ID: nht75-2.47

DATE: 08/22/75

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: F. A. McNiel

TITLE: FMVSS INTERPRETATION

TEXT: On May 12, 1975, you petitioned the National Highway Traffic Safety Administration for rulemaking to amend Standard No. 108 to provide "A means that will hasten the illumination of a vehicles conventional stop warning lamps at any time that a 'panic' or any other exceptionally sudden stop is made, but wherein the said means will not affect the normal functioning of the vehicles lighting system at any other time."

We have given thoughtful consideration to your petition. It appears to us that the system you prefer would indicate only that the accelerator pedal had been released suddenly, and not that a sudden or "panic" stop was being made. In our view, a sudden release of the accelerator does not necessarily mean that a panic stop is in progress. Conversely, all sudden stops are not necessarily accompanied by a sudden release of the accelerator. In short, the presumed benefit of the system appears speculative, and no data have been submitted demonstrating that the signaling system would enhance highway safety. For these reasons your petition must be denied.

Standard No. 108 would not preclude the sale of your deceleration warning device in the aftermarket, subject to regulation by the individual States.

We appreciate your interest in motor vehicle safety.

Sincerely,

ATTACH.

Robert L. Carter Associate Administrator -- National Highway Traffic Safety Administration, Motor Vehicle Programs

Dear Mr. Carter:

The May 1, 1974 issue of 'Status Report' published by the Insurance Institute for Highway Safety contained an article stating that your agency had proposed amending Motor Vehicle Safety Standard No. 108 to allow the use of (1) a vertically mounted rear facing red-yellow-green lamp system that signals braking, no pedal application, or acceleration. -- or (2) Pulsating rear lamps that indicate when the vehicle is decelerating rapidly. - The proposal would also allow for the use of a combination of both systems.

Apparently both of these systems require auxiliary lamps in addition to the vehicles existing stop-light signal lamps. I am petitioning that Motor Vehicle Safety Standard No. 108 be further amended to include basically the following - "A means that will hasten the illumination of a vehicles conventional stop warning lamps at any time that a 'panic' or any other exceptionally sudden stop is made, but wherein the said means will not affect the normal functioning of the vehicles lighting system at any other time".

It has long been a universally recognized and accepted fact that the flash of a lead vehicles stop-lights signal a following driver that the lead vehicles momentum is being retarded, possibly to the extent of a complete stop. As everyone knows there has been no basic improvement in a vehicles stop warning system since the adoption of the brake operated stop-light switch. - You could obtain an 'add-on' stop-light kit for a Model-T more than fifty years ago that would function just as effectively as the conventional stop-light system that is now in use on all modern automobiles, - either one will illuminate a stop lamp the instant that the vehicles brakes are applied.

The warning that is produced by such conventional stop-light systems is adequate under the proceedure that is customarily used by most drivers in making a normal stop, but is woefully inadequate when a 'panic' or other unexpected sudden stop is made. The critical factor in this instance is the loss of time that occurs between the driver of a closely following vehicle seeing the flash of a lead vehicles stop-lights (at which time the lead vehicles brakes are already on), and the time that the following vehicles brakes are actually applied. This time loss is composed of two very distinct and separate parts, the first part being 'driver reaction' and the second part being 'warning lag'.

Driver reaction accounts for the time loss occuring between a driver perceiving the flash of a leading vehicles stop-lights and the complete release of the following vehicles accelerator pedal. This time interval varies in accord with a specific drivers mental alertness and physical agility. It is estimated that this time loss is at least one quarter of one second for an exceedingly alert driver, and considerably more for one that is less alert. There appears to be no discernable way by which this reaction time loss can be prevented.

Warning lag is the split second that is required for a driver to shift his (or her) foot from the accelerator pedal to the brake pedal and apply pressure to energize the brake operated stop-light switch, and illuminate the vehicles stop-lights. This time interval also varies to some extent according to the agility of a particular driver. -- Extensive tests have been conducted, using electronic detonating equipment to gauge the results. These tests have established the fact that this time loss is also approximately one quarter of one second for agile drivers. - This time loss can positively be totally eliminated.

It is an accepted fact that the majority of rear-end collisions occur when one driver in a congested flow of traffic unexpectedly jams on the vehicles brakes without prior warning, to make a 'panic' or other very sudden stop, and the driver of a closely following vehicle does not have sufficient braking time to stop before ramming the vehicle ahead. - This is particularily true of 'chain-reaction' pileups where the 'warning lag' is cumulative from car to car.

Enclosed is an outline for a hypothetical traffic situation of a type that is typical of todays congested traffic conditions. The accompanying chart that is based on the conditions as set forth by the hypothetical situation illustrates precisely the results that would be obtained by the elimination of 'warning lag'. - I am also enclosing sketches and an explanation of a particular means that I have perfected, that proves beyond the shadow of a doubt that the possibility of eliminating 'warning lag' as emphasized by chart is a reality - not a 'pipe dream'.

I was informed by the National Highway Safety Bureau more than five years ago:- "The National Highway Safety Bureau is cognizant of the fact that rear end collisions account for 10 per cent of the fatal motor vehicle accidents and 49 per cent of all motor vehicle accidents". - In line with these statistics I pose the following analysis in accordance with the submitted data.

Assume that one half of all drivers that crash into a vehicle ahead see the flash of the lead vehicles stop-lights, and are on their own vehicles brakes at the time of the crash. - If the lead vehicles were all equipped with a means for the elimination of 'warning lag', this would mean that one eight of the drivers that are involved in all motor vehicle accidents would have been applying their brakes for an additional ten feet (at 30 M.P.H.) before becoming involved in an accident that would cause damage to two cars. - If this ten feet of braking did not prevent an accident occurring, it would in every instance greatly reduce the force of impact, and the resultant damages to both of the vehicles that were involved. - Thus, if the safety feature that I am advocating was standard equipment on all motor vehicles, it would greatly reduce the damages sustained by one fourth of all motor vehicles that are involved in motor vehicle accidents of any kind! - Stupendous? - but true.

If this reduced the rear-end collision fatality toll by one tenth, it would amount to the saving of one life out of every one hundred of the current traffic fatalities. - The reduction in personal injuries resulting from such accidents would be very considerable, and the monetary saving by the public would be collosal. - Also, it should permit the Insurance Companies to make a very substantial reduction in the cost of premiums that are charged the public for motor vehicle insurance.

Any vehicle that is damaged in a traffic accident is not any more valuable after it has been repaired than it was prior to the accident occurring - consequently, all expenditures that are required for both the labor and materials used for repair or replacement of vehicles that are damaged in accidents that could have been prevented are wholly wasted. - If these really enormous outlays were available for constructive purposes, it would help to bolster our sagging national economy.

In relation to the enclosed data concerning the particular means I have perfected, sketch No. 1 shows the general assembly of switch unit. Sketch No. 2 shows the unit mounted behind the instrument panel in passenger compartment of vehicle, and sketch No. 3 shows unit mounted under hood in the engine compartment of the vehicle. - Both methods of mounting as shown have been very thoroughly tested, and each has been found to function perfectly. The accompanying specifications are drawn around sketches No. 1 and No. 2. Sketch No. 3 shows some alternations in the assembly of the unit, but functioning is identical to that of sketch No. 2.

If your engineers will thoroughly check all of the submitted data they will find it to be totally correct. - Also, careful analyzation of this data will reveal that factory installation of this type of safety equipment would cost no more than does the installation of conventional turn signals.

In view of the unquestionable reduction in damages to both the vehicles and their occupants that would accrue from the use of safety equipment such as I am advocating, I request that your organization give due consideration to amending Motor Vehicle Safety Standard No. 108 to include the use of such safety equipment for improving the performance of a motor vehicles existing stop warning lamps.

In the meantime, will you please inform me if the use of safety equipment such as is described by the enclosed data is permissible under the existing Motor Vehicle Safety Standard No. 108.

Yours very truly,

Fred A. McNiel

ID: nht75-2.48

DATE: 07/17/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA Z. VINSON FOR RICHARD B. DYSON -- NHTSA

TO: D. R. Bernard, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 28, 1975, providing further information for our determination whether certain "safety lights" would violate the National Traffic and Motor Vehicle Safety Act of 1966.

There is no Federal prohibition against sale of this accessory in the aftermarket. It would, however, be subject to regulation by the states. For the following reasons, it could not be used as original equipment. Standard No. 108 requires a minimum spacing of 4 inches (edge to edge) between the stop lamps and the rear turn signal lamps and a minimum spacing of 9 inches (centerline to centerline) between the turn signals. The purpose of this spacing is to provide a distinctive indication of the turning direction. A flashing stop lamp located in close proximity to the steady-burning stop lamp required by Standard No. 108 would, in our opinion, impair the effectiveness of the rear turn signal within the meaning of S4.1.3, during a combined braking and turning operation. Such a lamp would also be prohibited by S4.6(b) which, in effect, requires all original equipment stop lamps to be steady burning.

Yours truly,

ATTACH.

BERNARD & BERNARD -- ATTORNEYS AT LAW

May 28, 1975

Richard B. Dyson -- Assistant Chief Counsel, U.S. Department of Transportation, National Highway Traffic Safety Administration

Re: N40-30 (ZTV)

Dear Mr. Dyson:

Pursuant to your letter, we are providing the following supplemental information in order for you to reach a decision in regard to the proposed safety lights.

1. The flashing lights will be no brighter than the standard brake light, but will be mounted in close proximity to the said brake lights.

2. The flashing lights will be a different color from the turn signals and will not interfere with the operation nor be confused with the turn signals.

3. The flashing lights will be the same color normally as the brake lights and will have a frequency of flashes approximately twice the speed of the signal light for turns.

It is hoped that this information will be satisfactory to you, and your conclusion as soon as possible would be appreciated.

Yours truly,

D. R. Bernard

ID: nht75-2.49

DATE: 09/05/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Superindendent of Public Instruction, State Of Washington

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 15, 1975, to Mr. J. E. Leysath of this agency asking whether the State of Washington's proposed school bus light warning system conflicts with S4.1.4(b)(ii) of Federal Motor Vehicle Safety Standard No. 108.

That section requires an eight lamp signal system to be wired "so that the amber signal lamps are activated only by manual or foot operation, and if activated, are automatically deactivated and red signal lamps automatically activated when the bus entrance door is opened." Under the system Washington proposes, when a school bus stops, a "stop paddle sign" is extended by the operator, activating "a switching system which will terminate the yellow flashing lights and start the red flashing lights," before the door is opened.

Under the system you describe, the termination of the yellow lamps and activation of the red ones is dependent upon the operator extending the stop paddle sign. Should the operator forget to extend the sign, it does not appear that the system required by S4.1.4 would operate automatically when the door is opened. We therefore conclude that in order to meet S4.1.4 your school buses must be equipped with an override switch that would deactivate the amber lamps and activate the red ones when the door is opened, in the event that the stop paddle sign has not been extended.

Sincerely,

ATTACH.

July 15, 1975

J. E. Leyseth -- Motor Vehicle Programs, NHTSA N41-31, Department of Transportation

Dear Mr. Leyseth:

The Transportation, Traffic and Safety Division of the Office of Superintendent of Public Instruction, State of Washington, has a problem concerning the use of an eight light warning system on school buses that requires some help or an interpretation from you. We had thought our problem was connected with Standard 17, but after contacting Dave Soule we learned from him that we need to contact you instead. Mr. Soule did indicate that our proposed system is not in conflict with Standard 17, but would be in conflict with Standard 108, S4.1.4 without an exception from you.

The State of Washington has for many years required their school buses to be equipped with a four light (red) warning system for use in loading and unloading school bus passengers. Motorists are required by law to stop and hold until the students are loaded or unloaded and the warning system is deactivated. In conjunction with the light system, the State has also required for many years the use of a "stop paddle sign" on the side of the bus. The red light warning system is activated and deactivated with the use of the stop paddle sign.

The Office of the Superintendent of Public Instruction is currently engaged in activities to have the Washington State Legislature revise existing laws to permit the use of the eight light system. The proposal calls for the use procedure to be as follows: at a predetermined time or distance the driver will activate the yellow warning lights with a manual hand or foot switch. When the bus has stopped the driver will extend the stop paddle sign, which also has two flashing red lights mounted to it. The stop paddle sign, when extended, will activate a switching system which will terminate the yellow flashing lights and start the red flashing lights. When the stop paddle sign is retracted all flashing lights in the warning system are deactivated and the system is ready for the next cycle.

Two additional functions would be required. There must be a switch available to the driver to cancel the yellow warning lights once they have been started in the event that the paddle sign need not be used. The second requirement would be that the red flashing lights must activate when the paddle sign is extended, regardless of whether or not the yellow flashing lights are used.

This proposal conflicts with Standard 108, S4.1.4., (ii), which states that " . . . . the red signal lamps automatically activate when the bus entrance door is opened."

This State has not used the entrance door function in the warning light system for two reasons. Most importantly we wanted the driver to be able to engage the warning and traffic control system, make sure that traffic will indeed stop, before opening the door for students to load or unload. This provides a greater element of safety for the students. The loading cycle is also involved because we try to train students waiting for a bus on the opposite side of a street to hold and not cross the street or highway until the door is opened. This provides the driver with a signaling device to indicate to the students when it is safe to cross, and for them not to begin crossing when the paddle sign goes out or the red flashing lights come on.

The second reason is that many buses in the State of Washington are equipped with air powered entrance doors. Manual doors could possibly allow the driver to accomplish the above, but units with air doors could not accomplish the above procedure.

For the reasons stated this Office is hopeful that our proposed system is substantially in compliance with the spirit of Standard 108, and that an exception or variance could be granted to the State of Washington so that it may implement a system which will allow the stop paddle sign to activate the red flashing warning lights in the eight light system.

My office will be anxious to hear from you or to provide any further information that may be helpful to you on this request.

Thank you for your interest and consideration.

Sincerely, Superintendent of Public Instruction;

Jerry Toner, Consultant, Transportation, Traffic & Safety

ID: nht75-2.5

DATE: 11/25/75

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

TO: E. H. Wallace - Tire Division, OCA

TITLE: FMVSS INTERPRETATION

TEXT: Demonstration of Prototype Tires That are Not Certified as Complying with FMVSS No. 109

This is in response to your inquiry concerning the circumstances under which the demonstration of prototype tires would be permitted. I understand that representatives of Firestone Tire & Rubber Co. are visiting the NHTSA to discuss a newly designed passenger car spare tire which is not certified as complying with Standard No. 109. They wish to mount, on cars which have been driven to the DOT headquarters building on complying tires, samples of the spare tire and then to demonstrate the tire's performance on the local streets.

This demonstration would violate Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, because use of such tires on the public roads would constitute an introduction in interstate commerce of an item of motor vehicle equipment which did not conform with an applicable motor vehicle safety standard. The alternative which you have suggested, mounting and demonstration of the tires on a runway at Bolling Air Force Base or other place out of the public traffic stream, is not prohibited by the Act or by our regulations.

ID: nht75-2.6

DATE: 09/16/75

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

TO: Kleber Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 3, 1975, asking whether it is permissible to import into this country a tire designed exclusively for racing purposes.

Tires designed to be used exclusively on racing vehicles, i.e., vehicles other than "motor vehicles" within the meaning of the National Traffic and Motor Vehicle Safety Act, are not regulated by the Federal motor vehicle safety standards, and may be imported. The labeling that you propose to use appears to be appropriate to warn users of their intended purpose. Manufacturers of such equipment should take all reasonable steps to ensure that their products are not misused.

YOURS TRULY,

June 3, 1975

OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Attention : Marc Schwimmer

First, let me briefly describe KLEBER CORP. KLEBER CORP. is a wholly owned subsidiary of KLEBER-COLOMBES of Paris, France. We are the second largest tire manufacturer in France after MICHELIN. All our tires are of radial concept. Since the beginning of this year, we are developing a distribution network in the U.S.A. Naturally, our passenger tires conform with Federal Standard 109.

In Europe, KLEBER manufactures tires that are designed for small formula cars (i.e.: Formula Ford). These tires are to be used exclusively on racing vehicles and not on regular automobiles. They do not bear the D.O.T. engravings.

We would like to import these tires in the U.S.A. and find that our sole competitor would be a GOODYEAR tire called "G-19". The "G-19" has no D.O.T. markings but on both sidewalls the caption "FOR RACING PURPOSES ONLY - NOT FOR HIGHWAY USE" appears in 1/4 inch letters.

We would like to know if it is legal to import and sell our tires (similar to the G-19) in this country, if, like GOODYEAR, we indicate "FOR RACING PURPOSES ONLY - NOT FOR HIGHWAY USE" on both sidewalls. As additional warning, we plan to print the same text on all invoices and literature related to these type tires.

On this subject, I contacted Mr. Diehl of the D.O.T. who feels that there should be no problem but suggested we check with you.

I am at your entire disposal for any further information you may need and remain,

KLEBER CORP.

Guy A. Catherine

General Sales Manager

ID: nht75-2.7

DATE: 11/03/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Walt Robbins, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 5, 1975, enclosing a copy of your patent for a tire described as a "Radial, Bias Ply Tire" and requesting an interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires -- Passenger Cars. The tire would be constructed with three full body plies: two bias plies (angle 35 degrees) and one radial ply (angle 90 degrees).

S4.3(g) of the standard requires permanent molding of the word "radial" into or onto both sidewalls if the tire is a radial ply tire and, by implication, prohibits the use of the word "radial" if the tire is not a radial ply tire. In S3., "radial ply tire" is defined as:

a pneumatic tire in which the ply cords which extend to the beads are laid at substantially 90 degrees to the centerline of the tread.

The tire you have described is not within the scope of this definition because it includes ply cords extending to the beads which are not laid at substantially 90 degrees to the centerline of the tread. Therefore, the word "radial" must not appear on either sidewall.

SINCERELY,

Walt Robbins Incorporated

June 5, 1975

Mark Schwimmer National Highway Safety Administration Office of Chief Counsel

Enclosed is a copy of our patent #3,672,423. I would appreciate it if you would review this and notify me as to what the labeling requirements would be for the tire construction as shown in this patent, with reference to paragraph S4.3, subparagraph h, of MVSS100. As I interpret your labeling requirements, the radial designation would be adequate as this is a full radial ply. In addition to the radial ply, we have two bias plies, so my question to you is should this be designated radial or radial/bias.

I would appreciate an answer as soon as possible inasmuch as we have completed DOT testing and are ready for production. Your cooperation in this matter will be most appreciated.

VENTURE TIRE CORP.

Walter C. Robbins, Jr. President

United States Patent

Duduk

[15] 3,672,423

[45] June 27, 1972

[54] RADIAL, BIAS PLY TIRE

[72] Inventor: Alexander Duduk, 2300 S 24th Road Apt. #731, Arlington, Va 22206

[22] Filed: April 7, 1970

[21] Appl. No.: 26,411

Patent Omitted.

ID: nht75-2.8

DATE: 09/19/75

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

TO: Ben Perchik

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 29, 1975, concerning tire identification markings, received by this agency on August 29, 1975.

I have attached two diagrams that illustrate the meaning of the tire code markings on new and retreaded tires. Immediately following "DOT" is a two- or three-letter code (marked in red on the diagrams) that indicates the manufacturer or retreader of the tire. I have also attached a list of the tire manufacturers and retreaders using each code. Following the manufacturer's code are two numbers representing the tire size (marked in blue on the diagrams). Next, some tires will have three letters or numbers which represent an optional tire type code mainly of use to the manufacturer (marked in yellow on the diagrams). The last three numbers represent the date of manufacture (marked in green on the diagrams).

I hope this information proves useful to you.

ID: nht75-2.9

DATE: 11/19/75

FROM: AUTHOR UNAVAILABLE; William T. Coleman, Jr.; NHTSA

TO: Hon. J. L. Whitten - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of October 3, 1975, for Mr. Charles Russell of WJLJ, regarding tire failures on ambulances in Tupelo, Mississippi.

Pursuant to the National Traffic and Motor Vehicle Safety Act of 1966, the Department's National Highway Traffic Safety Administration (NHTSA) has issued Federal Motor Vehicle Safety Standard No. 109, 49 CFR 571.109, which specifies performance and labeling requirements for new tires for use on passenger cars. Among the labeling requirements is that such tires must have their load ratings molded into or onto both sidewalls. Standard No. 119, 49 CFR 571.119, establishes similar requirements for new tires for use on trucks, buses, trailers, motorcycles, and multipurpose passenger vehicles (MPV's). The choice of standard applicable to a given tire depends on that tire's primary intended use. These standards apply to tires, and not to vehicles.

To ensure that new vehicles are equipped with proper tires, the NHTSA has also issued Standard No. 110 for passenger cars and a proposed new Standard No. 120 that would apply to vehicles other than passenger cars. Briefly, Standard No. 110 requires each new passenger car to be equipped with tires which meet Standard No. 109 and which are of sufficient load carrying capacity, as evidenced by the load ratings found on the sidewalls. As proposed, Standard No. 120 would require MPV's (including ambulances) to be equipped with tires which meet either Standard No. 109 or No. 119, and which are of sufficient load carrying capacity. In the case of Standard 119 tires, sufficiency of load carrying capacity would be calculated directly from the tires' load ratings. In the case of Standard 109 (passenger car) tires mounted on an MPV, sufficiency would be determined by dividing the tire load ratings by a 110 percent correction factor before comparing these ratings with the vehicle's weight ratings. The use of passenger car tires on new ambulances would thus not be prohibited by the new standard, provided this load rating correction factor is applied. This provision would recognize an established practice which has not been found to preserve a safety hazard. Passenger car tires generally provide a softer, more comfortable ride than truck tires, because the latter operate at higher inflation pressures, and thus may even be more desirable on ambulances, provided they are of adequate load carrying capacity. The NHTSA expects to issue Standard No. 120 in the near future.

For your convenience, I am enclosing copies of Standards Nos. 109, 110, 119, and the proposed Standard No. 120.

ID: nht75-3.1

DATE: 09/04/75

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

TO: Yamaha International Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 5, 1975, asking whether a prototype "stiff rubber supported turn signal" would comply with S4.3.1 of Motor Vehicle Safety Standard No. 108.

S4.3.1 requires lighting equipment to "be securely mounted on a rigid part of the vehicle." Your proposed turn signal lamp is mounted at the end of a stiff rubber bracket which is attached to the vehicle. The bracket must be considered part of the vehicle. Obviously, even with a metal mounting there will be some vibration transmitted from the motorcycle to the lamp when the engine is running. We would consider the prototype mounting to be sufficiently "rigid" to conform to the standard if the rubber mount is stiff enough so that there is little or no amplification of vibration when the engine is running.

Yours truly,

ATTACH.

August 5, 1975

Office of the Chief Counsel National Highway Traffic Safety Administration Washington, D.C.

Dear Sir:

We are considering using a stiff rubber supported turn signal on some of our future model motorcycles.

We are not sure, however, if this device complies with the requirement of S4.3.1 of FMVSS 108, which states each lamp must be mounted on a "rigid part of the vehicle".

We would like to request an interpretation of FMVSS 108 to determine if this stiff rubber supported turn signal complies with the requirement for mounting of the lamp on a rigid part of the vehicle, as specified in S4.3.1.

We are sending, under separate cover, a sample of the device in question.

If you require any additional information or materials please contact me.

Sincerely,

Russ Jura -- Legislative Analyst, Engineering Division YAMAHA INTERNATIONAL CORPORATION

ID: nht75-3.10

DATE: 06/02/75

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Tiger Tanks; Division of Faull Enterprises, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 28, 1975, concerning the manufacture and installation of replacement tanks for Dodge, Ford, and Chevrolet vans.

The National Highway Traffic Safety Administration has promulgated no motor vehicle safety standard relating to replacement fuel tanks. There is, however, a safety standard which imposes performance requirements upon motor vehicles with regard to their fuel systems (Standard No. 301, Fuel System Integrity). Thus, if installation of your replacement tank is accomplished prior to the first purchase of the vehicle for purposes other than resale causing the vehicle's fuel system not to be in compliance with the applicable safety standard, the person installing the tank or offering the vehicle for sale would be in violation of @ 108(a)(1) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563). That would make the installer or seller subject to civil penalties of up to $ 1,000 for each violation.

Recent amendments to the Traffic Safety Act (Pub. L. 93-492) prohibit any manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable motor vehicle safety standard (@ 108(a)(2)(A)). Therefore, even if installation of your replacement tank occurred after the first purchase of the vehicle, the vehicle's compliance with the fuel system integrity standard would still be mandatory where one of the above named persons performed the installation. If the replacement tank caused the fuel system to no longer comply with the safety standard, the installer would have rendered inoperative a system installed in compliance with Standard 301.

The Traffic Safety Act authorizes the Secretary of Transportation to make determinations as to whether items of motor vehicle equipment contain defects which relate to motor vehicle safety. If he finds that a safety-related defect exists, he may compel the manufacturer to remedy the defect and notify purchasers of the hazard. Therefore, even though replacement fuel tanks are not the subject of a standard, they still must be designed for safety.

In addition, the Bureau of Motor Carrier Safety regulates interstate carriers, including fuel systems for operational and auxiliary equipment. These regulations might be of interest to you and are enclosed. Your attention is directed to the section concerning fuel systems, pages 51 through 54.

SINCERELY,

April 28, 1975

National Highway Traffic Safety Administration Department of Transportation

We wish to be informed as to what information is required of us to obtain your approval on our replacement fuel tank for Dodge, Ford and Chevy vans.

We are currently approved by the State of California Air Resources Board for the manufacturing installation and distribution of our fuel tank. (enclosure)

Our replacement fuel tank does not alter or change any standard fuel system or structual entities of the vehicle.

We are only adding an additional fuel capacity.

We are currently negotiating a contract with a company who is placing quite a large order and they are requesting that we have your approval.

We have checked with Ford Motor Company, Chrysler Corporation and General Motors Corporation and they have informed us that we do not need any approvals from them.

Thanking you in advance.

Alfred H. Faull President

Tiger Tanks Division of Faull Enterprises, Inc.

A Division of Faull Enterprises, Inc.

REPLACEMENT FUEL TANKS FOR DODGE, FORD, CHEVY VANS AND MINI MOTOR HOMES

* Construction of long ternes steel-lead coated inside and out.

* Made of the same metal as the Ford Motor Company. The Chrysler Corporation and General Motors Corporation use on all original fuel tanks.

* Construction of heavy duty 16 guage steel.

* Seam welded.

* New sending unit and mounting hardware included.

* Connects back to original equipment.

* Pressure tested.

* No inside oil coating to dissolve.

* No plastic lining to peel and clog fuel lines and carburetors.

* No rusting to clog carburetors.

* No exterior paint to peel and cause rusting.

* Approved by the California Air Resourse Board. MODEL WHEELBASE YEAR APPROX. CAPACITY - DODGE ALL WHEELBASE 70-75 48 gallons net FORD ALL WHEELBASE 68-75 46 gallons net CHEVY/GMC ALL WHEELBASE 71-75 45 gallons nets

O.E.M. SUGGESTED RETAIL $ 79.00 not installed $ 125.00 not installed $ 105.00 installed $ 150.00 installed

F.O.B. Carson, Calif. Terms are C.O.D.

Prices subject to change without notice.

Orders of 10 or more units - $ 69.95 per unit.

State of California AIR RESOURCES BOARD

EXECUTIVE ORDER F-39 Relating to the Accreditation of Auxiliary Gasoline Fuel Tank Evaporative Loss Control System

TIGER TANKS DIVISION OF FAULL ENTERPRISES INC.

Pursuant to the authority vested in the Air Resources Board by Sections 39106.5 and 39175 of the Health and Safety Code; and

Pursuant to the authority vested in the undersigned by Section 39023 of the Health and Safety Code;

IT IS ORDERED AND RESOLVED: That Tiger Tanks auxiliary gasoline fuel tank evaporative loss control system is accredited for installation on vehicles subject to evaporative emission control requirements and originally equipped with activated carbon canister type control systems.

This accreditation is for systems serving up to 100 gallons of total fuel storage. For each 50 gallons of fuel storage capacity the vapors shall be vented to a 500 to 625 gram capacity activated carbon vapor storage canister.

This Executive Order shall, without further action by the Executive Officer, cease to be of effect if fuel evaporative loss emission standards more stringent than those in effect on the date of this Order are established and made applicable to any vehicle for which the manufacturer's system is hereby accredited, unless prior thereto the manufacturer applies for and obtains from the Executive Officer, based upon a showing that its system complies with such more stringent standards, an appropriate amendment to this Order or a new Executive Order.

The manufacturer must obtain prior approval from the Air Resources Board before any production changes are made on the gasoline fuel evaporative loss control system that would affect evaporative emissions, or before the system is sold, offered for sale, or advertised under a different name, whether by the manufacturer or any other person.

The Department of Motor Vehicles, the California Highway Patrol, and the Bureau of Automotive Repair will be notified by copy of this order and attachment.

Executed at Sacramento, California, this 10th day of December, 1974.

GEORGE J. TAYLOR

WILLIAM SIMMONS FOR Executive Officer

NET GALLONS 48

(Graphics omitted)

NET GALLONS 46

LONG WHEEL BASE ONLY

NET GALLONS 45