ID: nht87-1.27

TYPE: INTERPRETATION-NHTSA

DATE: 02/02/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Guy Vander Jagt

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Guy Vander Jagt U.S. House of Representatives Washington, DC 20515-2209

Dear Mr. Vander Jagt:

Thank you for your November 3, 1986, letter on behalf of your constituent, Miss Reva Darling of Ludington, Michigan, who asked about requirements for safety belts on buses used for school transportation and other purposes. Your letter has been referred t o my office for reply, since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety.

Miss Darling is interested in extending the applicability of Michigan's safety belt use law to belts on "public" buses. She believes that safety belts should be installed on school buses and buses used by transit and charter companies, and suggests that funding be made available to encourage the installation of belts on those vehicles.

I appreciate this opportunity to respond to your inquiry. By way of background information, under the National Traffic and Motor Vehicle Safety Act, NHTSA is authorized to develop motor vehicle safety standards applicable to all new motor vehicles, inclu ding school buses and charter and transit buses. Our belt installation requirements vary according to the type of vehicle; for example, different requirements apply to passenger cars than to buses. For buses generally, our requirements only specify that a safety belt must be installed for the bus driver. They do not require safety belts for passengers on large buses used for pupil transportation and other purposes.

We have not required large buses to have safety belts for passengers because we have not found sufficient justification for such a requirement, given that buses have excellent safety records. This safety record arises in part from the fact that, in crash es with other vehicles, buses tend to be substantially heavier than the other vehicle while cars tend to weigh approximately the same as the vehicle with which they crash. As a result, the crash forces experienced by bus occupants tend to be less than th ose experienced by car occupants. Also, because of the elevated stating positions in large buses, bus occupants sit above the area typically damaged in a collision with another vehicle. Further, we require large school buses to provide passenger crash pr otection with higher and stronger seats, additional seat padding, and better seat spacing and performance. That approach, together with the other attributes of large school buses, provides adequate levels of crash protection in school buses without safet y belts. I have enclosed a copy of a NHTSA publication, "Safety Belts in School Buses," which addresses in more detail the issue of whether safety belts should be required on school buses.

NHTSA does not prevent States and local jurisdictions that wish to order safety belts on their own large buses from doing so. Although large buses are not required by Federal law to have passenger safety belts, bus owners are free to purchase their buses with safety belts installed if they believe their particular circumstances warrant such installation. However, we have no reason at this time to believe that such an installation is necessary as a Federal requirement applicable to all transit buses.

Miss Darling asks whether there have been any proposals to apply Michigan's safety belt use law to public buses. Safety belt use requirements art a matter of State rather than Federal law. Therefore, Michigan state officials would be able to answer Miss Darling's particular question concerning the state law.

On a final matter, Miss Darling suggested that funding be made available to equip buses with safety belts. For your information, while the Administration has not proposed any legislation affecting school buses, H.R. 749 (introduced in the 99th Congress) proposed incentive grants to the States encouraging the adoption and enforcement of laws requiring the use of safety belts in school buses. H.R. 749, however, was not enacted.

I hope this information is helpful. Please contact my office if we can be of further assistance.

Sincerely,

Erika Z. Jones Chief Counsel

The Honorable Guy Vander Jagt House of Representatives Washington, D.C. 20515

Dear Vander Jagt:

Thank you for your letter forwarding correspondence from your constituent, Miss Reva Darling.

I have transmitted your inquiry to the appropriate Departmental officials who are familiar with this matter and they will respond to you directly.

I appreciate your contacting me and hope you will not hesitate to call if I can be of any further assistance.

Sincerely,

Edward J. Babbitt Director, Office of Congressional Affairs

Mr. Ed Babbitt Director of Congressional Affairs Department of Transportation 400 7th Street, S.W., Room 10406 Washington, D.C. 20590

Dear Mr. Babbitt:

I have enclosed a copy of correspondence I received from a constituent, Miss Reva Darling, relative to seat belts in public buses.

As you will note, Miss Darling is interested any information on this issue. I would appreciate any information or comments you may be able to provide in response to her query.

Thank you for your time and attention to this matter. I look forward to hearing from you in the near future.

With all good wishes,

Sincerely,

Guy Vander Jagt Member of Congress

Rep. Guy Vander Jagt 2334 Rayburn Bldg. Washington, D.C. 20515

Dear Rep. Vander Jagt,

Hello, my name is Reva Darling and I am a junior in high school. I am writing in regard to the recent seatbelt law established in Michigan last year.

My question is this: Has there been any proposals in conjunction with applying this law to public buses? By buses, I am referring to both charter and/or school related buses. I believe that funding to make seatbelts possible on these vehicles is highly worthwhile considering the number of passengers and lives involved. I would appreciate any information that you could send me about hi s.

Thank you for your time.

Sincerely,

Reva Darling

Reva Darling 2456 S. Meyers Rd. Ludington, MI 49431

ID: nht87-1.28

TYPE: INTERPRETATION-NHTSA

DATE: 02/05/87

FROM: G T DOE -- LOTUS ENGINEERING

TO: ERIKA Z JONES -- CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 10/15/87 FROM ERIKA Z JONES TO GT DOE; VSA 108, STANDARDS 208, 216 LETTER DATED 09/18/87 FROM ERIKA Z JONES TO J. DOUGLAS HAND

TEXT: Dear Madam

Lotus is proposing to introduce a convertible car into the United States. It is planned to develop and certify the car as a two seat convertible. It is recognised, however, that if no other provision is made, accessory manufacturers may offer 'hardtop' conversions to our customers. In anticipation of the latter possibility, a factory manufactured and approved quality hardtop optional conversion would be offered. The hardtop would consist of a composite roof structure, which would replace the convert ible canopy and support frame. The removal of the latter would reveal a trimmed luggage shelf behind the two designated seating positions. It is conceivable that, although the shelf would not be recognised as a seating area, small occupants could trave l in this area. The fitting of the hardtop would in no way degrade the quality, reliability, or safety of the vehicle. The application of the hardtop conversion is depicted in the accompanying illustration.

It is possible that, whilst vehicles would be imported as convertibles, individual dealers might elect to fit hardtops to new vehicles and display them in their showrooms in this condition.

Could you please give interpretations with respect to the following:-

1. Convertibles are not required to conform to the roof crush requirements of FMVSS 216. Would the designation of the vehicle as a convertible remain unaffected by the hardtop conversion?

2. Would the requirement for seating and restraint system provision remain unaffected by the hardtop conversion?

Please do not hesitate to contact the undersigned for any further information, or discussion regarding the above.

ID: nht87-1.29

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/87

FROM: HANNS-OTFRIED WESTERMANN--HELLA KG HUECK & CO.

TO: DR. BURGETT--NHTSA

TITLE: RE MULTI BULB DEVICES

ATTACHMT: ATTACHED TO LETTER DATED 8-22-90 TO H. WESTERMANN FROM P. J. RICE; (A36; STD. 108)

TEXT:

We intend to equip motor vehicles with signalling devices, which have - opposite to conventional lamps - a great number of replaceable miniature bulbs instead of e.g. one 32 cp bulb. The miniature bulbs are about 2 to 3 cp each, as is actually applied t o CHMSL.

This design shows a number of advantages:

1. The failure probability of the signal function of a device is very low, because the burn out of a single bulb does not drop the light-out-put of the lamp below the minimum value required.

2. The average life of the miniature-bulbs is greater than the one of current 32 cp bulbs: about 3 per cent mortality rate after 1500 burning hours.

3. The devices can be built smaller and particularly with less depth.

4. The openings in the vehicle's body work can be avoided in part or totally, because the devices can be surface mounted.

5. The absence of body work openings increases the vehicle's stability and avoids sealing problems.

Summary: "Multi-bulb-devices" increase the traffic safety and lower the system costs over the vehicle's life time.

FMVSS No. 108 opposes this idea, because it is required that lamps with 2, 3 or more lighted sections have to comply with higher intensity requirements than a lamp with only one compartment or bulb. The reason for this requirement is to assure a uniform ly conspicuous surface luminance. These higher intensity requirements because of the larger overall lens area are not applicable to our design with a great number of miniature bulbs.

In spite of the great number of bulbs (10 to 20, depending on function) the total area of the lamp is not larger than the one of current one-compartment-lamps. The luminous Intensity requirement for 3- or more compartment lamps for this lamp size would c ause undesirable high luminances.

For each of the many bulbs the lighted lens area is substantially smaller than the required minimum area (22 inches square) for each compartment of multi-compartment lamps, but the total area of all bulbs is in compliance with the requirement for one-com partment-lamps.

We kindly ask for your comment on the legal aspects of this deviating design with many miniature bulbs and in particular, whether the intensity requirements of single-compartment lamps are applicable. (For LED-lamps it is even discussed, that for their higher conspicuity the intensity requirements could be lowered below those of single-compartment lamps). In our opinion the minimum requirements should not depend on the type of design (number of bulbs or compartments) but on the overall visible lens ar ea.

We want to draw your attention to the changes of ECE Regulations R6 and R7:

"If with a single lamp containing more than one bulb one of this bulbs fails, the lamp with the remaining bulbs shall comply with the minimum value required ...

Any failure of a bulb in such a lamp shall be clearly visible, if the lamp is switched on."

ID: nht87-1.3

TYPE: INTERPRETATION-NHTSA

DATE: 01/06/87

FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA

TO: Russell Thatcher -- Director, Mobility Assistance Program, Exective Office of Transportation and Construction, Commonwealth of Massachusetts

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Russell Thatcher Director Mobility Assistance Program Executive Office of Transportation and Construction Commonwealth of Massachusetts 10 Park Plaza, Room 3510 Boston, MA 02116-3969

Thank you for your letter of October 3, 1986, to NHTSA Regional Administrator Jack Connors requesting an interpretation of Standard No. 210, Seat Belt Assembly Anchorages. Your letter was referred to my office for reply.

You explained that you are in the process of buying a number of vans which will be outfitted with Republic Seating Corporation's Model D117 seats. You stated that questions have been raised about whether the safety belt placement on those seats complies with our standard. You enclosed a quarter-scale diagram of the seat in question showing the location of the safety belts and asked our opinion about whether the safety belt placement complies with our standard.

Under the National Traffic and Motor Vehicle Safety Act, which this agency enforces, it is the responsibility of a vehicle manufacturer to certify that its products comply with the requirements of our standards. This agency does not have the authority to approve a manufacturer's design plans. We can offer our opinion, but it is the manufacturer's obligation to ensure that the finished vehicle complies with all of the applicable standards.

The standard which affects the mounting angle for safety belts is Standard No. 210, Seat Belt Assembly Anchorages. The drawing enclosed with your letters shows that the lap safety belt anchorage for this seat is installed on the frame of the seat. S4.3.1 .3 of the standard provides:

In an installation in which the seat belt anchorage is on the seat structure, the line from the seating reference point to the nearest contact point of the belt with the hardware attaching it to the anchorage shall extend forward from that contact point at an angle with the horizontal of not less than 20o and not more than 75o.

According to the drawing enclosed with your letter, the line from the seating reference point to the nearest contact point of the safety belt, on the outboard side of the seat, with the hardware attaching it to the anchorage is 75o. If the outboard porti on of the safety belt is installed in a completed vehicle in the location shown in the drawing would meet the requirement of S4.3.1.3, since its mounting angle is not more than 75o.

We cannot offer a opinion as to whether the inboard portion of the safety belt would comply with S4.3.1.3, since the mounting angle for that portion of the safety belt is not depicted in the drawing. I want to emphasize again, that this letter represents the opinion of the agency based on the facts you have presented. It is a manufacturer's responsibility under the Vehicle Safety Act to certify that its completed vehicle complies with our standard.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

Mr. Jack Connors, Regional Administrator National Highway Traffic Safety Administration 55 Broadway / Kendall Square Cambridge, Massachusetts 02142

Re: Interpretation of, and Compliance with, Specification 49 CFR Section 571-210 Subsection 4.3.1.3

Dear Mr. Connors:

The State of Massachusetts, acting through the Executive Office of Transportation & Construction, administers the Federal 16(b)(21 and State Mobility Assistance Programs. These programs provide grant subsidies to private and public non profit agencies ac ross the state for the purchase of wheelchair lift equipped vans and minibuses used to transport elderly and disabled persons.

We are currently in the process of purchasing forty three (43) vans from Collins Bus Corporation which will be outfitted with Republic Seating Corporations Model D117 seats. Questions have been raised about the current seat belt placement being utilized by Republic Seating.

We would like to request an opinion from your office on whether or not the design complies with federal standards. Attached is a quarter-scale diagram of the seat showing the location of the seat belts.

Your expeditious handling of the matter would be greatly appreciated. During the last year approximately 100 vehicles across the State have been purchased and are being operated in transportation programs.

Should you require additional information, please contact my Assistant Director Royal Spurlark or myself at 973-?000. should you need to contact Republic Seating for information, you can call Mr. Peter Redding, President of that company at (312) 628-8500 .

Sincerely,

Russell Thatcher Director Mobility Assistance Program

SEE HARD COPY FOR GRAPHIC ILLUSTRATIONS

ID: nht80-1.6

DATE: 01/21/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Edison Rubber Company

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your letter of November 9, 1979, inquiring if it is permissible for your suppliers to cut off the DOT serial numbers on used tires before selling those tires to your company. You stated in your letter that your company buys used tires from several companies. These tires generally either have cuts in the tread or sidewalls or are out of round. Your company then resells the tires to another company, which resells the tires to the public.

The answer to your question is no. The presence of the DOT identification number on tires is required by several of this agency's regulations. Our tire identification and record keeping regulation (49 CFR Part 574) requires that each manufacturer place the DOT number on at least one sidewall of each tire that it manufactures. The number serves several purposes. It is indispensable in aiding consumers to identify tires subject to a recall campaign for safety defects and noncompliances with the safety standards. It also aids this agency in enforcing its tire safety standards. Federal Motor Vehicle Safety Standards 109 (Passenger car tires, 49 CFR 571.109) and 119 (Tires for vehicles other than passenger cars, 49 CFR 571.119) require that each tire manufacturer certify that its tires conform to all applicable Federal safety standards by branding or molding the DOT number on the tire.

Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1397(a)(2)(A)), states 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. . . an item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . ." By removing the DOT identification number from a tire, the person would be knowingly rendering inoperative an element of design on the tire which is included on the tire for compliance with the requirements of a Federal motor vehicle safety standard. Section 109 of the Act (15 U.S.C. 1398) specifies a penalty of up to $ 1,000 for each violation of section 108.

Sincerely,

ATTACH.

November 9, 1979

Steve Kratzke -- Office of Chief Counsel

Dear Mr. Kratzke,

This letter is to follow up the several phone calls I have had with you regarding the legality of cutting Department of Transportation serial numbers off of used tires.

At your earliest convenience, please send me a written reply to the question following the two situations described below:

1. My company, Edison Rubber Company, buys tires that have cuts in the sidewall or tread from several companies. Edison Rubber Company then sells these cut tires to another company which repairs the cuts and then resells these tires to the general public.

2. My company, Edison Rubber Company, also buys from several companies tires that are out of round (the customer felt that their car did not ride smoothly). Edison Rubber Company then resells these tires to another company which resells them to the general public.

My question relates to both of the above situations: Are the companies that sell these tires to Edison Rubber Company allowed to cut the serial numbers off of these tires legally so as not to get them back as adjustment tires?

Your speedy response is appreciated as it would save my suppliers much time and effort in disposing of their junk tires. Please call me if you have any questions.

Yours truly,

Jeffrey Libman, President -- Edison Rubber Company

ID: nht80-1.7

DATE: 01/25/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Grumman Flexible Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. In a telephone conversation with Ms. Debra Weiner of my office, you asked whether section S5.2.2 of the standard would apply to the windshield wiper controls which Grumman Flexible intends to install in its transit buses. As I understand your description, there are to be separate controls for the left and right windshield wipers and each control will allow for operation of the wiper over a continuous range of speeds.

The answer to your question is no. Section S5.2.2 of Standard 101-80 provides that:

Identification shall be provided for each function of any automatic vehicle speed system control and any heating and air conditioning system control, and for the extreme positions of any such control that regulates a function over a quantitative range. (emphasis added).

The function identification requirements are not applicable since their applicability is expressly limited to speed controls and to heating and air conditioning controls. The applicability of the extreme position identification requirements is similarly limited since "such controls" refers back to those controls already identified in S5.2.2.

ID: nht80-1.8

DATE: 01/31/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Doug Smith

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your December 6, 1979, letter asking questions about Standard No. 211, Wheel Nuts, Wheel Discs, and Hub Caps. In particular, you ask whether winged projections are permitted in a rim as long as they do not extend beyond the lip of a rim or the sidewall of a tire.

When the standard was issued, the agency concluded that winged projections could catch the clothing of children or pedestrians thereby posing a safety hazard. As a result, the standard prohibits the use of all winged projections regardless of the extent to which they extend from a rim. The standard, however, only prohibits winged projections and does not affect other projections from a rim.

SINCERELY,

December 6, 1979

Roger Tilton Office of Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Tilton:

After talking with you this after noon I'm writing for your ruling on wing projections covered in Motor Vehicle Safety Standard no. 211-S3.

I am of the opinion that if the knock off (winged projection) does not extends beyond the lip of the rim or the sidewall face of the tire mounted on the rim, it will be all right with the knock off in the center.

As I understand the ruling, it is designed to eliminate catching people or objects and dragging them into the wheel. By not extending beyond the lip of the rim or sidewall face the knock off would be safe.

Please return you ruling to me as soon as possible.

Doug Smith

Attachment Omitted.

ID: nht80-1.9

DATE: 02/06/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: The Yokohama Rubber Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: Your September 10, 1979, letter to our Tire Division has been referred to me for reply, since you are requesting an interpretation of Federal Motor Vehicle Safety Standard No. 119 (49 CFR @ 571.119). You asked two questions in your letter. First, you asked whether the definition you offered for "maximum speed" was correct. If it was correct, you stated that the tire could exceed the speed restriction shown on the tire at a lighter load, and showed how the information could be set forth on the tire. The listing of varying maximum loads at different maximum speeds is not permitted to appear on the tire. Second, you asked if speed restricted tires could specify a speed restriction other than the 35, 50, and 55 mile per hour (mph) restrictions shown in the endurance test schedule of Standard No. 119. The answer to this question is no.

Regarding your first question, you defined a tire's maximum speed as "the highest speed at which a tire can carry the maximum single load that is molded on the tire sidewall." This definition is an acceptable one for tires with a speed restriction listed for them. However, you went on to note that if this definition was acceptable, then a tire could list varying maximum loads at varying maximum speeds. Such a listing is expressly prohibited by the language of Standard No. 119.

S6.5 of Standard No. 119 specifies that each tire subject to the Standard shall be marked with the information that is set forth in following paragraphs. Paragraph (d) of S6.5 requires the maximum load rating and corresponding inflation pressures for single load tires, the type of tire about which you are inquiring, to appear as: Max load lbs. at psi cold. Paragraph (e) of S6.5 requires that a speed restriction on the tire appear only as: Max speed mph. Hence, a single load tire can be labeled with only one maximum load and only one maximum speed.

Your second question was whether a manufacturer could restrict the speed of a tire subject to Standard No. 119 to a speed other than the three speed restrictions shown in Table III of the Standard. Paragraph S6.1 requires all tires to pass the endurance test requirements of the Standard, and Table III shows the load and speeds to which the tires will be subjected during the endurance test. If the tire being subjected to the endurance test does not qualify for the special speeds and loads as one of the three speed restricted tires shown in the table or as a motorcycle tire, the tire would be tested at the speed and load shown under the heading "All other". This would mean that the tire's speed restriction would be ignored for purposes of the endurance test, and it would be tested as if it were a non-speed restricted tire. Such a tire would presumably fail the endurance test under these conditions, and no tire which fails to pass the endurance test can be sold in the United States. As a practical matter, therefore, speed restrictions other than the three shown in Table III of the Standard are not recognized by this agency.

The three speed restrictions shown in Table III of the Standard were adopted from descriptions of three types of speed restricted tires used by the United States tire industry in 1972, when the agency was initially promulgating Standard No. 119. If your company would like to add another speed restriction to those shown in Table III, you should file a petition for rulemaking with this agency requesting an amendment to Standard No. 119.

Sincerely,

ATTACH.

September 10, 1979

Tire Division, National Highway Safety Administration,

Re: Confirmation of the definition of Max. Speed

Dear Sirs,

We would like to confirm that meaning of Max. Speed specified in S6.5e of FMVSS No. 119 is as follow:

1 Max. Speed means the highest speed at which a tire can carry the max. single load that is molded on the tire sidewall.

If the actual carrying load is lower than max. single load, the tire can run at a higher speed than the Max. Speed molded on the tire sidewall.

Example

Tire Size 1000R20 Load range H

Max. Load single 6610lbs

Max. Speed 35MPH Load LBS Speed MPH 6610 Max. Load 35 Max. Speed 5300 42 4600 50

2 According to Table Endurance Test Schedule, Max. Speed For Speed-restricted Service is specified as 55, 50 or 35 MPH. May we choose speeds different from the above?

In this case, if Max. Speed chosen is 40 MPH, should the 50 MPH endurance test condition be used?

We would appreciate it very much if you would give careful consideration to our questions.

Very truly yours,

The Yokohama Rubber Co., LTD -- Tire Quality Assurance Department; Taiji Ide, Manager

ID: nht80-2.1

DATE: 04/14/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: American Moped Associates

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of March 11, 1980, forwarding to Mr. Schwartz of my office the proposed vehicle identification number (VIN) scheme for American Moped Associates, and in confirmation of your subsequent telephone conversation with Mr. Schwartz.

Your VIN scheme complies with the requirements of Federal Motor Vehicle Safety Standard No. 115, with the following exceptions. The fourth through eighth characters of the VIN are required by S4.5.2 and Table I of the Standard to encode certain descriptive characteristics of the vehicle. For motorcycles, which include mopeds, this information is (1) type of motorcycle, (2) line, (3) engine type and (4) net brake horsepower. While the information which American Moped Associates proposed to encode in the fourth through eighth characters will undoubtedly be useful to your company, it is not necessary to advise the agency of your internal coding. Further, while much of the information the Standard requires to be decoded from these characters is self-evident because of your product line, it is none-the-less necessary to forward this information to the agency as specified in the Standard.

Based on your discussions with Mr. Schwartz, it appears this may be easily accomplished utilizing essentially the same format as you currently propose. It is my understanding that you no longer intend to encode the color in the fifth position of the VIN, but rather utilize a single "filler" character such as an "M". Further, I understand that all your mopeds utilize the same engine and comprise two lines characterized by the number of speeds. Consequently, based on your product line, your submission to the agency might read:

Characters 1-3 LAM: WMI assigned to American Moped Associates. Character 4 (internal use) Character 5 M: Indicates moped type; gasoline, one cylinder engine with a displacement of ; net-brake horsepower measured at the crankshaft of . Character 6 (internal use). Character 7 1 indicates one-speed Indian line. Character 7 1 indicates two-speed Indian line. Character 8 (internal use) Character 9 Check digit. Character 10 Model year. Character 11 T: Indicates Taipei plant of manufacture.

Y: Indicates Yuanlin plant of manufacture. Characters 12-17 Sequential number.

Please feel free to contact Mr. Schwartz should you have any further questions on this matter. Sincerely,

ATTACH.

AMERICAN MOPED ASSOCIATES

March 11, 1980

Frederic Schwartz -- Office of the Chief Counsel, National Highway Traffic Safety Administration

Dear Mr. Schwartz:

Pursuant to our recent telephone conversation concerning implementation of our VIN number, please find below for your approval a sample VIN number with notes explaining our coded identifiers.

LAMMB11A - AT123456

LAM - WMI assigned to American Moped Associates

M - Carburetor Type - alternate would be K

B - Color Black - G; Green - R; Red - W; White

1 - Wheel Type 1; Spoke - 2; Mag

1 - Number of Speeds 1; 1 Speed - 2; 2 Speed

A - Series changes letter from A to Z --- Check digit

A - Year of manufacture

T - Plant of mfr. T; Taipei - Y; Yuanalin

12346 - Numerical Sequence

If you have any questions, please feel free to call me at 1-800-854-6213.

Sincerely,

Bart Achille -- National Sales Manager

ID: nht80-2.10

DATE: 04/22/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Union Springs Central School District

TITLE: FMVSS INTERPRETATION

TEXT:

APR 22 1980

Steven J. Kalies, Ed.D Asst. Supt. for Business Union Springs Central School District Union Springs, New York 13160

Dear Dr. Kalies:

This is in response to your letter of January 22, 1980, asking whether the Dubl-Life Saver Support restraint vest manufactured by Easy Way Products Co. is in compliance with applicable Federal motor vehicle safety standards. The advertisement you enclosed with your letter describes the Dubl-Life Saver as a support restraint vest for the safe transportation of all sizes of handicapped children in motor vehicles. The advertisement further claims that the safety belts used with the vest exceed "federal specifications".

Based on the information in the advertisement, it appears that the restraint vest does not provide pelvic restraint and thus does not comply with Standard No. 209, Seat Belt Assemblies. I have referred this matter to the agency's Office of Vehicle Safety Compliance for appropriate action.

The University of Michigan's Highway Safety Research Institute has conducted tests of various devices used to restrain handicapped children. I have enclosed a copy of a Society of Automotive Engineers paper describing the results of the testing.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

January 22, 1980

National Highway Traffic Safety Administration Office of Chief Counsel 400 7th St., S.W. Washington, D. C. 20590

Gentlemen:

As requested in the attached letter from Mr. Irving Rodness, Motor Vehicle Program Specialist, we are enclosing a copy of the brochure concerning the Dubl-Life Saver Support restraint vest from Easy Way Products Co.

Please advise as soon as possible if this vest meets federal specifications, as stated in the attached brochure.

Sincerely,

Steven J. Kalies, Ed.D Asst. Supt. for Business

jf Enc.

January 18, 1980

Mr. Steven J. Kalies Union Springs Central School District Union Springs, New York 13160

Dear Mr. Kalies:

During our telephone conversation, I envisioned the device you described being covered by our Federal Motor Vehicle Safety Standard (FMVSS) 209, Seat Belt Assemblies. By the description on the price sheet you enclosed in your letter of 1/8/80, I am now not too sure. This device may not be covered at all or is covered under our FMVSS 213, Child Restraint.

After a conversation with the NHTSA's Office of Chief Counsel, I am taking the liberty of forwarding your letter to them for their review and response. It would be helpful if a brochure or picture of this device could be sent to our Washington Office. If available, mail it to: NHTSA, Office of Chief Counsel (NOA-30), 400 7th Street, S.W., Washington, D.C. 20590, ATTN: Mr. Stephen L. Oesch. Thank you for bringing this matter to our attention.

Sincerely,

Irving Rodness Motor Vehice Program Specialist

cc: OCC NOA-30