ID: nht94-6.30

DATE: April 14, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: John Rhein -- Fisher-Price, Inc. (East Aurora, NY)

TITLE: None

ATTACHMT: Attached to letter dated 5/3/93 from John Rhein to John Womack (OCC 8639)

TEXT:

This responds to your letter about the consumer registration card required by Safety Standard No. 213, "Child Restraint Systems." I apologize for the delay in responding.

You ask about three features of a registration card you wish to produce, and enclosed a sample card setting forth a "proposed format." You first ask whether you may specify "Please Print" on the card. The answer is yes. NHTSA interpreted Standard 213 as permitting this feature, in an October 20, 1993 letter to Mr. Richard Glover of the Evenflo Juvenile Furniture Company.

You also ask whether you may use "open box spaces" for the consumer's name and address, to encourage consumers to print the information clearer (one character per box space). The answer is yes. NHTSA interpreted Standard 213 as permitting "blocked squares" for the consumer's name and address in a June 14, 1993 notice (copy enclosed) denying Evenflo's petition for reconsideration of the rule that established the registration card requirement.

Finally, you ask whether you may enlarge the consumer name and address space of the card, to provide consumers more space to print the information and thus increase the likelihood the information will be legible. The answer, with reference to the sample card you provided, is yes. Under S5.8 of Standard 213, the registration form must conform in size, content and format to forms depicted in the standard (figures 9a and 9b). The figures specify a minimum size for the card. Moreover, in the enclosed June 1993 notice, NHTSA explained that "(f)ormat refers to the general appearance of the form and to aspects such as type size, size and placement of margins, size and placement of the spaces for the consumer's name and address, and overall organization of the printed material."

The sample card you provided meets the minimum size requirement specified in the standard, and the general appearance and overall organization of the card is the same as that depicted in the standard (figure 9a). While the consumer name and address space is slightly larger than depicted in the standard, we conclude that this slight deviation is consistent with the standard's format requirements. This conclusion is based on the fact that this slight change does not affect the general appearance or overall organization of the card, and because the change provides consumers more space to print the information, i.e., it will not detract from the utility of the card.

Please contact Ms. Deirdre Fujita of my staff at (202) 366-2992 if you have any questions.

ID: nht94-2.40

TYPE: Interpretation-NHTSA

DATE: April 14, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: John Rhein -- Fisher-Price, Inc. (East Aurora, NY)

TITLE: None

ATTACHMT: Attached to letter dated 5/3/93 from John Rhein to John Womack (OCC 8639)

TEXT:

This responds to your letter about the consumer registration card required by Safety Standard No. 213, "Child Restraint Systems." I apologize for the delay in responding.

You ask about three features of a registration card you wish to produce, and enclosed a sample card setting forth a "proposed format." You first ask whether you may specify "Please Print" on the card. The answer is yes. NHTSA interpreted Standard 213 as permitting this feature, in an October 20, 1993 letter to Mr. Richard Glover of the Evenflo Juvenile Furniture Company.

You also ask whether you may use "open box spaces" for the consumer's name and address, to encourage consumers to print the information clearer (one character per box space). The answer is yes. NHTSA interpreted Standard 213 as permitting "blocked squa res" for the consumer's name and address in a June 14, 1993 notice (copy enclosed) denying Evenflo's petition for reconsideration of the rule that established the registration card requirement.

Finally, you ask whether you may enlarge the consumer name and address space of the card, to provide consumers more space to print the information and thus increase the likelihood the information will be legible. The answer, with reference to the sample card you provided, is yes. Under S5.8 of Standard 213, the registration form must conform in size, content and format to forms depicted in the standard (figures 9a and 9b). The figures specify a minimum size for the card. Moreover, in the enclosed Ju ne 1993 notice, NHTSA explained that "(f)ormat refers to the general appearance of the form and to aspects such as type size, size and placement of margins, size and placement of the spaces for the consumer's name and address, and overall organization of the printed material."

The sample card you provided meets the minimum size requirement specified in the standard, and the general appearance and overall organization of the card is the same as that depicted in the standard (figure 9a). While the consumer name and address spac e is slightly larger than depicted in the standard, we conclude that this slight deviation is consistent with the standard's format requirements. This conclusion is based on the fact that this slight change does not affect the general appearance or over all organization of the card, and because the change provides consumers more space to print the information, i.e., it will not detract from the utility of the card.

Please contact Ms. Deirdre Fujita of my staff at (202) 366-2992 if you have any questions.

ID: nht95-2.4

TYPE: INTERPRETATION-NHTSA

DATE: March 16, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Harry C. Gough -- P. E., State of Connecticut, Department of Motor Vehicles

TITLE: NONE

ATTACHMT: ATTACHED TO 3/28/94 LETTER FROM JOHN WOMACK TO THOMAS D. TURNER; ALSO ATTACHED TO 7/7/93 LETTER FROM JOHN WOMACK TO THOMAS D. TURNER; ALSO ATTACHED TO 11/18/94 LETTER FROM HARRY C. GOUGH TO NHTSA CHIEF COUNSEL

TEXT: Dear Mr. Gough:

This responds to your letter to this office asking whether the retroreflective tape required to outline school bus emergency exits can, in the case of the rear emergency door, be placed on the door itself. The short answer is no.

You stated that the State of Connecticut requires that school bus bumpers be black. You further stated that one school bus manufacturer supplied buses with the bottom piece of the retroreflective tape installed on the rear bumper. You then noticed that a number of school buses from a different manufacturer had the bottom part of the tape installed on the door itself. You asked whether the language of S5.5.3 of Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus emergency exits and window reten tion and release, permitted the installation of the retroreflective tape on the door itself.

Paragraph S5.5.3 of FMVSS No. 217 (49 CFR 571.217) provides:

Each opening for a required emergency exit shall be outlined around its outside perimeter with a minimum 3 centimeters wide retroreflective tape, either red, white, or yellow in color, . . . .

This requirement was imposed by amendment to FMVSS No. 217 promulgated by a final rule published in the Federal Register on November 2, 1992 (57 FR 49413). In discussing this requirement in the preamble portion of the final rule, we said at 57 FR 49421:

Accordingly, the final rule requires a minimum 1 inch wide strip of retroreflective tape, either red, white, or yellow in color, to be placed around the outside perimeter of the emergency exit opening, not the emergency exit itself (emphasis added).

As you may know, the buses with the tape on the emergency exit doors have been recalled by the manufacturer. For information about the recall, you can contact the bus manufacturer, Thomas Built Buses, P. O. Box 2450, High Point, NC 27261.

Enclosed for your information are two interpretative letters issued by this office on related issues pertaining to the retroreflective tape requirement. See letter to Mr. Thomas D. Turner, Manager, Engineering Services, Blue Bird Body Company, dated July 7, 1993; and letter to Mr. Turner dated March 28, 1994.

I hope the above information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992.

Sincerely,

ID: nht95-4.58

TYPE: INTERPRETATION-NHTSA

DATE: October 16, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: John C. Golden -- Product Manager, Lighting & Electrical, Federal Mogul Corporation

TITLE: NONE

ATTACHMT: ATTACHED TO 5/31/95 LETTER FROM JOHN C. GOLDEN TO JOHN WOMACK

TEXT: Dear Mr. Golden:

This responds to your request for an interpretation asking if, under NHTSA's requirements, your company may market a lighting device, called a "Lightman," for use on warning triangles. I apologize for the delay in responding. As explained below, the an swer to your question is yes. However, since the Federal Highway Administration (FHWA) regulates use of warning triangles carried in commercial vehicles, that agency's regulations could also affect your product.

You explain that the Lightman is a battery operated safety strobe device, which is in the shape of an equilateral triangle measuring 3 1/2 inches on each side. You would like to market the Lightman specifically for use on warning triangles, but are conce rned about the minimum area requirements of Safety Standard No. 125, Warning Devices. You ask, "Does the mounting of one of these devices . . . take away minimum reflective area such that it would render the warning triangles illegal or ineffective?"

As you note, Standard No. 125 specifies requirements for the configuration of warning devices. Warning devices that are subject to Standard No. 125 must be certified as meeting those configuration requirements. As we understand the Lightman, it will be sold to motorists separately from the Standard No. 125 warning devices. However, we understand that you will market the Lightman as appropriate for use with previously-certified warning devices.

There is a provision in our statute that regulates the modifications that motor vehicle manufacturers, dealers, distributors and repair businesses may make to certified vehicles and equipment. (See section 30122 of Title 49 U.S.C. 30101 et seq., copy en closed.) However, this provision does not regulate the modifications that individuals make to their vehicles or items of equipment, such as warning triangles. Thus, under NHTSA's statute, an individual would not be precluded from placing the light on hi s or her equilateral triangle.

As you note in your letter, the FHWA regulates use of warning devices with regard to commercial trucks, and should be contacted about your question. Responding to your request for a contact in FHWA, we suggest Mr. James Scapellato, Director, FHWA Office of Motor Carrier Research and Standards, at the following address and telephone number:

400 Seventh Street, S.W. Rm. 3107 Washington, DC 20590.

Telephone: (202) 366-1790

We will be happy to forward your letter to Mr. Scapellato, if you would like us to do so.

I hope this information is helpful. If you have any further questions about our regulations, please feel free to call Dorothy Nakama of my staff at (202) 366-2992.

ID: nht71-5.40

DATE: 10/05/71

FROM: AUTHOR UNAVAILABLE; D. Schmeltzer for L. R. Schneider; NHTSA

TO: Aston Martin Lagonda Limited

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 8, 1971, in which you request clarification of Motor Vehicle Safety Standard No. 202, "Head Restraints". You state that you are of the opinion that "a head restraint system that can be retracted into the seat and thus made ineffective by virtue of being adjustable is in conflict with the prime object of the standard in reducing the frequency and severity of neck injuries in rear end or other collisons."

Standard No. 202 does not prohibit head restraints from being adjustable in an up-and-down direction, as long as the top of the restraint, at its fully extended design adjustment position, is at least 27.5 inches above the seating reference point (S4(b)(1)). While some of these adjustable head restraints may not be completely effective in cases where they are placed at their lowest adjustment position and used by tall drivers, we have determined that this design, as long as it meets the requirements of the standard, is a minimum performance level that meets the need for motor vehicle safety. Consequently, use of these types of restraints does not conflict with the standard.

The standard establishes only a minimum performance level, however, and the NHTSA endorces efforts by manufacturers to exceed the

2 requirements is establishes. Many manufacturers have installed head restraints in their vehicles that meet the standard's requirements yet do not present the disadvantages you describe.

We are pleased to be of assistance.

ASTON MARTIN LAGONDA LIMITED

September 8 1971

Douglas W. Toms, National Highway Traffic Safety Administrator, National Highway Traffic Administration,

As designers and manufacturers of the Aston Martin DBS V8 car, currently being marketed in U.S.A., we are concerned at what appears to be a very loose interpretation of Motor Vehicle Safety Standard No. 202, Head Restraints - Passenger Cars, Section 5.4(b), adopted by certain American automobile manufacturers.

Aston Martin Lagonda have been concerned for many years with primary and secondary safety aspects of the car, and we hold the view that a head restraint system that can be retracted into the seat and thus made ineffective by virtue of being adjustable, is in conflict with the prime object of the Standard in reducing the frequency and severity of neck injuries in rear end or other collisions.

We would appreciate clarification on this point, for our concern is to maintain the highest standard of interior safety as exemplified by our current production car.

H. Beach Director of Engineering

c.c. Mr. R. Layland, President, A.M.L. Inc. Mr. J. B. Walker, Vehicle Safety Engineer, A.M.L. Limited.

ID: nht95-7.23

TYPE: INTERPRETATION-NHTSA

DATE: October 16, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: John C. Golden -- Product Manager, Lighting & Electrical, Federal Mogul Corporation

TITLE: NONE

ATTACHMT: ATTACHED TO 5/31/95 LETTER FROM JOHN C. GOLDEN TO JOHN WOMACK

TEXT: Dear Mr. Golden:

This responds to your request for an interpretation asking if, under NHTSA's requirements, your company may market a lighting device, called a "Lightman," for use on warning triangles. I apologize for the delay in responding. As explained below, the answer to your question is yes. However, since the Federal Highway Administration (FHWA) regulates use of warning triangles carried in commercial vehicles, that agency's regulations could also affect your product.

You explain that the Lightman is a battery operated safety strobe device, which is in the shape of an equilateral triangle measuring 3 1/2 inches on each side. You would like to market the Lightman specifically for use on warning triangles, but are concerned about the minimum area requirements of Safety Standard No. 125, Warning Devices. You ask, "Does the mounting of one of these devices . . . take away minimum reflective area such that it would render the warning triangles illegal or ineffective?"

As you note, Standard No. 125 specifies requirements for the configuration of warning devices. Warning devices that are subject to Standard No. 125 must be certified as meeting those configuration requirements. As we understand the Lightman, it will be sold to motorists separately from the Standard No. 125 warning devices. However, we understand that you will market the Lightman as appropriate for use with previously-certified warning devices.

There is a provision in our statute that regulates the modifications that motor vehicle manufacturers, dealers, distributors and repair businesses may make to certified vehicles and equipment. (See section 30122 of Title 49 U.S.C. 30101 et seq., copy enclosed.) However, this provision does not regulate the modifications that individuals make to their vehicles or items of equipment, such as warning triangles. Thus, under NHTSA's statute, an individual would not be precluded from placing the light on his or her equilateral triangle.

As you note in your letter, the FHWA regulates use of warning devices with regard to commercial trucks, and should be contacted about your question. Responding to your request for a contact in FHWA, we suggest Mr. James Scapellato, Director, FHWA Office of Motor Carrier Research and Standards, at the following address and telephone number:

400 Seventh Street, S.W. Rm. 3107 Washington, DC 20590.

Telephone: (202) 366-1790

We will be happy to forward your letter to Mr. Scapellato, if you would like us to do so.

I hope this information is helpful. If you have any further questions about our regulations, please feel free to call Dorothy Nakama of my staff at (202) 366-2992.

ID: nht74-2.23

DATE: 09/24/74

FROM: AUTHOR UNAVAILABLE; James B Grefory; NHTSA

TO: Midland-Ross Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Midland-Ross' February 8, 1974, petition for an amendment of S5.1.2.1 and S5.2.1.2 of Standard No. 121, Air brake systems, to establish separate air reservoir volume requirements for several brake chamber types generally available in the air brake component market.

The standard presently requires air reservoir volumes to be a multiple of the vehicle's brake chamber volumes. Midland-Ross also requested that S5.1.2.2 and S5.2.1.3 be amended to require that a reservoir withstand hydrostatic pressure five times greater than stated on its label without rupture, or permanent circumferential deformation exceeding one percent. The standard presently requires that an air reservoir withstand internal hydrostatic pressure of five times the vehicle compressor cutout pressure or 500 pounds, whichever is greater. The pecition also requests modifications of the trailer test rig, which were made in a recent amendment of the standard (39 FR 17563, May 17, 1974).

You suggested that our requirement for air reservoir volume as a multiple of brake chamber volume will encourage installation of smaller equipment and thereby create a safety problem. We cannot agree, in view of the standard's stopping distance requirements which in effect mandate the installation of high performance components. Indications to date are that manufacturers have in fact not reduced brake chamber volumes. A certain degree of chamber stroke standardization may occur, which the NHTSA views as favorable. For these reasons your request is denied.

With regard to the air reservoir pressure requirements of S5.1.2.2 and S5.2.1.3, you argued that a reservoir manufacturer is unable to establish the required strength of his product because he cannot control the compressor cutout pressure of the vehicle on which the reservoir is installed. It should be understood that the standard is not an equipment standard with which Midland-Ross must comply, but a vehicle standard with which the vehicle manufacturer must comply. We have determined that the reservoir should be designed to manage the pressures to which it might be exposed on the vehicle on which it is installed. The vehicle manufacturer is able to establish a compressor cutout pressure (on powered vehicles, and, based on that value, order the appropriate reservoir to meet the requirement. It is evident that commercial considerations will standard compressor cutout pressures on reasonable range of available reservoir strengths. Midland-Ross as a manufacturer of reservoirs is free to establish a range of reservoir strenghts, and label the reservoirs as described in your petition. For the reasons cited, however, your petition to mandate this is denied.

We agree the requirement that a reservoir "withstand" a certain pressure can be further specified, and we are considering a proposal to do this in the future.

At this time the NHTSA has adopted the SAE Standard No. J10a, which specifies that there be no rupture or permanent circumferential deformation exceeding one percent.

Sincerely,

ATTACH.

PETITION FOR RECONSIDERATION

FEDERAL MOTOR VEHICLE SAFETY STANDARD 121 DOCKET 73-13 NOTICE #3

BY POWER CONTROLS DIVISION MIDLAND-ROSS CORPORATION

M. J. Denholm Director of Engineering

February 8, 1974

Midland-Ross regrets to find that several of the proposals issued under Notice 1 of Docket 73-13 have not been incorporated in the rule issued under Notice 3 of the Docket.

The purpose of this petition is to request reconsideration of outstanding petitions and comments not yet resolved or acted upon from previous notices. In addition, we wish to offer additional information to supplement our comments on Docket 70-16 and 17, Notice 3, and the petition for reconsideration of Docket 70-17, Notice 4.

Taking the sections as they appear in FMVSS 121 as amended by Docket 73-13, Notice 3, we ask for your consideration of the following:

S5.1.2.1

S5.2.1.2

On March 23, 1972, we petitioned for consideration of this section of Docket 70-16 and 70-17, Notice 3.

Quote: "The combined volume of all service brake chambers at maximum travel of the pistons or diaphragms" requires definition in that volume can be measured in more than one way resulting in significant variation in result. For example: Displacement determined by pressurizing a chamber hydrostatically to 5 psig would result in approximately 10% less volume as compared to that indicated when the same chamber is pressurized to 100 psig hydrostatically. The hydrostatic pressure would be applied using an incompressable fluid; the volume of fluid displaced being the measure of the chamber volume. We recommend the standard be revised to read as follows:

'S5.1.2.1 . . .the combined volume of all service brake chambers at maximum travel of the pistons or diaphragms when measured with 5 psig applied to the chamber.' This will eliminate the possibility of a dual standard when determining compliance."

On August 14, 1973, we petitioned again for reconsideration of this section of Docket 70-17, Notice 4; and again on July 11, 1973, against Docket 73-13, Notice 1.

Quote: "The requirement under both these sections is restrictive and not necessarily in the public interest. For example, Midland-Ross Type 30 service chambers provide 2.75 inch stroke where units of other manufacturers are as low as 2.5 inch. The long stroke provides a desirable margin for poor brake adjustment. We believe this advantage will render our product non-competitive. To become competitive a reduction in stroke, with the attendant reduction in reservoir capacity requirement will be necessary. We feel, in light of recent experience with designs to meet FMVSS, 121, Notice 4, that this is arbitrary and an unnecessarily expensive retrograde step, caused by the wording of this section. In addition, chamber displacement varies dependent upon the applied pressure.

"This is caused by ballooning of diaphragms as pressure is increased. It should be noted that a three or four axle rigid truck would require significantly larger reservoirs under this rule than would a two-axle tractor designed to tow two or three trailers. Taking into account these three factors, it is recommended that S5.1.2.1 and S5.2.1.2 be reworded as follows:

'S5.1.2.1 The combined volume of all service reservoirs and supply reservoirs shall be at least the value obtained by the following product: Buses, and tractors and trailers designed to tow air-braked vehicles:

(12) x (115%) x (Combined volume of all service brake chambers)

Trucks not designed to tow other air-braked vehicles: (8) x (115%) x (Combined volume of all service brake chambers)

The combined volume of all service brake chambers is that volume obtained at maximum travel of the pistons or diaphragms with 100 psi hydrostatic pressure applied to the chambers with the brakes adjusted as specified by the vehicle manufacturer for new, unburnished brakes.

'S5.2.1.2 The total service reservoir volume shall be at least the value obtained by the following product: (8) x (115%) x (Combined volume of all service brake chambers)

The combined volume of all service brake chambers is that volume obtained at maximum travel of the pistons or diaphragms with 100 psi hydrostatic pressure applied to the chambers with the brakes adjusted as specified by the vehicle manufacturer for new, unburnished brakes."

No action has resulted from any of these petitions. We feel both arguments are still valid. We would like to add additional argument to that furnished on August 14, 1973, as follows:

An optional method of determining reservoir volume would consist of using an established minimum working volume for each standard size of service chamber. The minimum working volume would then be used to compute the reservoir requirement in the manner stated in the standard. Using this approach, the need for the changes recommended on March 23, 1972, would be eliminated also. We therefore recommend the S5.1.2.1 be reworded as follows: S5.1.2.1 The combined volume of all service reservoirs and supply reservoirs shall be determined by adding the volumes specified in Table V, Column 1 for each air-operated service brake actuator.

S.5.2.1.2 shall read:

S5.2.1.2 Total service reservoir volume shall be determined by adding the volumes specified in Table V, Column 2 for each air operated service brake actuator.

TABLE V Reservoir Volume Required Per Actuator * Column 1 * Column 2 Actuator Trucks-Buses Trailers Type 9 Diaphragm 240 cubic inches 160 cubic inches Type 12 Diaphragm 300 cubic inches 200 cubic inches Type 16 Diaphragm 528 cubic inches 352 cubic inches Type 20 Diaphragm 612 cubic inches 408 cubic inches Type 24 Diaphragm 732 cubic inches 488 cubic inches Type 30 Diaphragm 1056 cubic inches 704 cubic inches Type 36 Diaphragm 1464 cubic inches 976 cubic inches

*Piston or Rolling 12 x volume at max. 8 x volume at max.

Diaphragm working stroke working stroke

The above revisions to S5.1.2.1 and S5.2.1.2 are requested due to the variation in design of diaphragm type service brake chambers. These chambers are of generally similar construction, but because of manufacturing tolerances and slight differences in stroke length, their maximum volumes are different by a few percentage points. The current reservoir volume requirement based on maximum displacement encourages the use of small volume chambers (to reduce required reservoir volumes). In use, however, these small volume chambers provide less reserve than larger displacement units. This is true because the larger displacement units generally have slightly longer operating strokes. This additional stroke is a safety advantage in event that brake drums expand from heat buildup or shoes are allowed to wear without brake readjustment.

The chamber volume differences caused by variations in maximum stroke length are not significant to a vehicle in normal operation. This is because either chamber design would require the same amount of air to operate a properly adjusted brake; either unit when stroked to the same distance (any value short of maximum stroke; would displace nearly the same volume of air. Chamber volume requirements per brake application would be the same for either chamber design unless the stroke exceeded the maximum stroke length of the short stroke chamber. In that case, (abnormal situation) the long stroke chamber would require more air than a short stroke unit but would produce brake torque to stop the vehicle. The short stroke unit would be stopped internally without producing brake torque.

If S5.1.2.1 and S5.2.1.2 are not revised, market pressure will force redesign of long stroke chambers to limit stroke (and maximum volume). This could be carried to an extreme whereby the redesigned chambers would have even shorter strokes than current chambers. This type unit would then have economic advantages that would encourage their use; but they would actually be inferior to current chambers from a safety point of view.

The chamber volumes proposed in Table V were arrived at by applying the current requirement of 12 times chamber volume at maximum stroke (eight times for trailers) to the maximum volume of the truck industry's most common air brake chamber. These values do not represent a change in the spirit of the law, only in its detail. The original method of determining reservoir volume would be retained for piston actuators or other devices whose stroke and displacement have not become standardized in the industry.

S5.1.2.2

S5.2.1.3

On March 23, 1972, we petitioned for reconsideration of both of these sections of Docket 70-16 and 70-17, Notice 3.

Quote: "The requirement that the reservoirs under both of these sections should 'withstand' an internal hydrostatic pressure is nondefinitive and open to interpretation. In addition, manufacturers of air brake reservoirs are not necessarily in a position to determine what the cutout pressure of the compressor will be for a particular reservoir application prior to design and development of the reservoir as required under Paragraph S5.1.2.2. In addition, there is a significant inconsistency between the requirements for reservoir strength on a truck or bus and those for reservoirs used on a trailer as both reservoirs on a combination vehicle would be pressurized by the same compressor to the same pressure levels. It would appear reasonable, in the interest of safety, to adopt a common standard. It would also appear to be advisable to use a standard which is both proven and perfectly acceptable based on long periods of experience. It is therefore recommended that Paragraphs S5.1.2.2 and S5.2.1.3 be revised as follows:

'Each reservoir shall be capable of accepting a hydrostatic pressure of not less than five times the reservoir rated working pressure for a minimum of one minute. When subjected to this pressure for this time period there shall be no rupture or permanent circumferential deformation exceeding 1%. The reservoirs meeting this requirement must be permanently identified for rated working pressure."

On August 14, 1973, we again petitioned for reconsideration of these sections of Docket 70-17, Notice 3. Comments were also made on Docket 73-13, Notice 1.

Quote: "The requirement that the reservoirs under both of these sections should withstand an internal hydrostatic pressure is nondefinitive and open to interpretation. In addition manufacturers of air brake reservoirs are not necessarily in a position to determine what the cutout pressure of the compressor will be for a particular reservoir application prior to design and development of the reservoir as required under Paragraph S5.1.2.2. In addition, there is a significant inconsistency between the requirements for reservoir strength on a truck or bus and those for reservoirs used on a trailer. Both reservoirs on a combination vehicle would be pressurized by the same compressor to essentially the same pressure levels. It would appear reasonable, in the interest of safety, to adopt a common standard. It would also appear to be advisable to use a standard which is both proven and perfectly acceptable based on long periods of experience. It is therefore recommended that Paragraphs S5.1.2.2 and S5.2.1.3 be revised as follows:

'Each reservoir shall be capable of accepting a hydrostatic pressure of not less than five times the reservoir rated working pressure for a minimum of one minute. When subjected to this pressure for this time period, there shall be no rupture or permanent circumferential deformation exceeding 1%. The reservoirs meeting this requirement must be permanently identified for rated working pressure.'

Note: This recommendation reflects the current SAE Standard Practice (SAE J10b) in regard to reservoir certification and therefore should provide clarification without creating unnecessary hardships."

An additional point which was not specifically made in the two petitions quoted from relates to manufacturing practice and product application.

As a major reservoir manufacturer, Midland-Ross produces all reservoirs for air-braked vehicles in one of three diameters. Each diameter is engineered from differing material thicknesses to withstand a predetermined working pressure. Usually this is 150 psi. When reservoirs are supplied to the industry we have no knowledge of the compressor cutout pressure. The compressor cutout pressure is usually adjustable in service. A situation over which the reservoir manufacturer has no control. By establishing a maximum rated working pressure for the reservoir to be marked on the unit, the user then has direct knowledge of the limit to which the compressor cutout pressure can be safely adjusted. We feel that adopting this method would result in better understanding on the part of the user as this has been the standard used historically. It would eliminate the need to re-educate operators and provide a sounder basis for economic reliable manufacture and application of air brake reservoirs.

S5.3.3

S5.3.4

On March 23, 1972 we pointed out in our petition for reconsideration the inadequacies of the test standard shown in Docket 70-16 and 70-16, Notice 3, Figure 1. Partial response to this petition was exhibited in Docket 73-13, Notice 1, S6.1.12.

Docket 73-13, Notice 3, essentially returns to 70-17, Notice 3 level, thus effectively ignoring our original petition and also our comments on Docket 73-13, Notice 1, submitted to the Administration on July 11, 1973.

We ask for consideration of our updated proposal as follows:

S5.3.3 Brake actuation time. With an initial service reservoir system air pressure of 100 psi, the air pressure in each brake chamber shall reach 60 psi in not more than 0.25 second measured from the first movement of the service brake control. A vehicle designed to tow a vehicle equipped with air brakes shall be capable of meeting the above actuation time requirement with a 50-cubic-inch test reservoir connected to the control line coupler. A trailer shall meet the above requirement with its brake system connected to a trailer timing test rig as shown in Fig. 1 which meets the requirements of S5.3.3.1 and S5.3.3.2.

S5.3.3.1 The following should be added:

"The trailer test rig shown in Fig. 1 shall be constructed such that the pressure in a 50 cubic inch test volume connected to the control coupling is raised from zero to 60 psi in .063 second minimum when tested on the test rig. Time shall be measured from the first mechanical movement of the device controlling air flow to the control coupling."

S5.3.3.2 The following should be added:

"The trailer test rig shown in Figure 1 shall be constructed such that the pressure in a 50 cubic inch test volume connected to the control coupling is exhausted from 95 to 5 psi in .220 second minimum when tested on the test rig. Time shall be measured from the first mechanical movement of the device controlling air flow from the control coupling.

Figure 1 should be revised as shown:

(Graphics omitted)

S5.3.4 Brake release time. With an initial brake chamber air pressure of 95 psi, the air pressure in each brake chamber shall fall to 5 psi in not more than 0.50 second measured from the first movement of the service brake control. A vehicle designed to tow another vehicle equipped with air brakes shall be capable of meeting the above release time requirement with a 50-cubic inch test reservoir connected to the control line coupling. A trailer shall meet the above release time requirement with its brake system connected to the test rig shown in Fig. 1 and which meets the requirements of S5.3.3.1 and S5.3.3.2.

The above changes to Section S5.3.3 and Figure 1, and additions to S5.3.3.1 and S5.3.3.2 are recommended in an effort to more completely define the TRAILER TEST RIG. Until this rig is defined, uniform timing will not exist on trailers built to FMVSS 121. The original Figure 1 was designed to duplicate a tractor. It did this but as a test instrument it is inadequately defined. The air delivery performance of this device (as well as the tractors it was modeled from) will vary significantly. This is unacceptable when proof of vehicle compliance to the standard depends upon tests made with this unit. The proposed Figure 1 is a black box with narrowly defined performance characteristics. Devices built to this requirement will undoubtedly exhibit performance variations when tested against one another, but their level of consistency will far exceed that obtained by a unit in the standard which is only partly defined.

ID: aiam3284

Dear Mr. Kneip: This is in response to your letter of May 7, 1980, in which you aske whether the proposed Nebraska certificate of title may be used as a substitute for the Federal odometer disclosure form required by 49 CFR Part 580.; The Nebraska title differs from the minimum Federal requirements i that there is no certification that the odometer reading reflects the actual mileage or the mileage over 99,999 miles, or is not the actual mileage. The buyer is not required to sign the Nebraska title as he is the Federal form (sic). In addition, your title does not refer to the legal consequences of a false disclosure. If you can make these additions, the Nebraska title will satisfy the Federal requirements.; For your information, I have enclosed a copy of the *Federal Register notice which discusses the short form odometer disclosure that States may use on their titles to satisfy Federal requirements, a letter to Maryland in which we indicate that formal approval by NHTSA is not necessary if the title contains the specified information, and sample titles that the NHTSA has approved.; If you need any further inforamtion, please do not hesitate to contac us.; Sincerely, John Womack, Assistant Chief Counsel

ID: aiam0653

Dear Mr. Gerth:#On November 9, 1971, you wrote concerning th requirement in Standard No. 101 that a control be provided to adjust the intensity of control illumination, continuously variable from an 'off' position to a position providing illumination sufficient for the vehicle operator to readily identify controls under conditions of reduced visibility. You asked an interpretation that 'the term 'off' means a control position which provides minimal control illumination which is not distracting to the driver who has adapted to dark ambient roadway conditions.'#In our opinion, the word 'off' means a control position providing no illumination, and we therefore do not concur in your interpretation. You have asked, however, as an alternative, that your letter be considered as a petition for rulemaking to amend Standard No. 101 to provide an option permitting the type of control already incorporated in Mercedes-Benz vehicles.' We have tentatively determined that your petition has merit, and that quantitative levels for control illumination intensity should be established in Standard No. 101. We shall therefore initiate appropriate rulemaking with a proposed effective date of September 1, 1973.#Sincerely, Douglas W. Toms, Administrator;

ID: aiam0095

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