ID: aiam2270

Dear PFC Phillips: This is in reply to your letter of April 8, 1976, asking about Stat laws applicable to fog lamps, driving lamps, and quartz-iodine halogen driving lamps.; The American Association of Motor Vehicle Administrators, 1828 Street, N.W., Washington, D.C. may be able to provide you answers with respect to State laws, as each State, rather than the Federal government, sets its own requirements for registration and use of motor vehicles within its borders.; The only aspect that you mentioned which we cover in our Federa vehicle lighting standard is the minimum and maximum height of headlamps above the road surface. These measurements are 24 inches and 54 inches respectively, measured from the center of the headlamp on the vehicle at curb weight. If a State has a law on maximum and minimum headlamp height it is required to be identical to this one. States may permit or prohibit fog lamps, driving lamps, and quartz-iodine halogen driving lamps as they choose since there are no Federal requirements for them.; Yours truly, Stephen P. Wood, Assistant Chief Counsel

ID: aiam0980

Dear Mr. Long: This is in reply to your letter of January 30, 1973, concerning acryli headlamp covers.; Federal Motor Vehicle Safety Standard No. 108 incorporates Society o Automotive Engineers (SAE) Standard J580a, which prohibits the use of acrylic headlamp covers as original equipment. The requirements of SAE Standard J580a have also been incorporated in a number of State regulations, which are applicable to vehicles in use. Copies of Standard No. 108 and SAE Standard J580a are enclosed for your information.; A Notice of Proposed Rule Making (Docket 69-19, Notice 3) on Standar No. 108 was issued on October 16, 1972. This Notice includes a provision for optional use of headlamp covers which conform to certain performance requirements. Such requirements are specified in paragraph S7.9 of the Notice (copy enclosed). Acrylic Industries Pty. Ltd. may be interested in commenting on this *proposed* revision of Standard No. 108. The closing date for comments is April 18, 1973.; If you have any questions on the enclosed documents, please do no hesitate to contact me.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: aiam0095

Dear Mr. Heath: Thank you for your letter of July 1, 1968, to Mr. George C. Nield concerning a clarification of paragraph S 3.4.3 of Federal Motor Vehicle Safety Standard No. 108.; Paragraph S 3.4.3 specifies that, as a minimum, the taillamps shall b illuminated when the headlamps are illuminated, except when the headlamps are being flashed. The phrase 'except when the headlamps are being flashed', permits the vehicle manufacturer to use a separate switch or flasher for illuminating the headlamps only when it would not be appropriate or in the interest of safety to simultaneously illuminate the taillamps and headlamps. In addition to the examples cited in your letter, such devices could also be used for flashing the headlamps on public transit vehicles to indicate an emergency situation.; Since the subject matter of S 3.4.3 is taillamps and since Federa Standard No. 108 is otherwise silent as to headlamp flashing, this matter appears to be within the purview of the California vehicle code.; Thank you for your continued interest in the motor vehicle safet standards.; Sincerely, David A. Fay, Office of Standards on Accident Avoidance Motor Vehicle Safety Performance Service;

ID: aiam0886

Dear Mr. Mann: This is in reply to your letter of September 20, 1972, in which yo enclose a brochure describing your feed mover as requested by Mr. Andrew Moss, of my staff.; An examination of the material submitted would seem to indicate tha your classification of the feed mover as farm machinery is valid. We would not, therefore, consider it to be a 'motor vehicle' within the meaning of the National Traffic and Motor Vehicle Safety Act (the Act) based on the information furnished.; In addition to the Act (PL 89-563) and 19 C.F.R. 12.80, that you hav requested, we are also enclosing Part 571 (formerly Part 371) of Title 49 of the Code of Federal Regulations. Of particular interest to you would be the interpretations on mini- bikes that set forth criteria to assist manufacturers in classifying their products insofar as off-road use is concerned.; If you have further questions, we will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs;

ID: aiam3087

Dear Mr. Bechtel: This is in response to your letter of May 1, 1979, requesting a interpretation of the definition of 'incomplete vehicle' contained in Federal Motor Vehicle Safety Standard No. 115, and in confirmation of your subsequent telephone conversations with Mr. Schwartz of my office.; The term 'incomplete vehicle' is defined in S3 of the standard to mea 'an assemblage consisting, as a minimum, of frame and chassis structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attached components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed trailer.; You are correct in saying that most of the components listed in th definition are not meant to be part of a trailer. Consequently, an incomplete Trailer would consist of only those components, such as a frame, listed in the definition which are meant to be part of the completed trailer. The outfitting of an incomplete trailer for a specific purpose would not be sufficient to make Halliburton Serviced responsible for assigning the vehicle identification number.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam1971

Dear Mr. Bernard: This is in reply to your letter of May 28, 1975, providing furthe 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 th 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, Richard B. Dyson, Assistant Chief Counsel

ID: aiam0807

Dear Mr. Matthews: This is in response to your letter of July 5, 1972, requesting a opinion as to how manufacturers may take into account a vehicle's speed capability in establishing GAWR.; The Certification regulations do not specify particular speed criteri for establishing weight ratings. As a minimum, however, we believe the speed chosen should reflect the maximum speed at which it is reasonable to expect the vehicle to be driven. In the case where a vehicle is subject to some low-speed uses, such as seasonal sue as a snow plow, we believe the figure on the certification label should be based on that use of the vehicle in which its expected speed is greatest. The regulations do not provide for variable ratings based on speed.; Finally, you ask whether cautionary labels dealing with GAWR and GVW figures may be installed in the cab. The NHTSA does not object to the use of such labels. They may be used, as appropriate, to indicate permissible use of higher loads in low-speed applications.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: nht87-1.29

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/87

FROM: HANNS-OTFRIED WESTERMANN--HELLA KG HUECK & CO.

TO: DR. BURGETT--NHTSA

TITLE: RE MULTI BULB DEVICES

ATTACHMT: ATTACHED TO LETTER DATED 8-22-90 TO H. WESTERMANN FROM P. J. RICE; (A36; STD. 108)

TEXT:

We intend to equip motor vehicles with signalling devices, which have - opposite to conventional lamps - a great number of replaceable miniature bulbs instead of e.g. one 32 cp bulb. The miniature bulbs are about 2 to 3 cp each, as is actually applied t o CHMSL.

This design shows a number of advantages:

1. The failure probability of the signal function of a device is very low, because the burn out of a single bulb does not drop the light-out-put of the lamp below the minimum value required.

2. The average life of the miniature-bulbs is greater than the one of current 32 cp bulbs: about 3 per cent mortality rate after 1500 burning hours.

3. The devices can be built smaller and particularly with less depth.

4. The openings in the vehicle's body work can be avoided in part or totally, because the devices can be surface mounted.

5. The absence of body work openings increases the vehicle's stability and avoids sealing problems.

Summary: "Multi-bulb-devices" increase the traffic safety and lower the system costs over the vehicle's life time.

FMVSS No. 108 opposes this idea, because it is required that lamps with 2, 3 or more lighted sections have to comply with higher intensity requirements than a lamp with only one compartment or bulb. The reason for this requirement is to assure a uniform ly conspicuous surface luminance. These higher intensity requirements because of the larger overall lens area are not applicable to our design with a great number of miniature bulbs.

In spite of the great number of bulbs (10 to 20, depending on function) the total area of the lamp is not larger than the one of current one-compartment-lamps. The luminous Intensity requirement for 3- or more compartment lamps for this lamp size would c ause undesirable high luminances.

For each of the many bulbs the lighted lens area is substantially smaller than the required minimum area (22 inches square) for each compartment of multi-compartment lamps, but the total area of all bulbs is in compliance with the requirement for one-com partment-lamps.

We kindly ask for your comment on the legal aspects of this deviating design with many miniature bulbs and in particular, whether the intensity requirements of single-compartment lamps are applicable. (For LED-lamps it is even discussed, that for their higher conspicuity the intensity requirements could be lowered below those of single-compartment lamps). In our opinion the minimum requirements should not depend on the type of design (number of bulbs or compartments) but on the overall visible lens ar ea.

We want to draw your attention to the changes of ECE Regulations R6 and R7:

"If with a single lamp containing more than one bulb one of this bulbs fails, the lamp with the remaining bulbs shall comply with the minimum value required ...

Any failure of a bulb in such a lamp shall be clearly visible, if the lamp is switched on."

ID: aiam5324

"Dear Mr. Metz: This responds to your letter to this agency regarding new windshield wiper system you intend to develop for front windshields. I apologize for the delay in responding. The drawing you enclosed with your letter shows a wiper system consisting of one wiper arm and blade, as distinguished from the conventional systems consisting of two wiper arms and blades. Your wiper system takes different paths on the forward and the return strokes of the wiper cycle. Thus, as you stated in your letter, 'the vision areas are fulfilled only in the sum of forward and return movement.' You asked whether that is permissible under Federal Motor Vehicle Safety Standard (FMVSS) No. 104, Windshield Wiping and Washing Systems (copy enclosed), and if so, whether the minimum frequencies specified by FMVSS 104 apply to this wiper system. As explained below, the answer to both questions is yes. The essential feature of a windshield wiper system, from a safety standpoint, is its ability to clear a specific portion of the windshield. The number of wipers necessary to provide the driver with a sufficient field of view is not specified in FMVSS 104. Therefore, the number of wipers is immaterial so long as the minimum percentages of critical areas are cleared. The areas to be wiped are specified in paragraphs S4.1.2 and S4.1.2.1 of the standard. S4.1.2 establishes three windshield areas for passenger car windshields, designated as areas 'A', 'B', and 'C.' Each area is required to have a certain percentage of the glazing area wiped as shown in Figures 1 and 2 of SAE Recommended Practice J903a, May 1966 (copy enclosed), using the angles specified in Tables I, II, III, and IV of FMVSS 104, as applicable. Those tables apply to passenger cars of varying overall widths, namely, from less than 60 inches to more than 68 inches. The angles set forth in the tables vary according to the overall width of the vehicle. Finally, paragraph S4.1.2 provides that the percentage of each area required to be cleared must also be within the area bounded by a perimeter line on the glazing surface one inch from the edge of the daylight opening. With that background in mind, I will address your first question. FMVSS 104 does not specify whether the wiper needs to clear a windshield on either or both strokes. SAE Recommended Practice J903a, at paragraph 2.5, however, defines an effective wipe pattern as 'that portion of the windshield glazing surface which is cleaned when the wiper blade travels through a cycle) (emphasis added). A 'cycle' is defined in paragraph 2.14 of SAE Recommended Practice J903a as consisting of 'wiper blade movement during system operation from one extreme of the windshield wipe pattern to the other extreme and return' (emphasis added). It is NHTSA's opinion, therefore, that so long as the required windshield area is cleared by your wiper in a complete cycle, the requirements of paragraphs S4.1.2 and S4.1.2.1, FMVSS 104, have been met. As indicated above, your wiper system must comply with the minimum frequencies specified in section S4.1.1, Frequency, of FMVSS 104. That section requires that each windshield wiping system must have at least two frequencies or speeds. One must be at least 45 cycles per minute (cpm), regardless of engine load and speed. The other must be at least 20 cpm, also regardless of engine load and speed. In addition, the difference between the higher and lower speeds must be at least 15 cpm, regardless of engine load and speed. There are no exceptions to these frequency requirements, regardless of the number or design of the wiper arms comprising the system. Your letter did not indicate whether your wiper system is designed to be used on passenger cars or motor vehicles other than passenger cars, or both. Please note that section S2 of FMVSS 104, Application, provides that the standard applies to multipurpose passenger vehicles, trucks, and buses in addition to passenger cars. All those vehicles are required to have power-driven windshield wiping systems that meet the frequency requirements of section S4.1.1. The wiped area requirements of S4.1.2, however, apply only to passenger cars. I hope this information will be helpful to you. Should you have any further questions or need any additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures";

ID: aiam5260

Dear Mr. Paradis: This responds to your FAX of November 18, 1993 requesting a clarification of our letter of November 16 as it applies to the rear of the trailers shown in items; 5 and 7 which accompanied your letter of August 31, 1993. As we advised yo with respect to rear markings, Standard No. 108 requires a horizontal strip of retroreflective sheeting across the full width of the trailer. With respect to the trailer shown in; 7, retroreflective tape can be applied across the full width of th 'approach ramp' to meet the requirements since the ramp will be in the down position when the trailer is moving. As we further advised you, paragraph S5.7.1.3(b) anticipates that the length of the color segments may have to be modified to facilitate using material near rear lamps. In the worst cases of trailers with rear surfaces no wider than the minimum required for lamps, breaks in the rear treatment are unavoidable to clear the lamps. But NHTSA expects the manufacturer to minimize the breaks by using red material adjacent to red lamps. With respect to; 5, we recommend applying red/white conspicuity treatment on either sid of the identification lamps, with red material used in the remaining outboard areas. I hope that this answers your questions. Sincerely John Womack Acting Chief Counsel;