ID: nht95-4.44

TYPE: INTERPRETATION-NHTSA

DATE: October 3, 1995

FROM: Tom Byrne -- Vice President, Goodridge (USA) Inc.

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: 12/12/95 letter from Samuel J. Dubbin to Tom Byrne (Redbook (2); Std. 106)

TEXT: Goodridge (UK) Ltd. has been awarded approval/certification for its Brakelines by the TUV Manheim, Germany. The test procedures and requirements were those of FMVSS 106. We are therefore now able to offer Stainless Steel Braided Brakelines that are leg al for Street and Highway use in Europe and we believe the United States. We have completed the necessary paperwork and have filed for a USA DOT Manufacturers number.

In order to avoid any possible confusion or irregularity, can you please confirm: * an independent laboratory certification that the line meets the requirements of FMVSS 106 is valid for the United States. * that such a brakeline can be used with an adapter into the master cylinder or caliper (for example, where pipe thread has been used). * are there any special marking requirements for the United States? We are required to tag with our manufacturers nam e, type of assembly and date of manufacture.

I am submitting to you a copy of our TUV Certificate and an English translation. This is confidential material and I ask that you please give it confidential treatment. I thank you for your consideration of my request and look forward to your timely res ponse. Please feel free to contact me at (408) 452-1664.

ID: nht95-4.45

TYPE: INTERPRETATION-NHTSA

DATE: October 3, 1995

FROM: Ken Van Sciver -- President, Sciver Corporation

TO: Chief Counsel -- NHTSA

TITLE: NONE

ATTACHMT: 12/8/95 letter from Samuel J. Dubbin to Ken Van Sciver (A43; Std. 206; VSA 102)

TEXT: Safety Administration:

The Sciver Corporation has developed a new product, the Auto Bib, hereafter known as product. We have already began the development and marketing of this new product. The reason for this letter is to familiarize ourselves to any local, state, or govern ing agency with regards to the consumers safety standards if applicable with this product.

After speaking with Walter Meyers in one of your departments, he suggested we submit drawings and describe our product to the New Product Safety Committee for review. We have enclosed a promotional sheet that gives detailed instructions of it's uses and installation of this product. The intentions of this product are to provide the consumer a way of protecting their vehicle's door from the abuse caused by their small pets, the sun, and children.

If you could please forward any information and findings at your earliest convenience it will be appreciated.

Enclosures: product description product installation instructions

(Enclosures omitted.)

ID: nht95-4.46

TYPE: INTERPRETATION-NHTSA

DATE: October 4, 1995

FROM: Donald B. Karner -- Electric Transportation Applications

TO: Mary Versailles -- Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: 1/24/96 letter from Samuel J. Dubbin to Donald B. Karner (A44; Part 567; Part 571.3)

TEXT: Electric Transportation Applications has been contracted to conduct electric vehicle performance testing. During our listing, we encountered an issue concerning FMVSS Certification of a converted vehicle. Mr. Jude Clark of our staff spoke with you last week, and understood that your office was willing to provide NHTSA's opinion on this issue. We are writing to obtain this opinion.

Our questions center on changes made to a vehicle's seating capacity:

1. When a converter recertifies a vehicle with fewer designated seating positions than the number specified on the Original Equipment Manufacturer's (OEM) FMVSS Certification label, what actions must the converter take to prevent the seat from being occ upied?

2. Must the payload of the vehicle (GVWR less curb weight) be greater than the number of certified seating positions times 150 pounds (or some other number representing the weight of a typical passenger)?

3. What vehicle options, if any, must be considered in determinate of the curb weight used in question 2?

Thank you for your help in this matter. We are looking forward to your reply.

ID: nht95-4.47

TYPE: INTERPRETATION-NHTSA

DATE: October 9, 1995

FROM: Samuel J. Dubbin -- Chief Counsel, NHTSA

TO: Guy Dorleans -- International Regulatory Affairs Manager Valeo

TITLE: NONE

ATTACHMT: Attached to 9/29/95 letter from Guy Dorleans to NHTSA Chief Counsel

TEXT: Dear M. Dorleans:

This responds to your letter of September 29, 1995, with respect to the use of light-emitting diodes (LEDs) to fulfill the lighting requirements of Standard No. 108.

You have enclosed a design for a lamp incorporating tail, stop, and rear turn signal functions, the illumination for which will be provided by red LEDs. At night, the LEDs will provide sufficient illumination to meet taillamp photometrics, with increase d illumination when the brake pedal is applied, "so that the sum of the photometrics of the stoplamp and the tail lamp is fulfilled." When the turn signal is activated, "all the diodes are energized at full intensity during the on-period of the turn sign al (and) the sum of the photometrics of the rear turn signal lamp and the tail lamp is then fulfilled. . . ." You ask for "confirmation that this new lighting combination is correct."

We consider this lamp, as you have more fully described it in your letter, to be an acceptable design for meeting the requirements of Standard No. 108.

If you have any questions, you may refer them to Taylor Vinson of this Office (phone: 202-366-5263).

ID: nht95-4.48

TYPE: INTERPRETATION-NHTSA

DATE: October 9, 1995

FROM: Samuel J. Dubbin -- Chief Counsel, NHTSA

TO: Yoshiaki Matsui -- Manager, Automotive Equipemnt, Legal & Homologation Section, Stanley Electric Co.

TITLE: Accessory Lamp with LEDs

ATTACHMT: Attached to 9/18/95 letter from Yoshiaki Matsui to NHTSA Chief Counsel

TEXT: Dear Mr. Matsui:

This responds to your letter of September 18, 1995, describing a combination tail, stop, and rear turn signal lamp which incorporates incandescent bulbs to perform assigned functions, and which contains light-emitting diodes (LEDs) in a compartment along the outboard side.

With respect to red LEDs adjacent to the tail and stop lamp, you state that the lamp is designed to conform to Standard No. 108 using the incandescent bulbs only, and that your regard the LEDs as an "accessory" acceptable to NHTSA (Your Question 1).

We agree. Because the LEDs are not necessary to conformance with Standard No. 108, they are considered supplemental lighting equipment. Such equipment is permitted by paragraph S5.1.3 of Standard No. 108 if it does not impair the effectiveness of light ing equipment required by Standard No. 108. You state that when the taillamp and LEDs are lit simultaneously, the total intensity does not exceed the maximum intensity specified for a one-section taillamp. It would therefore appear that the presence of the LEDs does not impair the effectiveness of the taillamp (or the stop lamp, which will have a higher intensity).

The red LEDs will provide a red color through the amber lens that covers the turn signal lamp, and will remain on when the turn signal is activated (Your Question 2). This design also appears permissible. We have never considered contiguous rear steady -burning red and flashing amber lamps to be prohibited by Standard No. 108 (the basic design of your lamp), and we do not believe that the supplemental red LEDs will impair the effectiveness of the amber turn signal lamp.

If you have any further questions, you may refer them to Taylor Vinson of this Office (phone: 202-366-5263).

ID: nht95-4.49

TYPE: INTERPRETATION-NHTSA

DATE: October 9, 1995

FROM: Rita Cola Carroll, M.A. -- Chairperson, Bus Safety Committee, Great Valley School District, Paoli, PA

TO: Office of Chief Council for the NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 11/21/95 LETTER FROM Samuel J. Dubbin to Rita Cola Carroll (A43; Std. 222)

TEXT: Dear Sir or Madam,

I represent the Bus Safety Committee from Great Valley School District in Southeastern Pennsylvania. I would like to request a formal written response to the following question. If a child is not sitting fully in a school bus seat, that is, a child's b ody is partially extending into the aisle, is the child afforded the protection of the bus compartment in accordance with the Federal Motor Vehicle Safety Standard 222? A rapid response to this question would be most welcome.

Sincerely,

ID: nht95-4.5

TYPE: INTERPRETATION-NHTSA

DATE: August 30, 1995

FROM: John Womack -- Acting Chief Counsel, NHSTA

TO: Nancy Tavarez -- Bietrix Industries

TITLE: NONE

ATTACHMT: ATTACHED TO 08/08/95 LETTER FROM NANCY TAVAREZ TO JOHN WOMACK (WALMA) (OCC 11118)

TEXT: Dear Ms Tavarez:

This is in response to your FAX of August 8, 1995, with respect to the importation of "Phoenix Halogen Auto Bulbs H4 series, H3, H1 and 9000 series-HB1 for the USA market." We understand that you presently have a shipment of these awaiting entry. You st ate that "Mr. Taylor Benson recently informed us that these lights required DOT approval."

Taylor Vinson repeatedly informed you on the phone that DOT does not approve bulbs or any other kind of equipment. If there is a Federal motor vehicle safety standard in effect covering an item of equipment, the manufacturer (or importer for resale) is responsible for certifying that the equipment complies with that standard. The certifier does not need DOT permission or approval for that action.

The appropriate Federal regulations in this instance are Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment and 49 CFR Part 564 Replaceable Light Source Information.

There is no Federal regulation that applies to the H4 bulb. Although the H4 bulb is legal for use only in motorcycle headlamps, neither Standard No. 108 nor Part 564 applies to motorcycle headlamp bulbs, and it is not necessary for H4 bulbs to be certif ied in order to enter the United States. H4 bulbs may not be used in headlamps for motor vehicles other than motorcycles. However, the HB2 bulb, based on the H4, is legal for use in headlamps for all types of motor vehicles.

If the H1 and H3 bulbs are to be used for auxiliary lamps such as fog lamps, there is no Federal regulation that requires their certification either.

However, if the H1 and H3 bulbs are intended for use in headlamps (the markings on their boxes may indicate this), they are subject to both Standard No. 108 and Part 564. What we require is that the bulb be marked with (1) the name and/or trademark regi stered with the U.S. Patent and Trademark Office of its manufacturer or of its importer (Bietrix); (2) the ANSI number, ECE identifier, and manufacturer's part number, individually or in any combination; and (3) a DOT symbol. The DOT symbol is the certi fication by Phoenix or by Bietrix that the H1 or H3 bulb has been designed to conform to the specifications for these bulbs that are on file in Part 564. We believe that Phoenix should be aware of these specifications. For your information, "(1)" is re quired by paragraphs S7.7(h) and S7.2(b) of Standard No. 108, "(2)" by paragraph S7.7(h) and section VIII of Appendix A of Part 564, and "(3)" by paragraphs S7.7(g) and (h) of Standard No. 108. I am FAXing a copy of paragraph S7.7 and Part 564 for your information.

The HB1 light source is required to be marked with the same information as the H1 and H3 as indicated above, but the authority for this is paragraph S7.7(f); this also requires the base to be marked "HB1". However, the DOT symbol in this instance would represent the certification by Phoenix or by Bietrix that the HB1 bulb has been designed to conform to the specifications of paragraphs S7.7(a) and Figure 3 of Standard No. 108. Again, we believe that Phoenix should be familiar with the specifications f or the HB1 light source.

If the HB1 light sources (or H1s and H3s for headlamp use) you wish to import bear all these markings, you may import them under Box 2A of the HS-7 Declaration Form as equipment certified as meeting the standards. If they do not bear these markings, the y may not be imported until marked and certified by Phoenix or by Bietrix according to the regulations discussed above.

If you have further questions, please call Mr. Vinson at (202)366-5263.

ID: nht95-4.50

TYPE: INTERPRETATION-NHTSA

DATE: October 10, 1995

FROM: Edward Mansell -- Chief Engineer, Polar Tank Trailer, Inc.

TO: Philip R. Recht -- Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 12/1/95 LETTER FROM Sanuel J. Dubbin to Edward Mansell (Redbook 2; Std. 108)

TEXT: Dear Mr. Recht,

We are requesting and interpretation of the language included in Federal Motor Vehicle Safety Standard No. 108 Lamps, reflective Devices and Associated Equipment, paragraph S5.7 Conspicuit Systems.

The NHTSA has made it clear that the exact location and configuration of conspicuity sheeting is subject to variation based on the practicability of installation. Our request involves the practicability of installation of conspicuity sheeting on the rea r of some Food Grade Tank Trailers (FGTTs).

Paragraph S5.7.1.4.1(a) calls for sheeting to be placed across the full width of the trailer as close as practicable to 1.25 meters above the road surface. For many tank trailers the rear bumper, located approximately 0.5 m above the road surface, is th e closest practicable location for installation of conspicuity sheeting. For some FGTTs, however, rear-mounted load/unload ports, pumps and valves are located directly above the center portion of the rear bumper.

Conspicuity sheeting affixed to a bumper under the load/unload ports is subjected to repeat exposure to hot water as run off from wash downs cascades over the sheeting. Typically this area is washed at least once per day with water up to 200 degrees F.

This repeated exposure to hot water degrades the conspicuity sheeting. Modes of failure include: loss of red coloring; delamination; loss of brightness; bubbling; cracking; and loss of adhesion. The deleterious effects of this exposure is evident regar dless of the manufacturer of the sheeting. Analysis shows that sheeting applied to the rear of trailers with designs which do not result in the cascade of hot water over the sheeting do not experience these problems.

P2

We interpret paragraph S5.7.1.4.1(a) to allow, that since installation of sheeting in a location subject to frequent hot water run off is not practicable, in the case of FGTTs with designs which results in water cascading from the load/unload area over t he center fo the rear bumper, the sheeting may be applied from the extreme ends of the bumper to points no more than 6 inches (150mm) to the left or right of the area directly below the load/unload area. Further, for FGTTs which use a cabinet to enclose the load/unload area, conspicuity sheeting should be mounted on the cabinet doors to augment the sheeting on the bumper.

Otherwise, the center section of the sheeting should be located on the tank, above the load/unload area.

We believe that this proposal meets the intent of Standard 108 by delineating the rear of FGTTs without requiring manufacturers to redesign trailers to redirect the flow of wash water. We look forward to your interpretation of the Standard and await you r reply.

ID: nht95-4.51

TYPE: INTERPRETATION-NHTSA

DATE: October 11, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Thomas K. O'Connor -- Chief of Maintenance and Operations, Metropolitan Water Reclamation District of Greater Chicago

TITLE: NONE

ATTACHMT: ATTACHED TO 8/3/95 LETTER FROM THOMAS K. O'CONNOR TO NHTSA (OCC 11189)

TEXT: Dear Mr. O'Connor:

This responds to your letter asking about seat belt requirements for a step van with a GVWR greater than 10,000 pounds. You asked whether lap belts versus lap/shoulder belts are needed for compliance with the Federal motor vehicle safety standards. As discussed below, either lap belts or lap/shoulder belts may be used for this type of vehicle.

The National Highway Traffic Safety Administration's safety belt installation requirements are set forth in Standard No. 208, Occupant Crash Protection. I note that this standard specifies requirements based on vehicle type and seating position within th e vehicle. Different requirements also apply depending on the GVWR of the vehicle.

The requirements for trucks with a GVWR of 10,000 pounds or more are set forth in S4.3.2 of Standard No. 208. That section provides vehicle manufacturers a choice of two options for providing occupant crash protection. Option 1, dealing with automatic crash protection, is not relevant to your inquiry. Option 2, set forth in S4.3.2.2, requires vehicle manufacturers to install Type 1 (lap) or Type 2 (lap/shoulder) belts at every seating position. Thus, either lap or lap/shoulder belts may be used to me et S4.3.2.

I hope this information is helpful. If you have any further questions, please feel free to call Edward Glancy of my staff at (202) 366-2992.

ID: nht95-4.52

TYPE: INTERPRETATION-NHTSA

DATE: October 11, 1995

FROM: Gerald R. Stewart -- Office of Safety Performance Standards, Crash Avoidance Division, NHTSA

TO: Office of the Chief Counsel, NHTSA

TITLE: Request for Interpretation for Safety Grooves

ATTACHMT: Attached to 11/13/95 letter from Samuel J. Dubbin to Borje Kukka (A43; Std. 104; Std. 205)

TEXT: MEMORANDUM:

At a recent meeting I received a video tape and brochures on safety grooves which are used in Finland and other countries to help keep windshields and wiper blades clean in adverse weather. Mr. Borje Kukka from Helsinki Finland asked for help with regar d to which vehicle safety standards, if any, would be applicable to safety grooves.

I have sent Mr. Kukka a letter with most of the information he needs; however Mr. Felrice suggested that I request an interpretation from Chief Counsel to be sent to Mr. Kukka so that he has a complete understanding of whether safety grooves are consider ed an item of vehicle equipment or not.

I am submitting the video tape, brochures, and a copy of my letter to Mr. Kukka. Please prepare an interpretation letter for Mr. Kukka. If you have questions contact me at 366-5268 or Mr. Kukka at the following:

Borje Kukka Humalistonkatu 5 00250 Helsinki Finland

Phones: 011 358 0 493 013 private 011 358 02 419 820 Fax 011 358 0 407 315 cellular 011 358 49 414 727

Attachment

Mr. Borje Kukka Humalistonkatu 5 00250 Helsinki Finland

Dear Mr. Kukka,

Thank you for inviting me to your meeting with Mr. Nitze to review the safety groove principles and video tape. I was impressed with the simplicity of the process for grinding the grooves into a vehicle windshield and also with the performance of the gr ooves on keeping the windshield and wiper blades clean during adverse conditions.

I contacted the Office of Chief Counsel and a search of interpretations produced an example for a device which cleans windshield wipers. A copy is attached along with some general information which will help you. As I said in the meeting, it is importa nt for you to understand the term "render inoperative" as it refers to our Federal Motor Vehicle Safety Standards 205 and 104. Copies of these are attached. At the meeting I gave you a copy of the ANS 226 document which is referenced by Standard 205.

At this point, it is important for you to know whether the safety grooves would be considered by our agency as an item of motor vehicle equipment or not. I have provided your video tape and brochures to the Chief Counsel Office with a request for an int erpretation of the question of which vehicle safety standards, if any, are applicable to your safety grooves. An answer should be available within 60 days.

Thank you again for giving me an opportunity to learn about a simple process that can improve a driver's ability to drive safely. I hope this information is helpful to you. If you have questions or need more information please do not hesitate to call m e at 202-366-5268.