ID: 1982-1.18

TYPE: INTERPRETATION-NHTSA

DATE: 02/25/82

FROM: AUTHOR UNAVAILABLE; S. P. Wood for F. Berndt; NHTSA

TO: Indiana Mills & Manufacturing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking whether paragraph S4.2.2 of Safety Standard No. 208, Occupant Crash Protection, is applicable to school buses with a GVWR of 10,000 pounds or less.

The answer to your question is yes. Safety Standard No. 222 specifies in paragraph S5(b) that all seats, other than the driver's seat, in school buses with a GVWR of 10,000 or less shall meet the requirements of Safety Standard No. 208 as they apply to multipurpose passenger vehicles. The requirements for multipurpose passenger vehicles in Standard No. 208 are found in paragraph S4.2.2 for vehicles manufactured on or after January 1, 1976. There is no exception in S4.2.2 which allows school buses to comply with S4.2.1.2 of Standard No. 208.

School buses are not specifically mentioned in paragraph S4.2.2 of Standard 208, because that standard includes separate requirements for buses (including school buses) in paragraph S4.4. Under the general bus requirements of Standard 208, only the driver's position must be equipped with a seat belt. These requirements are supplemented by the more specific provision in Standard No. 222 which, as noted earlier, requires small school buses to meet the requirements of Standard 208 as they apply to multipurpose passenger vehicles.

I hope this has clarified your understanding of the requirements of these two standards. Please contact Hugh Oates of my staff if you have any additional questions (202-426-2992).

Sincerely,

ATTACH.

December 1, 1981

Frank Berndt, Chief Counsel -- National Highway Traffic Safety Administration

Dear Sir:

Federal Motor Vehicle Safety Standard 222, "School Bus Passenger Seating and Crash Protection" requires school buses with a GVWR of 10,000 lbs. or less to meet the requirements of FMVSS 208 for multi-purpose passenger vehicles at all seating positions other than the driver's seat.

Section 4.2.2 of FMVSS 208 does not specifically refer to school buses. It is our understanding that they are considered an exception under S4.2.2, and may instead meet the requirements of S4.2.1.2.

Please send us your official written opinion regarding the applicability of S4.2.2 of Standard No. 208 to school buses with a GVWR of 10,000 lbs. or less.

We appreciate your assistance.

Yours very truly, William E. Lawler -- Specifications Manager, INDIANA MILLS & MANUFACTURING, INC.

ID: 1982-1.19

TYPE: INTERPRETATION-NHTSA

DATE: 02/26/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Malcolm J. McCalmon -- International Sales Manager, CENTRA Leichtmetall - Rader GmbH

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter to Mr. Kratzke of my staff concerning the Federal requirements for vehicle wheels that are to be imported into the United States. You noted in your letter that the wheels would be for "original equipment on passenger vehicles and non-passenger vehicles (recreation vehicles)." There are two Federal Motor Vehicle Safety Standards which apply to wheel rims. There are no standards applicable to the rest of the wheel assembly, however.

The two applicable standards are No. 110, Tire selection and rims - passenger cars, and No. 120, Tire selection and rims for motor vehicles other than passenger cars. I have enclosed copies of both standards, along with Standards Nos. 109 and No. 119, which are applicable to tires. For those passenger car rims you manufacture there are two requirements, specified in section S4.4 of Standard No. 110. First, the rim must be constructed to the dimensions of one of the rims that is listed under the definition of a test rim in Standard No. 109. This means that the rim must comply with the dimensional specifications shown for that rim size in the current publications of specified standardization organizations, such as the Tire & Rim Association, the European Tyre and Rim Technical Organization, or the Deutsches Institut fur Normung. Second, in the event of a rapid loss of inflation pressure with the vehicle travelling in a straight line at 60 miles per hour, the rim must retain the deflated tire until the vehicle can be stopped with a controlled braking application.

For those rims you manufacture for use on vehicles other than passenger cars, Standard No. 120 also specifies two requirements. The first requirement, set forth in section S5.1.1, is that the rims on a vehicle must correspond with the size tire on the vehicle, i.e., be listed as suitable by the tire manufacturer, pursuant to either Standard No. 109 or No. 119. This would be done in the publications of the standardization organizations, as explainted above. This requirement is the responsibility of the vehicle manufacturer, since only it knows what size tires will actually be on the vehicle. The second requirement, set forth in section S5.2, is that the rim must be marked with certain specified information.

When a rim manufacturer determines that its rims comply with the requirements outlined above, it may certify the rims and sell them in the United States. In your letter, you inaccurately stated that there is no a specific DOT certification for rims. While there is no specific DOT certification number, as required by some other standards for items of equipment other than rims, a manufacturer must always certify that each item of motor vehicle equipment complies with all applicable Federal motor vehicle safety standards, pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1403) (copy enclosed). That section specifies that the certification for items of motor vehicle safety equipment, including rims, may be in the form of a label or tag on the item, or on the outside of a container in which the item is delivered. All of your rims to be sold in this country must contain such a certification.

The United States does not use a certification process similar to the EEC, in which the manufacturer delivers the item to be certified to the governmental entity, and that entity tests the item to determine if it can be certified. Instead, in the United States, the individual manufacturer must certify that the product complies with all applicable standards. Further, this agency does not require that a certification be based on actual tests of the equipment; 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 to determine in the first instance exactly what data or information it needs to allow it to certify that the equipment meets all applicable Federal standards. Obviously, with respect to the requirements for rims, a manufacturer is not expected to test if the rims have the necessary markings or if the rim size is listed in one of the publications of a standardization organization.

Should you have any further questions about these standards, feel free to contact me. If you need further information about the actual process of importing the rims into the United States or the form for the certification, you can contact the U.S. Customs Service Duty Assessment Division at 1301 Constitution Avenue, N.W., Washington, D.C. 20229.

SINCERELY,

ATTACH.

STEVEN KRATZKE -- Office of Chief Counsel, National Highway Safety Adm

JANUARY 25, 1982

Dear Mr. Kratzke,

We are a wheel manufacturing corporation in West Germany and we wish to insure that our wheels also comply with the U.S. D.O.T. requirements, specifically for original equipment on passenger vehicles and non-passenger vehicles (recreation vehicles).

In a phone conversation with Mr. Art Casanova from the N.H.S.A. I found out that there is not a specific D.O.T. certification, there is only a specific marking requirement, as written in Article No. 571-120. Mr. Casanova stated that as long as we marked our wheels as required, we comply with D.O.T. standards, he suggested that I write to you to get an official letter stating the same.

If there are more rigid requirements please let me know exactly what is required and send me instructions on how to accomplish what ever needs to be done.

Thanking you in advance I remain

Sincerely Yours,

Malcolm J. Mc Calmon -- Intern Sales Manager, CENTRA GMBH

ID: 1982-1.2

TYPE: INTERPRETATION-NHTSA

DATE: 01/06/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Rogers Ferraro & Cody, P.C.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 2, 1981, to Dr. Robert L. Henderson of this agency asking for an opinion regarding the legality of a warning system devised by your client, David Stepkin.

Mr. Stepkin's system "flashes the rear brake lights continuously when either brake is applied on a motorcycle." With respect to Federal regulation of motorcycle lighting systems, I refer you to 49 CFR 571.108, Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment, a copy of which is enclosed. Paragraph S4.6(b) in essence requires that brake lamps (or stop lamps as we call them) be steady burning. This requirement would appear to preclude use of your system.

In addition, the substitution of a flashing signal for the steady one to which the public is accustomed might create confusion, thereby impairing the effectiveness of the stop lamp. You will note also that paragraph S4.1.3 prohibits the installation of motor vehicle equipment that impairs effectiveness of required lighting equipment.

ENC.

ROGERS FERRARO & CODY, P. C.

December 2, 1981

Dr. Robert L. Henderson c/o NHTSA Driver and Pedestrian Research Department of Transportation

Re: Motorcycle-Pulsating and/or Modulating Rear Lights

Dear Dr. Henderson:

I am an attorney who practices in the State of New York and I represent the interests of one, David Stepkin. Mr. Stepkin has devised a warning system which basically flashes the rear brake lights continuously when either brake is applied on a motorcycle. Of course, the purpose of the item is to create rear visability and therefore to prevent the driver of another vehicle travelling behind a motorcycle, from striking the motorcycle due to poor visability.

I am sure you are aware of the fact that motorcyclists are one of the highest prospective candidates for injuries on our roads. Mr. Stepkin, and I as his attorney, feel that this particular item would certainly help to reduce that statistic.

The item in question is a small unit which is attached by splicing the wire between the brake light switch and the rear brake light. The unit is then attached and is ready for operation. Mr. Stepkin, of course, considered attaching the unit to the rear of the bike but has found that this approach is impractical since many bikes will not accommodate an additional auxilliary light. Experience has shown that this is the most effective and practical method. It also, of course, saves energy because no additional lights are needed.

It has come to our attention that there may be certain restrictions in the use of these particular lights. However, we feel that this particular mechanism should not be in conflict with any such regulations because the filament of the bulb is always on.

I am not aware of any specific regulation outlawing such items on the Federal level and certainly, we have been able to ascertain that no such regulation outlawing such lights exists on the State level.

Therefore, I would appreciate it if you would take the time to drop us a short letter advising us whether any regulations concerning this particular item exist and, if you have a copy of those regulations, we would appreicate receiving same. If you feel that the matter should be handled by another department, please advise and we will forward it promptly.

I wish to thank you in advance for your time and courtesy in this matter.

THOMAS J. CODY

ID: 1982-1.20

TYPE: INTERPRETATION-NHTSA

DATE: 03/02/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Indiana Mills & Manufacturing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 2 1982

NOA-30

Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing, Inc. 120 West Main Street Carmel, Indiana 46032

Dear Mr. Lawler:

This responds to your recent letter requesting an interpretation concerning paragraph S4.3(c)(1) of Safety Standard No. 209, Seat Belt Assemblies. You ask for clarification of the cases in which a 5,000-pound attachment bolt may be used in lieu of a 9,000-pound bolt.

Paragraph S4.3(c)(1) of Standard No. 209 specifies that attachment bolts used to secure the pelvic restraint of a seat belt assembly to a motor vehicle shall withstand a force of 9,000 pounds, except that "attachment bolts of a seat belt assembly designed for installation in specific models of motor vehicles in which the ends of two or more seat belt assemblies cannot be attached to the vehicle by a single bolt shall have a breaking strength of not less than 5,000 pounds." The intent of the requirement in S4.3(c)(1) is to assure that inadequate attachment bolts will not be used to attach seat belt assemblies to a vehicle. A 5,000-pound bolt may be used only if the belt assembly is designed for use in specific models of vehicles in which only one end of a belt assembly can be attached by a single bolt.

In answer to your question, the agency does not "have in mind" certain brands or models of vehicles which would qualify under this exception, and the exception is not limited to single-seat vehicles. Further, the requirement does not mean that a seat belt assembly that can be used in more than one application must be installed with a 9,000-pound bolt. If a particular assembly is designed for use in several different models in all of which only one end of the belt assembly can be attached by a single bolt, then a 5,000-pound bolt is sufficient. The distinction is that an aftermarket belt for universal application must be accompanied with a 9,000-pound bolt, because in some vehicle models it would be possible to mount two ends of seat belt assemblies with a single bolt.

You should note that paragraph S4.1(k) of Standard No. 209 requires the manufacturer of seat belt assemblies for aftermarket use to furnish an instruction sheet stating whether the assembly is for universal installation or for installation only in specifically stated motor vehicles. If you - provide 5,000-pound bolts for any of your assemblies, the instruction sheet required by S4.1(k) should specify that the assemblies are to be used only in the vehicle models you list.

I hope this has answered all your questions.

Sincerely,

Frank Berndt Chief Counsel

January 26, 1982

Mr. Frank Berndt, Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street S.W., Room 5219 Washington, D.C. 20590

Dear Sir:

Paragraph S4.3(c)(1) of Standard No. 209 (49 CFR 571.209) requires a 9,000 lb. breaking strength attachment bolt "...except that..." 5,000 lb. breaking strength attachment bolts may be used under certain conditions.

We are uncertain about the intent of two phrases in Paragraph S4.3(c)(1):

1. "...designed for installation in specific models of motor vehicles...", and

2. "...ends of two or more seat belt assemblies cannot be attached to the vehicle by a single bolt...."

With regard to the first phrase, does the National Highway Traffic Safety Administration have in mind certain brands, models, or types of vehicles? Does the phrase mean that a given seat belt assembly must be designed for a given application in order to attach it (in that application) by 5,000 lb. breaking strength bolts? Conversely, does the phrase mean that a seat belt assembly that may be used in more than one application must be installed using 9,000 lb. breaking strength bolts?

Phrase two raises questions, also. Does it mean that the 5,000 lb. breaking strength bolt may be used only with single seat vehicles? If a vehicle has more than one seat, must the seats be situated so that it is physically impossible to mount (for example) the right end of the left seat belt assembly and the left end of the right seat belt assembly to the same bolt? If the attachment hardware is designed to accomodate one and only one attachment bracket on a single attachment bolt, may a 5,000 lb. breaking strength bolt be used?

We would appreciate receiving from you an official written explanation of the intent of S4.3(c)(1) of Standard No. 209.

Thank you for your assistance.

Yours very truly,

William E. Lawler Specifications Manager

WEL:ld

ID: 1982-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 03/05/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: BMW of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter asking several questions about the use of informational readout displays in relation to FMVSS 101-80, Controls and Displays; 105, Hydraulic Brake Systems; and 208, Occupant Crash Protection.

Each of your questions assumes the use of informational readout displays as telltales. The light intensity requirements of Standard No. 101-80 currently prevent informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section requires that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.

The agency has recently issued a notice of proposed rulemaking (NPRM) that would permit informational readout displays to be used as telltales. We have enclosed a copy of that notice.

I would like to point out the following statement in the NPRM:

Various amendments may be necessary to Standard No. 101-80, as well as to several other safety standards which include requirements for warning indicators, to permit fuller use of informational readout displays. The amendments proposed by this notice are a first step in that direction.

We would welcome any comments that you might have on this matter to assist us in future rulemaking. You may also wish to consider submitting a petition for rulemaking on any changes that you believe should be made.

The following discussion explains the effect that the proposal would have on your questions.

Question 1

Your first question asks whether the words "Fasten Seat Belts" may be used in an informational readout display instead of the seat belt warning symbol under FMVSS 101-80 and 208. The answer would be yes under the proposal. The NPRM states:

Sections S4.5.3.3(b) and S7.3 of @ 571.208 would be amended to permit the words "Fasten Belts" or "Fasten Seat Belts" as an alternative to the seat belt warning symbol in informational readout displays.

Question 2 Your second question concerns the possibility of allowing cancellation of telltales by voluntary action on the part of the driver. The question asks whether it is permissible to provide a push button that enables drivers to cancel telltales. The answer to this question, which is not dealt with in the NPRM, is no.

While the question is asked separately for the seat belt telltale and telltales not required by any safety standard in the first place, the answer is not dependent on that distinction. Section S5.3.3 of Standard No. 101-80 requires that the light intensity of each telltale shall not be variable and shall be such that, when activated, that telltale and its identification are visible to the driver under all daytime and nighttime conditions. We interpret this section to mean that a telltale cannot be cancellable. If it were cancellable, the telltale would not meet the requirements that it not be variable and that it be visible to the driver under all daytime and nighttime conditions.

We note that the activation requirements for the seat belt telltale depend on whether it is for a manual belt or automatic belt. For a manual belt, section S7.3 of Standard No. 208 states that the seat belt assembly provided at the driver's seating position must be equipped with a warning system that activates for a period of not less than 4 seconds and not more than 8 seconds a continuous or flashing light. Thus, while a manufacturer has the discretion to provide an activation time of between 4 and 8 seconds, the telltale still may not be cancellable.

Section S4.5.3.3 requires a different type of warning system for automatic belts. While the audible signal must be activated for a period of not less than 4 seconds and not more than 8 seconds, the visual warning light must be activated for as long as the belt is not fastened.

Question 3

Your third question asks whether it is permissible to use an informational readout display to meet the visual brake warning system requirements of Standard No. 105. The answer would be yes under the proposal.

Section S5.3.5 of Standard No. 105 states:

Each indicator lamp shall have a lens labeled in letters not less than 1/8-inch high, which shall be legible to the driver in daylight when lighted. The lens and letters shall have contrasting colors, one of which is red . . . .

It is our interpretation that the illuminated pattern of letters and glazing of an informational readout display would constitute a "lens labeled in letters." This interpretation leaves unanswered other questions about whether a particular informational readout display would meet other requirements of Standard No. 105, such as the color requirement of section S5.3.5.

Question 4

Your fourth question asks whether an informational readout display specifying specific brake problems constitutes separate indicator lamps under the language of Standard No. 105, if a brake warning lamp is present which separately fulfills the requirements of S5.3.5 of Standard No. 105. The answer is no.

Section S3 of Standard No. 105 specifies various performance requirements for brake system indicator lamps. Under section S3.5, a manufacturer may meet the requirements either by a single common indicator or by separate indicator lamps.

It is our interpretation that if a manufacturer separately meets the requirements of section S3 by a single common indicator lamp, additional indicator lamps that are added voluntarily by the manufacturer are not subject to Standard No. 105's requirements.

Question 5

Your fifth question asks about the requirements for an informational readout display which is a telltale. The NPRM proposes the following language:

S5.3.3.2 Telltales and gauges incorporated into informational readout displays --

(a) Shall have not less than two levels of light intensity, a higher one for day and a lower one for nighttime conditions.

(b) In the case of telltales and gauges not equipped with a variable light intensity control, shall have a light intensity at the higher level provided under paragraph (a) of this section whenever the headlamps are not illuminated.

(c) In the case of telltales and gauges equipped with a variable light intensity control, shall be visible to the driver under all daytime and nighttime conditions when the illumination level is set to its lowest level.

The agency does find the system that you are considering developing very interesting. If you do submit a petition for rulemaking, there is one issue that we would appreciate your addressing. Our initial reaction to the idea of permitting drivers to cancel telltales is one of concern, since drivers might either cancel a telltale inadvertently or simply forget that they have done so. An informational readout display which flashed its warnings in sequence might answer those concerns. We would appreciate your addressing the safety consequences of those and any other alternatives that you might be considering.

Sincerely,

ATTACH.

BMW OF NORTH AMERICA, INC.

March 19, 1981

Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration, U.S. Department of Transportation

RE: Request for Interpretation Informational Readout Displays

Dear Mr. Berndt

This letter seeks confirmation of interpretations we discussed with Mr. Carson in our meeting with him on December 18, 1980. The questions we have relate to the use of Informational Readout Displays under FMVSS 101, 208, 105.

To better understand our questions, we are enclosing a description of the display system to which our questions apply.

Question 1

This question relates to the use of the words "Fasten Seat Belts" in the case of an informational readout display.

FMVSS 101-80, S5.2.3 permits informational readout displays to use the word or abbreviation shown in Table 2, Column 3 instead of the seat belt warning symbol. Column 3, however, provides no word or abbreviation, but instead refers to FMVSS 208. FMVSS 208, S7.3. only permits the use of words before September 1, 1980.

We believe this was an oversight when identification requirements of FMVSS 101 and 208 were consolidated in 45FR47151. In 43FR27541, it is made clear that NHTSA intends to further the development of readout displays by permitting optional use of symbols or words.

We request comment on our interpretation that the words FASTEN BELTS or FASTEN SEAT BELTS can be used in a readout display instead of a symbol to comply with the visual seat belt-warning requirements of FMVSS 101-80 and 208.

Question 2

This question relates to the activation or deactivation of displays by a voluntary manual action by the driver (pressing a push button control).

a. FMVSS 208, S7.3 requires a visual seat belt warning system that, triggered by the ignition, activates from 4 to 8 seconds. If a multi-message informational readout display is used as the visual seat belt warning (as described in Question 1), would it be permitted to provide a push button that cancels the seat belt warning by a voluntary manual action of the driver in favor of a readout for a malfunction or other warning. Would the above be permitted if a symbol in the readout went on for the duration of the 4 to 8 seconds?

b. FMVSS 101 by itself does not require that the displays listed in Table 2 be provided.

Basically the same question as 2a. applies to the other displays listed in Table 2, for which no requirement for activation in a reference standard exists.

If a multi-message informational readout display is used for any of those displays, would it be permitted to provide a push button that cancels such displays by a voluntary manual action of the driver.

Question 3

This question relates to the use of light emitting diodes or light emitting crystals to display the word "BRAKE" as required by FMVSS 105.

FMVSS 105, S5.3.5 requires a visual brake warning system using an indicator lamp with a lens labeled in letters. Would it be permissible to use an informational readout display for this purpose, considering the illuminated pattern of letters and its glazing as a "lens labeled in letters?"

Question 4

This question relates to the display of clarifying words in addition to the display "BRAKE."

FMVSS 105, S5.3.5 permits the use of a single brake warning indicator lamp, but requires that if separate indicator lamps are used for the various functions of S5.3.1(a)-(d), then each indicator must be separately and appropriately labeled. However, FMVSS 101-80, S5.2.3 in addition to the required words of Table 2, Column 3, permits the use of clarifying words at the manufacturer's discretion. If a separate, single brake warning indicator lamp, which by itself fulfills the requirements of FMVSS 105, is supplemented by an informational readout specifying the particular brake problem, would the readout be considered clarifying words or separate indicator lamp? The importance of this question is that, in the event of function checking (S5.3.2) or multi-malfunction (S5.3.5), while the BRAKE warning light would illuminate, the readout display could only illuminate one message at a time relative to the S5.3.1(a)-(d) functions.

We request comment on our interpretation that the readout constitutes clarifying words rather than separate indicator lamps because the brake warning lamp separately fulfills the requirements of S5.3.5.

Question 5

This question relates to the light intensity of informational readout displays.

FMVSS 101 S5.3.3.b requires: ". . . light intensities for informational readout systems shall have at least two values . . ." and ". . . The light intensity of each telltale shall not be variable and shall be . . . . visible to the driver under all daytime and nighttime conditions."

What are the requirements for an informational readout display if it displays a message which, by definition of FMVSS 101, S4, qualifies as a telltale?

We would appreciate your giving these questions your earliest possible attention.

Very truly yours

Karl-Heinz Ziwica, Manager -- Safety & Emission Control Engineering

Enclosures

DESCRIPTION OF SYSTEM

Display fields above speedometer, immediately in front of driver.

(Graphics omitted)

Display I

This display uses light emitting diodes or light emitting crystals to display words.

It displays the word "BRAKE" whenever required by FMVSS 105. Specific brake information will simultaneously appear on Display II.

Display II

This display uses light emitting diodes or light emitting crystals to display words.

This information readout display (multi-message) informs the driver of malfunctions or provides warnings.

Messages displayed are some of those listed in FMVSS 101-80, Table 2:

- Fasten seat belts

- Fuel level

- Oil pressure

- Coolant temperature

- Electrical charge

and in addition terms such as

- Brake wear

- Headlamp or taillamp

- Fluid levels (engine oil, transmission oil, coolant, washer)

In the event of a multi-malfunction, a computer chooses the message to be displayed on the basis of priority. The symbol to the right of the message field informs the driver of the existence of a multi-malfunction.

Display III

A warning light (lens and bulb) calls for the driver's attention and informs him of the importance of the message by either a blinking (high priority) or steady illumination (low priority).

Selector Control

With this push button control the driver can manually activate or deactivate the message on Display II (multi-message display).

In the case of a double malfunction, the first malfunction is indicated; after pressing the push button, the display indicates the second malfunction.

Example of the sequence of displays which are illuminated in case of a double malfunction: (Graphics omitted)

DRIVER PRESSES THE SELECTOR CONTROL.

(Graphics omitted)

ID: 1982-1.22

TYPE: INTERPRETATION-NHTSA

DATE: 03/08/82

FROM: SENATE

TITLE: SENATE BILL NO 1317; AMENDED IN SENATE 03/08/82

ATTACHMT: ATTACHED TO LETTER DATED 11/28/89 FROM STEPHEN P WOOD -- NHTSA TO WILLIAM E ALKIRE -- BRAKELIGHT ENHANCER, REDBOOK A34, STANDARD 108; LETTER DATED 08/24/89 FROM WILLIAM E. ALKIRE -- BRAKELIGHT ENHANCER, TO TAYLOR VINSON -- NHTSA, RE BRAKELIGHT ENHANCER; OCC 3876; SENATE BILL NO 684, CHAPTER 410; APPROVED 07/27/83

TEXT: AMENDED IN SENATE MARCH 8, 1982

SENATE BILL

No. 1317

Introduced by Senator Johnson

January 7, 1982

An act to amend Section 25251.5 of the Vehicle Code, relating to vehicles.

LEGISLATIVE COUNSEL'S DIGEST

SB 1317, as amended, Johnson. Vehicles.

Existing law permits a motor vehicle to be equipped with a system in which an amber light is mounted on the rear of a vehicle to communicate a component of deceleration.

This bill would authorize a motor vehicle to be equipped with 2 amber lamps which may be operated after deceleration as specified either separately or in combination with another lamp system.

Vote: majority. Appropriation: no. Fiscal committee: no. State-mandated local program: no.

The people of the State of California do enact as follows:

ID: 1982-1.23

TYPE: INTERPRETATION-NHTSA

DATE: 03/10/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: K-D Lamp Co.

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION

NOA-30

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

Dear Mr. Tuerck:

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

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

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

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

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

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

Vehicle controls shall be identified as follows:

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

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

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

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

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

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

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

Sincerely,

Original Signed By

Frank Berndt Chief Counsel

August 13, 1981

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

ATTH: Mr. Frank Berndt-Chief Counsel

Dear Mr. Berndt:

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

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

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

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

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

Sincerely,

Chris Tuerck Ass't. Chief Engineer

ID: 1982-1.24

TYPE: INTERPRETATION-NHTSA

DATE: 03/17/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Michelin Tire Corporation

TITLE: FMVSR INTERPRETATION

TEXT:

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

Dear Mr. White:

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

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

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

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

Sincerely,

Frank Berndt Chief Counsel

REF: PART 574

18 January 1982

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

Gentlemen:

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

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

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

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

Yours truly,

MICHELIN TIRE CORPORATION Technical Group

John B. White Engineering Manager Technical Information Dept.

abb

ID: 1982-1.25

TYPE: INTERPRETATION-NHTSA

DATE: 03/17/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Transportation Products Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 17 1982

NOA-30

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

Dear Mr. Anderson:

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

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

I hope that this resolves the question for you.

Sincerely,

Frank Berndt Chief Counsel

February 18, 1982

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

Gentlemen:

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

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

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

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

Very truly yours,

E. L. Anderson Project Engineer

EA/ms Enc. cc: Paramount

ID: 1982-1.26

TYPE: INTERPRETATION-NHTSA

DATE: 03/23/82

FROM: MIKE SMITH -- PRESIDENT, FLEET TIRE SERVICE

TO: NHTSA

TITLE: NONE

ATTACHMT: MEMO DATED 6-30-82, NOA-30, TO MIKE SMITH, FROM FRANK BERNDT - NHTSA

TEXT: We are a tire retreader located in southwest Arkancas and are in the process of importing 220 tires from Brussels for the explicite purpose of retreading. Our paper work on the acquisition of these casings lists them as rubber tires in error.

We will list all the serial numbers on the tires at time of receipt and keep a permanent shop record of such, which is our normal procedure. At this point the tires will be buffed and we will have a local police authority examine each tire and ascertain each tire has been buffed for retreading.

We have visited with Mr. Buckley of the Department of Transportation and he was unable to give us a definite ruling on this procedure for meeting proof of conformity.

Will you please advise if this method will be acceptable to you. If not, please furnish us with an alternative method for proof of conformity.

These tires have already arrived in New Orleans and we are proceeding with our plans for receiving and retreading.