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.

ID: nht68-3.12

DATE: 01/26/68

FROM: AUTHOR UNAVAILABLE; Roger H. Compton: NHTSA

TO: Fire Department, Lynn, Massachusetts

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 12, 1967, you questioned several requirements of Initial Motor Vehicle Safety Standard No. 108 as applied to fire trucks.

Paragraph S3.1.1.3, which permits the installation of additional equipment if it does not impair the effectiveness of the required equipment, will not prohibit the installation of rotary flashing lights on fire trucks. Therefore, a waiver of this clause is not necessary for fire trucks.

Paragraph S3.5 a revised by the latest amendment to Standard No. 108, and issued December 11, 1967, (copy enclosed), permits the flashing of steady-burning lamps for signalling purposes. Therefore, the flashing of side marker and clearance lamps on fire trucks to signify an emergency vehicle will not be prohibited by the requirements of this paragraph.

Standard No. 108 does not require that front identification lamps be located on the roof of the vehicle cab, but only that they be "as near as practicable to(Illegible Word) vertical centerlines." If, however, they are mounted on the upper body structure, "no part of the lamps or mountings may extend below the top of the vehicle's windshield." This mounting flexibility will permit a selective location of identification lamps and rotary warning lamps which will not cause the rotary lamps to blot out the identification lamps. Also to be considered is the effectiveness of the identification lamps when the vehicle is operated on the highway and without illumination of the rotary lamps. Therefore, fire trucks need not be excepted from the requirement for front identification lamps.

Rear identification lamps mounted on the edge of or under the rear step of a fire truck will meet the location requirements as specified in Standard No. 108. Adequate guards or protective shields are available and commonly used on lamps located in these positions. Therefore, fire trucks need not be excepted from the requirement for rear identification lamps.

If you have any further comments or questions on the requirements of Standard No. 108, I hope you will let us know.

ID: nht68-3.13

DATE: 02/09/68

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

TO: Electrographic Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 18, 1967, to Mr. Lowell K. Bridwell, you describe the procedure initiated by you for identifying and marking light hit containers. You ask for our acknowledgement of the procedure. It is not clear from your letter, but we gather that you manufacture truck bodies and ship light kits in a separate box, either to accompany or separate from the truck bodies.

The so-called "lighting Standard," Standard 103 of the initial Federal Motor Vehicle Safety Standards, to entitled "Lamps, Reflective Devices, and Associated Equipment." The standard applies to multipurpose passenger vehicles, trucks, trailers and buses, that are 80 or more inches wide overall, except pole trailers and converter dollies. It is the manufacturer of the completed vehicle who must certify that the vehicle conforms to all applicable Federal motor vehicle safety standards, including Standard No. 103. Unless the manufacturer of the lighting equipment and the completed vehicle are the same, the manufacturer of lighting equipment is not required to certify that such equipment conforms to Standard No. 103. It would seem logical to expect that the manufacturer of the completed vehicle would require from the manufacturer of the lighting equipment some indication that the lighting equipment is in conformity, but that is a matter to be settled between the two persons involved. Thus, while we have no objection to the procedure described in your letter, we do wish to emphasize that it does not relieve the vehicle manufacturer of insuring compliance and certifying to such compliance where appropriate.

Thank you for your interest. If further information is needed, please feel free to contact this office.

ID: nht68-3.14

DATE: 05/24/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 5, 1968, (Reference 61.A218.A1115) addressed to Dr. William Haddon, Jr., concerning the location of clearance lamps on several styles of truck bodies manufactured by the Utility Body Company.

Rear clearance lamps mounted at the top corners of the sleeper cab of the vehicle in Figure 1 of the drawing attached to your letter would not be in conformance with the requirements of Federal Motor Vehicle Safety Standard No. 108. On this same vehicle, the required location of the front clearance lamps is at the top corners of the sleeper cab. The additional set of front clearance lamps on the truck cab would not be required or prohibited by Standard No. 103. Locations of rear clearance lamps on the vehicles shown in Figure 2 and Figure 3 of the drawing are in accordance with the requirements of Standard No. 108.

Our records do not indicate that we have furnished any evidence to the Utility Body Company regarding location of rear clearance lamps as shown in Figure 1. Under their letter of March 11, 1968, this company submitted to us a print of their drawing, which is identical to the drawing enclosed with your letter, and requested our comments on the proposed locations of their lighting equipment. The above information will be furnished to the Utility Body Company in reply to their March 11 letter and should serve as clarification of the requirements of Standard No. 108. This clarification also indicates that no conflict exists between the requirements of Standard No. 108 and the requirements of the California Vehicle Code with respect to location of your clearance lamps.

ID: nht68-3.15

DATE: 05/15/68

FROM: AUTHOR UNAVAILABLE; William Hadden, Jr.; NHTSA

TO: Mercedes Benz of America, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your telegram of May 3, 1968, concerning the use of tabular-type bulbs to back the requirements of Federal Motor Vehicle Safety Standard No. 108.

Paragraph S3.1 and Tables I and III of Standard No. 108, as amended (32 F.D. 13933, December 10, 1967), specify that certain lamp assemblies such as license plate lamps, backup lamps and tail lamps, shall conform to the basic SAE Standards for the lamp assemblies. These basic standards in turn refer to SAE Standard 7573 on bulbs and to SAE Standard 3567 on bulb sockets. This relationship between the basically referenced standards and subreferenced standards has been the subject of prior communications with the industry and appears to be in need of clarification.

The basically referenced SAE Standards also refer to SAE Standard J575, "Test for Motor Vehicle Lighting Devices and Components." Paragraph "C" of SAE Standard J575 states in part as follows: "Where special bulbs are specified, they should be submitted with the devices and the same or similar bulbs used in the tests and operated at their rated mean epherical candlepower." This provision of SAE Standard J575 permits the use of special bulbs, including tubular-type bulbs, which do not conform to the detailed requirements of Table I of SAE Standard J573. It also follows that the sockets for these special bulbs need not conform to SAE Standard J567. I must emphasize, however, that these provisions for special bulbs in no way except the lamp assemblies from testing all performance requirements specified in Standard No. 108, including those specified in the basically referenced SAE Standards and in subreferences SAE Standard J575.

In view of the several inquiries we have resolved on this particular(Illegible Word) of the requirements of Standard No. 108, we anticipate that an official interpretation, providing the clarification presented in this letter, will be published in the Federal Register in the near future.

Thank you for your continued interest in the Federal Motor Vehicle Safety Standards.

ID: nht68-3.16

DATE: 02/07/68

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

TO: American Quality Coach Corporation

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of January 8, 1968, to the Federal Highway Administration, requesting regulations relating to motor vehicle safety requirements.

The type of vehicle that you have described appears to be a bus accordingly to the statutory meaning of Part 255.3, Initial Federal Motor Vehicle Safety Standards. Accordingly, Standards 102, 107, 205 and 209 would be applicable to your vehicles manufactured after January 1, 1968. We invite your attention to Section 114 of Public Law 89-563 and the notice of Certification Requirement.

In addition to the existing Federal Motor Vehicle Safety Standards and Public Law 89-563, we are enclosing information concerning proposed rule making that may affect future regulations.

We trust this information will be of assistance to you.

ID: nht68-3.17

DATE: 03/02/68

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

TO: Field Body Company Inc.

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of January 8, 1968, in regard to certification of your product and questions regarding interpretation of the Chassis-Cab regulation.

In regard to your letter furnishing us certification information, what 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 an actual sample of your certification label and the method of attachment.

Concerning your request for clarification in regard to the extent of responsibility for adherence to applicable safety standards to your type of vehicle, the following should be of assistance:

First, your vehicle, completed, falls into the category defined as a "truck" and as such, must adhere to Safety Standards 102, 107, 108, 205 and 209. We have enclosed a copy of the Federal Register, Volume 32, No. 23, dated February 3, 1967, and several other pertinent amendments.

Regarding extent of responsibility of the chassis-cab body manufacturer, and final assembler of the units into a completed vehicle, these are clarified in Section 2 you refer to in your letter. I assume this is Federal Register Volume 33, No. 1, dated January 3, 1968, "Notice of Ruling regarding Chassis-Cabs," but in case it is not I am enclosing a copy for your reference. This notice defines two main points which I will endeavor to state in a few words as follows:

If the original manufacturer of the chassis, after January 1, 1968, cannot or does not include all the safety standard regulations required for the type of end product or completed assemblage, then the final assembler is responsible to certify that all applicable safety standards are included and the vehicle is so certified and labeled.

Thank you for your interest in the safety program.

ID: nht68-3.18

DATE: 03/12/68

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

TO: The Reuben H. Donnelley Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 27, 1968, to the Federal Righway Safety Bureau, in regard to obtaining information about Safety Standard No. 209, seat belt assemblies.

Regarding your question on seat belt usage as pertaining to a fire apparatus vehicle, seat belts are not required to be installed, however, if seat belts are installed on a truck by a manufacturer, the seat belt assemblies, as equipment, must meet the requirements of Standard 209, specifically, requirements of the Department of Commerce, National Bureau of Standards for seat belts for use in motor vehicles (15 CFR 9)(30 FR 8432).

Thank you again for your interest in the safety program.

ID: nht68-3.19

DATE: 03/25/68

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA

TO: Renault

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 1, 1967, concerning tests made on the Renault 10 model for compliance with Federal Motor Vehicle Safety Standard No. 203.

We recognise the validity of a system which takes advantage of the energy absorbing characteristics of the surrounding vehicle structure as on alternative to the more conventional approach of employing on energy absorbing column and/or wheel. As you mentioned, SAE J944 was not written with that type of energy absorbing system in mind. The structure which you intend to employ to provide the energy absorbing requirements specified in Federal Motor Vehicle Safety Standard No. 203 might in reality first be severely stressed and deformed in a crash eltuation. Therefore any laboratory test used to evaluate such a system should recognize this detrimental influence. In the event that you would wish to submit a proposed alternative test procedure which incorporates a barrier test is specified in Standard No. 204 prior to testing for compliance with Standard No. 203, we would be pleased to consider such a request.

Your second point concerns the need for a more explicit definition of translational motion. SAE J944 states that the body-block contacts the wheel in translational motion. It does not say that this motion must continue after impacting the wheel. Your magnetic release mechanism appears to impart approximately translational motion to the body-block at impact and is a satisfactory procedure. The fact that the body-block is free to rotate forward after impact is a stimulation of an actual crash situation and the body-block was not intended by SAE J944 to be restrained in translational motion after impact. Since the body motion in on actual crash situation will very somewhat the Bureau feels that a more explicity definition of translational motion is unnecessary.

The third series of tests as described in Report No. 287.397 using a right test fixture and the free flying body-block are compatible with the SAE J944 test procedure.

Your interest in motor vehicle safety is appreciated.