ID: nht73-3.47

DATE: 03/30/73

FROM: AUTHOR UNAVAILABLE; Mike Pescoe, Attorney; NHTSA

TO: Mr. William Goldberg

TITLE: FMVSS INTERPRETATION

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

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

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

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

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

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

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

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

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

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

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

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

ENCLS.

ID: nht73-3.48

DATE: 04/03/73

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: The Flexible Co.

TITLE: FMVSR INTERPRETATION

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

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

ID: nht73-3.49

DATE: 04/04/73

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

TO: Wagner Electric Corp.

TITLE: FMVSS INTERPRETATION

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

Answers to your questions are as follows:

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

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

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

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

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

ENC.

ID: nht73-3.5

DATE: 11/22/73

FROM: AUTHOR UNAVAILABLE; Claude S. Brinegar; NHTSA

TO: Honorable John E. Moss; House of Representatives

TITLE: FMVSS INTERPRETATION

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

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

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

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

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

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

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

ID: nht73-3.50

DATE: 04/04/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Young Windows, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 20, 1973, requesting clarification of the certification and labeling requirements of Motor Vehicle Safety Standard No. 205, "Glazing Materials", for persons who cut sections of glazing materials. You state your understanding is that such persons should add to the cut piece the DOT symbol and the manufacturer's code mark used on the larger piece from which the smaller piece was cut. Your understanding of these requirements is not correct. The labeling requirements of Standard No. 205 were most recently amended on November 11, 1972 (37 FR 24035, copy enclosed). These amendments become effective April 1, 1973. They require a person who cuts glazing material to mark it in accordance with section 6 of ANS Z26. This does not include the DOT symbol and the mark of the manufacturer of the larger sheet, and these items should not be included by persons who only cut the material. That person must also certify the material in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act (15 USC 1403). One method by which this can be done is to affix a removable label to the glazing material which states that it conforms to the Federal safety standard.

You ask how the "AS12" and "AS13" marking should be affixed. The "AS" designation is part of the labeling required by section 6 of ANS Z26, and it should be applied in the manner that the other labeling items of that section are applied. We understand etching is the method ordinarily used, and it is appropriate.

ENC.

ID: nht73-3.6

DATE: 01/03/73

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

TO: Office of Operating Systems

TITLE: FMVSS INTERPRETATION

TEXT: Your memorandum of November 27, 1972, concerning non-tabulated values for tire inflation pressures.

In response to the above-captioned memorandum, we, in coordination with the Chief Counsel's office, have concluded that Standard No. 110 does not preclude the use of odd-numbered tire inflation pressures on the placard required by S4.3 of Standard No. 110, and that the standard does not prohibit interpolation of the load values of the Standard No. 109 tables for purposes of compliance testing.

The relevant language of Standard No. 110 is in paragraphs S4.3 and S4.3.1:

S4.3 Placard. A placard, permanently affixed to the glove compartment door or an equally accessible location, shall display the --

(c) vehicle manufacturer's recommended cold tire inflation pressure for maximum loaded vehicle weight and, subject to the limitations of S4.3.1 for any other manufacturer-specified vehicle loading condition . . .

S4.3.1 No inflation pressure other than the maximum permissible inflation pressure may be specified unless --

(b) The vehicle loading condition for that pressure is specified; and

(c) The tire load rating from Table 1 of @ 571.109 for the tire at that pressure is not less than the vehicle load on the tire for that vehicle loading condition.

There is nothing in the standard which specifically requires the inflation pressure to be one actually listed (even-numbered) in the Tables of Standard No. 109. While paragraph S4.3.1(c) of Standard NO. 110, in referring to the load rating found in the table, arguably implies such a requirement, we cannot, without more specific language, read into the standard that recommended inflation pressures must be even-numbered. The mere fact that the specific tire load rating will not be printed in the table, however, does not preclude enforcement of the placard requirement. Because interpolation of values in a table is accepted engineering practice, we conclude that it is reasonable to interpolate such values in the Tables of Standard No. 109, for purposes of enforcing Standard No. 110, where manufacturers have specified odd-numbered inflation pressures.

ID: nht73-3.7

DATE: 01/03/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Messrs. Carter and Carter

TITLE: FMVSR INTERPRETATION

TEXT: This is reply to your letter of December 14, 1972, to the Federal Highway Administration on behalf of your client, a snow plow dealer. You ask for verification "that the addition of a snow plow to a completed truck is considered the addition of a readily attached component and does not require recertification."

We confirm that a person adding a snow plow to a completed truck is not a final-stage manufacturer who is required by 49 CFR Part 568 to certify compliance of the vehicle with Federal motor vehicle safety standards. He is, however, responsible for insuring that the modified vehicle complies with Standard No. 108 before delivering it to its purchaser.

ID: nht73-3.8

DATE: 01/04/73

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

TO: Toyo Kogyo USA

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 28, 1972, asking for an interpretation of S5.2 of Safety Standard No. 105a.

The transmission you describe has a separate park position, and this position must be engaged before the ignition key can be removed. We confirm that a vehicle equipped in this manner may meet the parking brake system requirements of S5.2.2 rather than those of S5.2.1.

As for your second question, a vehicle with a manual transmission that must be placed in reverse gear before the ignition key can be removed would also meet the requirements of paragraph S5.2.2.

ID: nht73-3.9

DATE: 01/11/73

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

TO: Pilot, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 15, 1972, to the Department, you ask "Do the regulations require that the brake lite be activated prior to the onset on any brake pressure due to pedal travel can some brake pressure be on before the brake lite lights?"

Paragraph S4.5.4 of Motor Vehicle Safety Standard No. 108 Lamps Reflective Devices and Associated Equipment requires that "the stop lamps shall be activated upon application of the service brake." The standard does not state a specific time or brake line pressure at which activation shall occur so that some brake pressure is permitted at the activation point.

ID: nht73-4.1

DATE: 04/04/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Great Southern Equipment Company of Tampa

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 31, 1973, requesting "an application form and requirements for the mounting of hydraulic cranes behind the cab of . . . trucks".

Under NHTSA regulations, the operations you perform appear to make you a final-stage manufacturer who is responsible for the conformity of the completed vehicle to the Federal Motor Vehicle Safety Standards, and for certifying conformity in accordance with NHTSA Certification regulations (49 CFR Part 567), and regulations regarding Vehicles Manufactured in Two or More Stages (49 CFR Part 568). As a manufacturer you are also required to submit certain information required by Part 566, "Manufacturer Identification".

Copies of NHTSA regulations may be obtained as indicated on the enclosed, "Where to Obtain Motor Vehicle Safety Standards and Regulations". We have no requirements involving application to this agency. If after reviewing the regulations you have specific questions, we will be happy to answer them.

ENC.