ID: nht68-2.4

DATE: 05/16/68

FROM: ROGER H. COMPTON -- NHTSA; SIGNATURE BY DAVID A. FAY

TO: White Trucks, Division of White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 20, 1968, to Mr. Lowell Z. Bridwell, requesting clarification of paragraph S3.4.3 of Federal Motor Vehicle Safety Standard No. 109.

In your referenced letter you have asked two questions as follows:

"1. While we provide as standard on all tractor models built on or after January 1, 1968, a 7-wire trailer connection and cable, is it satisfactory to furnish the 3-wire cable and connector being requested by many customer? Would we still be considered as conforming to Standard No. 103 with such a cable and contector?

2. Upon customer request, will we still be considered as conforming to the requirements of Standard No. 103 if, in addition to providing the standard double pole double throw switch which would actuate the brown circuit for the tail, clearance and certain marker lights on the trailer, we also furnish a separate switch for the black circuit on the trailer which would illeminate the remainder of the running lights, provided the trailer was wired in accordance with SAE Recommended Practice J560A."

In answer to question No. 1, either the 7-wire or 6-wire trailer connection and cable may be used on truck-tractors, provided the wiring is such that trailer tail lamps will be illuminated when the truck-tractor headlamps are illuminated. It is also to be noted that Standard No. 105 does not specify the number of wires to be used in the trailer connector and cable.

In answer to question No. 2, on trailers wired in accordance with SAE Recommended Practice J560a, a seperate switch for the black circuit on the trailer is permitted under the provisions of Standard No. 103. Again, the wiring and switching for the brown circuit must provide illumination of the tail lamps when the headlamps are illuminated.

The above answer also appear to be responsive to the questions raised in your letter of March 14, 1963.

Thank you for writing.

ID: nht68-2.40

DATE: 11/13/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: NSU Motorenwerke Aktiengesellschaft

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 8, 1968, to Mr. Eugene Laskin, Acting Director, Office of Standards Preparation, concerning reflex reflectors.

The use of two Class B reflectors combined with the fail lamps on the rear of your vehicles will not impair the effectiveness of the two Class A red reflex reflectors required in Motor Vehicle Safety Standard No. 108. These devices are therefore in accordance with Standard No. 108, including paragraph S3.1.2.

Since this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment, the above comments are for your information only, and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.

ID: nht68-2.41

DATE: 04/30/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Gilbert, Segall and Young

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 3, 1968, to Dr. Williams Haddon, Jr., requesting a clarification of the location requirements for license plate lamps as specified by Federal Motor Vehicle Safety Standard No. 108.

The installation requirements contained in the SAE Standard that are referenced in Standard No. 108 are enforceable requirements unless specifically excepted by Standard No. 108. With respect to the installation of license plate(Illegible Word), Standard No. 108 provides an exception to the "Installation Recommendation" contained in SAE Standard(Illegible Words) in that Standard No. 108 requires a location(Illegible Word) rear license plate." This exception permits installation of the license plate lamp or lamps at the top, sides or bottom of the license plate, instead of top and sides only as specified by the SAE installation recommendations.

Thank you for writing.

ID: nht68-2.42

DATE: 09/04/68

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Robert Bosch GMBR

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 21, 1968, addressing to Mr. Lester D. Johnson, Commissioner of Customs, with a copy to Alan S. Boyd, Secretary of the Department of Transportation, concerning the effect of a joint Customs and Transportation regulation on replacement parts for vehicles manufactured prior to the effective date of Federal Motor Vehicle Safety Standards and particulary replacement white parking lamps.

Motor Vehicle Safety Standard No. 108 specifies that the parking lamps on passenger cars, multipurpose passenger vehicles, trucks and buses of less than 80 inches overall width shall be two number, amber in color on all such vehicles manufactured after January 1, 1969. Accordingly, these specifications do not apply to the replacement parts required to keep vehicles already manufactured in safe operating condition.

ID: nht68-2.43

DATE: 06/17/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Consumers Power Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 9, 1968, to Mr. J. E. Leysath of this Bureau, requesting our comments on the rear lighting arrangements you plan to use on several of your service vehicles.

With reference to the rear lighting arrangements only and with exceptions as noted below, the lighting installations shown on your standard lighting drawing appear to meet the requirements of Federal Motor Vehicle Safety Standard No. 108 with respect to location and number of lamps.

1. The rear clearance lamps on vehicles designated by Specification Numbers (50)(54), (49), (52) and (53) do not appear to be located as near as practicable to the upper left and right extreme edges of the vehicle. Clearance lamps located on or immediately forward of the rearmost post on vehicle (50)(54) and the dump truck (54 + 74) shown on your photograph would be more in accordance with the requirements of the standard. Location of rear clearance lamps at greater heights on the rear of vehicles (50)(54), (49), (52) and (53) appears to be practicable.

2. Assuming that vehicles (27), (42) and (22)(28)(29) are less than 80 inches in overall width, Standard No. 108 requires that such vehicles manufactured on or after January 1, 1969, be equipped with either rear side marker lamps or rear side reflex reflectors. Vehicles manufactured on or after January 1, 1970, must be equipped with both rear side marker lamps and rear side reflex reflectors. If these vehicles are 80 inches or more in overall width, additional lighting requirements as specified in Standard No. 108, effective January 1, 1968, apply.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

Thank you for your interest in the Motor Vehicle Safety Standards.

ID: nht68-2.44

DATE: 12/17/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Perley A. Thomas Car Works, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 19, 1968, to Mr. E. Leysath of this Bureau, concerning a clarification of the requirements of paragraph S3.4.3 of Federal Motor Vehicle Safety Standard No. 108.

As you indicated, paragraph S3.4.3 of initial Standard No. 108, which was published in the Federal Register on February 3, 1967, required that tail lamps, license plate lamps, and side marker lamps be illuminated when the headlamps are illuminated. The effective date of the initial standard was January 1, 1968. However, on December 16, 1967, an amendment to the initial standard was published in the Federal Register. This amendment delayed the effective date of paragraph S3.4.3 until May 1, 1968, and in addition revised that paragraph to require, as a minimum, that the fail lamps be illuminated when the headlamps are illuminated. Therefore, the requirements of paragraph S3.4.3 were not applicable to vehicles manufactured during the period of January 1, 1963 through April 30, 1968. During that period, selection of the lamp switching arrangement was at the option of the vehicle manufacturer.

Thank you for writing.

ID: nht68-2.45

DATE: 05/31/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of January 15 and March 25, 1958, to the National Highway Safety Bureau, concerning the applicability of Federal Motor Vehicle Safety Standard No. 108 to snow removal and heavy duty on-off highway vehicles manufactured by Oshkosh.

Standard No. 108 requires that headlamps be mounted not more than 54 inches above the road surface. Since your snow removal vehicles may be used in hauling operations as a secondary function, and since your heavy duty vehicles are used on the public roads, they are required to be equipped with headlamps located in accordance with Standard No. 108. Additional headlamps mounted on the cab roof or elsewhere on the front of the snow removal vehicle is permitted by the standard.

With reference to your heavy duty vehicles, headlamps located in the bumper, with adequate openings in front of the headlamps; or headlamps located below the bumpere, with protective shields around the headlamps would be permitted by Standard No. 108.

With respect to the requirements of Standard No. 108, we must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard. The certification information that you have provided us in your letter of January 15 is in accordance with our requirements.

We trust this information will be of assistance to you in your desire to comply with the existing safety standards.

ID: nht68-2.46

DATE: 07/22/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Dompster Brothers, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 28, 1968, to Mr. James R. O'Gorman, Acting Director, Office of Performance Analysis, requesting comments on the lamps, reflective devices and associated equipment on your container handling equipment.

The lamps and reflectors shown on your drawing A-B4333 through A-B4339 enclosed in your Engineering Bulletin No. 1 dated May, 1965, appear to be in conformance with the requirements of Standard No. 1 (Illegible Word) Since no dimensions are included on your drawings, we can only assumes that the locations are as specified in the standard.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and is no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.

ID: nht68-2.47

DATE: 05/20/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 16, 1968, your reference 61.A218. A1115, to the National Highway Safety Bureau concerning applicability of Federal Motor Vehicle Safety Standards 108 and 205 to compers.

Your questions along with our corresponding answers are listed below: uestion: 1. Do Federal Standards Nos. 108 and 205 apply to Camper bodies which are not manufactured as a part of a vehicle but which may be purchased separately and later installed on a pickup truck by its owner? Answer: The enclosed Notice of Making Regarding Compare affirms the applicability of Federal Standard No. 205 to camper bodies. Federal Standard No.

108 is a standard applicable to chassis cabs and to complete motor vehicles. Question: 2. Do Federal Standards Nos. 108 and 205 apply to campers which are sold by the pickup truck dealer as part of a new vehicle even though the camper body itself is actually a load on the pickup and is designed to be recovered from the pickup when the owner decides to transport other types of loads? Answer: The applicability of Federal Standard No. 205 is covered in the enclosure. Federal Standard No.

108 is a requirement upon the dealer who sells a motor vehicle. If the vehicle is designed for more than one configuration in use, the dealer must provide that both configurations are in compliance with Federal Motor Vehicle Safety Standards.

The enclosed information on the National Traffic and Motor Vehicle Safety Act of 1966 are provided to further assist you.

ID: nht68-2.48

DATE: 09/27/68

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr.; NHTSA

TO: United States Senate

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 13, 1968, calling my attention to Mr. Paul Johnston's comments and suggestions on the requirements for school bus signal lamps as specified in Motor Vehicle Safety Standard No. 108.

As Mr. Johnston pointed out, Standard No. 108, effective January 1, 1969, provides for optional use of either the eight-lamp or four-lamp signal system. This optional provision was adopted after careful consideration of the comments and recommendations which were received in response to the Notice of Proposed Rule Making as published in the Federal Register on February 3, 1967. The "Minimum Standards for School Buses", as published by the National Conference on School Transportation, and the regulations governing minimum standards for school buses in various states were also considered during development of the optional provision for signal lamp systems. Results of our studies and investigations indicated that approximately forty states were using either the four-lamp or eight-lamp signal system. Other states were using the adopted system with only minor variations in the installation and operational requirements.

Standard No. 108, effective January 1, 1969, was published in the Federal Register on December 16, 1967. Under the procedural rules of the Federal Highway Administration, any person adversely affected by this order may petition the Administrator under Part 216, Subchapter B, Section 216.31 or Section 216.35, published in the Federal Register on November 17, 1967, a copy of which is enclosed. No petition of the adopted requirements for school bus signal lamps has been filed.

Although we do not dispute the safety benefits which Mr. Johnson claims for a six-lamp system, I must emphasize that our long-range objective is the adoption of one nationwide system. Even with the presently adopted systems, a motorist could be faced with the problem of interpreting two sets of signals during a very short time period. This problem will become more prevalent with the anticipated increase in rapid interstate traffic. To permit the use of a third optional system, six-lamp or other, would further complicate the situation.

Standard No. 108 applies only to new school buses manufactured on or after January 1, 1969. Retrofitting of buses presently in operation is not required. Since Iowa's fleet of buses is presently equipped with a six-lamp system, it appears that considerable data on the effectiveness of this system could be accumulated from this fleet during the next several years, or until such time that a single nationwide system is proposed. We will be pleased to carefully review and consider any such data which Mr. Johnson can provide in the future.

In summary, it is the position of this Bureau that the provision of Standard No. 108 permitting optional use of either the four-lamp or eight-lamp signal system is reasonable, practicable and in the interest of highway safety. Therefore, we do not believe that a change in this provision to permit optional use of a third or six-lamp system is justified.

We have reviewed our files with respect to the written and personal contacts Mr. Arthur Roberts, Director of Pupil Transportation, has had with this Bureau.

This review indicates that the correspondence from Mr. Roberts was submitted in response to the Notice of Proposed Rule Making on Standard No. 112 (subsequently combined with Standard No. 108) as published in the Federal Register on February 3, 1967. It is not the practice of the Bureau to reply individually to the numerous responses received from published rule making notices, which often run to thousands of pages. However, a summary of the comments represented by the responses and the disposition of these comments is presented in the preamble to Standard No. 108 as published in the Federal Register on December 16, 1967. With respect to Mr. Roberts visit on May 7, 1968, the topics of discussion related primarily to the technical requirements of Standard No. 108 and other information relative to the merits of converting Iowa's school buses to either the four-lamp or eight-lamp system. Our understanding was that Mr. Roberts received the information he was seeking at the time of his visit and that no follow-up correspondence was necessary on our part.