ID: nht76-1.47

DATE: 11/17/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your September 16, 1976, question whether any Federal regulation requires that the maximum load rating assigned to a passenger car tire be reduced by approximately 10 percent in calculating its maximum load rating for use on a multipurpose passenger vehicle (MPV), truck, or bus.

The answer to your question is yes. Standard No. 120, Tire Selection and Rims for Motor Vehicles Other than Passenger Cars, became effective September 1, 1976, and provides for the reduced maximum load rating you describe. Section S5.1.2 of the standard provides in part that "[when] a tire listed in [the passenger car tire standard] is installed on a multipurpose passenger vehicle, truck, bus, or trailer, the tire's load rating shall be reduced by dividing by 1.10 before calculating the sum [that must at least equal the axle system's gross axle weight rating]." A copy of the standard, with subsequent amendments, is enclosed for your information.

SINCERELY,

DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

September 16, 1976

John W. Snow National Highway Traffic Safety Administration

We have noted that page XI of the 1976 Tire and Rim Association standards, copy enclosed, requires that a passenger car tire be loaded to not more than 91 percent of its rated load when used on a truck, bus or multipurpose passenger vehicle. Is this limitation included as a part of Federal Motor Vehicle Safety Standards Nos. 109 or 119?

If the requirement is applicable, we propose to include it in our Vehicle Equipment Inspection Guide. If the restriction is not referenced in the standard, are we preempted from adopting it as a part of the enclosed State regulations on tires?

WARREN M. HEATH Commander Engineering Section

ID: nht76-1.48

DATE: 02/24/76

FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA

TO: file

TITLE: FMVSS INTERPRETATION

ID: nht76-1.49

DATE: 12/08/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Kelsey-Hayes Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Kelsey-Hayes' April 21, 1976, question whether motor vehicle rims that are labeled in conformity with the requirements of Standard No. 120, Tire Selection and Rims for Vehicles Other Than Passenger Cars, may be installed on passenger cars.

The requirements of S5.2 of Standard No. 120 for labeling of rims for use on multipurpose passenger vehicles, trucks, buses, trailers, and motorcycles do not affect the use of those rims on passenger cars. This situation would change if Standard No. 110, Tire Selection and Rims, is modified in the future to prohibit one or more of the items required by S5.2, but such an eventuality is considered to be unlikely.

Sincerely,

ATTACH.

KELSEY-HAYES COMPANY

November 9, 1976

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

RE: Request for Interpretation: FMVSS-120

Dear Mr. Berndt:

We requested an interpretation on this safety standard in April, 1976 and have not yet received a reply. A copy of my April 21 letter is enclosed for reference.

May we hear from you soon on this matter? We have some pressing business decisions to make.

Very truly yours,

John F. McCuen

enclosure

KELSEY-HAYES COMPANY

April 21, 1976

Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration RE: Request for Interpretation - FMVSS-120 Non-Passenger Car Rims

Dear Mr. Berndt:

Kelsey-Hayes Company is a domestic manufacturer of motor vehicle equipment including rims for passenger car, truck, and other vehicle applications.

We make some rims that are used for both original equipment passenger cars and original equipment recreational trailers. As we understand the provisions of FMVSS-120, such a rim, when manufactured and sold for use on a trailer, must conform to FMVSS-120. It is not clear, however, whether rims conforming to FMVSS-120 may also be used on new passenger cars.

We envision circumstances under which a rim marked in conformance with FMVSS-120 is inadvertently shipped to a passenger car assembly plant for use on a new passenger car. We seek your interpretation of whether or not a manufacturer of passenger cars may use rims conforming to FMVSS-120. Assuming there is a safety benefit to the marking of rims for use on vehicles other than passenger cars, we assume those benefits are comparable when the same rim is used on a passenger car. This apparent benefit would seem to outweigh the costs associated with segregating identical wheels as a factor of the customers to whom we ship them to.

Accordingly, (Illegible Words) which would enable us to sell (Illegible Words) to FMVSS-120 for original equipment passenger car applications.

Very truly yours,

John F. McCuen

ID: nht76-1.5

DATE: 02/18/76

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your February 3, 1976, letter pointing out an error in the publication of Federal Motor Vehicle Safety Standard No. 101, Control Location, Identification, and Illumination, in Supplement 109 to the Federal Motor Vehicle Safety Standards and Regulations.

While the Federal Register is, of course, the official source of the law, we share your concern for the accuracy of the supplements. The error in Table 1 of Standard No. 101 was discovered immediately upon its publication and steps were taken to correct it. We expect the correction to appear in the supplement to be mailed on February 25, 1976.

YOURS TRULY,

Ford Motor Company

February 3, 1976

Dr. James B. Gregory Administrator National Highway Traffic Safety Administration

Re: "Federal Motor Vehicle Safety Standards and Regulations" - Supplement 109, dated December 3, 1975

In the subject publication, the technical reproduction of Federal Motor Vehicle Safety Standard 101, "Control Location, Identification and Illumination, Passenger Cars, Multipurpose Passenger Vehicles, Trucks and Buses" is in error. Columns 3 and 4 of Table I are incorrect, and page 3 was revised without a change in the revision date.

Attachments I through IV show Table I:

* as it appears in the December 3 supplement,

* before the latest amendment,

* amendments published in Docket 1-18; Notice 11 (40 FR 31770-71) July 29, 1975,

* as it should appear.

We appreciate the fact that the Federal Register is the official source for information related to amendments to the rules. Howeve, the value of the supplement lies in the fact that the revisions and pagination provide for a complete and up-to-date reference that is of continued use. Mistakes in this document may lead to unnecessary confusion.

Because of the importance of this document in our daily work and because the source of the information originates with your staff, we would like to request that you look into this matter to correct the current mistake and, if possible, have some member of your staff included in a galley proof review procedure to ensure that supplements are complete and accurate.

J. C. Eckhold Director Automotive Safety Office

Table 1 -- Control Identification and Illumination COLUMN 1 COLUMN 2 COLUMN 3 Permissible Motor Vehicle Equipment Control Word or Abbreviation Symbol Engine Start Engine Start (Illeg.) None Engine Stop Engine Stop (Illeg.) None Manual Choke Choke None Head Throttle Throttle None Automatic Vehicle Speed Control Headlamps and Taillamps Lights (Illegi.) (Illeg.) Vehicular Hazard Warning Signal Hazard (Illeg.) Clearance Lamps Clearance Lamps or CL (Illeg.) Identification Lamps Identification Lamps or ID LPS None Windshield Wiping System Wiper or Wipe (Illeg.) Windshield Washing System Washer or Wash (Illeg.) Windshield Defrosting and Defrost or Def None Defogging System Heating and Air Conditioning None System

(Graphics omitted) COLUMN 1 COLUMN 4 COLUMN 5 Alternate Motor Vehicle Equipment Control (Illeg.) Illumination Symbol Engine Start None Engine Stop None Yes Manual Choke None Hand Throttle None Automatic Vehicle Speed Control None Yes Headlamps and Taillamps (Illeg.) Vehicular Hazard Warning Signal Yes Clearance Lamps (Illeg.) Yes Identification Lamps None Yes Windshield Wiping System (Illeg.) Yes Windshield Washing System Yes Windshield Defrosting and None Yes Defogging System Heating and Air Conditioning None Yes System

n1 Use when engine control is separate from the key locking system.

n2 Use also when clearance, identification lamps and/or side marker lamps are controlled with the headlamp switch.

n3 Use also when clearance lamps, identification Lamps and/or side marker lamps are controlled with one switch other than the headlamp switch.

n4 Framed areas may (Illegible Words).

(Graphics omitted)

TABLE 1 - Control Identification and Illumination COLUMN 1 COLUMN 2 Motor Vehicle Equipment Control Word or Abbreviation Engine Start Engine Start (Illeg.) Engine Stop Engine Stop (Illeg.) Manual Choke Choke Hand Throttle Throttle Automatic Vehicle Speed Control Headlamps and Taillamps Lights (Illeg.) Vehiclular Hazard Warning Signal Hazard Clearance Lamps Clearance Lamps (Illeg.) or CL LPS Identification Lamps Identification Lamps or ID LPS Windshield Wiping System Wiper or Wipe Windshield Washing System Washer or Wash Windshield Defrosting and Defrost or Def Defogging System Heating and Air Conditioning System

(Graphics omitted) COLUMN 1 COLUMN 3 COLUMN 4 Permissible Motor Vehicle Equipment Control Illumination Symbol Engine Start None Engine Stop None Yes (Illeg.) Manual Choke None Hand Throttle None Automatic Vehicle Speed Control None Yes Headlamps and Taillamps (Illeg.) Vehicular Hazard Warning Signal (Illeg.) Yes Clearance Lamps (Illeg.) Yes Identification Lamps None Yes Windshield Wiping System (Illeg.) Yes Windshield Washing System (Illeg.) Yes Windshield Defrosting and None Yes Defogging System Heating and Air Conditioning None Yes System

(Illegible Lines)

(Graphics omitted) Column 1 Column 4 Alternate Permissible Symbol . None None None None None Headlamps and Taillamps (Illeg.) Vehicular Hazard Warning Signal (Illeg.) Clearance Lamps (Illeg.) None Windshield Wiping System (Illeg.) Windshield Washing System (Illeg.) None None (Illegible Word) areas may be filled.

(Graphics omitted)

TABLE I - Control Identification and Illumination COLUMN 1 COLUMN 2 COLUMN 3 Motor Vehicle Equipment Word or Permissible Control Abbreviation Symbol Engine Start ENGINE START n1 None Engine Stop ENGINE STOP n1 None Manual Choke CHOKE None Hand Throttle THROTTLE None Automatic Vehicle Speed Control None Headlamps and Taillamps LIGHTS n2 (Illeg.) Vehicular Hazard Warning Signal HAZARD (Illeg.) Clearance Lamps CLEARANCE LAMPS n3 or CL LPS (Illeg.) Identification Lamps IDENTIFICATION LAMPS or ID LPS None Windshield Wiping WIPER or System (Illeg.) (Illeg.) Windshield Washing WASHER or WASH (Illeg.) System Windshield Defrosting DEFROST or DEF None and Defrosting System Heating and Air None Conditioning System

COLUMN 1 COLUMN 4 n3 COLUMN 5 Motor Vehicle Equipment Alternate Illumination Control Permissible Symbol Engine Start None Engine Stop None Yes n1 Manual Choke None Hand Throttle None Automatic Vehicle Speed Control None Yes Headlamps and (Illeg.) n4 Taillamps Vehicular Hazard (Illeg.) n4 Warning Signal Yes Clearance Lamps (Illeg.) n4 Yes Identification Lamps None Yes Windshield Wiping (Illeg.) System Yes Windshield Washing (Illeg.) System Yes Windshield Defrosting None Yes and Defrosting System Heating and Air None Yes Conditioning System

n1 Use when (Illegible Word) control is separate from the key locking system.

n2 Use also when clearance, identification lamps and/or side maker lamps are controlled with the headlamp switch.

n3 Use also when clearance lamps, identification lamps and/or side market lamps are controlled with one switch other than the headlamp switch.

n4 Heated areas may be filled.

(Graphics omitted)

ID: nht76-1.50

DATE: 06/12/76

FROM: AUTHOR UNAVAILABLE; T. W. Herlihy for S. P. Wood; NHTSA

TO: Toyota Motors Sales, U.S.A., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your February 23, 1976, letter concerning the rim marking requirements of S5.2 of Federal Motor Vehicle Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.

In its present form, S5.2 requires a rim to which the standard applies to be marked with its size designation and, if it is a multi-piece rim, its type designation as well. There is no prohibition on the marking of additional information beyond that which is required. Therefore, the marking of single piece rims with a type designation is permitted.

Please note that, in a notice published on May 6, 1976 (41 FR 18659, Docket No. 71-19, Notice 4), the National Highway Traffic Safety Administration delayed the effective dates of several of the standard's requirements. In particular, the effective date of S5.2, Rim Marking, was delayed until August 1, 1977. A copy of this notice is enclosed for your convenience.

Yours truly,

Enclosure

ATTACH.

TOYOTA MOTOR SALES, U.S.A., INC.

FACTORY REPRESENTATIVE OFFICE

February 23, 1976

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

Re: Interpretation of FMVSS No. 120, S5.2

Dear Mr. Berndt:

This is to request interpretation of Federal Motor Vehicle Safety Standard No. 120, 'Tire Selection and Rims for Vehicles other than Passenger Cars," which was published in the Federal Register of January 23, 1976 as Docket No. 71-19; Notice 3.

In S5.2, it lists the information required to be marked on each rim on and after August 1, 1976. As we understand it, this requirement does not prohibit marking of additional information on rims. For example, although S5.2(6) requires that each rim be marked with information of the rim size designation, and, in the case of multipiece rims, the rim type designation, we believe that single piece rims should also be marked with the rim type designation, such as the type of flange denoted as J, JJ, etc., for reasons of vehicle safety.

We would appreciate your informing us of the correct interpretation at your earliest convenience.

Very truly yours,

D. KIWANO FOR

K. Nakajima -- Director/General Manager, Factory Representative Office

ID: nht76-1.6

DATE: 04/06/76

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood; NHTSA

TO: American Bosch Electrical Products

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 23, 1976, question whether Standard No. 104, Windshield Wiping and Washing Systems, still references SAE J903a as it did in 1969, and whether a future reference to SAE J903b or SAE J903c is anticipated.

The answer to your first question is yes. The answer to your second question is no. A proposed change in Standard No. 104 would be published in the Federal Register, and interested persons would be given an opportunity to comment.

Yours truly,

ATTACH.

American Bosch Electrical Products

February 23, 1976

Administrator -- National Highway Traffic Safety Administration

Subject: Federal Motor Vehicle Safety Standard 104

Gentlemen:

As a manufacturer of automotive windshield wiping systems we have a requirement to maintain compliance with the referenced standard. FMVSS 104, effective January 1, 1969, references SAE J903a (May 1966) as criteria for test conditions of wiping systems. Concerning these two documents we have several questions:

1. Is FMVSS 104 currently of effective date January 1, 1969?

2. Are any changes in FMVSS 104 pending that (Illegible Word) reference SAE J903b or SAE J903c? If so, please explain.

This information is needed for present planning. Please reply to the attention of the undersigned.

Sincerely,

Alvin L. Slayton, Engineer -- Product Reliability Department

ID: nht76-1.7

DATE: 02/26/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Alaska Traffic Safety Bureau

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to a request by Mr. William Hall, National Highway Traffic Safety Administration (NHTSA) Regional Administrator for Region X, for a review of Federal Motor Vehicle Safety Standard No. 104, Windshield Wiping and Washing Systems with special consideration of the comments of Mr. Robertson in his memorandum of November 24, 1975.

It is the opinion of this agency that Standard No. 104 is appropriate for the State of Alaska. The essential feature of a wiping system, as far as safety is concerned, is its ability to clear a specific portion of the windshield. The number of wipers necessary to provide the driver with a sufficient field of view is immaterial so long as the minimum percentages of critical areas are washed and wiped. These areas are established in the standard and are determined by the angles from the driver's eye position over which the windshield must be kept clear to provide a proper field of view. While targets of driver attention and environmental conditions may differ from state to state, if the critical areas are clear, the field of view provided to the driver is sufficient. The 1976 Scirocco appears to provide the required field of view.

The question therefore becomes whether the Federal standard on windshield wipers is intended to cover all aspects of wiping systems. If so, the situation is analogous to that presented to the court in Motorcycle Industry Council v. Younger, No. CIV S74-126 (E.D.Cal. 1974) which resulted in a holding that Standard No. 108 did preempt an inconsistent state regulation in the field of lighting requirements. The NHTSA has determined that the standard on windshield wiping systems, No. 104, is intended to leave the number of wipers to the discretion of the manufacturers. Under Thorpe v. Housing Authority of Durham, 393 U.S. 268 (1969), and Chrysler v. Tofany, 419 F2d 499, 511-12 (2d Cir, 1969), the interpretation of this question by the administering agency is "of controlling weight unless it is plainly erroneous or inconsistent with the regulation." Thus, a state regulation differing from the standard would impair the Federal superintendence of the field within the meaning of the doctrine set forth in Florida Lime & Avocado Growers v. Paul, 373 U.S. 132, 141-142 (1963) and be preempted under section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966, U.S.C. 1392(d).

ID: nht76-1.8

DATE: 07/15/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Pacet International

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your June 15, 1976, question whether Arcoflex windshield wiper blades must be certified as being in compliance with Federal motor vehicle safety standards before they may be sold as aftermarket equipment through vehicle distributors' dealer parts programs.

Standard No. 104, Windshield Wiping and Washing Systems, requires vehicles to be equipped with a power-driven windshield wiping system that meets specified performance requirements. It is up to vehicle manufacturers to certify that each vehicle they produce conforms to the requirements of Standard No. 104, in accordance with the certification procedures specified in 49 CFR Part 567.

Standard No. 104 is not an equipment standard, however, and is not applicable to wiper blades sold in the aftermarket. Therefore, there is no requirement that Arcoflex windshield wiper blades be certified, so long as they are not installed on vehicles as part of the wiping system prior to the first sale of the vehicle.

Sincerely,

ATTACH.

PACET INTERNATIONAL

The Chief Counsel -- NHTSA

Gentlemen

This Company imports Arcoflex windshield wiper blades from Italy and sells them through the import aftermarket throughout the US. It is my understanding that your Department has no interest in this activity.

Recently, however, we have endeavored to sell our product to the import car manufacturers' US distributors for marketing through their dealer parts programs. The representatives of some of these companies have expressed the concern that, since they are wholly owned by the car manufacturers, your Department may wish for our product to be certified, even though it will not be used as original equipment on their cars.

Please be kind enough to clarify, therefore, whether or not Arcoflex wiper blades need to be certified by your Department before they may be sold through import car distributors' dealer parts programs.

Your immediate attention to this matter would be greatly appreciated, since important sales decisions depend upon your reply.

Yours very truly,

Peter W Mole

ID: nht76-1.9

DATE: 08/09/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Clayton Dewardre Company Limited

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Clayton Dewandre Company's May 20, 1976, request for confirmation that its "Dual Brake Booster" system is designed to conform to the definition of "split service brake system" and the requirements of S5.1.2 and S5.1.3 specified in Standard No. 105-75, Hydraulic Brake Systems. In unimpaired braking, the Dual Brake Booster system supplies two separate brake circuits, the primary circuit which is initially powered by the driver's application of pedal force and subsequently supplemented by pressurized fluid from the pump accumulator system, and the secondary circuit which is powered by pressurized fluid from the pump accumulator system. In the event of a primary circuit failure, a mechanical connection unimpaired by a loss of reservior fluid continues to modulate the secondary circuit. In the event of the a secondary circuit failure, the driver's pedal application continues to actuate the primary circuit by muscular effort alone. A single master cylinder reservoir is provided to supply the primary circuit. A single pump reservoir supplies the pump, accumulator, and secondary circuit.

As you are no doubt aware, the National Traffic and Motor Vehicle Safety Act does not authorize a "type approval" of vehicle design as the basis for certification (15 U.S.C. @ 1397(a)(1)(A)). Our comments on the description of your system do not relieve the vehicle manufacturer of its responsibility to design a system for each of its products that actually complies with the standard's requirements.

From your description of the system, it would appear to qualify as a "split service brake system" as that term is defined in S4 of the standard. You state that, in the event either subsystem is failed, the other subsystem is capable of indefinite operation. This conforms to the

2

NHTSA's September 14, 1973, letter to Citroen on the meaning of "unimpaired operation" of a subsystem.

With regard to partial failure performance, you state that the vehicle can meet the requirements of S5.1.2 (inadvertently designated as S5.1.1 in your letter) using either of the two subsystems.

With regard to the requirements of S5.1.3 (for inoperative brake power assist unit or brake power unit), you indicate that the vehicle is capable of stopping within the specified distances of column IV of Table II "purely by muscular effort of the driver". By this we assume you mean that the vehicle conforms to the condition required for testing under S5.1.3.1, i.e., with one power unit inoperative and deleted of all reserve capability. Please note that the NHTSA regards the "pump and accumulator" energy source to constitute a "brake power unit" and not a "brake power assist unit", because the described unit "provides the energy required to actuate the brakes, either directly or indirectly through the auxiliary device, with the operator action consisting only of modulating the energy application level." (S4 definition of "brake power unit").

We are assuming that Clayton Dewandre does not object to making public the designs described in your May 20 letter. The NHTSA will place the materials in the public docket three weeks after the date of this letter unless we hear otherwise from you.

Yours truly,

ATTACH.

Clayton Dewandre Company Limited

May 20, 1976

James B. Gregory -- Administrator, National Highway Traffic Safety Administration, U.S. Department of Transportation

Dear Sir,

Request for advice on the conformities of New Design equipment to the revised Hydraulic Brake System Standard FMVSS 105-75

Clayton Dewandre would like to take this opportunity to introduce to you our newly developed Hydraulic Brake Booster and associated system, (Illegible Word) on behalf of our potential customers, we seek clarification from you regarding its compliance with the revised Hydraulic Brake Standard FMVSS 105-75.

We would refer to section S4 and the definition of a "Split Service Brake System" which includes a statement that a failed sub-system, quote "shall not impair the operation of any other sub-system".

Our interpretation of the expression "impair" is "reduce (Illegible Word) prescribed effective level", and that same implied level is quantified under requirements S.5.1.1. Partial Failure and S.5.1.3. In-operative Brake Power Assist Unit. Both the latter clauses call for the same level of performance i.e. stopping distances from a vehicle speed of 60 m.p.h. without exceeding a pedal force of 150 lbs. Vehicle Cars Trucks<10000 lbs. trucks>10000 lbs. Stopping 456' 517' 613' distance (.263g) (.233g) (.195g)

We would like to show, with reference to the attached description of the Dual Brake Booster, that with a power failed situation or rear brakes failed, we have the same residual secondary braking i.e. the front brakes, being activated purely by muscular effort of the driver, with chamber (a) acting as a conventional master cylinder. The designed performance for this condition in the case of a 2000 Kg (4,400 lbs) gross weight vehicle would be .3g for a pedal force 71 lbs (316N). This meets the prescribed performance tabled above.

Should a failure occur in the other sub-system (Illegible Words) mechanically by further movement of the pedal (approximately 12 mm.) for full output to "knee point". Fluid under pressure is delivered by the valve in proportion to pedal effort. Again in this case, the system is tuned to provide an acceptable performance. The attached figures show a retardation of .3g for 52 lbs (231N) pedal force, which is well within the prescribed limits.

2

(Illegible Text)

Yours faithfully,

W. M. PAGE -- Senior Engineer - Systems Engineering

[Attachments Omitted.]

ID: nht76-2.1

DATE: 05/04/76

FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA

TO: FILE

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: TELEPHONE CONVERSATION CONCERNING STANDARD NO. 120, TIRE SELECTION AND RIMS FOR MOTOR VEHICLES OTHER THAN PASSENGER CARS

On April 20, 1976, I received a telephone call from Mr. John McCuen, an attorney for Kelsey-Hayes (313 941-2000). He asked the following questions concerning Federal Motor Vehicle Safety Standard No. 120:

1. "Is use of the 'DOT' symbol permitted on rims manufactured before the August 1, 1976, effective date for the standard's rim marking requirements?" I replied that the agency's present position is as it has been in the past, namely, that such use is not permitted. I added that this interpretation is being reevaluated.

2. "Some rims are capable of being used on passenger cars as well as on multipurpose passenger vehicles. Is it permissible to label such rims pursuant to Standard No. 120, even though some might then be mounted on passenger cars?" I requested that Mr. McCuen send in a request for a written interpretation of that aspect of the standard.

3. "May rims manufactured before August 1, 1976, be sold in the replacement market after that date?" I replied that they may.