ID: 1983-1.2

TYPE: INTERPRETATION-NHTSA

DATE: 01/07/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Stanley Electric Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 23, 1982, to Mr. Elliott of this agency asking whether you may distinguish between U.S. and Japanese-manufactured lighting equipment subject to Federal Standard No. 108 by marking the lenses "U.S.A. DOT" and "JAPAN DOT", rspectively.

As you know, the National Highway Traffic Safety Administration has not adopted the SAE standard on equipment marking, J759c. This means that the only marking subject to Standard No. 108 is that which certifies compliance to all applicable Federal motor vehicle safety standards, the DOT symbol. We believe that the intended proximity of the words "Japan DOT" in your Japanese-manufactured equipment might create the impression that Stanley was certifying compliance to the requirements of the Japanese Ministry of Transport, rather than to those of the U.S. Department of Transportation. Therefore, we suggest that you place the word "Japan" at the end of the line rather than adjacent to the "DOT" symbol.

SINCERELY,

STANLEY ELECTRIC CO., LTD.

November 23, 1982

Att.: Marx Elliott Office of Rulemaking

National Highway Traffic Safety Administration

Dear Mr. Elliott,

We, Stanley Electric Co., Ltd. corporated in Japan (hereafter reffered to as STANLEY-JPN) have estblished Stanley Electric U.S. Co., Inc. corporated in London, Ohio (hereafter reffered to as STANLEY-US) with 100 % investments, and we are in process of preparing to start producing, beginning with the lighting equipments for 1984 model vehicles.

In the work we are proceeding, we are faced with a problem, the first case for us, which relates to the identification marking to be indicated on the lighting devices. So, we would like to ask you whether or not our view is right.

Honda Motor Co., LTD. (Japan) will manufacture the same type of vehicles both in Japan and in U.S.A (HONDA OF AMERICA). Therefore, their lighting devices of the same design will be manufactured by STANLEY-JPN and by STANLEY-US, and supplied to the Honda plant in each area.

Because these lighting devices are of the same design (STANLEY-JPN keeps the original drawings. And only STANLEY-JPN takes proceedings for their modifications.), we intend to indicate the same indentification making to the products made in Japan and made in U. S. A. However, in order to make a country of origin clear, it is our intention to add the marking "JAPAN" or U.S.A." to the identification marking, though it is not explained in Lighting Identification Code-SAE J759c.

The following is an example:

For products made in Japan : "STANLEY 043-6371 SAE AIST 80 JAPAN DOT"

For products made in U.S.A.: "STANLEY 043-6371 SAE AIST 80 U.S.A. DOT"

Please let us know whether or not the above view has no problem.

Thanking you in advance,

H. Miyazawa Director, Automotive Lighting Engineering Dept.

ID: 1983-1.20

TYPE: INTERPRETATION-NHTSA

DATE: 02/24/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Garvin-Fram Inc. -- Jack Garvin

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Jack Garvin Vice President-Operations Garvin-Fram, Inc. 817 Albion Avenue Schaumburg, Illinois 60193

Dear Mr. Garvin:

This responds to your recent letter to Mr. Kratzke of my staff requesting information concerning any regulations applicable to the salvage and sale of farm implement tires exposed to a warehouse tire. This agency has no such regulations, and I am not aware of any Federal regulations.

The National Traffic and Motor Vehicle Safety Act, as amended 1974 (15 U.S.C. 1381 et seq.), gives this agency authority to regulate motor vehicles and motor vehicle equipment. Tires for use on motor vehicles are subject to regulation as motor vehicle equipment. Section 102(3) of the Safety Act (15 U.S.C 1391(3)) defines a motor vehicle as "any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways.." Farm implements have been determined not to be motor vehicles because they are not manufactured primarily for use on public roads. Therefore, tires for use on farm implements are not considered motor vehicles equipment, and are not regulated by this agency. The inventory sheet attached to your letter shows that these tires are of a size and strength that were designed for use on farm implements. Accordingly, you may conduct the salvage and sale of these farm implement tires as you wish without violating any of this agency's regulations.

In your telephone conversation with Mr. Kratzke, you mentioned that some tires for use on passenger cars were also involved in the fire and asked about any agency requirements for subsequent sale of these tires. With respect to those tires, the manufacturer that has certified the tires as complying with our safety standards ( by molding the letters "DOT" on the sidewall) must make a determination of whether the certification is still valid. If the manufacturer determines that the certification is still valid, the tires may be sold. If, on the other hand, the certification is not still valid, the manufacturer must remove its DOT symbol from the sidewall of the tires, and those tires coud not be sold. The means by which the manufacturer determines whether or not its certification is still valid is left completely to the discretion of the individual manufacturer. I have enclosed a 1981 interpretation explaining this more fully. I appreciate your concern for tire safety and for complying with our safety regulations.

Sincerely,

Frank Berndt Chief Counsel Enclosure

January 18, 1983

National Highway Traffic Safety Administration Office of the Chief Council 400 7th St. S.W., Room 5219 Washington, D.C. Attn: Mr. Steve Kratzke

RE: Farm Implement Tires

Dear Mr. Kratzke:

Enclosed is an inventory of the farm implement tires I referred to in our phone conversation on January 18, 1983.

Basically, what we would like to know is are there any Federal regulations, particularly through the NHTSA, regarding the salvage and sale of distressed farm implement tires. In this case, the tires were involved in a fire in Zealand, Michigan, however these particular tires were approximately 50 to 75 feet away from the fire area. Additionally, there were approximately 1000 passenger tires between the fire area and implement tires, acting as an insulator from the heat.

I will await your reply in writing before disposing of the tires. Additionally, after receiving your letter, I will again contact the manufacturer to see if they would like to run tests on these tires for quality control purposes, which they have to date refused to do.

Very truly yours,

Garvin-Fram, Inc.

Jack Garvin Vice President-Operations

ID: 1983-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 03/04/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: E- Z- Go Textron

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 4, 1983, telling of your wish to build a four-wheeled light weight traffic enforcement vehicle similar to a three-wheeled machine manufactured by Cushman. You have asked whether you have to meet passenger car safety standards "or can we obtain a waiver for this vehicle only to comply with motorcycle safety standards?" You have enclosed a brochure on the vehicle you propose to modify, Textron's GX-800.

I am sorry to say that only vehicles with three wheels or less are defined as "motorcycles" for purposes of compliance with the Federal motor vehicle safety standards. Years ago, the agency totally excluded from the application of those standards four-wheeled vehicles with a curb weitht of 1000 pounds or less such as the GX-800. However, that exclusion was terminated in the early 1970's.

A manufacturer of 10,000 vehicles or less per year may petition for a temporary exemption from any safety standard where immediate compliance would cause substantial economic hardship. However, he must make a good faith effort to bring the vehicle into compliance during the exemption period. Although this would appear impossible with your vehicle because of its physical limitations, the agency has in the past exempted replicas of 1900-style vehicles where full compliance was manifestly not feasible. I enclose a copy of Title 49 Code of Federal Regulations Part 555 which sets out the exemption procedures. If your planned vehicle would have a cargo box, similar to the one on the Cushman vehicle, your vehicle could be considered a "truck" for compliance purposes.

As a car or truck, your vehicle would also have to comply with Federal fuel economy and emissions standards. Exemptions from fuel economy standards may be sought under 49 CFR Part 525. As to the emissions standards, you should write the Environmental Protection Agency.

ENC.

February 4, 1983

Ed Glancy Office of Chief Council National Highway Traffic Safety Adm.

Dear Mr. Glancy:

I have proposed that E-Z-Go Division of Textron Inc. build and market a traffic enforcement vehicle similar to the Cushman police vehicle (see enclosure).

I also propose that this vehicle should be a four wheeled vehicle for greater stability rather than a three wheeled vehicle.

This vehicle would be a modification of one of our current vehicles with the addition of a cab, rear bed enclosure, four wheel brakes, hand parking brake, larger diameter "DOT" tire, complete "DOT" lighting package, windshield wipers, seat belts, and a top speed of 35 M.P.H. (see our brochure).

My question is: Do we have to comply with automobile safety standards or can we obtain a waiver for this vehicle only to comply with motorcycle safety standards?

This vehicle would be sold primarily to city governments.

Thank you very much for your attention to this proposal.

John C. Dobbs Project Engineer

EZ-GO TEXTRON

Police Vehicle GASOLINE/ON-ROAD *

To the police officer or security patrolman, productivity takes on a more significant meaning. To provide security, the patrol vehicle must not only save steps and work, but it must be reliable enough to assure that the officer is in the right place at the right time. It must be responsive, maneuverable, and easy to get in and out of.

That's why thousands of hardworking Cushman Police Vehicles are currently in use across the nation. Police Vehicles are a natural for sufficiently mobilizing the patrolman, marking tires, transporting emergency and or just providing weatherproof comfort for traffic control officers.

The tight 17-foot (5.2m) clearance circle and narrow 48" (1219mm) width allow the Police Vehicle-mounted officer to park and go places conventional vehicles could never go. It easily maneuvers in cramped quarters or congested traffic.

And the 18-hp air-cooled OMC engine is specially designed to handle a full day of demanding stop-and-go driving on regular gas.

There's a big 16-cubic-foot (0.45m(3)) cargo box for carrying traffic cones, warning signs or other law enforcement or first aid equipment. The power-assisted, lockable steel lid provides easy access to all enclosed contents. And there is additional open storage space between the box and the cab.

Even when the weather is bad, the Police Vehicle is ready. It has a big 15" (381 mm) wiper, an optional heater/defroster and optional cloth or lockable steel doors to provide operator visibility and comfort, even in cold climates.

The Police Vehicle comes in Police blue and white. For municipal, military or private security patrol, the Cushman Police Vehicle is the proven productivity booster. It makes the most of every manhour on any force.

(Graphics omitted) SPECIFICATIONS/MODEL 434 POLICE VEHICLE

STANDARD EQUIPMENT/DIMENSIONS/ACCESSORIES/MODIFICATIONS (Illegible Text)

** NOTE: This vehicle complies with U.S. Dept. of Transportation Motor Vehicle Safety Standards applicable to motorcycles. Operators should wear helmets which meet Motor Vehicle Safety Standard 218 and are marked with symbol "DOT" Certain states laws require wearing of helmets and special license for motorcycle operators.

Drawbar Pull

(Level Ground Maximum Speed 39 MPH) 4.2:1 Axle Ratio Speed Drawbar Speed Drawbar Engine MPH Lbs. km/h kg RPM 1st 1st 1st 1st 2000 39 430 143 195 2400 107 490 172 222 2800 124 425 200 193 3200 142 400 229 181 3600 160 360 257 163

(Maximum Speed 29 MPH) 6.5:1 Axle Ratio Speed Drawbar Speed Drawbar Engine MPH Lbs. km/h kg RPM 1st 1st 1st 1st 2000 54 500 103 272 2400 77 615 124 279 2800 89 595 143 270 3200 102 560 164 254 3600 115 500 185 227

Gradeability ** Gross Gross 4.2:1Axle 6.5 to 1 Axle Weight Weight Gradeability % Gradeability % Lbs. kg 1st 2nd 3rd 1st 2nd 3rd 1200 544 39 23 14 50 33 20 1300 590 36 21 13 50 30 18 1400 635 33 19 12 49 28 17 1500 680 31 18 11 46 26 16 1600 726 29 17 10 42 24 15 1700 771 27 16 10 40 23 14 1800 616 25 15 9 37 21 13 1900 562 24 14 9 35 20 12 2000 907 23 13 8 33 19 11 2100 953 22 12 8 31 18 10 2200 998 20 11 7 29 17 9

* Gross vehicle weight equals weight of the vehicle, plus operator, plus payload.

** Calculated equivalent based on available power efficiency and axle ratio.

(Graphics omitted)

THE E-Z-GO GX-800. THE LASTING IMPRESSION IT LEAVES WON'T BE ON YOUR TURF.

E-Z-GO introduces a new concept in landscape maintenance. The light-turf vehicle that's perfect when you need a utility car, and a truck is too much.

It's as strong as an ox, but gentle as a lamb.

The E-Z-GO GX-800 is the perfect utility vehicle for landscaping. It's light and gentle on your valuable grounds. Yet it's strong enough to carry loads, climb hills, and ride in bad weather. The body is constructed of Galvanneal, steel plating that's treated with rust preventive zinc Oxide. So they drive the fairway longer than any other utility vehicle. The chassis is welded high-yield tubular steel. It features a protective vinyl bumper strip, and a four-way diamond pattern treadplate design on the bed makes the GX-800 stronger all around. (Loadbed is not Galvannealed).

Put all your garden tools to bed.

The GX-800 has a 44" x 40" x 8" loadbed in the back that's deep enough to carry all your turf tools. It carries up to 800 lbs., and heavy duty springs and shocks make the ride smooth and comfortable, no matter how tough the rough. The loadbed tilts for complete access to drive package. And the sides and tailgate are easily removed.

This beast is a beauty on your budget.

You can afford three GX-800 vehicles for the price of one heavy-duty pickup truck. It's light enough so that it's economical on fuel and requires only standard maintenance. And it'll last years and years because it's engineered by E-Z-GO.

The GX-800 is suited for anything.

From the electronic ignition, to the dual rear brake, to the hypoid ring and pinion differential, the E-Z-GO GX-800 light turf vehicle is strong enough for any landscaping job. Yet it is light enough so it won't be a landscraper. It's perfect for golf courses, cemeteries, public parks, office grounds-keeping, or large, private residential landscaping.

The GX-800 is especially a utility runabout. It's a tremendous timesaver for the superintendant who has to get around the grounds to oversee his crew. It can take the shortest route to its destination. For more information, call your nearest E-Z-GO representative.

E-Z-GO GX-800 LIGHT TURF VEHICLE.

CHASSIS/POWERTRAIN SPECIFICATIONS.

Engine: 2 cycle, 244CC single cylinder air cooled, oil injected with electronic ignition. Drive Train/Transmission: Variable speed, fully automatic, forward and reverse. Torque Converter: Automatic, variable speed, dry type. Differential: Hypoid ring and pinion, 12.25 to 1 ratio.

Brakes: Mechanical, drum type, dual rear wheel brakes with over 47 square inches swept area. Foot operated parking brake with automatic release. Electrical System: External starter/generator, 12 volt negative ground system, with forward and reverse starting. Speed: Governed at 12 MPH, adjustable. Air Cleaner: Dry, replaceable cartridge. Carburetor: Fixed jet, float bowl with separate fuel pump. Suspension: Front: Heavy duty leaf springs with shocks. Rear: Heavy duty coil springs with heavy duty shocks. Steering: Rack and pinion. Fuel System: 6 gallon capacity. DIMENSIONAL SPECIFICATIONS. Weight: 810 lbs, dry. Fuel capacity 42 lbs. Length: 106 inches. Width: 48 inches (at rear wheels). Height: 47 inches (at steering wheel). Floor Height: 11 inches. Load Bed Height: 24 inches. Ground Clearance: 5 inches (at differential). Seat Height: 29 inches. Wheel Base: 71 inches. Front Tread Centers: 32-1/2 inches.

Rear Tread Centers: 39 inches. Turning Clearance Diameter: 23 feet Tires: 18 X 8:50 X 8 Softrac. Load Capacity: 800 lbs. (including operator and passenger). Load Bed Size: 44 inches wide, 40 inches long, 8 inches deep. Capacity: 8 cubic feet. FEATURES AND OPTIONS. Features: 1. Load Bed: Tilts for complete access to drive package. Removeable sides and tailgate. 2. Chassis: Welded high yield tubular steel. 3. Body: Galvanneal body and heavy duty four-way diamond pattern treadplate truck bed. 4. Body Protection: Wrap-around vinyl bumper/rub strip, chrome front bumper, and flexible rear fenders. 5. Battery: Delco Freedom II, maintenance free. 6. Safety: Key switch and electric horn. OPTIONS: Lighting Package Chrome Hubcaps Hour Meter Turn Signals Specifications subject to change without notice.

ID: 1983-1.22

TYPE: INTERPRETATION-NHTSA

DATE: MARCH 4, 1983

FROM: HOUTAN MOSTAGHIM -- VICE PRESIDENT, PAN UNITED

TO: CHIEF COUNSEL -- NHTSA

TITLE: DOG CLIP.

ATTACHMT: MEMO DATED 3-21-83, FROM FRANK BERNDT, FROM HOUTAN MOSTAGHIM, NOA-30

TEXT: The purpose of this letter is to request official legal interpretation on a piece of safety device which, this company is currently intending to import and distribute in the territories of the United States.

This device refers to a so called "complimentory buckle component" of a seat belt, which is engaged and secured in a seat buckle component.

This device is designed to be attached and secured to the collar or homes of a pet in any vehicle with seat belt buckle component, in order to protect the driver from the pet's sudden and gross moves inside the vehicle.

For further clarification and explanation of this device, I am enclosing a copy of respective patent document for your kind review. This document is accompanied with a picture of the device in actual size, plus some other informative material and pictures.

What we need to find out are: 1-) Does this device apply to any of the National Traffic and Motor Vehicle Safety regulations? 2-) Do we need to obtain any kind of import permit from your organization to proceed with the importation of the device? 3-) Based on the regulations, does the device require any testing and licensing prior to actual commencement of importation? 4-) What types product liabilities should our company entertain, as the sole importer and distributor of this device? 5-) Can these liabilities be covered through appropriate insurance coverages. And if so, please kindly, supply us with a list of insurance companies that are currently involved in such underwritings. After the review of the material, you would realize that, this device is primarily designed to increase safety for the driver and other passengers, rather than the pet's. Therefore, we believe the prompt promotion and marketing of this device in the U.S., would directly contribute to relative improvement in highway and traffic safety concerns of your respected organization.

We would strongly entertain your suggestions, comments and advise on this matter. I am looking forward to your kind response, mean while I remain. ENCLS: AS STATED IN TEXT

ID: 1983-1.23

TYPE: INTERPRETATION-NHTSA

DATE: 03/11/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Anton Ostermeier

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of February 4, 1983, supplying the further information we requested on January 28.

The 1955 Mercedes replica which you contemplate building is a hybrid of new and old parts. The body is of your construction and consists of new parts. You fabricate the chassis using new tubing; however, its front cross member may be either a new replacement Mustang part (1974-1978 models) or one actually taken from a vehicle in use. Similarly, the front suspension, differential and rear suspension, and transmissions may be new replacement parts or taken from vehicles in use. You will employ used rear wheel cylinders in the braking system and used engines (either a 1964 Chrysler Slant 6 or a 1969 Chevrolet V-8). Any equipment that has previously been used will be rebuilt to the manufacturer's specifications, and new parts will be incorporated where necessary.

As a general rule, the agency has no requirements for "used" vehicles. Whether a vehicle is treated as new or used depends on the origin of its parts. For example, we regard an assemblage consisting of a new body on the chassis of a vehicle previously registered for use on the public roads as a "used" motor vehicle and therefore not subject to the Federal motor vehicle standards. On the other hand, the agency will consider a truck newly manufactured when an old cab is replaced with a new one unless at least the engine, transmission, and drive axle of the assembled vehicle are not new and at least two of these components were taken from the same vehicle.

The vehicle you propose to manufacture is somewhat different from either of these examples, but we have concluded that it is a "new" motor vehicle and must comply with Federal motor vehicle safety standards applicable to new passenger cars. Not only do previously unused parts appear to predominate in your plans, but, in addition, the old parts that are used will be rebuilt with new parts where necessary, to the manufacturer's original specifications. With the exception of the 1964 engine, the rebuilt components were originally used in vehicles manufactured to meet the Federal motor vehicle safety standards and there appears no reason why your product may not also be manufactured to comply, even though it is a replica of a 1955 car.

Use of the 1964 engine could raise problems of compliance with Safety Standard No. 124, Accelerator Control Systems, and with Safety Standard No. 301, Fuel System Integrity. However, in that event, we believe that you (as a producer of less than 10,000 vehicles a year) would be eligible to apply for a temporary exemption from those standards, or any other standard where immediate compliance would cause you substantial economic hardship. I enclose an information sheet which tells you where you may obtain a copy of our regulations, including the standards and temporary exemption petition procedures.

If you have further questions, we would be happy to assist you.

ENC.

U.S. Department of Transportation National Highway Traffic Safety Administration

Frank Berndt Chief Counsel

February 4, 1983

Dear Mr. Berndt,

General Description of the products used in the construction of the 300SL Mercedes Replica by Gullwing Car, Inc. 19240 South Vermont Avenue, Gardena, Calif. 90248. (213) 324-9847 as follows.

Frame;

The frame is of square steel tubing construction, using new tubing. Sizes are as follows;

1" x 1" x .065

1" x 1" x .090

.75 x .75 x .065

.75 x .75 x .125

3" x 2.5" x .375

3/16" flat stock

The front cross member is 1973 to 1979 Mustang 11. This assembly is purchased both new old stock and used. It is welded into our frame assembly using original weld points, angles, forward aft locations and ground clearances. Even the axel weight has been maintained as prescribed for the 1973 to 1979 Mustang 11 manufacturing specifications. This unit is assembled and jig built as shown by previously supplied pictures the Dept. of the Chief Counsel, this insures the product uniformity.

Bumpers both front and rear;

Bumpers are constructed of stamped nickel chrome plated steel as orginally manufactured for the 1953 thru 1957 Gullwing 300SL. It is bolted to the frame through spring steel brackets as was the original production car.

Front Suspension;

The front suspension used is the 1973 to 1979 Mustang 11 and is used in its entirety. This suspension is purchased both new old stock and used. When purchased used, units are completely disassembled. Basic units are inspected to assure conformity to the original manufacturers specifications, then reassembled using new parts. i.e. all new bushings, all new bearings, bearing races and seals. The stearing gear is stock 1973 to 1979 Mustang 11 rack and pinion and is installed as prescribed for the 1973 to 1979 Mustang 11 by the manufacturer. Front end alignment as to Caster, Camber, Toe-in, suspension travel and clearances are maintained as originally designed.

Differential and Rear Suspension;

The products used is the 1979 to 1983 Ford Fairmont rear suspension and differential, it is used in its entirety unaltered. It is installed in our frame to the exact same specifications as it would be installed in the 1979 to 1983 Ford Fairmont frame, i.e. clearance, mounting points, angles and travel. These specifications and locations are maintained by the jig building of our frame. These units are purchased both new old stock and used. When purchased used they are disassembled, inspected and rebuilt to original manufacturer specifications using new bearings, bearing races, seals, gaskets and gears where ever necessary.

Brakes;

The rear brakes are drum type 10" x 1 and 3/4" hydraulicly operated. They are the original brakes for the 1978 to 1983 Ford Fairmont. They are installed unaltered and in there entirety. New brake lining and wheel cylinders are used and assembled to the original manufacturers specifications. The front brakes are of Disc type and are used in there entirety as prescribed for the 1972 to 1979 Mustang 11. The lining is new and the wheel cylinders are rebuilt with new parts to original manufacturers specifications.

Brake Lines;

Flexible brake lines both front and rear are original equipment type.

Master Cylinder;

Master cylinder is the duel type vacuum boosted as used in 1979 to 1983 Ford Fairmont. Hydraulics to wheels is supplied through compatable differential valve and andoized double flared steel tubing and is of the sizes and routing using the practices of the manufacturers. note: Vehicle weight is between 2,050 lbs and 2,500 lbs.

The brakes system employed is capable of handling a 3,200 to 3,800 lb vehicle and is more than adequate.

Engines;

Two engines are available in our Gullwing Replica. They are 1964 225 cubic inch slant 6 Chrysler engine and the 1969 350 cubic inch V-8 Chevrolet engine. The engines are purchased used and rebuilt to the original manufactures specifications, using new parts where ever necessary.

Transmission;

The transmission selections are as follows, for the Chrysler slant 6 the Borge Warner 4 speed standard shift transmission and the aluminum automatic 3 speed torque flight transmission. For the Chevrolet V-8 engine the 4 speed Munci transmission and 350 hydromatic transmission are used. These units are purchased both new old stock and used. When purchased used they are completely disassembled, inspected and reassembled to manufacturers specifications, using new parts when ever necessary.

Body;

Body is constructed of four layers, first layer of epoxy, second layer of 2oz fiberglass matting and epoxy, third layer 4oz fiberglass matting and epoxy, fourth and inside final layer of 2oz fiberglass cloth and epoxy. Fiberglass sequence is layed up in a female mold and Kiln dried for optimum cure and strength. Through temperature control. note: enclosed in the windshield frame is a 3/4" x 3/4" x .090 square tubing. Center section of roof contains steel support and hinge box, a rear window support also of 3/4" x 3/4" x .090 square tubing. The center hinge box assembly is bolted to front and rear window support tubing. When completely assembled driver and passenger are protected 360 degrees with steel bolted to frame assembly. On both left and right sides by no less than 8 inches of bridged frame work, not to mention inner and outer epoxied fiberglass panels and padded leather upholstery.

Lights;

Headlights are seal beam type, rear tail light lens are the reflector type required. Fully automatic signal and hasard lights are incorperated.

Glass;

All glass is new. Front windshield is two layered safety glass as prescribed by D.O.T.S. Door glass left and right is of the tempered type required by D.O.T.S. Left and right 1/4 windows, is also of tempered type required by D.O.T.S. As is the back window glass.

Rims and Tires;

Rims and tires are both 14" and 15", customers obtion. They will be supplied new old stock and new only.

The above is a summary of my replica's construction. I hope this supplies you with the information you requested to assist me with my list of requirements. Please contact me for any further information you may require.

ID: 1983-1.24

TYPE: INTERPRETATION-NHTSA

DATE: 03/11/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: J.V.R. Enterprises -- Robert A. Wirffel

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Robert A. Wirffel J.V.R. Enterprises 8511 No. Canterbury Avenue Sun Valley, California 91352

Dear Mr. Wirffel:

This in reply to your letter of February 6, 1983, to Mr. Vinson of my staff regarding the legality under Federal Motor Vehicle Safety Standard No. 108 of your "Safe-T-Signal" directional indicator. The signal, and 8-inch amber arrow, is located under the right side of a semi-trailer, approximately at mid point, and is intended to warn vehicles in the adjacent right traffic lane that the semi-trailer makes wide right turns. The system supplements the trailer's existing turn signal, as we understand it.

There is nothing in Standard No. 109 that prohibits use of your system as it does not appear to impair the effectiveness of the lighting equipment, such as turn signals, required by Standard No. 108 as original equipment. However, you must insure that it is permitted in States in which the device is likely to be used.

We note the statement in your letter that the amber arrow is "D.O.T. approved" and in your descriptive sheet as well, plus the statement that is "conforms to applicable federal motor vehicle standards (C.H.P approved) ." This is legally incorrect, as the U.S. Department of Transportation does not "approve" lighting equipment , nor does Standard No. 108 specify requirements with which a supplementary turn signal system must conform. If you wish to assure prospective purchasers that Federal requirements as "Permissible under Federal Motor Vehicle Safety Standard NO., 108."

Sincerely,

Frank Berndt Chief Counsel

ID: 1983-1.25

TYPE: INTERPRETATION-NHTSA

DATE: 03/11/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Ms. Susan Reilly -- Reilly Manufacturing

TITLE: FMVSS INTERPRETATION

TEXT:

Ms. Susan Reilly Reilly Manufacturing P.O. Box 51 Mt. Vernon, Iowa 52314

Dear Ms. Reilly:

This responds to your letter asking whether a motorcycle helmet fastener your company produces, called "Alpha Clip," complies with Federal requirements.

By way of background information, this agency does not give approvals of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to ensure that its vehicles or equipment comply with applicable standards.

Safety Standard No. 218, Motorcycle Helmets, includes various minimum performance requirements for motorcycle helmets. The only requirement directly relevant to your fastener is the retention test, which is set forth at section S5.3. The letter you enclosed from the University of Southern California suggests that the clip passes that test.

I would note that Standard No. 218 only applies to new motorcycle helmets and not to replacement equipment for motorcycle helmets. Thus, unless your clip was sold as part of a new motorcycle helmet, the requirements of Standard No. 218 would not be directly applicable. (Please note, however, that the agency discourages helmet users from modifying their helmets. Section S5.6.1 of the standard requires that the following instruction be placed on helmets: "Make no modifications..")

I would also note that should a safety-related defect be discovered in your device, whether by the agency or by yourself, you as the manufacturer would be required under sections 151 et seq. of the Act to notify owners, purchasers, and dealers and provide a remedy for the defect. These provisions apply regardless of whether the device is covered by a safety standard. A copy of the Act is enclosed.

Sincerely

Original signed by Frank Berndt, Chief Counsel

Reilly Manufacturing P.O. Box 51 Mt. Vernon, IA 52314 (319) 895-8479

Mr. Frank Berndt 400 Seventh St. SW Washington, DC 20590

Dear Mr. Berndt:

At the advice of Mr. Gilky of the NHTSA Safety Compliance Office I am writing for your judgement as to the compliance of our Motorcycle Helmet Fastener to Federal requirements. We believe the "Alpha Clip" meets all requirements and is a safe and reliable product. I have included the clip, packaged for mail order, for your review. As of now, we market only the clip, not O-rings or helmets, and the consumer is responsible for installation.

I have also included a copy of a (unreadable) of U.S.C.. He then tested our fastener as a public service. Since receiving his letter we've added a plastic vinyl cap fitted to the hook, creating an interference fit.

Other recent information is as follows: 1 The hook is designed to fold in within itself when tension is released (we are in the process of moving the design patented)

2. Made of nickel plated (unreadable) steelwire of .142 +.005 - .000 inches dia. Length .900 I .020 in., width l.l90 I .020 in., width .702 I .010 Weight .

3. Has a deformation point of 600 pounds tensile

4. Does not protrude from the helmet

5. Installs directly to helmet strap - nothing is removed from the helmet.

I have also sent a clip and information to Mr. B. Roven, Coordinator of Motorcycle Safety for the Iowa DOT, if you wish to contact him for comment. Please let us know your judgement on our clips compliance as soon as possible.

Thank you for your time and cooperation.

Sincerely, Susan Reilly

June 3, 1983

Mr. Steve Reilly RR 2 Mount Vernon, IA 52314

Dear Steve,

Thank you for sending your new retention clip to us for evaluation. Professor Hurt asked me to run some tests on it and give you some comments.

The beauty of your clip design is that it could be retrofitted to most helmets providing a much more convenient method of fastening than conventional D-rings.

The first test I did was to use your clip on a complete helmet for the actual DOT retention test. Enclosed is that portion of the standard. I used an Electro E3 which has an extremely strong retention system. This choice of helmets made your part the weak link. With the Reilly clip in place, the test result was 0.54 inch elongation @ 300 lbs., about normal for an Electro. The clip showed no deformation at this load.

Taking the entire system up in loading, the strap began to slip at 640 lbs. when the unwelded ends of the clip deformed. This load at failure is typical for many helmets that pass the DOT requirements.

The problem that your design has is answered by many industrial safety codes that require a safety snap latch on all hooks. This spring-loaded device swings inward when engaging the hook and then returns to block the throat of the hook creating a closed loop. Bell Tourlite bicycle helmets use a somewhat similar hook with a safety latch made by Fastex. A less satisfactory solution would be to close up the radius of the hook bend to create an interference fit onto the D-ring.

Please feel free to send out any future revisions to us for evaluation. As with the better mousetrap, the world is ready for a better helmet retention strap fastener.

Sincerely, Original signed by David Thom, Laboratory Technician

ID: 1983-1.26

TYPE: INTERPRETATION-NHTSA

DATE: 03/18/83 EST

FROM: FRANK BERNDT -- NHTSA CHIEF COUNSEL

TO: LINDA ANDERSON

TITLE: NONE

ATTACHMT: NOVEMBER 21, 1982 LETTER FROM ANDERSON TO OESCH IS ATTACHED

TEXT: This responds to your November 21, 1982, letter and subsequent January 12, 1983, letter submitting supplementary information concerning a play tray that you want to produce. You ask in general whether that tray would be required to comply with any of the requirements applicable to child seating systems in Standard No. 213, Child Restraint Systems. In a conversation that you had with Mr. Roger Tilton of my staff, you indicated that you no longer need information relating to the first two questions raised in your November letter. Accordingly, we will focus on the other issues that you raised.

The play tray that you describe would be attached to a child seat by the use of velcro fasteners secured around the restraint belts of the child seat. You state that the restraints would have to be in their proper position before the tray, which itself is not designed as a restraint, could be attached. You ask whether a manufacturer of a child seat could sell such a tray as a part of its child seating system or whether it could be marketed separately.

If the play tray were marketed as part of a child seat, it would be required to comply with all of the requirements of the standard applicable to child seats. Section S5.2.2.2 prohibits any fixed or moveable surfaces in front of the child except for surfaces that adequately restrain the test dummy in the 20 mph test. If the tray attached to the child restraint so that it is the only surface in front of the child, the child restraint would have to be tested with just the tray as specified in Section S5.2.2.2. It does not appear likely that the tray would comply with those requirements.

If your tray is manufactured and marketed separately to consumers who own child restraint systems, it would not be required to comply with the requirements of Standard No. 213. That standard applies to new child seating systems that are designed to restrain, seat or position children. Your tray sold by itself would not constitute a child seating system designed to restrain, seat or position children and thus would not be subject to this standard.

You should be aware, however, that your tray would be considered motor vehicle equipment. As such it would be subject to our defect authority. If it were found that a substantial number of your trays were being improperly used as the sole restraint device on a child seat by connecting the tray without using the proper seat belt restraint system, the agency might determine that this constitutes a safety-related defect. Also, this could be the source of product liability suits in the event that your tray was involved in an accident where a child is injured while improperly restrained. From our analysis of your diagrams, this type of misuse appears to be likely.

In a final question, you asked whether the regulations ever change. The answer to that question is yes. The agency frequently amends its own regulations acting upon new information or changed safety needs. Further, the agency receives petitions from members of the public to amend its regulations. The process for submitting those petitions is outlined in Part 552 of our regulations (copy enclosed).

Enclosure

ID: 1983-1.27

TYPE: INTERPRETATION-NHTSA

DATE: 03/21/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: China United Trading Corp. Ltd. -- Yang Ru-Tang, General Manager

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter asking about the requirements for importing tires into this country from China. I have enclosed a copy of a 1981 letter I sent to Mr. Deng Shin-Wen, the chief engineer of the Shanghai No. 1 Rubber Plant. That letter generally explains the requirements which must be met in order to import tires into this country. While that letter answers many of your questions, I will repeat the requirements to ensure that you understand them, and respond to those questions not covered in the previous letter.

To receive a DOT code mark, a tire manufacturer must complete the enclosed application form and return it to the address shown on the form. A separate application must be filed for each manufacturing plant, and a separate code mark will be assigned to each plant.

Before a code mark is assigned, the tire manufacturer must designate an agent for the service of process, according to the requirements of 49 CFR @ 551.45 (copy enclosed). That section specifies that the designation of agent must meet the following six criteria:

1. A certification that the designation is valid in form and binding on the manufacturer under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made;

2. The full legal name, principal place of business and mailing address of the manufacturer;

3. Marks, trade names, or other designations of origin of any of the manufacturer's products which do not bear his name;

4. A statement that the designation shall remain in effect until withdrawn or replaced by the manufacturer;

5. A declaration of acceptance duly signed by the agent appointed, which may be an individual, a firm, or a U.S. corporation; and

6. The full legal name and address of the designated agent.

In addition, the designation must be signed by one with authority to appoint the agent; the signer's name and title should be clearly indicated beneath his signature. When this agency has received a completed application for a code mark and a valid designation of an agent, a code mark will be assigned to the manufacturer promptly, usually within two weeks. You should note that the code mark is sent to the manufacturer at the mailing or main office address shown on the application, and not to the designated agent. The DOT code mark assigned to the manufacturer remains valid until such time as the manufacturer notifies this agency that it is no longer using that code mark.

No testing of the tires is done by this agency before assigning the DOT code mark. The United States does not use a certification process similar to the European Economic Community, in which the manufacturer is required to deliver tires to be certified to the governmental entity for approval. Instead, in the United States the individual manufacturer must certify that the tires comply with all requirements of Standard No. 109 (49 CFR @ 571.109) if they are passenger car tires or Standard No. 119 (49 CFR @ 571.119) if the tires are for use on motor vehicles other than passenger cars. I have enclosed copies of both these standards for your information. Further, this agency does not require that the certification be based on a specified number of tests or any tests at all; we only require that the certification be made with the exercise of due care on the part of the manufacturer. It is up to the individual manufacturer in the first instance to determine what data, test results, or other information it needs to enable it to certify that its tires comply with the applicable standards. Certainly, we recommend that a manufacturer selling tires in the United States test those tires according to the procedures specified in the applicable standard. Once a manufacturer determines that its tires meet the requirements of the applicable standards, it certifies that compliance by molding the letters "DOT" on one sidewall of each certified tire.

For purposes of enforcement this agency conducts spot checks of tires after they have been certified, by purchasing and testing tires according to the procedures specified in the applicable standard. If the tires pass the tests, no further steps are taken.

If the tires fail the tests and are determined not to comply with the applicable standards or if it is determined that the tires contain a safety-related defect, the manufacturer of the tires is required to remedy the problem. Section 154(a)(2)(B) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1414(a)(2)(B)) specifies that, in the case of tires which fail to comply with a standard or contain a safety related defect, the manufacturer may elect to either:

(1) repair the tires so that the defect or noncompliance is removed; or

(2) replace the tires with an identical or reasonably equivalent tire which does not have the defect or noncompliance.

Whichever of these options is chosen, the tire manufacturer must bear the expense and cannot charge the tire owner for the remedy.

With respect to the markings required on the sidewall of the tires, those markings and their required size and location are set forth in section S4.3 of Standard No. 109 for passenger car tires and S6.5 of Standard No. 119 for tires for use on motor vehicles other than passenger cars. 49 CFR Part Part 574 (copy enclosed) also sets forth marking requirements for all types of tires.

If you have any further questions on this subject or need further information, please feel free to contact me.

ENCLS.

Jan. 19, 1983

OCC

Raymond Peck, Administrator, Department of Transportation National Highway Traffic & Safety Administration,

Gentleman,

We are China United Trading Corp. Ltd., Shanghai Division, newly established and located at One Penn Plaza Suite 1915, 250 W 34th St., New York, N.Y. 10119, and are agent of some import & export corporations in Shanghai, China. Now China National Chemicals Import & Export Corp., Shanghai Branch, located at 27 Zhongshan Road (E.1), Shanghai, China, who are the exporter of tires manufactured in Shanghai, intends to export and sell their truck and car tires in the United States.

We understand that an application must be made and approved with a Code Number before any foreign tires can be imported and sold in the U.S. market. In this connection, we need to get the following information with your assistance.

1. Is your office the right organization for the application to be submitted?

2. Should the application be made by the manufacturers or by their agent as mentioned above? What is the procedure in detail?

3. What is the procedure for quality examination of tires before you issue the Code No. and allow importation? Do you have your own laboratories for test or appoint any ones for test? Where shall the exporters or their local agents submit samples of tires for such a test?

4. Should each size, specification of the tires be tested in this way? How many tires are necessary as samples to complete such a test?

5. Is it necessary for the tires to be tested before they are allowed to be sold or to be tested by random selection at anytime from the market after selling?

6. If the tire does not pass the sellective examination, can re-examination be made or not? Is there any restriction for the re-examination?

7. What kind of responsibility would be borne by the manufacturer if the product does not pass the quality examination requirements? Is there any penalty in this respect?

8. Would the quality records by selective examination or test report be informed to the manufacturer?

9. What kind of reponsibility should be borne by the application agent and/or the manufacturer if any quality problems arise when a vehicle is in performance?

10. After DOT approval, where and what size should the DOT Code Number be put on the tires? Besides the DOT Code Number, what else are also necessary to be shown on the tires?

11. Once the DOT approval has been obtained, how long will it remain valid?

Please send us some papers concerning the above questions, if you have any.

Your early reply and assistance will be highly appreciated.

general manager yang Ru-tang

China United Trading Corp. Ltd., Shanghai Division

ID: 1983-1.28

TYPE: INTERPRETATION-NHTSA

DATE: 03/21/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Gold Bug

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 9, 1983, letter asking about the compliance of a device that you manufacture with Federal motor vehicle safety standards. The device is a head support for children which has several uses, one of which would be in a car seat. You specifically ask to obtain the Federal seal for use on your package.

Only those items of equipment to which specific Federal safety standards apply are marked with the DOT symbol which indicates that they are in compliance with applicable safety standards. From our analysis of your product, it is not a piece of equipment subject to any Federal motor vehicle safety standard. Since your device does not need to comply with any of our requirements, you would not need, nor would you be permitted to use, the DOT symbol.

We would recommend, however, from a product liability point of view that you ensure that your product complies with flammability requirements. I am enclosing a copy of our flammability standard that you might use as a guideline, although as I stated earlier, you would not be required to comply with this standard.

ENC.

February 9, 1983

Diane Steed National Highway Traffic Safety Administration

Dear Ms. Steed,

Your name was given to us by Diane Emrick of the Colorado Division of Highway Safety.

We manufacture a product called Head Up. We are enclosing a sample for your inspection.

We would like to put the National Seal on the package. As you can see the Colorado Division has approved this item.

Please let me know the procedures for acquiring the National Seal. Thank you.

Robert P. Eschino, Vice President