ID: GF002714

ID: 21809.ztv

Mr. Charles I. Sassoon
Panor Corp.
125 Cabot Court
Hauppauge, NY 11788





Dear Mr. Sassoon:





This is in reply to your fax of June 14, 2000, to Michael Cole of our Office of Vehicle Safety Compliance.

You have had an inquiry from your customer, California Bus Sales, asking whether "they could utilize a LED beehive light classified 'side marker lamp' as a turn signal indicator." You have enclosed certificates from a test laboratory indicating that four different LED side marker lamps comply with both Federal Motor Vehicle Safety Standard No. 108 (FMVSS No. 108) and Canadian Motor Vehicle Safety Standard No. 108. We assume that the certificate is intended to cover compliance only with the side marker lamp requirements of each of the two safety standards.

The meaning of the word "indicator" is unclear. If you mean to ask whether the side marker lamp may flash when a vehicle's principal turn signal lamp system is operating, our answer is yes. Paragraph S5.5.10(b) of FMVSS No. 108 specifically allows side marker lamps to be wired for signaling purposes.

However, it seems unlikely that the LED beehive light could be used as an original equipment turn signal lamp that meets the performance requirements of FMVSS No. 108. For one thing, a turn signal's brightness is approximately 50 times that of a side marker lamp. The certificates that the LED beehive lights meet the requirements for side marker lamps is insufficient to indicate compliance with turn signal lamp requirements. Even if tests should indicate that the LED beehive light meets all the performance requirements that apply to turn signal lamps, the lamp would have to be mounted in accordance with the location and visibility requirements of FMVSS No. 108.

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).





Sincerely,





Frank Seales, Jr.
Chief Counsel





ref:108
d.7/25/00

ID: 1984-1.9

TYPE: INTERPRETATION-NHTSA

DATE: 02/02/84

FROM: AUTHOR UNAVAILABLE; Barry Felrice; NHTSA

TO: Yamaha Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Michael J. Schmitt, Counsel Yamaha Motor Corporation, USA 6555 Katella Avenue Cypress, CA 90630

Dear Mr, Schmitt:

This is in response to your letter asking for an interpretation, of the permissibility of using two type 2A1 headlamps mounted symmetrically disposed about the vertical centerline of the motorcycle.

Federal Motor Vehicle Standard (FMVSS) No. 108, "Lamps, Reflective Devices, and Associated Equipment states in S4.1.1.34 that a motorcycle may be equipped with one of the following headlamp systems, one of which is the "A" type neadlamp system described as follows:

Type 1A1 or Type 1A . . . . 1 lamp and either Type 1A1 or Type 2A . . . . 1 lamp

The standard is specified this way because the 2A1 lamp is a lower beam lamp and the 1A1 is an upper beam lamp. While the 2A1 lamp does have an "upper beam", photometrically it provides only "fill-in" light. The 1A1 lamp provides the high output upper beam. It is not possible to achieve safe upper beam light using only the 2A1 lamp, regardless of how many are used. Therefore, your proposed headlighting application would not be permitted by FMVSS No. 108.

Sincerely, Barry Felrice Acting Associate Administrator for Rulemaking

November 21, 1983

Mr. Charles Kaehn Head, Lighting and Visibility Group National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

RE: FMVSS 108

Dear Mr. Kaehn,

Yamaha would like to incorporate a headlamp system featuring two type 2A1 headlamps. The lamps will be symmetrically disposed about the vertical centerline of the motorcycle. Is such a system permissible? We appreciate your assistance and response in this matter.

Sincerely,

Michael J. Schmitt Counsel

MJS/ts

cc: Shin Kubono

ID: 1984-2.2

TYPE: INTERPRETATION-NHTSA

DATE: 05/21/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Hella North America Inc. -- Walter A. Genthe

TITLE: FMVSS INTERPRETATION

TEXT:

January 23, 1984

Dear Mr. Berndt:

Westfaelische Metall Industrie KG is currently designing headlamps for several automobile manufacturers.

These headlamps are designed to comply with Safety Standards 108 as amended by Docket 81-11 (latest issue: Notice 7).

Preliminary requests by our customers mandate an inclusion of parking/front position lamps and/or turn signal lamps and/or side marker lamps in the overall headlamp design.

A standard U.S. light bulb, meeting FMVSS 108 and/or applicable SAE recommended practices, will be used for these respective functions.

We intend to incorporate these functions into the headlamp compartment, retaining the bulb in question by means of a sealed attachment, similar to the one used in the C6 capsule installation.

No degradation of the system will result, since both functions are contained in one sealed compartment, covered by one common lens. No impairment of the effectiveness of the headlamp function is anticipated, nor will the headlamp impair the function of the parking/position/side marker lamp.

All photometric and environmental specifications for such lamps will be met and no component will be used which is outside the scope of FMVSS 108.

To clarify our intent, a sketch showing the principal design has been enclosed.

We are requesting a statement concerning the agency's opinion in this matter; specifically, as it concerns the legality of the proposed system, whole or in part, and solicit any suggestions as to necessary changes should the system not be in compliance with FMVSS 108, as amended by Docket 81-11.

This matter is of considerable urgency, because of design and manufacturing lead times.

A reply at yyor early convenience coud therefore be appreciated.

Very truly yours,

HELLA NORTH AMERICA INC.

Walter A. Genthe President

WAG/1h

Encls.

cc: Dr. Ernst, K 1 Mr. Westermann, K 1 Mr. Fikus, AF

Insert artwork here.

MAY 21, 1984

Mr. Walter A. Genthe President Hello North America, Inc. P.O. Box 499 Flora, Illinois 62839

Dear Mr. Genthe:

This is in reply to your letter of January 23, 1984, with respect to the inclusion of other lighting functions in a replaceable bulb headlamp compartment. These functions could include parking lamps, turn signal lamps, or side marker lamps. The bulb used would meet Standard No. 108/SAE specifications for the function chosen and they would be incorporated into the compartment bya a "sealed attachment." You represent that there will be no impairment of any function, and that the overall assembly will meet all photometric and environmental specifications. You have asked whether such a combination assembly is permissible under Standard No. 108.

The agency interprets Standard No. 108's specifications for replaceable bulb headlamps as allowing only one bulb in a lamp assembly to be used for headlighting purposes. It is silent as to whether additional bulbs may be used to provide other lighting functions. This means that such a bulb is permitted.

Obviously the inclusion of a second bulb can affect the characteristics of the assembly, whether through heat build up, the introduction of contaminants through the junction of the bulb and assembly, etc. These problems would appear to be minimized under the assumptions set forth in your letter. We believe therefore that, under these conditions, an auxiliary bulb could be included in the headlighting compartment, provided that the assembly meets all applicable requirements of Standard No. 108 for each function. Problems that may develop in service would be subject to the safety related defects authority of the National Traffic and Motor Vehicle Safety Act.

If Hella proceeds with a multi-bulb, design, we would like to request that it share with us the types of tests it will be developing which it deems necessary to insure adequate safety performance, so that our knowledge of state of the art lamp technology may be broadened.

Sincerely,

Frank Berndt Chief Counsel

C6/C6 **INSERT GRAPH**

**INSERT GRAPH**

ID: nht79-3.29

DATE: 04/05/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: U. S. Suzuki Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

April 5, 1979

Mr. Michael Petler Assistant Manager Safety and Legislation Department U.S. Suzuki Motor Corporation 13767 Freeway Drive Santa Fe Springs, California 90670

Dear Mr. Petler:

This is in response to your request of March 22, 1979, for an interpretation of Federal Motor Vehicle Safety Standard No. 109. First, I would like to apologize for the delay in responding to your request of September 14, 1978. As was explained to you in a telephone conversation on March 22, your letter and the response thereto was apparently lost when the Chief Counsel's offices were moved. Although we took great care to ensure that something like this would not happen, it seemingly did in this case. I regret this and hope that it has not caused any undue inconvenience for your company.

You asked whether it was permissible under Standard 109 for a manufacturer to stamp the maximum permissible inflation pressure of a tire and its maximum load rating on the tire in both English units (pounds and psi) and metric units (kilograms and kPa). S4.3(b) and (c) of the standard specify that each tire shall have permanently molded onto the sidewalls the maximum permissible inflation pressure and the maximum load rating for the tire. This agency has interpreted this requirement to mean that the information must appear on the sidewalls in the English units, since this is the system of measurement which will be used and understood by most consumers. However, so long as the information appears in English units, there is no reason that it could not also be expressed in equivalent metric units, if the presentation of the additional information does not cause confusion about the required information. By stating not only the pressure and rating values, but also the units of value, your company would avoid causing any such confusion. Therefore, the expression of inflation pressure and load rating in English and metric units as shown in your illustration is permissible under Standard 109.

Sincerely,

Frank Berndt Acting Chief Counsel

March 22, 1979

Steven Kratzke Office of Chief Counsel National Highway Traffic Safety Administration Room 5213 400 Seventh Street, S.W. Washington, D.C., 20590

Dear Mr. Kratzke:

As per our telephone conversation of this date, as requested I have enclosed a copy of my letter of September 14, 1978, to Mr. Levin regarding our request for interpretation of FMVSS No. 109.

If you are in need of any additional information please feel free to contact us.

Thank you for your interest and assistance in this matter.

Sincerely,

F. Michael Petler Assistant Manager Safety and Legislation Department

FMP/ks Enc.

September 14, 1978

Joseph J. Levin, Esquire Chief Counsel National Highway Traffic Safety Adminisiration Room 5219 400 Seventh Street, S.W. Washington, D.C. 20590

RE: Request for interpretation, FMVSS #109, New Pneumatic Tires- Passenger Cars

Dear Mr. Levin:

We have been requested by our parent company, Suzuki Motor Co., Ltd. to request from your agency, an interpretation of Section S4.3 of this standard, as to the permissibility of molding specific information on the sidewall of a 6.00-16 passenger car tire in both U.S. and Metric (SI) units. We note that in Section S.4.3.4. (a) and (b) that dual markings have been allowed for tires if the maximum inflation pressure of a tire is 240, 280 or 300 KPa.

Our company would like to know whether FMVSS #109 would permit the information required in S4.3 (b) and (c) to be molded onto the 6.00-16 tire sidewall in the following manner by our tire supplier.

That information is:

MAX LOAD 1400 LBS (635 KG) AT 32PSI (221KPA) MAX PRESS

For your convenience we have attached a copy of a drawing that shows the various required markings that would appear on this tire as required in S4.3 of the standard. The letter height would be 4mm, and the letters would be raised 0.4mm for items (b) and (c) of S4.3.

If you are in need of any additional information please feel free to contact us.

Thank you for your assistance in this matter.

Sincerely,

F. Michael Petler Assistant Manager Safety & Legislation Department

attachments (1)

FMP/vw

ID: nht78-2.12

DATE: 08/29/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Cibie Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in belated reply to your letter of December 15, 1977, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. Your request concerned the legality of installation on motor vehicles of remote manual or of automatic headlamp aiming equipment.

If a headlamp assembly meets the requirements of Standard No. 108 when installed with or without auxiliary means of aiming, we consider the assembly to be in conformance. Your device does not appear to impair the effectiveness of the required lighting equipment within the prohibition of S4.1.3, and either device that you described would apparently provide an additional safeguard against glare when the rear of the vehicle is heavily loaded.

SINCERELY,

CIBIE CORPORATION

Office of the Chief Counsel N.H.T.S.A.

December 15 1977

Dear Sir

Headlamp "Aim Correction"

Cibie Corporation is a Delaware Corporation, the American subsidiary of CIBIE PROJECTEURS of Bobigny, France. Cibie Projecteurs manufacturers automotive lighting equipment of every description: headlamps, fog and spotlamps, combination lamps, etc. In addition, headlamp aim correction units are manufactured for passenger cars.

In Europe, these aim correction units are referred to as headlamp levellers; this terminology may lead to confusion with suspension levellers in the United States, hence I have coined the name "aim correction units" in the absence of a recognized term.

The aim correction units manufactured by Cibie are of two types: manual and automatic. Both types are additional to the normal aim features of the headlamp system to which they are applied. That is to say, the correct aim of the headlamps is first established by means of a screwdriver adjustment made externally to the headlamp by a person standing at the front of the car. (Sometimes the screwdriver is not required, where the slotted-head screw has a finger-tip knob molded onto it, allowing the basic aim to be made with the fingers directly.)

The movement of the headlamps that is applied by the aim correction units to the basic correct adjustment is in a downward sense only, to compensate for a full luggage load in the trunk. Thus, the aim correction units cannot of themselves produce dazzle; however, failure by the driver to take advantage of them can allow dazzle to persist (due to luggage load) that could otherwise be removed by their use.

Dealing with the two types of aim correction unit, taking the manual type first: there are two types of manual aim correction unit, two-position and variable.

The earlier two-position type incorporates a cam in the headlamp mounting itself. A small lever, moved by hand, produces a downward correction of the headlamp aim; this lever is accessible by raising the engine hood of the car.

The later variable type incorporates a small piston unit and control knob under the instrument panel, operable from the driving seat. Hydraulic tubing connects the piston unit to a slave unit on each headlamp, lowering the headlamp aim by any desired amount within the design limits of movement. Again, the aim correction is downwards only.

The automatic aim correction unit incorporates hydraulic sensors on the vehicle suspension which, by means of hydraulic tubing and the same slave units, correct the headlamp aim downward without any action on the part of the driver. In the case of the automatic system, headlamp aim is also corrected dynamically for vehicle pitching movements as well as statically for luggage load.

These three types of aim correction unit have been in use in Europe for many years. The automatic unit is currently standard equipment on the Lancia Beta.

Council Directive 76/756 of the European Common Market now requires passenger cars to be fitted with headlamp aim correction units, operable from the driver's seat or automatic. Thus, it is entirely possible that European passenger car manufacturers may wish to export to the United States models of cars in which the European headlamps have been replaced with SAE sealed beams, in accordance with FMVSS 108, but still retaining the aim correction feature, whether manual or automatic.

Cibie Projecteurs, as manufacturer of the aim correction units, would wish to be in a position to advise its customers as to the eligibility of these units for importation into the United States.

Therefore, Cibie Corporation requests a legal opinion as to whether a passenger car that complies in all respects with FMVSS 108, but in addition is equipped with manual or automatic aim correction as described above, would be deemed still in compliance with FMVSS 108.

Inasmuch as the application of the Council Directive takes effect during 1978, the earliest possible answer to this enquiry would be greatly appreciated.

H J T YOUNG Vice President - Technical Affairs

ID: nht92-9.14

DATE: February 11, 1992

FROM: Lance Watt -- Director of Engineering, The Flxible Corporation

TO: Paul Jackson Rice -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/10/92 from Paul J. Rice to Lance Watt (A39; Std. 108)

TEXT:

The Flxible Corporation is a major domestic manufacturer of city transit buses and requests an interpretation concerning FMVSS 108, "Lamps Reflective Devices, and Associated Equipment," while also referencing FMVSS 121 "Air Brake Systems."

An air brake system is used on our vehicles. As the driver starts to apply the service brake pedal to slow or stop the vehicle, a service brake stop lamp switch is activated. The stop lamp switch is installed to comply with Section S5.1.7 of FMVSS 121, "Air Brake Systems." The stop lamps are in turn activated by the stop lamp switch.

The Flxible Corporation offers optional transmissions which have internal hydraulic retarders for supplemental braking as a means to increase brake lining life. This retardation deceleration would be over and above that obtained by the normal service brake system. In our current design, the transmission retarder is electrically operated during the initial travel of the service brake pedal. As the service brake pedal is further depressed, the service brakes are activated, and this in turn triggers the stop lamp switch which in turn illuminates the stop lamps.

The Flxible Corporation has received requests from customers to activate the transmission retarder when the ACCELERATOR pedal is released. In this scenario, the service BRAKE pedal would not be used to activate the transmission retarder. However, if required, the driver could also depress the brake pedal to in turn activate the service brakes in order to achieve an even higher rate of vehicle deceleration over and above that obtained by the transmission retarder itself.

If the brake pedal were not depressed however, and with the vehicle deceleration caused solely by transmission retardation, the stop lamps would not be illuminated and therefore, following vehicles may be unaware of this sudden reduction in vehicle speed.

Some of our customers have also requested to have the transmission retarder activate the stop lamps to provide following vehicles with a warning that a sudden reduction in vehicle speed was in progress, even though it was caused by the transmission retarder as opposed to a service brake application. Again, this application of the stop lamps would be achieved by release of the accelerator and without depressing the brake pedal, and potentially without any intent to apply the service brakes on the part of the driver.

Section S5.5.4 states: "The stop lamps on each vehicle shall be activated upon application of the service brakes." This is interpreted by Flxible to mean the brake pedal would activate the service brakes which would activate the stop

lamp switch which in turn would activate the stop lights. By virtue of our customer's requests, the stop lamps would already be activated when the driver released the accelerator pedal and without any application of the brake pedal.

Flxible has in the past requested a NHTSA ruling on a further scenario outside of that, but somewhat related to that which is described here-in. Please find attached a copy of that request along with a copy of your response for reference.

Additionally, some of our customers, especially those in locations likely to experience icy or slippery road conditions, request a retarder cut off switch in order to disable the retarder and reduce the possibility of uncontrolled drive axle wheel lock-up. In cases such as this, without a dual system that would then allow stop light switch and stop light activation to be caused by application of the brake pedal as in our standard system today, a stop light activation would occur at the time of accelerator release with minimal if any change in vehicle forward speed, and again, potentially with no intent on the part of the driver to use the service brakes.

Flxible to date has resisted the customer requests as noted, however, these customers, without a specific NHTSA ruling on the request as stated above, threaten to declare Flxible a non responsive bidder on transit bus procurements. The basis of their complaints or requests in this regard stem from the fact that they require operating standardization across their various manufacturer fleets to prevent operator error or confusion.

A ruling is requested on whether a non-compliance with Section S5.5.4 of FMVSS 108 would result, if the stop lamps were activated without depressing the brake pedal as requested by our customers.

Flxible appreciates the opportunity to petition for a ruling in this complex matter so that we may use your response accordingly in responding, to our customer's requests.

Should you desire any further clarification or information on this subject, please feel free to contact the writer at (614) 362-2730.

ID: nht74-5.38

DATE: 04/22/74

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

TO: Meiji Rubber & Chemical Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your February 27, 1974, request concerning brake hose identification codes and labeling, conflicts of Federal and State standards, and procedures for certifying hose, end fittings, and hose assemblies in compliance with Standard No. 106, Brake hoses. This also responds to your March 25, 1974, (ref T-76) request for approval of your proposed hydraulic and vacuum brake hose labeling.

Notice 10 was published on February 26, 1974. It modified the labeling requirements, and a copy is enclosed. It is certain that another notice will be published shortly which may modify the marking requirements further. Therefore I advise that you not undertake modifications of your labeling in the near future.

In answer to your February 21 letter, if we require a code at a later date, the code will not relate to the MRA code. Concerning the marking of multi-piece fittings, the designation must appear on each part of a reusable end fitting, although this requirement is presently under reconsideration.

With regard to conflicting State regulations such as Pennsylvania's, our regulation as of September 1, 1974, preempts any State brake hose regulations which are not identical with respect to the some aspects of performance. The National Traffic and Motor Vehicle Safety Act of 1966 provides at @ 103(d):

Whenever a federal motor vehicle safety standard established under this subchapter is in effect, no state or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard. . . .

2

However, it is permissible, if a manufacturer wishes, for him to place Pennsylvania labeling on the reverse side of the hose.

It is the responsibility of the manufacturer to certify that his products comply with Standard No. 106. You may conduct a test program, or you may hire an independent test laboratory to conduct the test program for you. One test laboratory in the United States which tests brake hose is VPI of Blacksburg, Virginia. The National Highway Traffic Safety Administration does not conduct certification tests, but it does conduct tests on manufacturer products to enforce compliance.

In answer to your March 25 letter, the hydraulic brake hose marking on "Face A" appears to conform to the requirements of S5.2.2, assuming that letter "size" refers to letter height. Notice 10 permits the manufacturer designation to be other than block capital letters. "Face B" is not regulated by our standard.

With regard to the brake hose end fitting and brake hose assembly examples, they appear to conform to S5.2.3 and S5.2.4 if the letter "size" refers to letter height. It should be noted that Notice 10 excludes labeling of two-piece fittings and certain assemblies and that the next notice may make further modifications.

With regard to vacuum brake hose, your "Face A" example appears to conform to S5.2.2 if letter "size" refers to letter height. S5.2.1 is not applicable and therefore the stripe is not required. "Face B" is not regulated by our standard.

ENC.

MEIJI RUBBER & CHEMICAL CO., LTD.

February 21, 1974

National Highway Traffic Safety Administration

Dear Sirs:

Subject: Brake Hoses for FMVSS

As to the Part 571-Federal Motor Vehicle Safety Standards (FMVSS), Brake Hoses of Docket No. 1-5: Notice 8 published in the Federal Register Vol. 38, No. 218 issued on Tuesday Nov. 13, 1973, we shall be pleased if you will kindly show us about the procedure for getting the code nos.

1. We manufacture brake hoses and metal fittings, assemble them into oil brake hoses, and sell them to automobile manufacturers. We have got the Code No. 57-1 from MRA. Please show us the relation between the code no. of MRA and that of newly published FMVSS.

2. Please show us the relation between FMVSS and the specifications regulated by a state such as the State of Pennsylvania.

3. In order to get the code no. FMVSS, what procedure should be followed by company as ours, who manufactures hoses and several types of metal fittings, and assembles them into oil brake hoses?

4. There are several types of forms in our metal fittings. Is it necessary to get the code no. on the respective types of our metal fittings?

5. Please introduce us to the public institutions who can test and qualify oil brake hoses to get the code no. FMVSS.

Your generous cooperation would be highly appreciated.

Yours Sincerely

H. Tsukano, Sub-manager Technical Division

MEIJI RUBBER & CHEMICAL CO., LTD.

March 25, 1974

Docket Section National Highway Traffic Safety Administration

Subject: Submission of Comments on Federal Motor Vehicle Safety Standards Docket No. 1-5: Notice 9

We would like to ask for the approval of our attached application about the Brake Hose Identification provided in the Docket No. 1-5; Notice 9 on the Federal Register, Vol. 39, No. 20, Tuesday, January 29, 1974.

H. Tsukano, Sub-Manager Technical Division

enc.

P.S. As for the expenses, we will pay on your request.

1

LABELING

I. HYDRAULIC BRAKE HOSE

1. Hydraulic brake hose (ID 1/8")

1-1. Printed parts

1-2. Face A (printed mark) (every 6 inches)

-- DOT MRCC 10/74 1/8 HR -- DOT MRCC

Notes: The color of printed letters is white.

The size of a letter is 1/8".

The width of line is 1/16".

MRCC stands for Meiji Rubber & Chemical Co.

1-3. Face B (printed mark)

M MEIJI RUBBER JAPAN 1/8 NO57-1 1974 SAE J1401

(which is indication of the approval for the export to a northern state (Pennsylvania).)

Notes: The white letters are printed continuously

The size of letter is 1/8".

M: The trade mark of Meiji Rubber & Chemical Co.

1/8: The inside diameter of hose 1974: year of production

N057-1: The approval number of RMA (Rubber Manufacturers Association) (444 Madison Avenue, New York 10022, U.S.A.) Line number 57

Yarn color code yellow yellow-black

RMA assignment Meiji Rubber Company, Ltd. attained on March 1st, 1967

SAE J1401 Society of Automotive Hydraulic Brake Hose

2. Hydraulic brake hose end fitting

DOT MRCC 1/8 H XY

Notes: Letters stamped

The size of a letter 1/16"

MRCC stands for Meiji Rubber and Chemical Co.

1/8: The inside diameter of hose X is the figure of production that comes after 197 Y means the month of production

3. Hydraulic brake hose assembly

DOT MRCC 10/74

Notes: Letters stamped

The size of a letter 1/8"

Rubber band width 8 mm red colored hypalon rubber

MRCC stands for Meiji Rubber & Chemical Co.

II. Vacuum Brake Hose (ID 3/8")

1. Printed parts

(A) Face A (printed mark) (every 6 inches)

-- DOT MRCC 10/74 3/8 VL -- DOT MRCC

Notes: The white letters printed

The size of a letter 5 mm

The width of line 3 mm

MRCC stands for Meiji Rubber & Chemical Co. 3/8 means the inside diameter of hose.

(B) Face B (printed mark) (every 6 inches) M MRCC JAPAN -- M ---

Notes: The white letters printed

The size of a letter 5 mm

The width of line 3 mm

M is the trade mark of Meiji Rubber & Chemical Co. MRCC stands for Meiji Rubber & Chemical Co.

ID: nht72-1.32

DATE: 02/05/72

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Garden Spot Oil Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your inquiry of December 21, 1971, to the Regional Representative of the Secretary of Transportation in Dallas, Texas, and undated letter to the Bureau of Motor Carrier Safety concerning the sale of tires branded "Unsafe for Highway Use."

By Notice No. 2, to Docket 70-2 (copy enclosed) the National Highway Traffic Safety Administration issued an amendment to Federal Motor Vehicle Safety Standard (FMVSS) No. 109 specifying the conditions under which tires that failed to pass the minimum performance requirements of FMVSS No. 109 could be sold. This amendment presently permits such tires to be reclassified as "Unsafe for Highway Use," and if properly labeled to be sold for farm wagons or other off-highway uses only. A dealer who sells such tires for passenger car use, or who removes or alters the legend "Unsafe for Highway Use" imprinted on the tire sidewall, in subject to a civil penalty of up to $ 1,000 per violation.

It is proposed that on or after March 1, 1972, no tire of a type and size designation specified in FMVSS No. 109, Table 1 of Appendix A, shall be sold, offered for sale, imported, or introduced or delivered for introduction in interstate commerce for any purpose unless it conforms to all the requirements of this standard. If implemented, this proposal will void the authority granted by Notice No. 2 to Docket 70-2 mentioned above.

If the Javelin Tire Company of Dallas, Texas, is representing the tires you have on hand as safe for highway use, we would appreciate any evidence to this effect which you can provide. An invoice or a statement from Javelin claiming these tires as suitable for highway use or an affidavit from you attesting to such claims by the Javelin Tire Company would be useful.

A copy of the proposed rule, published in Notice 3, Docket 70-2, is enclosed for your information. One of the matters being covered in the rulemaking is whether tires reclassified prior to the effective date of the proposed rule may be sold. Copies of your letters have been entered in the official Docket. When the final rule is issued, it will be published in the Federal Register with a definite effective date. Because of your interest in this matter, we will send you a copy of the amendment when finally issued.

Thank you for your interest in highway safety.

ID: RECARO_e-registration7970

Mr. Dan Mullins
RECARO North America, Inc.
3275 Lapeer Road West
Auburn Hills, MI 48326




Dear Mr. Mullins:

This replies to your inquiry as to whether the recent amendments to Federal Motor Vehicle Safety Standard (FMVSS) No. 213 require your company to revise its on-line registration form. As explained below, so long as online registration information is not provided on the paper registration form, your electronic registration form is not subject to the format requirements of the standard.

To improve the effectiveness of manufacturer campaigns recalling child restraint systems (CRSs) that contain a safety defect or fail to conform to FMVSS No. 213, manufacturers are required to provide a registration form (hereafter referred to as a "paper form") with each restraint (S5.8). The paper form must conform in size, content and format to the form depicted in the standard (figures 9a and 9b). To minimize the potential for confusion, no other information is permitted to appear on the paper form except for information that distinguishes a particular restraint from other systems.

In your e-mail you indicate that RECARO provides an electronic registration form on its website and that the internet address for the electronic form is provided in the CRS instruction manuals. You further state that the internet address is not provided on the paper form. You then ask if recent amendments to FMVSS No. 213 would subject RECAROs electronic registration form to the standards format requirements under this scenario.

On September 9, 2005, we amended FMVSS No. 213, in part, to permit the inclusion of an internet address for electronic registration of a CRS on the paper form (70 FR 53569). If a manufacturer chooses to provide such information, the website address must also be provided in the instruction manual (S5.6.1.7 and S5.6.2.2) and the format of the electronic registration form must conform to S5.8.2 (S5.8.1(d)).

However, S5.8.2 is only applicable if a manufacturer voluntarily provides an internet address for electronic registration on the paper form. We noted in the final rule that the amendments did not establish any new requirements for CRS manufacturers. If a manufacturer does not include an internet address on the paper form, then the electronic registration requirements do not apply even if the manufacturer elsewhere provides information on electronic registration.

I hope you find this information helpful. If you have any additional questions, please contact Mr. Chris Calamita of my staff at (202) 366-0536.

Sincerely,

Stephen P. Wood
Acting Chief Counsel

ref:213
d.1/24/06