ID: aiam0628

Dear Mr. Masters: This is in response to your letter of March 6, 1972, concerning warnin buzzers for the automobile industry.; The National Highway Traffic Safety Administration has issued tw safety standards which specify warning requirements. These requirements are given in Paragraph S4.4 of Standard 114 and Paragraph S7.3.1 of Standard 208. A copy of these two standards are enclosed for your review and further information.; You will note that these standards do not stipulate minimu requirements for the warning devices, and, at the present time, we have no plans to specify such requirements. The data sheet, however, which you enclosed will be useful to us should we specify such requirements in future amendments to these standards.; We appreciate your writing to us, and if we can be of any furthe service, please let us know.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;

ID: aiam0843

Dear Mr. Mason: This is in reply to your letter of August 30, 1972, on the possibl effects of bumper legislation on the type of bicycle and tire carrier manufactured by your company.; The National Highway Traffic Safety Administration has adopted Moto Vehicle Safety Standard No. 215 to establish a minimum level for the performance of passenger car bumpers in low speed impacts. The standard applies to new vehicles. It does not apply to equipment that may be placed on or near the bumper after the vehicle has been sold to a customer. If your products are installed after the sale of the vehicle, they are not affected by Standard No. 215.; The State statutes with which we are familiar also apply to ne vehicles and would presumably not affect the installation of your products. However, you might find it advisable to ask the opinion of responsible State officials on this question.; Sincerely, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1988

Dear Mr. Joyce:#This responds to your June 18, 1975, question whethe S5.3 of Standard No. 105-75, *Hydraulic Brake Systems*, requires that the brake fluid level warning system specified by S5.3.1 be instantaneous when the brake fluid level reaches the condition described in S5.3.1(b).#The answer to your question if no. The National Highway Traffic Safety Administration recognizes that a minimal interval between the occurrence of the specified condition and the appearance of the required signal is a physical fact. I enclose a copy of an interpretation of a similar require- ment of Standard No. 105-75 for your information. In the case of the brake fluid level indicator, a time interval that is insignificant with respect to the time required to respond to the signal would be permissible.#Sincerely,Frank A. Berndt,Acting Chief Counsel;

ID: aiam2581

Dear mr. Petler: This is in reply to your letter of May 6, 1977, asking whether it i permissible to label motorcycle tachometers with the symbol 'r/min' instead of 'RPM.'; Paragraph S5.2.3 of Motor Vehicle Safety Standard No. 123 *Motorcycl Controls and Displays* requires that motorcycle tachometers be identified by the letters 'R.P.M.' at a minimum, and provides that 'appropriate words may be spelled in full.' This means that the required identification must be either 'R.P.M.' or 'revolutions per minute.' S5/2/3 would not allow substitution of 'r/min' as the only identification of a tachometer. However, we have no legal objection to your furnishing that symbol as an additional means of identification of 'R.P.M.' if you so wish.; Yours truly, Frank Berndt, Acting Chief Counsel

ID: aiam2400

Dear Mr. Lungren: This responds to Trailmobile's August 13, 1976, question whether trailer would be considered to be newly manufactured for purposes of compliance with applicable safety standards if it is assembled from all new materials except for axles (axle beams, spindles and brakes, and associated brake drums, wheels, seals, and bearings) from an existing trailer whose identity and ownership would be continued in the reassembled trailer.; The answer to this question is yes. The assembly of a trailer entirel from new materials except for the trailer axles does not qualify as a 'repair' under NHTSA regulations (49 CFR S 571.7(f). This regulation states that such trailers be considered newly manufactured unless, 'at a minimum, the trailer running gear assembly (axle(s), wheels, braking and suspension) is not new ...' In the case you describe, the suspension would be new.; Sincerely, Frank Berndt, Acting Chief Counsel

ID: aiam3374

This is in response to your request on the adequacy of the Georgi certificate of title for use in lieu of a separate Federal odometer form.; As you know, the Federal odometer requirements that became effective a of January 1, 1978, have been substantially increased. We have made provision for those states that wish to include odometer information on their titles to use a shortened form that was adopted by the American Association of Motor Vehicle Administrators (AAMVA). We consider the AAMVA form to include the minimum amount of information ncessary for an adequate disclosure.; In addition to the information included on the sample title which yo submitted to our office, the buyer's signature is also required. If this signature is included, the title may be used in lieu of a separate Federal form.; Sincerely, John Womack, Assistant Chief Counsel

ID: aiam2396

Dear Mr. Lungren: This responds to Trailmobile's August 13, 1976, question whether trailer would be considered to be newly manufactured for purposes of compliance with applicable safety standards if it is assembled from all new materials except for axles (axle beams, spindles and brakes, and associated brake drums, wheels, seals, and bearings) from an existing trailer whose identify and ownership would be continued in the reassembled trailer.; The answer to this question is yes. The assembly of a trailer entirel from new materials except for the trailer axles does not qualify as a 'repair' under NHTSA regulations (49 CFR S 571.7(f). This regulation states that such trailers will be considered newly manufactured unless, 'at a minimum, the trailer running gear assembly (axle(s), wheels, braking, and suspension) is not new ...' In the case you describe, the suspension would be new.; Sincerely, Frank Berndt, Acting Chief Counsel

ID: 10715

Mr. Mark Warlick
Four Winds International Corporation
791 C.R. 15 P.O. Box 1486
Elkhart, IN 46515-1486

Dear Mr. Warlick:

This responds to your fax asking about the meaning of "designated seating position" for purposes of the Federal motor vehicle safety standards. You noted that the RVIA Handbook, dated April 23, 1991, states that "it is the NHTSA's position that, as a minimum, there must be as many [designated seating positions] as there are sleeping accommodations." You asked whether this statement is still in effect, and, if so, where you can find it in the Code of Federal Regulations. You also asked what defined area makes up one sleeping position.

This will confirm that it continues to be NHTSA's position that, as a minimum, there must be as many designated seating positions as there are sleeping accommodations. This position is based on the definition of "designated seating position," which is set forth at 49 CFR 571.3. Under that definition, the question of whether a position in a vehicle constitutes a designated seating position is dependent in part on whether the position "is likely to be used as a seating position while the vehicle is in motion." If a manufacturer designs a vehicle to sleep a particular number of persons, e.g., six persons, it is logical to assume that those six persons will ride in the vehicle to their sleeping destination. Therefore, there must be at least six designated seating positions in the vehicle. A more complete discussion of this issue is presented on p. 23234 of the enclosed Federal Register notice (Final rule amending the definition of "designated seating position," April 19, 1979).

We do not have a definition of what area makes up one sleeping position. NHTSA would consider all available information to determine the number of sleeping positions in a vehicle. This would include the size of the sleeping accommodations, e.g., whether an area is large enough to accommodate more than one person, and advertising by the manufacturer and dealers.

I hope this information is helpful. If you have further questions, please feel free to call Edward Glancy of my staff at (202) 366-2992.

Sincerely,

Philip R. Recht Acting Chief Counsel

Enclosure

ref:571 d:4/24/95

ID: 1982-2.23

DATE: 07/23/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Ron Gustafson

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of June 28, 1982, asking about requirements applicable to child restraints sold in the United States as well as any necessary permits or licenses. You also asked about any U.S. testing organizations, procedures or standards for child restraints.

All child restraints sold in the U.S. must conform with the minimum performance requirements of Federal Motor Vehicle Safety Standard No. 213, Child Restraint Systems. The standard also sets out the test procedures that are used to measure the performance of child restraints. There are no other performance requirements or test procedures applicable to child restraints. I am enclosing a copy of the standard.

You are not required to obtain a permit or license from this agency prior to selling a child restraint in the U.S., nor are you required to obtain approval from any U.S. testing organization. As a manufacturer of motor vehicle equipment, you are required by Part 566, Manufacturer Identification, of our regulation to submit certain identifying information to the agency. I have enclosed a copy of Part 566.

In addition, you would be required by the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1392 et seg.) to certify that your child restraint complies with all applicable Federal Motor Vehicle Safety Standards. Under the Act, you would also be responsible for conducting a notification and remedy campaign for any safety-related defect in your product. I am enclosing a copy of the Act, which defines your responsibilities as a manufacturer.

If you have any further question, please let me know.

ENCLS.

June 28, 1987

Furudals Bruks Kursinternat 790 70 FURUDAL Sweden

National Highway Safety Administration

To Whom it May Concern:

I am interested in receiving information concerning rules, regulations, requirements, procedures for testing, etc. concerning child safety seats in automobiles. There is interest in introducing a such a product in the USA. Therefore I would like to know of any minimum requirements (re: design, construction, materials, etc.) as well as any permits or licenses regarding those requirements. Also if there are any US testing organizations, procedures, or standards for this type of product please inform me. Thank you.

Ron Gustafson RON GUSTAFSON

ID: nht88-2.96

TYPE: INTERPRETATION-NHTSA

DATE: 08/10/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: STEPHEN BORKOWSKI

TITLE: NONE

ATTACHMT: LETTER DATED 06/24/88 TO ERIKA Z. JONES FROM STEPHEN BORKOWSKI, OCC - 2243

TEXT: Dear Mr. Borkowski:

This is in reply to your letter of June 24, 1988, asking about the legality of your "Bimmer Dimmer Safety Stop Light Concept". The concept has as its goal to lessen the chance of rear end collisions, by governing "the intensity of brake light brightness to indicate the degree of braking being applied to a vehicle."

Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment governs the legality of your concept. SAE Standard J586c Stop Lamps, August 1970, has been incorporated by reference, and specifies appropriate photometric requirements. Paragraph S4.5.4 of Standard No. 108 requires in pertinent part that "the stoplamps on each vehicle shall be activated upon application of the service brakes". We believe that this means that the lamp shall display the intensity that is designed into it to meet the photometrics of J586c. The photometrics are expressed in terms of a minimum for each test point and while there is not a corresponding maximum for each point, there is an overall maximum for the lamp. Thus, a lamp of variab le intensity could fall below the minimum at one or more test points or exceed the overall maximum. This, of course, would result in a noncompliance with Standard No. 108.

The agency examined the problem of rear end collisions and concluded that the most appropriate way to address it was through the center highmounted stoplamp, required equipment on passenger cars manufactured on and after September 1, 1985. This is inten ded not only to reduce the incidence of rear end collisions but also their severity. We are interested in the possibility of further reductions in rear end collisions. Because your concept may be of interest to that Office, I am forwarding a copy of yo ur letter to the agency's Associate Administrator for Research and Development for such further correspondence as may be warranted. We appreciate your interest in motor vehicle safety.

Sincerely,