ID: nht92-9.57

DATE: January 7, 1992

FROM: Thomas J. Magnan -- Sergeant, Traffic Safety Division, Metropolitan Police Department, City of St. Louis, Mo.

TO: Taylor Vinson -- Legal Counsel, NHTSA

TITLE: Re: "Hella" brand Position Indicator Lamp

ATTACHMT: Attached to letter dated 2/11/92 from Paul Jackson Rice to Thomas Magnan (A39; Std. 108)

TEXT:

I saw a demonstration of the new "Hella" brand Position Indicator Lamp at a safety show I attended in British Columbia, in September 1991.

I have since contacted a Hella distributor in St. Louis, Mo with questions on where this may be purchased and the price of the item. He informs me that Hella of Germany has told him that to sell or install this item on a vehicle in the United States is against the law, as it has not as yet been approved for sale or use in this country. I then contacted a Mr. Scott Toivanen at 1-604-687-7779 with the Canadian Distributor OBIRON ENTERPRISES INC. Mr. Toivanen informed me that he has attended meeting with representatives from this country, specifically NHTSA and DOT-OMC, and both agencies approved of this device, so long as the maximum vehicle width was not exceeded. I contacted Mr. Kevin Cavey at NHTSA, who was reportedly at one of these meetings and Mr. Cavey told me he didn't know what I was talking about, and suggested I write to you.

Please advise as to whether this item may be used on vehicles in the United States, providing the maximum vehicle width of 102.36 inches is not exceeded.

Enclosed please find related information on the product.

Attachments (Text and graphics omitted):

Brochure entitled IPS Corporation Introduces the Position Indicator Lamp. Indicates that the lamp is distributed in Alberta and British Columbia by Obiron Enterprises Inc.

Copy of a letter from Claus Bergmeier, President of International Product Specialities (IPS), announcing a new safety marker lamp for commercial vehicle application.

Copy of a report, dated 2/5/91, from the Canadian Standards Association, containing the results of examinations and tests of the IPS position indicator lamp. Demonstrates compliance with applicable SAE standards.

ID: nht92-9.58

DATE: January 7, 1992

FROM: Stephen C. Bartch -- Applications Engineer, Quigley Motor Company, Inc.

TO: Office of Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/18/92 from Paul Jackson Rice to Stephen C. Bartch (A39; Part 567; Std. 301)

TEXT:

We propose to convert the Ford E-series vans to our 4X4 drive system; however, the tank in the 1992 vans interferes with our transfer case placement.

After much consideration and examining other Ford tank arrangements on 4X4 vehicles, we came to the conclusion that to keep certification costs down and still show due-care in reference to FMVSS 301, we should either:

A. find a tank manufacturer that can build a tank with identical attachments as the OEM tank, or B. modify the OEM tank to eliminate the interference.

We found a tank supplier who can manufacture the tank to our specifications, so we can pursue both options.

The question that some of our customers are asking is about the legality of our fuel tank retrofit in regards to FMVSS 301. Could you summarize in writing our responsibilities regarding FMVSS 301 and state that we are not required by law to do crash testing on our vehicles?

Thank you for your cooperation and willingness to accommodate us.

ID: nht92-9.59

DATE: 01/06/92

FROM: Joseph B. Gordon -- Manager of Engineering, ESI BRAKE PARTS, DIVISION OF STANDARD MOTOR PRODUCTS, INC.

TO: Mr. Rich Van Iderstine -- U.S. Department of Transporation, NHTSA

COPYEE: Daniel Carboni, Sr. V.P. (Ignition and Brake Products) David Blasco -- (Product Test Lab)

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 2-18-93 FROM JOHN WOMACK TO JOSEPH B. GORDON (A40; STD. 108; VSA (a)(2)(A))

TEXT: EIS has been approached as to the possibility of our manufacturing a product which provides an intermittently blinking brake light function. Before we actually consider such a project however, we need to learn if there are any existing prohibitions or problems which would disqualify this device from being introduced to the marketplace.

Intended for use in passenger vehicles, the product under consideration is an addition to the existing rear brake light system which causes the brake lights to flash intermittently when pressure to the brake pedal is applied. While this mechanism would provide an added measure of visibility to alert traffic behind a braking vehicle, our concerns are whether such a device would be confused with hazard warning lights or if there are other problems/restrictions connected with its manufacture.

EIS would very much appreciate any advice or information NHTSA can provide us with on this proposed braking product at your earliest convenience.

ID: nht92-9.6

DATE: February 14, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: David Klopp -- Freedman Seating Company

TITLE: None

ATTACHMT: Attached to letter dated 1/30/92 from David Klopp to Mary Versailles (OCC 6926)

TEXT:

This responds to your fax of January 30, 1992 to Mary Versailles of my staff asking whether the anchorage strength test in Standard No. 210, Seat belt assembly anchorages, requires simultaneous testing of seat belt anchorages located on the seat frame of a seat having multiple seating positions.

Under the current requirements of S4.2.4 of Standard No. 210, only floor-mounted anchorages are subject to simultaneous testing. The requirement applicable to vehicles with seat-mounted safety belt anchorages, S4.2.4 of Standard No. 210, has been changed, effective September 1, 1992. For a vehicle manufactured on or after that date, seat-mounted anchorages will be tested simultaneously by loading all anchorages common to the same occupant seat.

I hope you find this information helpful. If you have any further questions please contact Mary Versailles at this address or by phone at (202) 366-2992.

ID: nht92-9.60

DATE: January 3, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Tony Llama -- President, Davenport Enterprises

TITLE: None

ATTACHMT: Attached to letter dated 12/13/91 from Tony Llama to Paul Jackson Rice (OCC 6784)

TEXT:

This responds to your letter of December 13, 1991, with respect to the permissibility of temporarily importing a Fiat from Brazil that is not in conformance with the Federal motor vehicle safety standards. The purpose of the importation is to design and build an air conditioning system for the car. Upon completion of this work, the Fiat will be exported.

You have enclosed a copy of my letter of August 2, 1990, granting permission for the importation of a van manufactured in the Soviet Union for which you had been asked to design an air conditioning system. In that letter, I informed you that it would be appropriate for you to enter the van pursuant to 49 CFR section 591.5(j), under the declaration that the vehicle is being imported solely for the purpose of research, investigations, and studies or demonstrations. Under the circumstances outlined in your letter, we believe that it would be appropriate for you to enter the Brazilian Fiat as well under section 591.5(j).

If you have any further questions, we shall be happy to answer them.

ID: nht92-9.61

DATE: 01/01/92 EST

FROM: B.J. Forney

TO: Diane K. Steed -- Traffic Sft. Adm.

TITLE: None

ATTACHMT: Attached to letter dated 5/19/92 from Paul J. Rice to B.J. Forney (A34; VSA 102)

TEXT:

I am seeking a written statement from your dept. as to the legality of on the road operation of such a system described in the enclosed brochure. (back page.)

In 1982 I spent $4,500 with Inv. Mkt in Pitts, PA. with only paper work to show for it.

If this system is not or would not be allowed on the roads, an attempt to recover my fee is anticipated.

This would help me in my future efforts to market this system with any trucking industry.

Return postage cost would be accepted.

Thank you for your opinions.

Attachment (letter)

March 27, 1990

Mr. B.J. Forney R 6, 61 Harrison, AZ 72601

Dear Mr. Forney:

Thank you for your letter dated March 21, 1990, relative to an Automotive Power Drive. Before submitting this matter to our appropriate management people for determination of their interest, I would like to propose the following:

(1) Any disclosure of information by you to representatives of Westinghouse is to be on a non-confidential basis and such information is received by Westinghouse with no obligation whatsoever.

(2) You will rely solely on your patent rights with respect to compensation for any information so disclosed.

If the foregoing understanding is acceptable to you, please so indicate by executing and returning the acceptance provided on the extra copy of this letter.

We appreciate your thinking of Westinghouse in connection with your invention.

Very truly yours,

L.M. Laffoon Mgr., Administrative Services Westinghouse Electric Corporation Law Department - Intellectual Property

Attachment (brochure)

Forney Air, NAT-2929 (Text and graphics omitted)

ID: nht92-9.62

DATE: 01/01/92 EST

FROM: Leonard Marks

TO: Office of the Chief Counsel -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9/15/92 from Paul Jackson Rice to Leonard Marks (A39)

TEXT:

I request of you any information you can supply me with pertaining to the safety laws and standards of seat belts.

I have developed a new adjustable attachment to seat belts which allows the user to lower the level so that it will no longer cut them in the neck and yet give them the safety of the belt. It will also give the persons that no longer use them because of the discomfort, to have the incentive to do so.

I would appreciate a response as early as possible as working models and dies are being manufactured.

I am available by phone if you have any question at (207) 934-5249. Thank you again for your immediate response.

ID: nht92-9.63

DATE: 01/01/92 EST

FROM: Scott D. Boone -- Van Conversions, Inc.

TO: Office of the Chief Counsel

TITLE: None

ATTACHMT: Attached to letter dated 9/8/92 from Paul Jackson Rice to Scott D. Boone (A40; Std. 208; Part 568)

TEXT:

We at Van Conversions convert from time to time Ford E-150's for day care centers. We usually do a 21 passenger capability and would like to have in writing all the State laws we need to comply with, from bolts used and materials preferred.

We won't touch anything until we hear from you. Thank you very much.

Usually Ford E-150's 21 passenger Step well Isle runner Tell me about seat belts 3 pt. Tell me about bolts used and grades.

ID: nht92-9.7

DATE: February 14, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Cliff Chuang -- President, Prospects Corporation

TITLE: None

ATTACHMT: Attached to letter dated 1/22/92 from Cliff Chuang to Dorothy Nakama (OCC 6893; Std. 118))

TEXT:

This responds to your request for an interpretation of Federal Motor Vehicle Safety Standard No. 118 Power Windows (49 CFR S571.118). As you noted in your letter, the agency has published a final rule amending Standard No. 118 in the April 16, 1991, edition of the Federal Register (56 FR 15290). You requested clarification of certain requirements in that final rule.

The agency has received several petitions for reconsideration of the final rule amending Standard No. 118. One such petition is from your company. The agency is currently reviewing the merits of each petition. The agency will issue a notice in the Federal Register granting and/or denying the petitions. In that notice, the agency will also address the concerns raised in your request for an interpretation of Standard No. 118. Please let us know if you have any questions about the issues raised in your letter after our response to the petitions for reconsideration has been published and you have had the opportunity to review it.

If you need more information on this subject, please feel free to contact Dorothy Nakama of my staff at this address, or by telephone at (202) 366-2992.

ID: nht92-9.8

DATE: February 14, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Jeff Ruff -- The Braun Corporation

TITLE: None

ATTACHMT: Attached to letter dated 10/30/91 from Jeff Ruff to Office of the Chief Counsel, NHTSA (OCC 6631)

TEXT:

This responds to your letter of October 30, 1991, regarding Standard No. 208, Occupant Crash Protection, and vehicles designed to be operated by persons with disabilities. Your letter indicates that you must remove "the support brace between the 'B' pillars and forward" when you alter a vehicle for a person who must transfer from a wheelchair to the driver's seat. You also indicate that the original manufacturer of the vehicle will not allow you to pass through certification for Standard No. 208 if these alterations are made.

The safety requirements for new light trucks and vans were upgraded as of September 1, 1991. Light trucks and vans manufactured on or after that date must be capable of providing occupant protection to belted front seat occupants when the vehicle is crash tested at 30 miles per hour (mph) into a concrete barrier. A vehicle that provides this crash protection will increase the safety of vehicle occupants.

As a result of this new requirement, this agency has recently received a number of phone calls and letters, from both van converters like your company and individuals, suggesting that the new light truck and van crash testing requirement will, in effect, prohibit van converters from modifying vehicles to accommodate the special needs of persons in wheelchairs. The agency also received a petition asking for an amendment to the light truck and van crash test requirement in Standard No. 208 "to eliminate requirements that inadvertently discriminate against individuals with disabilities including individuals who use wheelchairs."

On January 9, 1992, this agency granted that petition. You should understand that the granting of a petition for rulemaking signifies that the agency believes a further review of the issues raised in the petition appears to have merit, but it is not a determination that the light truck and van crash test requirement should be amended. Any determination to amend the crash test requirement would be made in the course of a rulemaking proceeding, in accordance with statutory criteria. By addressing the issue comprehensively, in response to this petition for rulemaking, instead of in a piecemeal fashion, in response to each of the individual requests, NHTSA will be able to ensure that the resulting requirement offers persons in wheelchairs the best possible safety protection.

However, we are aware that individuals seeking to purchase new vehicles modified for operation by persons with disabilities need more immediate relief than rulemaking can offer. To afford more immediate relief, this agency announced in a January 21, 1992 letter to Representative Porter Goss that NHTSA will not conduct any crash testing under Standard No. 208 of vehicles modified for operation by persons with disabilities while this

rulemaking is pending. This should allow your company to continue to produce such modified vehicles while this rulemaking is pending.

I hope this information is helpful. If you have any further questions or need some additional information, please contact Mary Versailles of my staff at this address or by telephone at (202) 366-2992.