ID: 1984-3.30

TYPE: INTERPRETATION-NHTSA

DATE: 09/27/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: H. Moriyoshi, Executive Vice President and General Manager, Mazda (North America), Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. Moriyoshi Executive Vice President and General Manager Mazda (North America), Inc. 24402 Sinacola Court Farmington Hills, Michigan 48018

This responds to your letter of August 3, 1984, seeking an interpretation of the requirements of Standard No. 201, Occupant Protection in Interior Impact. You specifically inquired about the application of the requirements of section S3.5 of the standard to four possible inner door panel designs Mazda is considering.

You explained that manufacturer-installed armrests originally were simple in design and only extended a short distance sufficient to provide actual support for the arm or elbow of an occupant, but that currently manufacturers "employ inner door panel designs that embody a continous and, in some cases, quite elaborate protrusion that extend the entire length of the door and serve many additional functions, often aimed at occupant convenience." You are concerned about whether the entire inner panel design would be considered an armrest.

You enclosed a drawing of four potential designs for an "inner door panel projection...that incorporate, in addition to a specific location that would be literally considered an armrest, ...other convenience functions. These additional functions, placed in remote locations from an occupant's trajectory during an impact, might include the door handle, power window switches, ashtrays, map pockets and remote side door mirror controls." You asked whether the entire designs would have to comply with section S3.5.1(b), which you understand applies to the whole armrest. You also asked how the designs could be changed to comply with section S3.5.1(a) or (c) and whether the agency's interpretation would differ if the designs were changed so that certain portions of the design were separate components.

First, I want to confirm that the requirements of S3.5.1(b), as with the requirements of S3.5.1(a), of the standard apply to the entire armrest, while S3.5.1(c) is limited to a portion of the armrest within the pelvic impact area. Based on a review of the four designs, we have concluded that the shaded and unshaded portions of each design would be considered an armrest since each design is an integral unit which provides an area for an occupant to rest his or her arm. We cannot comment on how these designs could be changed to comply with sections S3.5.1(a) or (c) since your letter does not explain why you consider it impracticable to meet the requirements of those sections of the standard.

The agency's answer would differ if the designs shown in Figures 1, 2 and 4 were changed so that the shaded areas of those designs were a separate component located away from what you have labeled the literal armrest and had features, such as power window switches, installed in them which would preclude their use as a conventional armrest. As to Figure 3, if the shaded portion of the design which does not have a portion of the "literal armrest" on top of it were likewise moved and included functions to preclude its use to rest the arm, the agency would not consider it an armrest. It would appear that, because of the large size of the entire shaded area shown in Figure 3, you might not be able to separate it and include sufficient design features to preclude its use as an armrest. If that could be done, the agency, again, would not consider it an armrest.

As shown by your careful discussion of the purpose of the armrest requirements of the standard, you are aware that the agency is concerned about reducing injuries caused by any protrusion in the vehicle. If you decide to modify your designs so that certain portions would not be considered armrests covered by the standard, I urge you to utilize a design which will minimize occupant injuries.

Sincerely,

Frank Berndt Chief Counsel 3 August 1984

Mr. Frank Berndt Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Re: Interpretation of FMVSS 201, Occupant Protection in Interior Impact

Dear Mr. Berndt,

Mazda respectfully requests consideration of this letter seeking the interpretation of terminology used in S3.5, Armrests, of FMVSS 201, Occupant Protection in Interior Impact.

Mazda understands that the requirements of S3.5.1(b) apply to the entire "armrest". This term has been generically used to define a protrusion mounted on the inner door panel and situated in such a manner as to allow an occupant to comfortably and conveniently rest their arm or elbow. The goal was to relieve the occupant of the fatigue that often accompanies automobile trips of extended length and provide a stable platform for the driver that decreases uneven and unnecessary movement. Originally, manufacturers installed "armrests" that were quite simple in design and extended along the length of the door only a significant distance to actually provide support to the occupant. Currently, however, many manufacturers employ inner door panel designs that embody a continuous and, in some cases, quite elaborate protrusion that extend the entire length of the door and serve many additional functions, often aimed at occupant convenience.

It is in this context that some confusion arises. The obvious intent of S3.5.1 was and is to protect the occupant from potentially injurious collisions with the inner door panel. Indeed, S3.5.1(c) refers specifically to the "pelvic impact area", presumably as the location of greatest possible risk. However, S3.5.1(a) and S3.5.1(b) apply to the entire "armrest" and, in the case of designs mentioned previously, could thereby be applicable to the entire length of the inner door panel, including those locations of the inner door panel that the lower body of an occupant would not contact under an impact situation. Therefore, a possible design that could assist in the overall goal of providing occupant convenience may be prohibited by strict implementation of the term "armrest".

Mazda has conceived four possible design configurations for an inner door panel projection (see Figures 1-4) that incorporate, in addition to a specific location that would be literally considered an armrest and therefore in compliance with S3.5.1 (b) (Mazda currently considers it impractical to utilize the requirements of S3.5.1 (a) or S3.5.1 (c) relative to the depicted configurations), other convenience functions. These additional functions, placed in remote locations from an occupant's trajectory during an impact, might include the door handle, power window switches, ashtrays, map pockets and remote side door mirror controls.

Therefore, upon consideration of the preceding remarks, please examine the inner door panel configurations depicted and discuss them individually. Also, please offer any comments, suggestions or recommendations that might serve to insure adequate occupant protection, compliance with FMVSS 201, S3.5.1 (b) and maximum design flexibility. Further, please comment on the efficacy of modifying the configurations depicted so that compliance with S3.5.1 (a) or S3.5.1 (c) might be possible. Finally, please discuss any relevance that the continuity of the projection might impart on your interpretation; for example, the shaded area shown in Figures 1-4 being a separate component or piece.

Your consideration is most appreciated.

Thank you.

H. Moriyoshi Executive Vice President and General Manager HM/mls

TYPE: INTERPRETATION-NHTSA

DATE: 10/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Rodger I. Bloch, Sales & Marketing Director, Scott Air, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Rodger I. Bloch Sales & Marketing Director Lavelle Road, P.O. Box 1745 Alamogordo, NM 88310

Dear Mr. Block:

This responds to your letter of August 15, 1984, concerning the application of Standard No. 301, Fuel System Integrity, to an air conditioning system you supply to school bus manufacturers. You explained that your system taps into the fuel system of the school bus. If your system is installed by a manufacturer as an item of original equipment on a school bus, the manufacturer of the bus, is required by Part 567, Certification, to certify that the vehicle with the auxiliary air conditioner complies with all applicable standards, including Standard No. 301.

If you are installing the air conditioners on the vehicle before its sale to its first purchaser for purposes other than resale, then you would be considered a vehicle alterer and under Part 567.7 be required to certify that the vehicle as altered complies with all applicable standards.

In addition, you, in effect, asked about how a manufacturer or alterer demonstrates that it has exercised due care in making its certification of compliance. The agency has recently written Blue Bird Body Co. concerning this issue and I am enclosing a copy of that letter.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

August 15, 1984

Dear Mr. Burndt:

Scott Air is a manufacturer of bus air comfort systems (air conditioning). It has been called to our attention by a manufacturer of school buses, that FMVSS 301-75 relating to fuel integrity was a concern to them. They have taken all steps to certify compliance to this standard. We are now supplying a self contained air conditioning system that is skirt mounted on the drivers side.

Our system is mounted to the chasis of the vehicle and incased in a steel housing, it is protected also by the steel brackets, by which it is mounted, as well as, the vehicle itself. Please see the enclosed photo's. We are tapping into the original certified fuel system of the vehicle and our system holds only about 6.5 ounces of fuel.

I have been talking to Mr. Taylor Vincent of your staff and also Mr. Tom Grubbs with the engineering department. They have both indicated we should be able to secure a DO CARE certification. Would you or your staff be so kind as to issue instructions to me, so I can proceed in this matter.

Your assistance in this matter is greatly appreciated.

Sincerely, Rodger I. Bloch Sales & Marketing Director ds Enclosure: omitted.

ID: 1984-3.31

TYPE: INTERPRETATION-NHTSA

DATE: 10/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Rodger I. Bloch, Sales & Marketing Director, Scott Air, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Rodger I. Bloch Sales & Marketing Director Lavelle Road, P.O. Box 1745 Alamogordo, NM 88310

Dear Mr. Block:

This responds to your letter of August 15, 1984, concerning the application of Standard No. 301, Fuel System Integrity, to an air conditioning system you supply to school bus manufacturers. You explained that your system taps into the fuel system of the school bus. If your system is installed by a manufacturer as an item of original equipment on a school bus, the manufacturer of the bus, is required by Part 567, Certification, to certify that the vehicle with the auxiliary air conditioner complies with all applicable standards, including Standard No. 301.

If you are installing the air conditioners on the vehicle before its sale to its first purchaser for purposes other than resale, then you would be considered a vehicle alterer and under Part 567.7 be required to certify that the vehicle as altered complies with all applicable standards.

In addition, you, in effect, asked about how a manufacturer or alterer demonstrates that it has exercised due care in making its certification of compliance. The agency has recently written Blue Bird Body Co. concerning this issue and I am enclosing a copy of that letter.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

August 15, 1984

Dear Mr. Burndt:

Scott Air is a manufacturer of bus air comfort systems (air conditioning). It has been called to our attention by a manufacturer of school buses, that FMVSS 301-75 relating to fuel integrity was a concern to them. They have taken all steps to certify compliance to this standard. We are now supplying a self contained air conditioning system that is skirt mounted on the drivers side.

Our system is mounted to the chasis of the vehicle and incased in a steel housing, it is protected also by the steel brackets, by which it is mounted, as well as, the vehicle itself. Please see the enclosed photo's. We are tapping into the original certified fuel system of the vehicle and our system holds only about 6.5 ounces of fuel.

I have been talking to Mr. Taylor Vincent of your staff and also Mr. Tom Grubbs with the engineering department. They have both indicated we should be able to secure a DO CARE certification. Would you or your staff be so kind as to issue instructions to me, so I can proceed in this matter.

Your assistance in this matter is greatly appreciated.

Sincerely, Rodger I. Bloch Sales & Marketing Director ds Enclosure: omitted.

ID: 1984-3.32

TYPE: INTERPRETATION-NHTSA

DATE: 10/19/84

FROM: ROGER HAGIE -- KAWASAKI MOTORS CORP USA

TO: OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: REQUEST FOR INTERPRETATION...FMVSS 108

ATTACHMT: ATTACHED TO LETTER DATED 01/02/85 FROM FRANK BERNDT -- NHTSA TO ROGER HAGIE, REDBOOK A26, STANDARD 108

TEXT: Dear Sir:

Kawasaki Motors Corp., U.S.A. requests an interpretation of the provisions of FMVSS 108 with respect to a new headlamp design/concept under development at Kawasaki.

We are aware of the interpretation issued by your office to Koito Manufacturing Co. (letter dated July 24, 1984) in response to their request of June 21, 1984. In this interpretation, you confirmed that two headlamps, each meeting the requirements of SAE J584 may be used on a motorcycle when mounted side-by-side as described by Koito's letter.

Kawasaki wishes to clarify a question which we feel was raised by the Koito request and your response, and to further determine your position with respect to our design ideas. Concerning the Koito request, Koito stated that their "headlamp unit is optically designed to be less than 75,000 cd". It is unclear to us whether Koito was referring to the output of a single lamp in their dual-lamp system, or whether the maximum output of both lamps together would not exceed 75,000 cd. Therefore, our first question is: Does the 75,000 limit (as specified by SAE J584) apply to each lamp individually, or must the total output of both lamps be limited to 75,000 cd?

Kawasaki is considering a headlamp design that consists of two reflectors, each with its own dual-filament bulb, and each capable of independent aim, installed in a single housing, and behind a single lens. Bulbs would be a standardized, replaceable unit, accessible from the rear of the housing. The assembly would meet all of the environmental and other requirements of SAE J584 and FMVSS 108. In some respects, this unit would be similar to the headlamp design proposed by Ford and approved by NHTSA on May 20, 1983. Our questions with respect to this design are: First, is such a design acceptable for a motorcycle? Secondly, would both reflectors have to be independently aimable, or could the aiming be accomplished by moving the whole lamp assembly as long as the aiming requirements of SAE J566 and the photometric requirements of SAE J584 are met?

Kawasaki would appreciate your earliest response to these questions. Please contact the undersigned if there are any questions or if any additional information is required.

Thank you for your attention to this matter.

Sincerely,

ID: 1984-3.33

TYPE: INTERPRETATION-NHTSA

DATE: 10/29/84

FROM: FRED W. BOWDITCH -- MVMA TECHNICAL AFFAIRS DIVISION

TO: DIANE K. STEED -- ADMINISTRATOR NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/14/85 EST, FROM BARRY FELRICE TO FRED W. BOWDITCH, REDBOOK A27, STANDARD 108

TEXT: Dear Miss Steed:

The Motor Vehicle Manufacturers Association of the United States, Inc. (MVMA) * files this petition under 49 CFR Part 552 requesting amendment of Federal Motor Vehicle Safety Standard No. 108.

* MVMA members are AM General Corporation, American Motors Corporation, Chrysler Corporation, Ford Motor Company, General Motors Corporation, International Harvester Company, M.A.N. Truck and Bus Corporation, PACCAR Inc., Volkswagen of America, Inc. and Volvo North America Corporation.

MVMA requests removal from section 4.1.1.36(a)(2) of the limitation requiring the three aiming pads to be located on the exterior face of the headlamp lens. So long as the aiming pads are accessible to the adjustable legs of the aimer locating plates described in Figure 9, there is no motor vehicle safety need to limit pad placement to the face of the lens. Adoption of this requested amendment would remove an unwarranted design restriction. By allowing the aiming pads to be located on a part of the headlamp other than the lens, e.g., the mounting flange at the lens-reflector joint, such amendment would facilitate, for example, the design of lower profile replaceable bulb headlamps. Use of such headlamps could enhance the aerodynamic properties of future vehicle designs. Accordingly, we request substitution of the following text for the current section 4.1.1.36(a)(2):

"S4.1.1.36(a)(2) Each replaceable bulb headlamp shall have three pads on the front surface of the lamp which form an aiming plane for mechanically adjusting and inspecting headlamp aim. In the front view of the lamp taken in a plane perpendicular to the longitudinal axis of the vehicle, the three pads shall be positioned to match corresponding locations, for either Group I or Group II, that are specified in Figure 9 (front view) for the adjustable legs of the locating plate. The pads shall be designed to permit use of a mechanical aimer conforming to SAE Standard J602 October 1980 "Headlamp Aiming Device for Mechanically Aimable Sealed Beam Headlamp Units", together with an adjustable locating plate described in Figure 9, to check the aim of the Headlamp. Group I aiming pad locations are those prescribed for the 2B1 sealed beam headlamp unit and Group II aiming pad locations are those prescribed for 1A1/2A1 sealed beam headlamp units. Each lens face shall have molded into it the settings, appropriate for that headlamp, of the lengths of the three legs of the adjustable locating plate. Each setting is to be located adjacent to the aiming pad to which it applies. The molded characters specifying the settings shall have a minimum height of 4mm".

If you would like to discuss this petition further, please call on us.

Very truly yours,

ID: 1984-3.34

TYPE: INTERPRETATION-NHTSA

DATE: 10/31/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHSTA

TO: Yea-tung Hung, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter to this office, asking for information on the necessary steps for certifying that a rim complies with applicable Federal Motor Vehicle Safety Standards. You were particularly interested in how to obtain "authorization" to place the required markings on rims. Markings are only required by Standard No. 120 to appear on rims for use on motor vehicles other than passenger cars. However, to be certain that I answer your request fully, I will explain our requirements for both passenger car rims and rims for use on other motor vehicles.

The two applicable standards are No. 110, Tire Selection and Rims -- Passenger Cars (49 CFR @ 571.110), and No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars (49 CFR @ 571.120). I have enclosed copies of both these standards for your information. For passenger car rims, section S4.4 of Standard No. 110 specifies two requirements. First, the rim must be constructed to the dimensions of one of the rims that is listed under the definition of a test rim in Standard No. 109. This means that the rim must comply with the dimensional requirements shown for that rim size in the current publications of specified standardization organizations, such as the Tire and Rim Association, the European Tyre and Rim Technical Organisation, or the Japan Automobile Tire Manufacturers Association. Second, in the event of a rapid loss of inflation pressure with the vehicle traveling in a straight line at 60 miles per hour, the rim must retain the deflated tire until the vehicle can be stopped with a controlled braking application. No markings are required on rims subject to Standard No. 110.

For rims for use on motor vehicles other than passenger cars, Standard No. 120 also specifies two requirements. The first requirement, set forth in section S5.1.1, is that the rims on a vehicle must correspond with the size tire on the vehicle, i.e., be listed as suitable for use with that tire size by the tire manufacturer, pursuant to either Standard No. 109 or No. 119. This would be done in the publications of the standardization organizations, as explained above. This requirement is the responsibility of the vehicle manufacturer, not the rim manufacturer, since only the vehicle manufacturer knows what size tires will actually be mounted on the rim.

The second requirement, set forth in S5.2, is that the rim be marked with five specified items of information. These are:

(1) A specified designation indicating the source of the rim's published nominal dimensions;

(2) The rim size designation and, in the case of multipiece rims, the rim type designation;

(3) The symbol DOT, which constitutes a certification by the rim manufacturer that the rim complies with the applicable requirements of the safety standards;

(4) A designation identifying the rim manufacturer by name, trademark, or symbol; and

(5) The month and year in which the rim was manufactured.

You specifically asked how to obtain "authorization from D.O.T." to engrave the symbol on the rim which indicates that it complies with the standards and regulations. As explained in Standard No. 120, this symbol is the letters "DOT". The United States does not use a certification process similar to the European countries, in which the manufacturer delivers the rims to be certified to the governmental entity, and that entity tests the rims to determine if it can be certified as complying with the applicable standards. Instead, in the United States, the individual manufacturer must certify that its rims comply with all applicable standards. Once the manufacturer determines that its rims do meet the requirements of Standard No. 120, it stamps the symbol "DOT" into those rims, without any authorization from this agency.

Should you have any further questions regarding the requirements applicable to rims, please feel free to contact me.

ENCLS.

OCC-1208

September 18, 1984

U.S. Department of Transportation Office of Chief Counsel NHTSA

Dear Sir,

This is to inquire that how to obtain the authorization from D.O.T. to engrave the symbol or words on the rim which shall indicate the quality of the rim is manufactured in accordance with the regulation set forth by the D.O.T.

On behalf of Shinn Fu Company of Taiwan, I have discussed this matter with Mr. Casanova and was told that there is not necessary to get special authorization for the rim except for the tire.

Please confirm this advice or advise us otherwise.

I am looking forward to hearing from you as soon as possible.

Yea-tung Hong

cc: SHINN FU CO.

ID: 1984-3.35

TYPE: INTERPRETATION-NHTSA

DATE: 10/31/84

FROM: AUTHOR UNAVAILABLE; FRANK BERNDT; NHSTA

TO: H.K. Porter Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. A. F. Netzer Hose Development Manager H.K. Porter Company, Inc. 1301 W. Sandusky Avenue Bellefontaine, Ohio 43311

Dear Mr. Netzer:

This responds to your September 19, 1984 letter to Mr. Vern Bloom of the National Highway Traffic Safety Administration (NHTSA) concerning Federal Motor Vehicle Safety Standard No. 106, Brake Hoses. Your letter was referred to this office for our reply.

You asked whether Standard No. 106 would permit the manufacture of an air brake hose for use with permanently attached end fittings when the size of the hose is not listed in Table III of that standard. The answer to your question is yes. Table III of Standard No. 106 specified dimensional requirements for air brake hose intended for use with reusable end fittings. The table does not limit the sizes of hoses used with permanent fittings.

He wish to emphasize that all other requirements applicable to air brake hoses which are found in Standard No. 106 would apply to your air brake hoses.

Sincerely,

Frank Berndt Chief Counsel

September 19, 1984

Mr. Vern Bloom U.S. Department of Transportation NHTSA NRM11 CAD 400 7th Street, Southwest Washington, D.C. 20590

Dear Sir:

We, as air brake hose manufacturers, have been requested by several customers to produce an air brake hose having an inside diameter as listed under SAE J1402 table "A" specification for permanently attached fittings. We find that the DOT 106 specification table "III" does not list a hose diameter for permanently attached fitting and would like to know if we would have any problems if we manufactured a hose with the dimensions as listed in SAE J1402 table "A".

Thank you very much, I remain

Very truly yours,

A. F. Netzer Hose Development Manager AFN/jah

ID: 1984-3.36

TYPE: INTERPRETATION-NHTSA

DATE: 11/02/84

FROM: Diane K. Steed -- NHTSA

TO: Jim Burnett -- Chairman, National Transportation Safety Board

TITLE: NONE

TEXT: This is in further response to recommendations H-83-44 and H-83-45 which your agency made to the National Highway Traffic Safety Administration (NHTSA) regarding the Highway Accident Report, "Jonesboro School District Schoolbus Run-Off-Road and Overturn, State Highway 214 at State Highway 18, near Newport, Arkansas, March 25, 1983" (NTSB/HAR-83/03).

NHTSA agrees with the National Transportation Safety Board that properly inspected and repaired school buses are essential to the safe transportation of school children. We also believe that the current provisions in Highway Safety Program Standard 1, Periodic Motor Vehicle Inspection, and Highway Safety Program Standard 17, Pupil Transportation Safety, as well as the relevant Federal Motor Vehicle Safety Standards, provide for an adequate level of safety when children are transported to and from school.

Of the 15,840 school districts in the United States, about 15,000 provide pupil transportation. Over 400,000 buses are involved in transporting the Nation's 22 million public, private and parochial school children to and from school each day. These buses are maintained by a number of persons having diverse backgrounds ranging in skill from "grease monkey" to those certified by the National Institute for Automotive Service Excellence (ASE). This fleet travels over three billion miles a year, and is remarkably free of problems. Information reported at national meetings indicates that accidents due to mechanical failure are estimated to be between three and five percent and very few result in injury or death.

With respect to the specific recommendations, we have the following comments:

RECOMMENDATION H-S3-44 (Class II, Priority Action)

Include in Highway Safety Program Standard (HSPS) 17 -- Pupil Transportation Safety and in the "Program Manual" for HSPS 17 the requirement that the States institute quality control procedures for schoolbus repairs to determine if needed repairs have been performed adequately or if major repairs are required.

COMMENT

State Directors of Transportation, school business officials and fleet supervisors with whom NHTSA has talked agree that school buses should be kept in good repair. They questioned, however, how quality control procedures could be applied to the repair of school buses when almost every repair is different. Most school buses currently undergo at least two inspections a year, as suggested by Standard 17, which procedure helps to detect major defects that require repair. In addition to this inspection, we understand that most drivers conduct a daily inspection which identifies the need for minor repairs. One supervisor observed that school bus drivers act as a form of practical quality control because they check to determine if the school bus is operating safely after the repair has been made.

A survey of almost 1,000 fleets by the National School Transportation Association revealed that 49 percent operated fewer than 10 buses. To institute quality control procedures for these small fleets would quickly exhaust the limited resources of most States. Instituting formal quality control procedures would be costly to the States, no matter whether facilities were built and equipment purchased, or alternative checking procedures were utilized.

Recommendation H-83-45 (Class II, Priority Action)

This five part recommendation would include in the Program Manual of Highway Safety Program Standard 17 -- Pupil Transportation Safety, the program areas listed below.

1. Specific, well-defined qualifications for hiring schoolbus mechanics;

2. Specific skill areas for schoolbus mechanics for which certification of proficiency is required;

3. A biolography of available courses that can be attended or course curricula that can be used as an example to obtain certification of proficiency in the required skill areas;

Comment

NHTSA plans to use a portion of staff resources to review the literature that pertains to school bus mechanic qualifications and skill areas needed for certification. Upon completion we will disseminate the appropriate information to State and local governments.

Many schools, colleges and vocational training centers offer various courses in auto-mechanics, but few people ever master all the major areas of vehicle repair and become master-mechanics. The majority of small fleet operators could not afford to hire such a skilled mechanic. Car dealers employ many skilled mechanics but many are neither equipped nor do they desire to repair school buses. It is highly unlikely that owners of small fleets would or could hire an ASE certified mechanic. It is also unlikely that most of the garages or service stations that maintain school buses have such a person in their employ because they are small independent private entrepreneures. The extreme diversity of the school bus fleet in the United States would be a major complication for a practical certification program.

In 1978, hearings were held by the House Subcommittee on Consumer Protection and Finance, of the Committee on Interstate and Foreign Commerce, to examine State and local as well as private sector approaches to the problem of unnecessary, incompetent, or fraudulent repair practices. Senator Philip Hart also held hearings in the late 1960s on Mechanic Training and Licensing. In spite of the adverse findings by these two committees, neither the Federal Government nor any State has gone so far as to require certification of mechanics doing work on cars or school buses. Because of the complexity of this problem, and the lack of Congressional action, NHTSA is of the opinion that it cannot go beyond publishing qualifications for school bus mechanics and identifying available training centers.

States whose accident records show the need for better maintenance care can be expected to take remedial action. Michigan, for example, provided workshops especially designed for school bus mechanics for over 10 years.

4. A requirement to institute and enforce procedures to prevent school activity groups from organizing, beginning, or continuing trips in mechanically unsafe vehicles;

Comment

A requirement to institute and enforce procedures to prevent school activity groups from organizing, beginning or continuing trips in mechanically unsafe vehicles is commendable. Such a requirement, however, would be effective only if it were enforced. Standard 17 currently suggests pre-trip inspections and a written report of any defect or deficiency discovered. We believe a reminder to the States of this suggestion would encourage them to give the proper attention to this safety area.

5. Requirements to place fire extinguishers at the front and rear of school buses, post signs in school buses on the location and use of emergency equipment, and brief passengers on the location and use of emergency equipment, both periodically and before beginning activity trips.

Comment

The placement of additional fire extinguishers outside the bus driver's compartment has led to increased theft and vandalism. These essential pieces of emergency equipment need to remain under the watchful eyes of the bus driver. The benefits of placing a second fire extinguisher in the rear of the school bus are so few as to make this requirement unwarranted. In case of a fire, a bus driver's first responsibility is to get the pupils to a place of safety. Having the personal skill and the equipment to handle a small fire are helpful, but not a necessity.

NHTSA suggests that all pupils who ride school buses should have instruction twice a year in safe riding procedures and emergency drills. This should provide sufficient information to students concerning the location and use of emergency equipment carried on the school bus. The location and use of fire extinguishers should be a part of this instruction.

Thank you for the opportunity to comment on these safety recommendations. If NHTSA can supply any additional information, please let me know.

ID: 1982-1.23

TYPE: INTERPRETATION-NHTSA

DATE: 03/10/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: K-D Lamp Co.

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION

NOA-30

Mr. Chris Tuerck Assistant Chief Engineer K-D Lamp Company 1910 Elm Street Cincinnati, Ohio 45210

Dear Mr. Tuerck:

This responds to your letter asking whether your sample turn signal and hazard switch design complies with the labeling requirements of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.

By way of background information, I would point out that the agency does not give advance approvals of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to determine whether its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with all applicable standards. The following interpretation only represents the agency's opinion based on the information provided in your letter.

Your letter states that the switch is used primarily on Class 7 and Class 8 trucks and truck tractors. We therefore assume that it would only be used on trucks with a GVWR of 10,000 pounds or more. We make that assumption because Standard No. 101-80 includes requirements for a vehicle's displays in addition to its controls if it has a GVWR of less than 10,000 pounds. As explained below, it is our opinion that the sample switch does comply with the labeling requirements of Standard No. 101-80.

The sample turn signal and hazard switch is designed to be clamped onto a vehicle's steering column to the left of the driver and looks something like a box. We assume that the box is to be installed so that the side of the box which has two pushbuttons on it, marked 'R' and 'L,' is on the left. Pressing the 'R' pushbutton, which is located toward the back, activates the right turn signal. Pressing the 'L' pushbutton, which is located toward the front, activates the left turn signal. Both buttons must be pushed simultaneously for the hazard warning signal.

Most of the identification for the switch is located on top of the box. Just above the right turn pushbutton is a thick black arrow pointing to the right. Just above the left turn pushbutton is a thick black arrow pointing to the left. Above each pushbutton there is also a triangle outlined in black, i.e., the hazard warning symbol specified by Table 1 of Standard No. 101-80. Between those identifications is located a pushbutton, identified by the use of both words and symbols, which clears the turn signals or hazard warning signal. The top of the box also includes three jewel-type pilot indicators which indicate when the turn signals or hazard warning signal are activated and additional labeling explaining the method of operation for the hazard warning signal.

Section S5.2.1 of Standard No. 101-80 states in relevant part:

Vehicle controls shall be identified as follows:

(a) Except as specified in S5.2.1(b), any hand-operated control listed in column 3 of Table 1 that has a symbol designated in column 3 shall be identified by that symbol. Such a control may, in addition, be identified by the word or abbreviation shown in column 2. Any such control for which no symbol is shown in Table 1 shall be identified by the word or abbreviation shown in column 2. Additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity. The identification shall be placed on or adjacent to the control. The identification shall, under the conditions of S6, be visible to the driver and, except as provided in S5.2.1.1 and S5.2.1.2, appear to the driver perceptually upright.

Both the turn signal and the hazard warning signal are listed in column 1 of Table 1 and have symbols designated in Column 3. Therefore, Standard No. 101-80 requires that those controls be identified by the designated symbols.

The primary issue raised by your design is whether the turn signal control symbol specified by Table 1, a pair of arrows, may be split where there are independent controls for the left and right turn signals. As explained below, it is our opinion that the pair of arrows may be split in that particular circumstance.

The symbol for the turn signal control is the same as the symbol specified by Table 2 for the turn signal display. A footnote to Table 2 explains that while the pair of arrows is a single symbol, the two arrows will be considered separate symbols when the indicators for the left and right turn operate independently and may be spaced accordingly.

Table 1 does not include that footnote for the turn signal control. A turn signal control would normally be expected to consist of one button or lever and would be required to be identified by the pair of arrows as one symbol. It is our interpretation, however, that the two arrows may be considered separate symbols where there are independent controls for the left and right turn signals, as in your sample switch. Separating the two arrows in such an instance has the advantage of indicating the direction of the signal activated by each pushbutton.

Table 2 also includes a footnote that indicates that the framed areas of the turn signal display symbol may be filled in. While Table 1 has a footnote that indicates that the framed areas of several symbols may be filled in, the turn signal control is not among those listed. It is our interpretation, however, in light of the footnote in Table 2, that a manufacturer may fill in the framed areas of the turn signal symbol whether it is used for a control or a display.

Thus, the symbols used on the sample switch for the turn signal controls are those specified by Standard No. 101-80.

Sincerely,

Original Signed By

Frank Berndt Chief Counsel

August 13, 1981

National Highway Traffic Safety Administration Office of Chief Counsel 400 Seventh Street, S.W. Washington. D.C. 20590

ATTH: Mr. Frank Berndt-Chief Counsel

Dear Mr. Berndt:

This is a request for a legal opinion regarding compliance of our Model KD723 Turn Signal and Hazard Switch with FMVSS 571.101-80 Controls and Displays. It is a push button switch of the clamp on style (see attached Instruction Sheet) and is used primarily on Class 7 and Class 8 trucks and truck tractors. This switch has been manufactured by K-D Lamp Co. for approximately twenty years and is specified by the McLean Trucking Co. on all their new truck tractors.

The push button design had led to some problems in marking the switch to meet 571.101-80 requirements. We had tried and discussed various designs of labels which would properly identify the various switch functions and had arrived at a design which we felt would be satisfactory. At about the same time an order was received from GMC Truck and Coach for their version of this switch. We discussed the label with their engineers and they in turn submitted the label design to their legal department for review. Their legal department was of the opinion that the label would bring our Model 723 switch into compliance with FMVSS 571.101-80.

There are three jewel type pilot indicators in the center of the cover. The two (2) outer indicators are green and meet the size (area of 3/16" dia. circle) and functional requirements of SAE Standard J588e Turn Signal Lamps which is a part of FMVSS 108. The same green indicators also meet the requirement of flashing simultaneously when the hazard system is turned on as specified in SAE Standard J910 Hazard Warning Switch. This standard is also a part of FMVSS 108. This latter function agrees in part with Note 2 under Table 2 of FMVSS 571.101-80. The center pilot indicator is red and serves only as a delineator between the two green indicators.

Early this year I visited with Mr. John Carson, Office of Vehicle Safety Standards and Mr. Edward Glancy of your office to discuss the subject switch. They, quite properly did not offer any solutions for bringing the switch into compliance. They suggested that, when we developed a method and design for marking the switch, we send you all the pertinent information along with a print of the label and switch (print attached) and a sample switch with label to show the color scheme. They felt that the print and the sample switch would provide sufficient data so that your office could determine if the switch is in compliance with FMVSS 571.101-80. Under seperate cover we are sending the switch via UPS to your attention.

We apologize for being so late in requesting your opinion and respectfully ask that this matter be handled as expeditiously as possible since the final dead line of September 1,1981 is very near.

Sincerely,

Chris Tuerck Ass't. Chief Engineer

ID: 1982-1.24

TYPE: INTERPRETATION-NHTSA

DATE: 03/17/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Michelin Tire Corporation

TITLE: FMVSR INTERPRETATION

TEXT:

NOA-30 Mr. John B. White Engineering Manager Technical Information Dept. Michelin Tire Corporation One Marcus Avenue Lake Success, New York 11042

Dear Mr. White:

This responds to your recent letter requesting an interpretation concerning the requirements of 49 CFR Part 574, Tire Identification and Recordkeeping. Specifically, you asked whether Michelin could use two different size codes in the tire identification number to identify tires of the same size. You asserted that this assignment of differing size codes would not impair Michelin's ability to conduct a recall of tires of that size, should such a recall be necessary. As long as Michelin maintains accurate records of the size codes assigned to the various tire sizes, it would be permissible to assign more than one size code to each tire size.

At the outset, it is important to note that the size code in the tire identification number is not the means used by the consumer to determine the size of the tires on his or her car. Section S4.3(a) of Standard No. 109 and section S6.5(c) of Standard No. 119 specify that the tire size designation must be labeled on both sidewalls. The size designation is the exact size and is not the same as the size code. To satisfy this requirement, Michelin should label all tires of the same size with just one size designation.

For purposes of record keeping, paragraph S574.5 requires that each tire be labeled with a tire identification number, and that this identification number contain four groupings of information. The first grouping is a symbol identifying the manufacturer (the symbol is assigned by this agency); the second grouping is a symbol identifying the tire size; the third grouping is an optional symbol containing further information on the specific characteristics of the tire; and the fourth grouping is a symbol identifying the week the tire was manufactured.

There is no requirement in Part 574 which prohibits more than one tire size code from being assigned to each tire size. Additionally, the purpose of the tire identification number requirements in Part 574 is to facilitate effective recalls of the tires from the public if those tires are found not to comply with an applicable safety standard or if the tires contain a safety-related defect. For tire manufacturers such as Michelin, this purpose is served by the requirement that the manufacturer keep records of the names and addresses of the initial purchaser of each of its tires for at least three years, as specified in paragraph S574.7. As you noted in your letter, this purpose would not be defeated if a manufacturer assigns more than one size code to a given tire size. Accordingly, a manufacturer may assign more than one size code in the tire identification number for a given tire size, since this is not specifically prohibited by Part 574 and does not conflict with the purpose of that Part.

Sincerely,

Frank Berndt Chief Counsel

REF: PART 574

18 January 1982

General Counsel U.S. Department of Transportation National Highway Traffic Safety Administration Washington, D.C. 20590

Gentlemen:

This is to request an interpretation of Part 574 - Tire Identification and Record Keeping.

Paragraph R574.5(b) requires that the second group of two symbols be used to identify the tire size. In addition, it requires that each new tire manufacturer shall maintain a record of each symbol used with the corresponding matrix or tire size and shall provide such record to the NHTSA.

Circumstances have arisen that will require us to use a size code for particular tire sizes that will be different than the code used on other tires of the same size. In other words in some cases we will have two different size codes for tires of the same size. This will, in no way, prevent us from maintaining control of tire location and tire records as required by the standard. Nor would it interfere with our ability to effectively recall such tires if necessary.

We do not think that this would be in violation of the standard but respectfully request your confirmation.

Yours truly,

MICHELIN TIRE CORPORATION Technical Group

John B. White Engineering Manager Technical Information Dept.

abb

ID: 1982-1.25

TYPE: INTERPRETATION-NHTSA

DATE: 03/17/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Transportation Products Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 17 1982

NOA-30

Mr. E. L. Anderson Project Engineer Transportation Products Inc. P.O. Box 329 Suffern, New York 10901

Dear Mr. Anderson:

This responds to your February 18, 1982, letter asking for an interpretation of Standard No. 217, Bus Window Retention and Release. In particular, you question the requirement of section S5.3.3 which specifies that a continuous warning device shall sound when a school bus ignition is in the "on" position and the release mechanism for an emergency door is not closed. You ask whether depressing the button on the outside of the door should activate the warning device.

The actual requirement of S5.3.3 states that the warning device must be audible when the release mechanism is not in the closed position. The release mechanism is that mechanism that keeps the door from opening. So, for example, if the outside button were depressed but the actual door latch did not open and the door would not itself open, it would not be necessary for the warning device to actuate. However, I assume that the outside button releases the latch which in turn allows the door to open. If this is the case, then at the moment that the latch is released, the warning device must be audible. If this did not occur, it would be possible that the door could be in an open position with the vehicle operating and without the knowledge of the occupants.

I hope that this resolves the question for you.

Sincerely,

Frank Berndt Chief Counsel

February 18, 1982

U.S. Department of Transportation National Highway Safety Administration Office of Chief Counsel 400 Seventh Street, S.W. Washington, D.C. 20590

Gentlemen:

We are requesting an interpretation of Paragraph S 5.3.3. of Federal Motor Vehicle Safety Standard 217. The paragraph in question is: "When the release mechanism is not in the closed position and the vehicle ignition is in the "on" position, a continuous warning sound shall be audible at the driver's seating position and in the vicinity of the emergency door having the unclosed mechanism."

The standard two and three point locking mechanism used on our school buses complies with this paragraph. However, in compliance with a specific application for a customer, the van manufacturer's locking mechanism which consists of a push button outside the van body and a pull type handle on the interior of the van body were retained. In order to comply with the aforementioned paragraph, a warning light and buzzer, a door jamb switch and related micro switch and related wiring were installed by us. (Wiring schematic attached).

The question concerns the push button outside the van body that actuates the door release mechanism. Does depressing the button on the outside of the door require a visible and audible device as outlined in paragraph S 5.3.3?

Trusting we have provided you with sufficient information to provide me with an answer in the next few days, we remain,

Very truly yours,

E. L. Anderson Project Engineer

EA/ms Enc. cc: Paramount