ID: 1985-01.10

TYPE: INTERPRETATION-NHTSA

DATE: 01/11/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHSTA

TO: Kazutoshi Kasagi -- Chief Inspector, International Trade and Industry Inspection Institute Ministry of International Trade and Industry (Japan)

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Kazutoshi Kasagi Chief Inspector Internationally Agreed Safety Division International Trade & Industry Inspection Institute Ministry of International Trade & Industry Japanese Government 15-1, 6 Chome Ginza Chuo-ku Tokyo, Japan

This is in reply to your letter of November 13, 1984, with respect to interpretations of the motorcycle headlighting requirements of Federal Motor Vehicle Safety Standard No. 108, and SAE J584.

You have asked "whether other lighting systems than referred in S4.1.1.34, such as non-sealed beam head lamp with two bulbs, are acceptable or not." The answer is yes. Non-sealed lamps meeting the requirements of SAE J584 are acceptable, including those with two bulbs, as the "At-Focus Tests" paragraph of J584 is directed to "light source or sources."

Your next question is whether photometric compliance is judged when one light is on or two, including the maximum permissible output of 75,000 cd. The answer to this question depends on the design of the lamp; if it is designed so that both bulbs operate simultaneously, then photometrics including maximum output are determined with both bulbs operating. If the design is such that one bulb produces lower beam and the other the upper beam, then compliance is judged by that method of operation. Should one bulb produce both lower and upper beams and the other bulb perform an unregulated lighting function, then the photometric compliance would be judged with only the bulb used for the regulated function. In this case, however, the unregulated bulb must not interfere with the effectiveness of the headlamp. This also answers your final question about conduct of the out-of-focus test. It is to be conducted according to the design intent of the operation of the headlamp, i.e. the design function of each bulb or bulbs.

You have also asked about the geometrical center of a design when one of two bulbs (both with an upper beam and a lower beam filament apparently) is on. Operation of only one bulb alone would result in an assymetrical lighting display off the vehicle's centerline. This is permitted by S4.1.1.34 of Standard No. 108 for the sealed beam lighting systems specified therein. Therefore, we could not logically disapprove of it for unsealed headlighting systems. However, if only one bulb performed both the lower beam function and the upper beam, and the other bulb performed an unregulated lighting function, then the bulb providing the lower/upper the lower beam function and the upper beam, and the other bulb performed an unregulated lighting function, then the bulb providing the lower/upper beams must be located on the vehicle's vertical centerline.

If you have any further questions, we shall be happy to answer them.

Sincerely,

Frank Berndt Chief Counsel

November 13, 1984

Mr. Frank Berndt, Chief Counsel Office of Vehicle Safety Standards, National Highway Traffic Safety Administration, DOT, 400 Seventh Street, S.W., Washington, D.C. 20590, U.S.A.

Dear Mr. Frank Berndt:

This is to ask you about interpretation and applicability of FMVSS 108 and SAE J584(Motorcycle Headlamp). Before asking questions, I'm pleased to introduce our organization. International Trade and Industry Inspection Institute (ITIII) is an affiliated inspection organization of Ministry of International Trade and Industry, Japanese Government and has three main functions. ITIII itself conducts test and inspections of industrial products under the control of MITI and ITIII administrates private inspection organizations, consumer bodies and manufacturers in terms of inspection and test. ITIII also is involved in the drafting process of inspection standards and inspection method of industrial products. ITIII has been an approved laboratory of lighting equipments by American Association of Motor Vehicle Administrators (AAMVA) and we have regular visits of Mr. Bardel and Mr. Cardarelli from AAMVA. We keep close relations with AAMVA for many years.

Inquiry

FMVSS 108 S4. 1. 1.34 specifies acceptable lighting system of motor cycles. This arises the question of whether other lighting systems than referred in S4.1.1.34, such as non-sealed beam head lamp with two bulbs, are acceptable or not. If it is acceptable, we have three questions to ask you further with regard to SAE J584.

Question 1

Which case should non-sealed beam lamp comply with specified photometric value of SAE J584 either when one bulb is lighted on or two bulbs are on? How should we interpret the requirement of Maximum 75000 cd in each case?

Question 2

Which should be the case of geometrical center when one bulb is on as illustrated below?

"INSERT GRAPHIC"

Question 3

How should we conduct out of focus test of the applicable case asked in question 1?

I hope this contact will be the first step to create good relation with your organization and I appreciate your quick response to our question.

Best regards,

Kazutoshi Kasagi

Chief Inspector, Internationally Agreed Safety Division

ID: 10755

Mr. David T. Holland
President
Europa International, Inc.
1570A Pacheco Street
Santa Fe, NM 87505

Dear Mr. Holland:

This responds to your letter of February 24, 1995, regarding the passive restraint phase-in requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection. You asked whether an importer which "imports Canadian specification MPV's (multipurpose passenger vehicles), such as the Chrysler Minivan, that meets (sic) the MPV passive restraint requirements of FMVSS 208 ... can count these vehicles toward the required percentage."

Section S4.2.5.6.1(a) states, "(a) vehicle that is imported shall be attributed to the importer." Thus, to determine compliance with the passive restraint phase-in requirements, Europa International should (1) count all trucks, buses, and mpv's with a gross vehicle weight rating of 8,500 pounds or less and an unloaded vehicle weight of 5,500 pounds or less, (2) count all such vehicles which meet the passive restraint requirements of FMVSS 208, and (3) determine if that class of vehicles is a sufficient percentage of the first class of vehicles to satisfy the phase-in requirements. However, as Mary Versailles of my staff cautioned you on the phone, some manufacturers are installing European (face) air bags but are not certifying that vehicles with such air bags meet the passive restraint requirements of FMVSS 208. Therefore, you should verify that any vehicle with an air bag is in fact certified to FMVSS 208's passive restraint requirements.

I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Philip R. Recht Chief Counsel ref:208 d:4/3/95

ID: 11986.ZTV

Herr Sandig
Reiter & Schefenacker
Eckenerstrasse 2
73730 Esslingen
Germany

Dear Herr Sandig:

This replies to your FAX of May 28, 1996, asking whether a proposed design for a center highmounted stop lamp is a single lamp, within the meaning of Federal Motor Vehicle Safety Standard No. 108.

In this design, a rectangular lens is separated by an opaque oval that covers the center portion of the lens. However, the sum of the effective projected luminous lens areas left uncovered exceeds the minimum 4.5 square inches required by paragraph S5.1.1.27(a)(1) of Standard No. 108.

This design does not comply with Standard No. 108. Paragraph S5.1.1.27 (a) requires vehicles to be equipped with "a high-mounted stop lamp." Table IV requires the lamp to be located "on the vertical centerline." The opaque area in your design functionally divides the center lamp into two lamps, neither of which is located on the vertical centerline.

In the past, the agency has advised that the lens of the center stop lamp may be obscured to a certain extent by decals or other trim, provided the minimum luminous lens area requirement was met, and the obscuration did not affect photometric compliance. These interpretations always assumed that the appearance of a single lamp would be maintained, even though the lens area itself did not present an uninterrupted light-emitting surface.

Paragraph S5.1.1.27(b) does allow two separate lamps on vehicles other than passenger cars when there is insufficient space above doors opening from the center, but your lamp is not designed to address this problem.

If you have any questions, you may refer them to Taylor Vinson of this Office.

Sincerely,

Samuel J. Dubbin Chief Counsel ref:108 d:6/14/96

ID: nht94-3.15

TYPE: INTERPRETATION-NHTSA

DATE: May 31, 1994

FROM: Jerry Miller -- Director of Operations, Associated Leasing Handicapable Vans

TO: Chief Console -- NHTSA

TITLE: None

ATTACHMT: Attachment dated 8/19/94 Letter from John Womack to Jerry Miller (Std. 222)

TEXT:

Associated Leasing Handicapable Vans is a builder of conversion vehicles for the transportation of handicapable individuals, both private and commercial. We are embarking on the manufacture of associated equipment to go into these vehicles. One such pie ce of equipment is a wheelchair tie down.

After conversations with Mark Levine, NHTSA, trying to obtain rules and regulations on this type of equipment and at the suggestion of Charles Hott, NHTSA Rulemaking Office. I am writing your office requesting information on or an official letter statin g there are no rules or regulations on wheelchair tie downs for vehicles other then school buses

I am looking for regulation and legal requirements for transporting persons in vehicles with wheelchair securement devices and occupant restraints, both private and commercial, other then school buses. It is my understanding NHTSA standard No. 57 CFR Pa rt 571.222 "School Bus Passenger Seating and Crash Protection" only applies to school buses and does not apply to any other vehicles.

I need to know specifically what the legal specified performance requirements are for the wheelchair securement devices. 1. What are the minimum strength requirements for the securement devices and systems themselves? 2. What are the minimum strength r equirements for the anchorage of those devices and systems to the vehicle?

I appreciate your cooperation and quick response in advising us on NHTSA's rules and regulations on wheelchair tie downs used for transporting the handicapable person in a vehicle other then a school bus.

ID: nht94-8.9

DATE: February 17, 1994

FROM: Karl-Heinz Ziwica -- General Manager, Environmental Engineering, BMW of North America, Inc.

TO: Barbara A. Gray, Office of Market Incentives, NHTSA, U.S. Department of Transportation

TITLE: NONE

ATTACHMT: Attached to letter dated 8/9/94 from Barry Felrice to Karl-Heinz Ziwica (Part 543)

TEXT: Dear Ms. Gray:

This letter is to inform the agency that beginning with the 1995 model year, BMW will be utilizing the 7-carline parts marking exemption granted by the NHTSA on October 9, 1986 (51 CFR 3633). As was explained to you by Mr. James C. Patterson of my staff on February 7, 1994, there have been three updates to the anti-theft device previously approved on the 7-carline. Accordingly, BMW requests that the NHTSA determine these updates constitute de minimus changes to the 7-carline's anti-theft device.

The following paragraphs describes the updates:

1. The remote device has become an integral component within the vehicle key and is the actuator for the alarm system. This change is identical to the change that BMW made on the 8-carline anti-theft device, which NHTSA has already determined to be de minimus (NHTSA letter from Mr. Barry Felrice to K.-H. Ziwica dated 10/04/93).

2. The monitoring circuits for radio theft and glove box entry, now, monitor glass breakage to further ensure the security of the entire occupant compartment, rather than, the individual components. All other monitoring (e.g. doors, hood, trunk, etc.) has remained as when the device was previously approved.

3. The anti-theft device's siren has been changed to a 112db siren.

If further information is needed or you have any questions regarding this matter, please contact Mr. Patterson on (201) 573-2041.

ID: nht78-3.23

DATE: 02/14/78

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

TO: Collins Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 15, 1977, letter asking several questions concerning Standard No. 217, Bus Window Retention and Release.

In your first question, you paraphrase the requirements of S5.3.3 concerning emergency exit force requirements and release motion and ask whether your understanding of the section is correct. Your interpretations of the standard's requirements are accurate.

Second, you enclosed photographs of a manufacturer's rear emergency door release mechanism and asked whether it complies with the standard's requirements. The force release mechanism shown in the pictures does not comply with the requirements of Standard No. 217. The release mechanism is not located in the high force access region as required by the standard, and the motion required for release of the exit is not upward as required by paragraph S5.3.3

Finally, you asked whether your enclosed copy of Standard No. 217 which includes paragraph S5.2.3.1 is up-to-date. The answer to your question is yes. You have been confused by paragraph S5.2.3.1 because it states that a bus must have, at a minimum, one rear emergency door or a side emergency door and a rear push-out window. The requirement for one rear emergency door does not preclude a schoolbus with a 10,000 pound GVWR or less from using two (double) rear emergency doors. Paragraph S5.4.2.2 states ". . . the opening of the rear emergency door or doors shall be . . ." (Emphasis added). The use of the term "doors" in paragraph S5.4.2.2 indicates that double doors are permitted.

ID: nht68-3.44

DATE: 07/26/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Toyota Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 27, 1968, in which you requested clarification of the term "optically combined" as applied to motor vehicle lights.

"Optically combined" in this context means that the same lens area is used for more than one function such as tail and stop lights or stop and turn signal lights or tail, stop and turn signal lights. The normal means used to accomplish this "optically combined" lamp has been to incorporate a single dual-filament bulb with a reflector and lens.

Since the design of your Toyota Crown combination stop, tail and turn signal lamp is such that a different part of the lamp area is used for the turn signal lamp, we do not interpret it to be optically combined with the tail and stop lamp.

The concurrence of the above interpretation with yours and that of the California Highway Patrol should not be construed to be an approval of your design. The results of recent research on lighting and signaling reviewed by this Bureau indicate that signal lights should be separated 4 1/2 to 5 inches minimum (centerline to centerline separation.) Although no dimensions are specified on your drawing it appears to be approximately full scale with a separation distance of 2 1/2 inches between the stop and turn signal lamps. The steady-burning stop lamp may therefore "wash out" or significantly reduce the effectiveness on the turn signal lamp. Federal Motor Vehicle Safety Standard No. 108 does not require a minimum separation distance between signal lights; however, upon completion of our present research contracts on rear lighting and signaling, we may consider such a requirement in the future.

ID: 1983-2.28

TYPE: INTERPRETATION-NHTSA

DATE: 07/12/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Ezon Products Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Louis Gaia V.P. Purchasing Ezon Products, Inc. P.O. Box 18134 Memphis, Tennessee 38118

Dear Mr. Gaia:

In your letter of June 2, 1983, to the Office of Chief Counsel, you asked if there were "any D.O.T. requirements on miniature bulbs?"

We understand your question to refer to bulbs used in lighting devices other than headlamps. Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, imposes no performance requirements on individual bulbs used in lighting devices other than those used in replaceable bulb headlamps (an option permissible as of July 1, 1983). Other lighting devices must meet the photometric requirements of the standard with the bulb, chosen by the lighting device manufacturer, installed.

I hope that this answers your question.

Sincerely,

Frank Berndt Chief Counsel

June 2, 1983

National Hwy. Traffic Agency Office of Chief Councel 400 7th St. S.W. Washington, D.C. 20590

Dear Sir:

We were advised by Mr. Al Kazmierzak from the D.O.T. to write you concerning the following.

Are there any D.O.T. requirements on automotive miniature bulbs?

Please advise.

Awaiting your reply,

EZON PRODUCTS, INC.

Louis Gaia V.P. Purchasing

LG/dd

ID: aiam5243

Dear Ms. Jones: This responds to your request for an interpretation o Federal Motor Vehicle Safety Standard No. 213, Child restraint systems. S5.2.3.2(b) of Standard No. 213 specifies a minimum thickness for materials of a certain compression- deflection resistance. You ask whether more than one piece of material may be used to meet the thickness requirement. The answer is yes. S5.2.3.2(b) does not require the material to be of a single piece, and the final rule that incorporated the requirement into Standard No. 213 did not address the issue. 44 FR 72131, December 13, 1979. Accordingly, more than one piece of material may be used. I hope this information is helpful. If you have any further questions, please contact us. Sincerely, John Womack Acting Chief Counsel;

ID: aiam1547

Dear Mr. Miyazawa: This is in reply to your letter of June 27 concerning the location o motorcycle turn signal lamps relative to a combination stop lamp and reflex reflector.; The minimum edge to edge separation distance specified in Table IV o FMVSS No. 108 for motorcycle turn signal lamps is to be measured from the edge of the illuminated surface of both lamps.; The answer to your question 2 is therefore applicable, '2. edge to edg of tail and stop lamp so drawn in sketch C?'; Sincerely, E. T. Driver, Director, Office of Crash Avoidance, Moto Vehicle Programs;