later models of both the pickup truck and camper you purchased. It is possible that those models and the ones you purchased are not substantially different. If that is the case the information on the labels can provide an indication of the extent that the weight ratings were exceeded by installation of the camper unit in question.

While I regret we cannot be of further assistance I wish you success in your efforts to solve this problem.

YOURS TRULY,

March 11, 1974

Lawrence R. Schneider, Chief Counsel National Highway Safety Administration

Re: January 22, 1974 N40-30 (MPP)

Dear Mr. Schneider;

I would like to thank you for the information which you sent in response to my inquiry to Senator Charles H. Percy.

The information was quite informative, and answered many questions that I have had for some time. I was very happy to learn that the Federal Government has instituted various standards to protect the consumer from unscrupulous automobile and truck dealers.

There are still several points which are not clear to me, and in order for you to understand my problem I must start at the beginning.

During January 1972 I decided that the time had come to invest in a camper unit of some type. For a period of one month I shopped around quite diligently comparing various units and prices.

On January 26, 1972 I finally decided that a neighborhood Dodge Dealer had a camper unit that was ideal for my needs and was in the price range that I could afford.

For simplification, attached to this letter is a supplemental sheet giving truck and camper information.

After taking delivery of the unit on January 31, 1972 I noticed that the truck appeared to be under great strain from the weight of the camper.

One month later the engine was idling roughly, the transmission was not shifting properly, the engine was burning oil. I took the unit on a short weekend trip to a nearby lake and could hardly believe the lack of control I had on the highway due to high winds. On several occasions I honestly thought that at 50 M.P.H. the unit would tip right over and kill someone.

I returned to the selling dealer and asked if they improperly matched the camper to the truck. I was assured that everything was OK and that it would take a little getting used to.

As time went on the mechanical problems increased and the overall truck handling performance decreased.

During the first six month's of ownership, I made an estimated 70 trips to the dealership to correct various mechanical problems.

I also began reading various books on truck weights and truck capacities, since I was convinced that the mechanical problems were directly attributed to an overweight camper unit. It was determined at this time that the camper unit exceeded the G V W maximums for this truck. Armed with this information I paid a vist to Mr. Warren Johnson, General Manager of the Northwest Dodge Dealership. Mr. Johnson told me that the G V W plate meant nothing and that there was nothing at all wrong with the truck.

Since I did not believe Mr. Johnson, I then paid a vist to the Dodge Motor Car Division Zone Office located in Elk Grove Village, Illinois. The Dodge zone office people understood my problem but told me there was nothing that they could do. They explained that the Dodge Corporation sold a 1972 Dodge D100 Pick-Up to Northwest Dodge, their dealer. Northwest Dodge purchased a Rover Camper from Coachmen Industries. I was told that Northwest Dodge was the final stage manufacturers and that they would be responsible.

Still having severe mechanical problems with the unit, I went to another Dodge dealer and asked their service department to check the unit over and tell me what was wrong. This Dodge dealer told me and also put in writing that the unit was overweight. The D100 1/2 ton pick-up could not safely handle the weight of the camper.

I might interject at this point that I received a recall notice from Dodge during the early part of 1972, asking me to return the unit to the selling dealer to have the bolts tightened on the truck bed. This I did, but the selling dealer charged me $ 20.00 to fullfill the obligation of the recall notice.

Other problems which I have had with the unit which might be of interest to you:

1. Broken right front coil spring.

2. Transmission does not shift properly.

3. Engine overheats.

4. Chipped exhaust valve (1 cylinder).

5. Four leaking shock absorbers.

6. Uneven tire wear.

7. Engine burns oil.

8. Two tires developed "bubbles" on sides due to excess weight.

10. Cracked exhaust valve (another cylinder) and two bent pushrods.

11. Two rear leaf springs out of shape. The two rear leaf springs instead of retaining a "U" shape, point completely downward. This is completely opposite their normal shape.

12. Splits in the metal on the bed of the truck.

In addition to all of these problems so far I now have a new problem. I recently took the unit to a State of Illinois safety test lane. This is a requirement in the State of Illinois before license plates are issued. Well naturally the unit was declared unsafe.

It is quite obvious now that Northwest Dodge purchased a one half ton Dodge D100 Pick-Up from the Dodge people. They also purchased a Rover Slide On camper unit from Coachmen Industries and put the two units together, qualifying Northwest Dodge as a Final Stage Manufacturer. It seems that Northwest Dodge violated Federal standards. What can be done about it now?

Can the Department of Transportation force Northwest Dodge to correct what they did? Can you force the dealership to reimburse me for the hundreds of dollars that I have been required to pay? Shouldn't Northwest Dodge be forced to beef up the truck to Federal specifications? Would it be wise or profitable to institute a civil action against Northwest Dodge for fraud? How can a consumer be treated this way by a dealership? It seems that there is no concern for the consumers safety at all!

I hope that I have given you enough information to properly evaluate the situation. Any information, assistance, or help that you can provide will be sincerely appreciated. You people are the experts and I would be gratefull for any solutions that you can provide.

Sincerely,

Bruce J. Motyka

Enclosure

Bruce J. Motyka

General Information

Date of purchase: January 26, 1972

Date of delivery: January 31, 1972

Description of unit: 1972 Dodge-D100 1/2 ton Pick-Up 318-V8 Engine Power Disc Brakes Automatic Transmission Power Steering G78 X 15(Illegible Word) car tires Rover Slide on Camper Model #708-3M

Purchased from: Northwest Dodge, Incorporated 1439 S. Lee Street Des Plaines Illinois 60018

G V W Weight Plate attached to truck: Make Dodge Model D10 V.I.N. D14AE23503564 T.O.N. R0912043 G V W as M F G D 05200 MAX FRONT CAP 2800 MAX G V W 05200 MAX REAR CAP 2945

Equipment I D: 1972 Dodge D100 Wheel Base 131 Rear Springs 1350 Front Springs 1300

Camper Unit: 1972 Rover Slide on Camper Model #: SM708 Serial #: 708721251 Unloaded Shipping Weight: 990

Vehicle Weighed: Front 2,800 LBS Rear 3,985 LBS

Total 6,785

Truck camper weighed by licensed certified weigmaster.

Truck camper loaded with gas, water, food, camping supplies, clothes and two adult males.

ID: nht74-5.34

Open

DATE: 04/15/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Ellis I. Kahn; Law Offices

COPYEE: MR. PESKOE; MR. FAY; MR. SHIFFLET

TITLE: FMVSR INTERPRETATION

TEXT: (Illegible Text)

ID: nht74-5.35

Open

DATE: 04/16/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: ITT Semiconductors

COPYEE: R. HITCHCOCK; MR. HERLIHY

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your March 25, 1974, question whether the belt warning system in 1974 or any future model year passenger car is required to activate if a passenger sits on a pre-buckeled belt in a passenger car whose engine is operating and the driver subsequently places the transmission gear selector in a forward position.

In 1974 and 1975 passenger car models, the (nonsequential) warning system would be required to activate in this situation only if the passenger weighed at least 47.3 pounds and the belt was not extended at least four inches from its stowed position, in a warning system based on belt extension.

It has been proposed that this requirement be extended one year through the 1976 models and that a new sequential belt warning system may be used at the front seating positions after September 1, 1976.

The requirements for the new proposed system are set out in the document you reference, Docket No. 74-14; Notice 1, a copy of which is enclosed. It would require that the seat belt be operated after the passenger has been seated.

ID: nht74-5.36

Open

DATE: 04/16/74

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

TO: Domi Racer Distributors, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 19, 1974, request to know if aircraft hydraulic hose is suitable for motor vehicle use under Standard 106, Brake hoses.

Standard No. 106, Brake hoses, presently applies to hydraulic brake hose for use in passenger cars, and therefore sale of aircraft hydraulic hose for use in motorcycles is presently legal. However, Standard 106 has been recently amended to require extensive performance testing and labeling of all motor vehicle brake hose manufactured after September 1, 1974. Sale of an aircraft hose manufactured after that date which has not been certified to conform to Standard 106 would violate @ 108(a)(1) of the National Traffic and Motor Vehicle Safety Act of 1966. This means that the hose must be properly tested for conformity to the standard, and labeled according to the standard, before it can be sold as motor vehicle hose.

Domi Racer

DISTRIBUTORS, Inc.

MESSAGE

TO NATIONAL HIGHWAY TRAFFIC SAFETY ADM. SUITE 214 EXECUTIVE PLAZA 1010 DIXIE HIGHWAY CHICAGO HEIGHTS, ILL 60411

DATE 3-19-74

GENTLEMEN; WE HAVE BEEN REFERRED TO YOUR OFFICE BY THE LOCAL BUREAU OF MOTOR CARRIER SAFETY.

OUR PRINCIPAL POINT OF CONCERN AT THE MOMENT IS FEDERAL REQUIREMENT FOR HYDRAULIC BRAKE HOSES TO BE IMPRINTED WITH AN SAE SPECIFICATION. WE ARE PRESENTLY MARKETING A HYDRAULIC HOSE FOR MOTORCYCLE USE WHICH CARRIES A MILITARY AIRCRAFT SPECIFICATION H-8794, ALSO FAA APPROVED.

SPECIFICALLY, WE WOULD LIKE TO KNOW IF AN FAA APPROVED HOSE WOULD NOT BE SUITABLE FOR USE ON THE PUBLIC HIGHWAYS AS IT IS A MUCH STRONGER PART THAN THE STANDARD ITEM IT REPLACES.

SINCERELY, J. K. WHITE

REPLY

ID: nht74-5.37

Open

DATE: 04/26/74

FROM: AUTHOR UNAVAILABLE; A. G. Detrick; NHTSA

TO: Conco Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter to Mr. W. J. Reinhart, dated March 26. In this letter you requested that the Office of Defects Investigation (ODI) reconsider the necessity of your revising the notification letters which were mailed by you in conjunction with your defect notification campaign (NHTSA No. 74-0038).

We have determined that your notification letter must be revised and that you must provide this office, and those owners who did not correct their vehicles, with a copy, sent certified mail, of the revised letter. It is not sufficient under Part 577 for you to state that a "safety hazard" exists "due to a decrease in visibility of the vehicle." This statement fails to conform to section 577.4(d) of the Defect Notification regulations (49 CFR Part 577). That section provides that the risk to traffic safety presented by the defect be evaluated in terms of whether or not vehicle crash is the potential occurrence. We believe it obvious within the context of Part 577 that the potential result of the failure of any vehicle to conform to the lighting requirements of Standard No. 108 is vehicle crash. The factors you cite, that the vehicles have limited use, go only to whether it is likely they may be involved in crashes, not whether crash is the potential or possible result. In this regard, we note that your own description of the likelihood of crash does not preclude the possibility that crash can occur.

ID: nht74-5.38

Open

DATE: 04/22/74

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

TO: Meiji Rubber & Chemical Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your February 27, 1974, request concerning brake hose identification codes and labeling, conflicts of Federal and State standards, and procedures for certifying hose, end fittings, and hose assemblies in compliance with Standard No. 106, Brake hoses. This also responds to your March 25, 1974, (ref T-76) request for approval of your proposed hydraulic and vacuum brake hose labeling.

Notice 10 was published on February 26, 1974. It modified the labeling requirements, and a copy is enclosed. It is certain that another notice will be published shortly which may modify the marking requirements further. Therefore I advise that you not undertake modifications of your labeling in the near future.

In answer to your February 21 letter, if we require a code at a later date, the code will not relate to the MRA code. Concerning the marking of multi-piece fittings, the designation must appear on each part of a reusable end fitting, although this requirement is presently under reconsideration.

With regard to conflicting State regulations such as Pennsylvania's, our regulation as of September 1, 1974, preempts any State brake hose regulations which are not identical with respect to the some aspects of performance. The National Traffic and Motor Vehicle Safety Act of 1966 provides at @ 103(d):

Whenever a federal motor vehicle safety standard established under this subchapter is in effect, no state or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard. . . .

2

However, it is permissible, if a manufacturer wishes, for him to place Pennsylvania labeling on the reverse side of the hose.

It is the responsibility of the manufacturer to certify that his products comply with Standard No. 106. You may conduct a test program, or you may hire an independent test laboratory to conduct the test program for you. One test laboratory in the United States which tests brake hose is VPI of Blacksburg, Virginia. The National Highway Traffic Safety Administration does not conduct certification tests, but it does conduct tests on manufacturer products to enforce compliance.

In answer to your March 25 letter, the hydraulic brake hose marking on "Face A" appears to conform to the requirements of S5.2.2, assuming that letter "size" refers to letter height. Notice 10 permits the manufacturer designation to be other than block capital letters. "Face B" is not regulated by our standard.

With regard to the brake hose end fitting and brake hose assembly examples, they appear to conform to S5.2.3 and S5.2.4 if the letter "size" refers to letter height. It should be noted that Notice 10 excludes labeling of two-piece fittings and certain assemblies and that the next notice may make further modifications.

With regard to vacuum brake hose, your "Face A" example appears to conform to S5.2.2 if letter "size" refers to letter height. S5.2.1 is not applicable and therefore the stripe is not required. "Face B" is not regulated by our standard.

ENC.

MEIJI RUBBER & CHEMICAL CO., LTD.

February 21, 1974

National Highway Traffic Safety Administration

Dear Sirs:

Subject: Brake Hoses for FMVSS

As to the Part 571-Federal Motor Vehicle Safety Standards (FMVSS), Brake Hoses of Docket No. 1-5: Notice 8 published in the Federal Register Vol. 38, No. 218 issued on Tuesday Nov. 13, 1973, we shall be pleased if you will kindly show us about the procedure for getting the code nos.

1. We manufacture brake hoses and metal fittings, assemble them into oil brake hoses, and sell them to automobile manufacturers. We have got the Code No. 57-1 from MRA. Please show us the relation between the code no. of MRA and that of newly published FMVSS.

2. Please show us the relation between FMVSS and the specifications regulated by a state such as the State of Pennsylvania.

3. In order to get the code no. FMVSS, what procedure should be followed by company as ours, who manufactures hoses and several types of metal fittings, and assembles them into oil brake hoses?

4. There are several types of forms in our metal fittings. Is it necessary to get the code no. on the respective types of our metal fittings?

5. Please introduce us to the public institutions who can test and qualify oil brake hoses to get the code no. FMVSS.

Your generous cooperation would be highly appreciated.

Yours Sincerely

H. Tsukano, Sub-manager Technical Division

MEIJI RUBBER & CHEMICAL CO., LTD.

March 25, 1974

Docket Section National Highway Traffic Safety Administration

Subject: Submission of Comments on Federal Motor Vehicle Safety Standards Docket No. 1-5: Notice 9

We would like to ask for the approval of our attached application about the Brake Hose Identification provided in the Docket No. 1-5; Notice 9 on the Federal Register, Vol. 39, No. 20, Tuesday, January 29, 1974.

H. Tsukano, Sub-Manager Technical Division

enc.

P.S. As for the expenses, we will pay on your request.

1

LABELING

I. HYDRAULIC BRAKE HOSE

1. Hydraulic brake hose (ID 1/8")

1-1. Printed parts

1-2. Face A (printed mark) (every 6 inches)

-- DOT MRCC 10/74 1/8 HR -- DOT MRCC

Notes: The color of printed letters is white.

The size of a letter is 1/8".

The width of line is 1/16".

MRCC stands for Meiji Rubber & Chemical Co.

1-3. Face B (printed mark)

M MEIJI RUBBER JAPAN 1/8 NO57-1 1974 SAE J1401

(which is indication of the approval for the export to a northern state (Pennsylvania).)

Notes: The white letters are printed continuously

The size of letter is 1/8".

M: The trade mark of Meiji Rubber & Chemical Co.

1/8: The inside diameter of hose 1974: year of production

N057-1: The approval number of RMA (Rubber Manufacturers Association) (444 Madison Avenue, New York 10022, U.S.A.) Line number 57

Yarn color code yellow yellow-black

RMA assignment Meiji Rubber Company, Ltd. attained on March 1st, 1967

SAE J1401 Society of Automotive Hydraulic Brake Hose

2. Hydraulic brake hose end fitting

DOT MRCC 1/8 H XY

Notes: Letters stamped

The size of a letter 1/16"

MRCC stands for Meiji Rubber and Chemical Co.

1/8: The inside diameter of hose X is the figure of production that comes after 197 Y means the month of production

3. Hydraulic brake hose assembly

DOT MRCC 10/74

Notes: Letters stamped

The size of a letter 1/8"

Rubber band width 8 mm red colored hypalon rubber

MRCC stands for Meiji Rubber & Chemical Co.

II. Vacuum Brake Hose (ID 3/8")

1. Printed parts

(A) Face A (printed mark) (every 6 inches)

-- DOT MRCC 10/74 3/8 VL -- DOT MRCC

Notes: The white letters printed

The size of a letter 5 mm

The width of line 3 mm

MRCC stands for Meiji Rubber & Chemical Co. 3/8 means the inside diameter of hose.

(B) Face B (printed mark) (every 6 inches) M MRCC JAPAN -- M ---

Notes: The white letters printed

The size of a letter 5 mm

The width of line 3 mm

M is the trade mark of Meiji Rubber & Chemical Co. MRCC stands for Meiji Rubber & Chemical Co.

ID: nht74-5.39

Open

DATE: 02/01/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Mrs. L. M. Thompson

TITLE: FMVSS INTERPRETATION

TEXT: I would like to thank you for your interest in the safety benefits of the interlock system and for forwarding the Seattle newspaper advertisement which offers a method to bypass the seat belt interlock.

The interlock standard only requires that new vehicles be equipped with required safety equipment. Therefore a purchaser may have the system modified to accommodate circumstances, such as physical incapacity, which makes use of the belts unwise or inconvenient.

The advertisement of a system to circumvent the standard, however, is a different matter, and whether it is legally permitted is a conclusion which the courts will have to determine. This agency is reviewing the legal remedies available which might permit removal of such a product from the market. Having promulgated the interlock option as part of the occupant crash protection standard, whose validity was sustained in court, we are committed to taking all possible actions to insure its effectiveness.

January 8, 1974

Dept. of Transportations U.S. Government Washington, D.C.

Gentlemen:

I noticed this ad in a newspaper and(Illegible Word) if such an operation is legal.

If my memory is accurate I believe the car manufacturer were ordered by the Federal Govt. to install interlock(Illegible Word). If this is true, then wouldn't it be an illegal act for anyone to tamper or modify it?

Is there anything you can do to prevent this?

Sincerely,

Mrs. L. M. Thompson 9624 - 4th St N.E. Everett,(Illegible Word) 98205

TO ALL 1974 AUTO OWNERS or PROSPECTIVE OWNERS

Are you aggravated by this safety belt ignition interlock system that forces you to perform a certain sequence before the car will start?

You, the owner of a 1974 auto may modify the interlock system so that you can be sure, in an emergency, or any other time, that your car will start even if some part of the interlock system malfunctions. This modification also allows you to buckle your seat belt, or not, as it pleases you.

There is a simple way that any one can easily make the modification to his own 74 auto and bypass the interlock.

This information is available (with complete simple instructions) in a report that may be purchased for the low sum of $ 4.00 with satisfaction guaranteed. Enclose cash, check or m.o. and specity make, model, and engine.

ORDER YOUR REPORT CASCADE HOUSE Box 2170-A Renton, Washington 98055

Seattle Post(Illegible Word)

12-30-73

Request an Interpretation

You may email your request to Interpretations.NHTSA@dot.gov or send your request in hard copy to:

The Chief Counsel
National Highway Traffic Safety Administration, W41-326
U.S. Department of Transportation
1200 New Jersey Avenue SE
Washington, DC 20590

If you want to talk to someone at NHTSA about what a request for interpretation should include, call the Office of the Chief Counsel at 202-366-2992.

Please note that NHTSA’s response will be made available in this online database, and that the incoming interpretation request may also be made publicly available.

Go to top of page