ID: nht68-2.49

DATE: 09/04/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: General Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 1, 1968, to Messrs. Eugene Laskin and J. E. Leysath of this Bureau, requesting comments on the Distributors Association's bulletins on lamps, reflective devices and associated equipment required by Motor Vehicle Safety Standard No. 108.

The five bulletins adequately illustrate the requirements of Standard No. 108 to the vehicles shown except as follows:

(1) Pages 1, 3, and 4 -- The statement "Identification, clearance and side market lights and side and rear reflectors are not required unless vehicle with body is 80 or more inches wide overall" should be changed, because Table III of Standard No. 108, effective January 1, 1969, specifics requirements for side marker lights and side and rear reflex reflectors on vehicles less than 80 inches wide.

(2) Page 2 -- The numbers indicating clearance and identification lamps in lower right view should be reversed, i.e., 10 and 11, respectively. Also, the turn, tail and stop lamps do not appear to be located as far apart as practicable.

(3) Page 4 -- The front clearance lamps mounted on the chassis cab are optional, because those on the van body meet the requirements of Standard No. 103.

(4) Page 5 -- (a) Identification and clearance lamps are not required if vehicle width is under 80 inches. (b) Two red reflectors are required on the rear of the vehicle.

(5) General, all pages -- Paragraph S3.1.1.6 permits vehicles less than 80 inches overall width manufactured before January 1, 1970, to be equipped with a combination of two side marker lamps and side marker reflectors on each side instead of two each as specified in Table III.

(6) General, Pages 1 through 4 -- Parking lamps are not required on vehicles that are 80 inches or were in overall width.

With respect to the requirements of Standard No. 108, 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 hat the assembled vehicle meets the requirements of the standard.

ID: nht68-2.5

DATE: 05/14/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Northern California Ready Mixed Concrete and Materials Association

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 8, 1968, to Mr. George Nield, concerning the location requirements for clearance lamps as specified by Federal Motor Vehicle Safety Standard No. 108.

Enclosed is a copy of the Federal Motor Vehicle Safety Standards (with amendments and interpretations through February 15, 1968). Standard No. 108 appears on page 39 of this publication. The location requirements for clearance lamps are included in Table II (page 50), of the standard. Since the requirements specify locations as near as practicable to the upper left and right extreme edges of the vehicle, the exact locations will vary, depending upon the design and utilization of the vehicle on which the lamps are mounted. When the rear identification lamps are mounted at the extreme height of the vehicle, rear clearance lamps may be mounted at optional heights. I would also point out that Standard No. 108 is applicable to new vehicles manufactured for sale on or after the effective date of the standard.

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 writing.

ID: nht68-2.50

DATE: 04/16/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Hercules Galion Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 15, 1968, to the Director, National Highway Safety Bureau, concerning your interpretation of the requirements of Motor Vehicle Safety Standard No. 108.

The lamps and reflectors shown on your drawing(Illegible Words) dated March 8, 1968 appear to be in conference with the requirements of Initial Standard No. 108; however, since no dimensions are specified on your drawing, we can only assume that the locations are as specified in the standard.

The certification requirements for complete vehicles incorporating chassis and bodies manufactured prior to and after January 1, 1968, are correctly stated in the information bulletin attached to your referenced letter and dated March 15, 1968.

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 Standard No. 108.

ID: nht68-2.6

DATE: 05/14/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 16, 1968, to Mr. Lowell K. Bridwell, Administrator, Federal Highway Administration, requesting a clarification of the electrical circuity arrangements that may be used to meet the requirements of paragraph S3.4.3 of Motor Vehicle Safety Standard No. 108.

Truck-tractors wired in accordance with your customers' orders stating, "the brown trailer circuit shall be connected to the headlamp switch and the black trailer circuit shall be energized through a seperate switch," will meet the requirements of paragraph 53.4.3, provided the trailer circuits conform to SAE Standard J560a. With this circuitry, your responsibility as a truck-tractor manufacturer would be fulfilled, regardless of the number of trailers that are towed by the truck-tractor.

Thank you for writing.

ID: nht68-2.7

DATE: 06/19/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Robert Bosch Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 24, 1968, to Mr. J. E. Leysath of this Bureau, concerning the testing of automotive flasher devices.

Motor Vehicle Safety Standard No. 108 specifies that turn signal flashers and vehicular hazard warning signal flashers conform to SAE Standards J590b and J945, respectively. These SAE standards, in turn, require that the test circuitry and test instrumentation conform to SAE Standard J823a. As you noted, the distribution of the 0.10+/-0.01 ohm series resistance in the standard test circuit (Figure 1 of J823a) is not specified in SAE Standard J823a. Therefore, your recommended distribution, namely, 0.025+/-0.005 ohms resistance between the power supply (positive terminal) and flasher input terminal, and 0.075+/-0.005 ohms resistance between the flasher output terminal and the flasher bulbs, would be permitted by SAE Standard J823a.

Flasher units having a ground terminal that is connected with the negative terminal of the power supply may be tested in the standard test circuit of SAE Standard J823a, provided the ground circuitry does not change the required resistance of 0.10+/-0.01 ohm looking into terminals A-B with the removable shunts in place (see note for Figure 1, SAE J823a).

The above-stated test provisions in no way except the flasher units from meeting all performance requirements specified in Standard No. 108, including those specified in basically referenced SAE Standards J590b, "Automotive Turn Signal Flashers," and J945, "Vehicular Hazard Warning Signal Flasher."

ID: nht68-2.8

DATE: 05/15/68

FROM: JOSEPH R. O'GORMAN -- NHTSA SIGNATURE BY ANDREW K. NESS

TO: Cheetah Coaches

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 19, 1967, to the National Highway Safety Bureau, in which you request information governing vehicle width and safety glass installation requirements on the vehicles you manufacture.

Regarding your question on vehicle width, Safety Standard No. 108 relative to lamps, reflectors and associated equipment, for specified vehicles 80 or more inches wide overall, defines the term "overall width" as the nominal design dimension of the widest part of the vehicle, exclusive of signal lamps, marker lamps, outside rear view mirrors, flexible fender extensions and mud flaps, determined with doors and windows closed and the wheels in the straight ahead position. Therefore, if your vehicle measures less than the Safety Standard No. 108 requires, compliance is not required.

Your question regarding installation of safety glass as specified by Safety Standard No. 205, relative to Glazing Materials, can be answered by directing your attention to Standard No. 205. It specifies adherence by a multi-purpose Passenger Vehicle, a category into which your pick-up campers fall. A copy of the Federal Register, Volume 32, No. 23 and amendment to this regulation, Volume 32, No. 131, is enclosed for your information.

The application of Safety Standard No. 205 to pick-ups, is covered by the enclosed Federal Register, Volume 33, No. 59.

Thank you for your cooperation and response to the Federal Highway Administration request regarding the certification requirement.

The label sample and information as to its location that you have provided will be very useful to us, however, in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with the serial indentification system in order that vehicles manufactured (completed) after January 1, 1968, can be identified.

Your interest in the safety program of the Bureau is appreciated.

ID: nht68-2.9

DATE: 06/24/68

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

TO: Selma Trailer and Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 2, 1968, which included additional information for certification under Public Law 89-563 and your coments.

You will note that Federal Motor Vehicle Safety Standard No. 108 does not restrict the height of the identification lamps from the roadway. You may find it suitable to mount these lights at a lower level than indicated in your illustrations.

With respect to the requirements of Standard No. 103, 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 manufacture from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

I am enclosing a copy of the National Traffic and Motor Vehicle Safety Act of 1966 which defines the vehicles to which it applies.

ID: nht68-3.1

DATE: 05/17/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Berliner Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 10, 1968, addressed to Mr. William H. Risteen, concerning the requirement for headlamp dimmer switches as specified in Federal Motor Vehicle Safety Standard No. 108.

Paragraph S3.4.1 of Standard No. 108 requires that a means for switching between lower and upper headlamp beams shall be provided in accordance with SAE Recommended Practice J564a or J565a. This general requirement is applicable to all vehicles, including motocycles, that are required, by Standard No. 106, to be equipped with lower and upper bean headlamps, even though SAE Recommended Practice J564a is addressed only to passenger cars.

Thank you for writing.

ID: nht68-3.10

DATE: 10/31/68

FROM: F. ARMSTRONG -- NHTSA; SIGNATURE BY JOSEPH R. O'GORMAN

TO: Rockford Motors Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of July 30, 1969, in which you request additional information in regard to certification requirements.

The statement in your letter to the effect that because detailed label requirements are now being prepared, you are not required to affix a certification label on your motorcycles currently being manufactured is not exactly correct. The "Certification Requirement Notice," published in the Federal Register, Volume 32, Number 215, dated November 4, 1967, a copy of which is enclosed, states that a certification label or tag should be affixed to each applicable motor vehicle if manufactured on or after January 1, 1968. In your case the only safety standard that currently involves motorcycles is Number 205, "Glazing Materials," pertaining to windshields. On January 1, 1969, another safety standard, Number 108, "Lamps, Reflecting Devices, and Associated Equipment," will involve motorcycles manufactured on or after that date.

For your immediate information, a copy of the Federal Motor Vehicle Safety Standards with Amendments is enclosed, with particular attention called to Table III, page MVSS 108-18 (1965) and Table IV, page MVSS 108-20 and 21 (1969).

In regard to your question as to whether you have to add the year of manufacture to your serial numbers, this is not a specific requirement, but would be an aid to clarifying the serial numbering system that identifies applicable vehicles as manufactured on or after January 1, 1968.

The study involving the possibility of specific changes to certification requirements is currently in the proposed rule making category and if changes do become finalized they will be published in the Federal Register.

Please furnish this office with the requirements shown in paragraph 3 in the enclosed Certification Requirement Notice at your earliest convenience.

I trust this information will be of assistance to you in regard to your inquiries.

ID: nht68-3.11

DATE: 01/26/68

FROM: AUTHOR UNAVAILABLE; Roger H. Compton; NHTSA

TO: Truck-Lite Company

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 6, 1967, you requested our comments on the applicability of SAE Standard J567, as sub-referenced in Motor Vehicle Safety Standard No. 108.

As mentioned in your letter, the intent of the reference to SAE J567 is to ensure that replacement bulbs are compatible with the standard bulb sockets. Therefore, any sealed, disposable type, bulb-lens unit, in which the bulb is not a replaceable component, need not comply with the requirements of SAE Standard J567. This provision in no way exempts these sealed units from the other requirements of Motor Vehicle Safety Standard No. 108.