ID: nht92-9.3

DATE: February 18, 1992

FROM: Wm. Richard Alexander -- Chief, Pupil Transportation, Maryland State Department of Education

TO: Mary Versailles -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/19/92 from Paul Jackson Rice to Wm. Richard Alexander (A39; Std. 222)

TEXT:

In our phone conversation of February 7, we discussed forward-facing wheelchairs on school buses (CFR 49 Part 571.222).

I am requesting that you verify in print our conversation that forward-facing wheelchairs on school buses do not need a crash barrier located forward of each wheelchair position. This would be based on the premise that each chair and child is restrained in some type of a belting system.

If you have any questions prior to responding, please do not hesitate to call me at (410) 333-2602.

ID: nht92-9.30

DATE: February 3, 1992

FROM: Kenneth R. Brownstein -- Senior Counsel, PACCAR Inc., Law Department

TO: Office of Chief Counsel, NHTSA

TITLE: Re: Request for Clarification of 571.120 - Standard 120

ATTACHMT: Attached to letter dated 3/23/92 from Paul Jackson Rice to Kenneth R. Brownstein (A39; Std. 120)

TEXT:

PACCAR Inc, a manufacturer of Kenworth and Peterbilt vehicles, hereby submits a request for clarification of S571.120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.

S5.1.3 of 571.120 states:

"In place of tires that meet the requirements of Standard No. 119, a truck, bus, or trailer may at the request of a purchaser be equipped at the place of manufacture of the vehicle with retreaded or used tires owned or leased by the purchaser, if the sum of the maximum load ratings meets the requirements of S5.1.2. Used tires employed under this provision must have been originally manufactured to comply with Standard No. 119, as evidenced by the DOT symbol."

The standard clearly allows purchasers of vehicles to supply the vehicle manufacturer with retread tires for installation on the new vehicle. The intent of the standard appears to be to allow the purchaser to choose whether or not the new vehicle has retread tires and to ensure they have knowledge of this fact. PACCAR manufactures a customized vehicle, allowing retail customers to specify particular components including tires for the vehicle. PACCAR believes that the intent of the standard would be met if a customer specifically orders retreads for his vehicle and the vehicle manufacturer supplied them rather than the purchaser.

It is requested that PACCAR be permitted to install, at the specific request of the buyer, retread tires. The tires installed would comply with Standard No. 119, as evidenced by the DOT symbol. By allowing PACCAR to buy the tires, the process would be more efficient and provide the truck owner an advantage in not having to make a separate purchase, eliminating duplicate paperwork. It would also eliminate extra shipping and handling of the tires.

Your response to this request is respectfully requested.

ID: nht92-9.31

DATE: February 3, 1992

FROM: Arthur J. Kuminski -- Design Engineer, Eberhard Manufacturing Company

TO: Paul Jackson Rice -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/30/92 from Paul J. Rice to Arthur J. Kuminski (A39; Std. 206)

TEXT:

Eberhard Manufacturing manufactures industrial and vehicular hardware. We are presently in the final stages of prototyping a custom lock system for Grumman Olson to be used on their "Route Star Walk-in Vans". Enclosed are a picture and some specifications on the Route Star to help explain how the door is used.

The reason for my letter is to request further interpretation from your organization on the testing standards for sliding doors on cargo vans. The following standards are the ones I have questions about:

Standard No. 206 S4.3 Sliding Doors - The track and slide combination system or other supporting means for each sliding door shall not separate when a total transverse load of 4,000 pounds is applied, with the door in the closed position.

S5.3 Sliding Doors - Compliance with S4.3 shall be demonstrated by applying an outward transverse load of 2,000 pounds to the load bearing members of the door (4,000 pounds total). The demonstration may be performed either in the vehicle or with the door retention components in a bench test fixture.

1. I will need specifications on how to perform this test on a test fixture using the striker assembly and the door latch only.

2. What load must the system withstand in the primary locked position to pass the test?

3. Is their a load requirement that the system must withstand in the secondary locked position to pass the test?

If you have any questions, please call me. Thank you for your help.

ID: nht92-9.32

DATE: February 2, 1992

FROM: A. Volmerange

TO: Mr. Harper -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/19/92 from Paul J. Rice to Anne Volmerange (A39; Std. 208; VSA 108(a)(2)(A))

TEXT:

My toyota dealer needs a written authorization from your office to install an old fashion three points belt on my 92 Tercel.

The two points belt which is on the car just don't fit me. I am five feet tall,and the shoulder belt ties either on my neck or on my breast. As these two body parts are too sensitive to take the pull of a restraining belt, I have to drive without it, in spite of the California Law.

Also, the holder of the shoulder belt can't be reached from my driving position since it is way behind the seat. This create a safety hazard since I would not be able to untie it in case of an emergency. One of my previous car burst in flames, and one of my hand opened the door, while the other untied the three points safety belt which I was wearing that day.

As a Registered Nurse, I am aware of the chest, neck and head injuries, and can't figure out why you have stopped using the three points belt. It was fitting all sizes drivers and all seat positions. Car dealers should be allowed to install them as many new cars owners hate the new system and don't use theirs belts.

ID: nht92-9.33

DATE: January 31, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: S. Suzuki -- Managing Director, Suzusho Trading Co.

TITLE: Your ref: ST-9015/91

ATTACHMT: Attached to letter dated 10/16/91 from S. Suzuki to Director, Office of Public and Consumer Affairs, NHTSA (OCC 6611)

TEXT:

This responds to your letter of October 16, 1991, to the Director, Office of Public and Consumer Affairs, with reference to the "Safety Shot" lighting device that you have developed. You have enclosed photographs illustrating three types of this device in operation.

In brief, the device consists of a center red highmounted stop lamp, immediately flanked by amber lamps that serve as supplementary turn signal/hazard warning signal lamps. Although the photos are not entirely clear, the device appears to consist of segmented compartments in a common housing, with thicker dividers separating the signal and stop functions. Type I incorporates an L.E.D. and is mounted at the top of the rear window. Type II also incorporates an L.E.D. and is mounted at the bottom of the window. Type III is located at the top of the rear window and uses conventional bulbs for its light source. You have been referred to us by Chrysler Corporation. We assume that you approached Chrysler with a view towards having your device accepted as original motor vehicle equipment. You have asked for our views on whether it is possible to use this device in the U.S. market.

In the United States, the applicable Federal motor vehicle safety standard for rear lighting is Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. Section S5.4 of Standard No. 108 does not allow a center high-mounted stop lamp to be physically combined with any other lamp or reflective device. Because Safety Shot appears to have a common housing for signalling and stopping functions, the lamps are "combined" within the meaning of the prohibition.

This means that the Safety Shot may not be used as original equipment on motor vehicles, and it may not be offered as a replacement for original equipment center highmounted stop lamps (required on each passenger car manufactured on or after September 1,1985).

If you wish to sell the Safety Shot as an accessory in the aftermarket, for passenger cars manufactured before September 1, 1985, different considerations apply. Installation of the Safety Shot by a manufacturer, distributor, dealer, or motor vehicle repair business is not permitted if it renders inoperative, in whole or in part, the function of any other rear lighting device.

The question, therefore, is whether the effectiveness of the function of any other rear lighting device is compromised by the Safety Shot to the extent that the other device's function is rendered, at the minimum, partially inoperative. We note that original equipment amber signal

lamps are not prohibited from flashing when the stop lamps are operating. It would not appear that the addition of the Safety Shot to a passenger car manufactured before September 1, 1985, would compromise the signals from the original turn signal and stop lamps in a manner to render them, at least, partially inoperative. However, the Safety Shot is subject to regulation by the individual States of the United States in which it is sold or used. We are unable to advise you on State laws, and suggest that you write for an opinion to American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203.

Motor vehicles are also required to be manufactured to conform to Standard No. 111, Rearview mirrors. Under this standard, if installation of the Safety Shot prevents the vehicle from meeting the rearview mirror field of view requirements specified, the manufacturer, distributor, dealer, or motor vehicle repair business installing the Safety Shot must install a rear view mirror on the passenger side of the vehicle (as a practical matter, most vehicles in the U.S. are manufactured with this additional mirror).

ID: nht92-9.34

DATE: January 30, 1992

FROM: David Klopp -- Freedman Seating Company

TO: Mary Versailles -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/14/92 from Paul Jackson Rice to David Klopp (A39; Std. 210)

TEXT:

Freedman Seating manufactures seating systems which are used in a variety of vehicles including shuttle buses, tour buses, etc. Examples of our seats are attached. The frames are mounted to the floor and, in many cases, to the wall of the vehicle also.

We would like an interpretation of FMVSS 210 regarding seats having multiple seating positions and with their seat belt anchorages located on the seat frame. Does the strength test in FMVSS 210 require simultaneous testing of all seat belt anchorages for each seat?

Please give me a call if you require additional information.

ID: nht92-9.35

DATE: January 29, 1992

FROM: J. Yoshimoto -- Manager, Technical Administration Dept., Koito Manufacturing Co., Ltd.

TO: James G. White -- Surface Group, Transport Canada

TITLE: Subject: CMVSS 108 "Lighting Equipment"; Reference: Canada Gazette Part II, Vol. 125, No. 26 dated December 18, 1991

ATTACHMT: Attached to letter dated 3/5/92 from Paul Jackson Rice to James G. White (A39; Std. 108)

TEXT:

Thank you for your kind consideration which you have always extended to us through SAE meeting.

We have studied the amended CMVSS 108 "Lighting Equipment" by Canada Gazette Part II Vol. 125, No. 26 dated December 18, 1991. And we would ask for your kind interpretation about "O" Mark on vertical/horizontal aim indicator of integral headlamp aiming device, specified in paragraph 108(28)(b)(ii)(A) and 108(28)(c)(ii)(A).

108(28)(b)(ii) a scale that has (A) a "O" mark that represents the vertical aim of zero degrees, ----------. 108(28)(c)(ii) a scale that has (A) a "O" mark that (I) presents the horizontal aim of zero-degrees ----------.

For these descriptions, it is unclear for us whether a mark of figure "O" be literally required for indicating zero degrees on vertical/horizontal aim indicator, or not.

In FMVSS 108 (U.S.), vertical/horizontal aim indicator of integral headlamp aiming device is required to have a zero mark, which does not necessarily mean a mark of figure "O", but may be just a reference mark. (Please refer to the attached copy of FMVSS 108 S7.7.5.2(a)(1) and (2).

Size of indicator is so small, that there is no space to add a figure "O" on it. Moreover, from the viewpoint of harmonization to FMVSS 108, CMVSS 108 should not require a figure "O" on the indicator, we think.

We would greatly appreciate if you would give us your kind interpretation to the above matter.

Thanking you for your kind and prompt reply in anticipation, we remain, With best regards.

ID: nht92-9.36

DATE: January 28, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA; Signature by Stephen P. Wood

TO: William R. Willen, Esq. -- Managing Counsel, Product Legal Group, American Honda Motor Co., Inc.

TITLE: None

ATTACHMT: Attached to letter dated 12/16/91 from William R. Willen to Paul Jackson Rice (OCC 6833)

TEXT:

This responds to Honda's request for an interpretation of Federal Motor Vehicle Safety Standard No. 123, Motorcycle controls and displays. You stated that Honda is developing a braking system for motorcycles that would offer full proportioning front and rear when utilizing either the front hand control, or the rear control. You asked whether such a system would be permitted by the standard, particularly in light of section S5.2.1. As discussed below, such a braking system would be permissible under Standard No. 123.

By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles and equipment meet applicable requirements. The following represents our opinion based on the facts set forth in your letter.

S5.2.1, Control location and operation, includes the following language:

If a motorcycle is equipped with self-proportioning or antilock braking devices utilizing a single control for front and rear brakes, the control shall be located and operable in the same manner as a rear brake control.

Table 1 of Standard No. 123 provides that a rear wheel brake control must be a right foot control and must depress to engage. (Table 1 also includes an additional option that is not necessary to address in this letter.)

Since Honda's motorcycle would be equipped with a self-proportioning device utilizing a single control for front and rear brakes, it would be subject to this requirement. If Honda's "rear foot control" is one that is operated by the right foot and must be depressed to be engaged, that control would satisfy S5.2.1.

It is our interpretation that so long as one control meets the specified requirements for location and operation, additional controls serving the same purpose may be provided voluntarily by the manufacturer and need not meet those requirements. I note that this view is similar to a position taken in an April 26, 1983 interpretation letter to an addressee whose identity has been withheld for reasons of confidentiality. In that letter, the agency stated, in the context of discussing S5.2.1, that

"(u)se of ... a self-proportioning device does not preclude additional brake actuation devices." I am, for your information, enclosing a copy of that letter. In the situation at issue, we would consider the front hand control on Honda's design to be an "additional brake actuation device," and therefore, not precluded by Standard No. 123.

I hope this information is helpful to you. If you have any further questions or need additional information, please feel free to contact Dorothy Nakama of my staff at (202) 366-2992.

ID: nht92-9.37

DATE: January 28, 1992

FROM: Carl J. Clement -- Clement Associates

TO: Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/30/92 from Paul J. Rice to Carl J. Clement (A39; Std. 302; Std. 201)

TEXT:

I am in the process of inventing an automotive sun-visor which has the promise of improving upon the safety of currently used sun-visors. Within a week or so I shall have completed a mechanical protype which will serve as a means of testing electronics and optics. Enclosed is a patent disclosure which explains the device in greater detail.

I have been advised that, before proceeding further, I should research Federal and State agencies which have to do with regulations concerning automobiles, particularly automobile interiors. For example, are there regulations which would preclude the installation of an automatically-moving 3" high X 6" wide visor between the driver's eyes and the windshield?

I should appreciate your advice and a copy of any regulations with which I must comply, or which might be changed should the invention be viewed favorably by your or other government agencies.

ID: nht92-9.38

DATE: January 24, 1992

FROM: Larry J. French -- President and CEO, Magnascreen

TO: Office of Chief Counsel, NHTSA

TITLE: Reference: 49 CFR, Part 571, Docket No. 91-11, Notice 2, RIN2127-AD81, Federal Motor Vehicle Safety Standards; Rearview Mirrors - Reflectance

ATTACHMT: Attached to letter dated 3/26/92 from Paul J. Rice to Larry J. French (A39; Std. 111)

TEXT:

Magnascreen is presently developing electronically controlled dimmable (day/night) rearview mirror products for motor vehicles.

Magnascreen has reviewed the revised Code of Federal Regulations, Title 49, 571.111, standard number 111, for motor vehicle rearview mirror requirements referenced above. Upon review, we are requesting that the NHTSA comment on the validity of Magnascreen's interpretation which follows:

"When a multiple reflectance level mirror is not powered by the vehicle power source, the reflectance of the mirror can be returned to a minimum of 35% reflectance (either automatically or by driver operated controls) USING AN ALTERNATE POWER SOURCE." (A power source other than the one intended to (illegible) the mirror.)

This interpretation allows multiple reflectance mirror designs to use an alternate power source to achieve the specified failsafe operation called out in CFR 49, 579.111, para. S11, Rearview Mirrors.

Your timely response will be appreciated, as this interpretation impacts Magnascreen's mirror product designs.