ID: nht90-4.77

TYPE: Interpretation-NHTSA

DATE: December 7, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA; Signature by S.P.W.

TO: Takahiro Maeda -- Assistant to the Vice President, Engineering Division, Yamaha Motor Corporation, U.S.A.

TITLE: None

ATTACHMT: Attached to letter dated 9-28-90 to Office of Chief Counsel, NHTSA from Takahiro Maeda (OCC 5275)

TEXT:

This is in reply to your letter of September 28, 1990, requesting an interpretation of Motor Vehicle Safety Standard No. 108.

Table IV of the standard establishes a minimum "edge to edge separation distance" between turn signal lamps and tail or stop lamps installed on motorcycles. You have asked whether the edge in question is the outer edge of the lamp assembly itself, or th e edge of the reflector in the lamp.

The minimum edge to edge separation distance is measured from the edge of the illuminated surface of one lamp to another, that is to say, from the edge of the effective projected luminous area of one lens to the edge of the effective projected luminous a rea of the other. It is unclear from the drawing you enclosed of the "tail/brake lamp" whether the edge of its effective projected luminous area of the lens is at the edge of the reflector, or at the edge of the lamp (as appears to be the case with the "turn signal"). If the former, the distance is measured between the edge of the tail/stop lamp reflector to the edge of the turn signal lamp assembly as you have initially indicated.

ID: nht90-4.78

TYPE: Interpretation-NHTSA

DATE: December 11, 1990

FROM: Chino O'Hara -- Minority Co-Ordinator, Del Mar Manufacturing Company

TO: Office of Chief Council -- NHTSA-NCC

TITLE: None

ATTACHMT: Attached to letter dated January 14, 1991 from Paul Jackson Rice to Chino O'Hara (A37; Std. 108; Std. 121; Std. 302; Std. 105; VSA 108(a)(2)(A))

TEXT:

Del Mar Manufacturing Co, has been in Business for over 20 years, we are a Certified Minority Owned Business here in Southern Cal. Our product (HUSKY-ANTI SQUEEK) is a breakthrough in the Automotive Aftermarket Brake Industry. Currently this product is being tested by GENERAL MOTORS, FORD, CHRYSLER, TOYOTA, HONDA, NISSAN and some military installations. The question keeps coming up (DO WE NEED DOT APPROVAL FOR OUR PRODUCT). If you can answer this question in a written response to us it would be appr eciated.

Attachment

MATERIAL SAFETY DATA SHEET DEL MAR MANUFACTURING CO. 2713-B N. TOWNE AVE. POMONA, CA. 91767 EMERGENCY TELEPHONE: 714-625-0555 SECTION I-PRODUCT IDENTIFICATION

Part Number: AS-88 Product Name: Husky Brake Anti-SqueekChemical Family: Brake Quite

SECTION II-HAZARDOUS INGREDIENTS

Ingredients: % TLVGraphite-Carbon Black: 4.8 --- Aliphatic Solvent : 27.0 400 Aromatic Solvents : 28.0 200

SECTION III-PHYSICAL DATA

Boiling Poin: Deg. F/C 181 F/83 C Specific Gravity: 1.1 Vapor Pressure (MM HG): 33 %Volatile Volume: 68 Vapor Density (AIR=1): 1.3 Evaporation Rate: 1.5Solubility in Water: Miscible Water/oil Dist Coeff: 9 Appearance and Odor: High Viscosity Black Liquid, Slightly Sweet Odor. Physical State: Liquid Freeze Pt.: Deg F/C 10F/-14C Threshold Odor.PPM 5PH: N/A

SECTION IV-FIRE AND EXPLOSION HAZARD

Flammability Classification: Flammable Liquid NFPA Rating: 1,3,0 Flash Point Deg. 54/11 C Extinguishing Media: Extinguish With Dry Chemical Water, ray or Fog Special Fire Fighting Procedures: Use Air Supplied Rescue Equipment in Closed Areas. Cool Exposed Container With Water. Explosive Power: Low Impact Sensitive: NoBurning Rate: Low

SECTION V-HEALTH HAZARD DATA

Threshold Limit Value: 390 PPM Effects of Overexposure: May Cause Dizziness, Light Headache, and Difficulty in Breathing in areas of High Concentration of Vapors. Any Victim Should Seek Air Free of Vapors. Emergency and First Aid Procedures: Eyes, Flush Immediately With Plenty of Waters. Skin, Wash with Soap and Water. If Swallowed, Do Not Induce Vomiting and Contact Physician Immediately.

SECTION VI-REACTIVITY DATA

Stability: Yes Conditions to Avoid: Keep Away From Heat, Sparks, Flames or Sources of Ignition. Incompatibility: Strong Oxidizers Hazardous Decomposition Products: No Hazardous Polymerization: No

SECTION VII-SPILL OR LEAK PROCEDURES

Steps to be Taken in Case Material is Released or Spilled: In Case of Spill: Flush Small Amounts to Sewer With Plenty of Water. Remove All Sources of Ignition, Ventilate Area, Clean up With Absorbent Material Contain and Pick up Waste Material, Put in a Sealed Approved Container. Report Quantity: 10,000 lb. Dispose of Waste In Accordance With Federal, State and Local Regulations.

SECTION VIII-SPECIAL PROTECTION INFORMATION

Respiratory Protection: Use Only in Well Ventilated Areas.

Ventilation-Local: Recommended Mechanical : Required Special : Keep Away From Heat and Flame

Protective Gloves: Vinyl or Leather Solvent Resistant Gloves, Eye Protection : Goggles Other Protective Equipment: Vinyl or Leather Apron & If Ventilation is Inadequate, Wear Approved Respiratory Equipment.

SECTION IX - SPECIAL PRECAUTIONS

Precautions To Be Taken In Handling and Storing: Store in Cool Dry Area, Keep Away From Heat, Sparks, Flames, or Sources of Ignition. Adequate Ventilation Required. Avoid Prolonged or Repeated Breathing of Gas, Fumes, Vapor or Spray Mist. Avoid Prolonged or Repeated Contact With Skin. Do Not Take I nternally. In Case of Accident or Illness, Contact Physician Immediately.

Other Precautions: Keep Out of Reach of Children. Read and Follow Directions on The Product Label.

Neither this data sheet nor any statement contained herein grants or extends any license, express or implied, in connection with patents issued or pending which may be the property of the manufacture or others. The information in this data sheet has bee n assembled by the manufacturer based on its own studies and on the work of others. The manufacturer makes no warranties, express or implied, as to the accuracy, completeness, or adequacy of the information contained herein. The manufacturer shall not be liable (regardless of fault) to the vendee, the vendee's employees, or anyone for any direct, special or consequential damages arising out of or in connection with the accuracy, completeness, adequacy, or furnishing of such information.

BRAKE ANTI-SQUEEK APPLICATION INSTRUCTIONS STEP 1 : DISASSEMBLY

A : Remove pads from caliper assembly. B : Sand pad surface using a light to medium sand paper or emery cloth. This will remove the glaze (on used pads). STEP 2 : CLEANING

A : Spray (clean) pad surface liberally with brake cleaner. This removes all contaminants from the pad surface. Let dry completely, approximately one minute. STEP 3 : BRAKE ANTI-SQUEEK APPLICATION

A : Heat metal backing plate until lining is hot to open pores in the lining. Soak pads in brake anti-squeek for 10 minutes face down to allow solution to penetrate the pads. Note: Metal backing plate must be heated up to promote faster drying. STEP 4 : REASSEMBLY & INSTALLATION

When pad surfaces are compltely dry, assemble and reinstate brake assembly.

STEP 5 : TESTING THE BRAKES

It should be noted that brakes will GRAB & GROAN tremendously during the first two or three stops. This is normal. USE HUSKY BRAKE ANTI-SQUEEK, EVERYTIME YOU DO A BRAKE JOB.

Subject: "Husky Brake Anti-squeek (HBAS)" "cure for noisy, nervous brakes" Thank you for stopping at our booth.

The Del Mar manufacturing Co. started business in July 1972 with idea to manufacture and distribute the finest line of automotive chemicals and tire sealing products available at very competative prices. Now after 18 years in business we have reached th is goal of having the highest quality in products available throughout the country for the automobile, bicycle and motorcycle industries. Our products include tire sealers for almost all kinds of tires, brake anti-squeek for disc or regular brakes, D-gu m and Saf-T-Dip: a carburetor parts cleaner and fiberglass metal cleaner and polish. We welcome your orders and look forward to doing business with you.

We have nationwide W.D program for our very unique product "HUSKY BRAKE ANTI-SQUEEK". We have manufacturing representatives in all states except east coast and south eastern states.

Unlike many other jelly type products which are applied to the back of the plate, HBAS is applied directly on the pad surface which will stop BRAKE SQUEEKING and will produce a surface that gives better braking.

The following are unique features of HBAS: * Quiets noisy brakes. * Will stop brake squeaking and eliminate pad squeal. * Produce a surface that gives better braking. * Recommended for use on old or new pads, either metallic, semi-metallic, or organic or non-asbestos organic.

Here is some suggested approach that shows you why you should use HUSKY BRAKE ANTI-SQUEEK.

1. 87% of all brake job "comebacks" are squeek related. 2. Husky brake anti-squeek should be applied to all brake jobs as "insurance" against squeek comebacks. 3. One can of HBAS will treat 8-10 brake jobs making it a very in- expensive item to the mechanic, less than $0.50 per brake job. (average brake job - $185.00).

This product has been accepted by a great number of new and used car dealers and many big name chains specializing in brake jobs throughout the unites states. We invite you to try this effective solution to a particularly irritating source of noise poll ution. You will be amazed to see the results of your brakes after HBAS application.

This product has been endorsed by top two undercar distributors, TRUSTAR and CYGNUS for their members, private label under their name.

Thank you very much for your time. Please don't hesitate to call us for any question you may have.

BRAKE SQUEAKS DRIVING YOU NUTS !!! Nationally 28% of the brake jobs done come back, of which 87.0% are from squeaks.

The reason is because of lack of time, training and competitive cost of the brake job.

A large part of the squeaks are caused from the rotor and brake pad vibration. Squeaks are vibrations.

To help you understand more fully, think of the rotor being trued up by grinding away the rotor surface from the center to the outside edge of the rotor. By doing so, even on a fine cut, you leave grooves very much like a phonograph record has.

When you install the brake pads face surface to the rotor with groves, the brake pad is softer than the rotor and the rotor cuts grooves in the brake pad. When the rotor turns, the grooves and the brake pads try to follow the rotor grooves to the outsid e edge of the rotor, very much like the record player arm and needle follows the grooves in the phonograph record. We call this record effect, causing a squeak.

With the brake pad it can only travel so far and then snaps back and starts all over again until the rotor and brake pad wear together to a smooth working surface. It takes about 3000 to 5000 miles for this to happen.

This is by far the largest cause of squeaks in the brakes today.

To help correct this , there is a product called "HUSKY", it is an anti- squeek compound, made by Del Mar Manufacturing Company.

It is a compound that is applied to the face surface of the brake pad which soaks into the padding material and has graphite in it to help the pad to slip and not drag on the rotor, therefore eliminating the pad and rotor wearing together to cause a sque ak.

For a few cents per brake job, you can be assured that your customer's brake job will not come back with that all too frequent squeak that cost you time and money and most of all your customers trust you did the job right the first time.

Attachment

One page advertisement for Husky Brake Anti-Squeek (Text and graphics omitted)

ID: nht89-1.71

TYPE: INTERPRETATION-NHTSA

DATE: 04/14/89

FROM: EUGENIA M. PIERAKOS; JAMES L. PIERAKOS -- SNOWLIFTING EQUIPMENT AND

TO: CONSULTANTS OF BUFFALO INC HENRY J. NOWAK -- 33RD CONGRESSIONAL DISTRICT, NY

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/27/89 FROM STEPHEN P. WOOD -- NHTSA TO HENRY J. NOWAK -- CONGRESS; REDBOOK A33; PART 571; LETTER DATED 04/30/89 FROM HENRY J. NOWAK -- CONGRESS TO JOHN STONNER -- DOT;

TEXT: Dear Congressman:

This firm is the Western New York State dealer for Jaeger Industries, Inc., manufacturers of curbside recycling equipment, brochure and specifications for same enclosed.

For some time now, the manufacturer has attempted to obtain official information/data regarding their equipment, specifically the use of chain steering for dual steering applications; brakes, throttle, etc. They have spoken to various officials in NYSMV D with no success. They have been referred to NHTSA in Washington (202-366-2992), spoken with Asst. Chief Consul Steve Wood and Chief Consul Erika Jones, and no one has provide Jaeger with any definitive answers.

Since USDOT has no office in the Buffalo area, we are asking your help in obtaining the data/regulations that apply to this vehicle, especially the dual steering mechanism, brakes, throttle, etc.

We know you are vitally interested in the recyling programs in our area, and realize that its success is very dependent on good equipment. Several communities in the Buffalo area are planning to purchase these vehicles, but we must be sure that it meets all Federal and State standards. In view of the urgency of this matter, we would appreciate your office expediting same, so that we can have factual information as soon as possible. Your cooperation in this matter is greatly appreciated.

Respectfully,

enclosures omitted

ID: nht89-1.72

TYPE: INTERPRETATION-NHTSA

DATE: 04/14/89

FROM: VIRVE AIROLA -- OY TOPPI AB FINLAND

TO: NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 05/31/90 FROM STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL TO VIRVE AIROLA; LETTER DATED 01/26/72 FROM RICHARD B. DYSON -- ASSISTANT CHIEF COUNSEL NHTSA TO K. NAKAJIMA -- TOYOTA

TEXT: Gentlemen;

Our company, Oy Toppi Ab, is a Finnish producer of plastic tubes and hoses. One of our most important products is Air Brake Tubing made of Polyamide PA 11. We produce this tubing both conforming to SAE J 844 and to the German standard DIN 74324.

For some time ago we quoted our tubes to the Swedish truck and bus producer Saab-Scania AB and received their product standard. Among other things this standard states following:

Quote: the manufacturer shall be registered at NHTSA in USA and the symbol DOT constituting certification by the manufacturer that the hose conforms to all applicable FMVSS standards. quote

We have no doubt that we will fullfill the requirements for the register and would appreciate it if you could send us the application formula as soon as possible.

In case any information or details are needed, please let us know and we will send them for you immediately.

Brochures [OMITTED]

ID: nht89-1.73

TYPE: INTERPRETATION-NHTSA

DATE: 04/17/89

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: ROBERT C. CRAIG -- QUALITY CONTROL MANAGER COSCO, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 02/03/89 FROM ROBERT C. CRAIG TO GEORGE L. PARKER -- NHTSA, RE 49 CFR 571-213, STANDARD NO 213 CHILD RESTRAINT SYSTEMS AT 5.5.1 LABELING, OCC 3119

TEXT: Dear Mr. Craig:

This responds to your February 3, 1989 letter to Mr. George Parker, our Associate Administrator for Enforcement, seeking an interpretation of Standard 213, Child Restraint Systems (49 CFR @ 571.213). Specifically, paragraph S5.5 of that standard require s each child restraint system to be permanently labeled with certain specified information. On of the items of information required to be permanently labeled on the child restraint is the manufacturer's recommendations for the maximum weight and height of children who can safely occupy the system, and those weight and height recommendations must be expressed in English units (pounds and inches). Your letter stated that your company would like to express its maximum weight and height recommendations in both English units and equivalent metric units (kilograms and meters), and asked whether this would be permitted by Standard 213. As long as the information is presented in a manner that is not likely to cause confusion, Standard 213 does not prohibit manufacturers from expressing required information in equivalent English and metric units.

For each of the labeling requirements set forth in NHTSA's regulations, this agency has consistently taken the position that manufacturers may present information in addition to the required information, provided that the additional information is presen ted in a manner that is not likely to confuse the user. Moreover, the agency has already concluded that passenger car tires may be labeled with required information expressed in equivalent English and metric units. See the enclosed April 5, 1979 letter to Mr. Michael Petler. We would apply the same reasoning in interpreting the labeling requirements of Standard 213. That is, Standard 213 permits manufacturers to present the required information in

both English and metric units, provided that the information is presented in a manner that is not likely to confuse persons using the child restraint system.

Sincerely,

ENCLOSURE

ID: nht89-1.74

TYPE: INTERPRETATION-NHTSA

DATE: 04/17/89

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: JAMES R. TOMAINO -- YOUNGSTOWN RUBBER PRODUCTS COMPANY

TITLE: NONE

ATTACHMT: LETTER DATED 01/30/89 FROM JAMES R. TOMAINO TO ERIKA Z. JONES -- NHTSA, OCC 3073

TEXT: Dear Mr. Tomaino:

This responds to your January 30, 1989 letter asking whether a "permanently embossed raised dot" on your air brake hose assembly satisfies the requirement in Standard No. 106, Brake Hoses, for a manufacturer identification. As explained below, we believ e that use of the raised dot may be potentially confusing, since it isn't readily apparent whether the mark represents an intentional effort to identify the manufacturer of the assembly or is an accidental by-product of the manufacturing process.

By way of background, Standard No. 106 sets forth two methods of labeling air brake hose assemblies made with crimped or swaged end fittings. S7.2.3 states that these assemblies must be labeled by means of a band around the assembly or, at the option of the assembly manufacturer, by means of marking at least one end fitting as described in S7.2.3.1. You have asked us about the labeling requirements under the second option.

Since, for reasons of drafting convenience, the second option incorporates the portions of the first option relating to the nature of and filing of the designation, it is necessary to begin with a discussion of the first option. The first option (S7.2.3( b)) provides that the bank must be marked with informtion including:

A designation that identifies the manufacturer of the hose assembly, which shall be filed in writing with: Office of Vehicle Safety Standards, Crash Avoidance Division, National Highway Traffic Safety Administration, 400 Seventh St., SW, Washington, D .C. 20590. The designation may consist of block capital letters, numerals or a symbol. (Emphasis added.)

The second option (S7.2.3.1) requires assemblies to be "etched, stamped or embossed with a designation at least one-sixteenth of an inch high that identifies the manufacturer of the hose assembly and is filed in accordance with S7.2.3(b)." (Emphasis adde d.) The concluding language,

"in accordance with S7.2.3(b)," modifies both of the preceding clauses, i.e., both "identifies the manufacturer of the hose assembly" and "is filed." Thus, the identification provided in compliance with the second option "may consist of block capital let ters, numerals or a symbol."

Since the raised dot is clearly neither a block capital letter or a numeral, the issue is whether it can be considered a symbol. The dictionary defines "symbol," for the purposes relevant to your inquiry, as follows: "something that stands for or sugges ts something else by reason of relationship, association, convention, or accidental but not intentional resemblance." (Webster's Third New International Dictionary, unabridged edition.) The agency concludes that the dot is not a symbol because it is not readily apparent that the raised dot stands for or suggests anything. Instead, the dot appears to be only an accidental by-product of the manufacturing process.

Manufacturer identification is crucial for the enforcement of Standard No. 106's requirements and the tracing of defective assemblies. We urge you to use a more distinctive mark to identify your company as the manufacturer of the assembly. To assist you , and in response to your March 17 telephone request, we are enclosing examples of designations which manufacturers of brake hoses, fittings and assemblies have registered with NHTSA. These examples should be helpful in providing ideas for another desig nation.

Please let me know if we can be of further assistance.

Sincerely,

ATTACHMENT

ID: nht89-1.75

TYPE: INTERPRETATION-NHTSA

DATE: 04/17/89

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: LEON E. PANETTA -- HOUSE OF REPRESENTATIVES

TITLE: NONE

ATTACHMT: LETTER DATED 02/04/89 FROM LEON E., PANETTA TO ERIKA Z. JONES

TEXT: Dear Mr. Panetta:

This letter responds to your inquiry on behalf of your constituent, Mr. Botelho. You asked whether Federal regulations require mirrors to be placed on the right side of vehicles and whether such mirrors must be convex in nature. Mr. Botelho expressed hi s objection to requiring convex mirrors, because he believes convex mirrors distort images and cause objects to appear further away than they actually are. I am pleased to have this opportunity to explain this requirement and its background for you.

Standard No. 111, Rearview Mirrors (49 CFR @ 571.111, copy enclosed)) establishes performance and location requirements for the rearview mirrors installed in new vehicles. Specifically, a passenger car whose inside rearview mirror does not meet the fiel d of view requirements of section S5.1.1 must have an outside mirror on the passenger side of either unit magnification of a convex mirror. In a September 2, 1982 final rule amending Standard No. 111, the National Highway Traffic Safety Administration ( NHTSA) explained that convex mirrors offer safety benefits by providing an expanded field of view to the rear, thereby reducing the need for the driver to turn around to view the rear directly. On the other hand, some users of convex mirrors that were u sed to the images shown by conventional plane mirrors incorrectly perceived that the object shown in the convex mirror was further to the rear than it actually was. Additionally, some users of convex mirrors experienced double vision, eyestrain, and naus ea. After considering these potential advantages and disadvantages, NHTSA amended Standard No. 111 so that it does not require any vehicle to be equipped with convex mirrors, but it permits the use of convex mirrors on the passenger side of cars and lig ht trucks, provided that the convex mirror meets certain additional requirements.

The additional requirements applicable to convex mirrors on the passenger side of cars and light trucks are:

1. A maximum radius of curvature for the convex mirror. This limits the range of convexities to which drivers will be exposed. It also

ensures that the field of view will be noticeably greater than for a plane mirror.

2. A minimum radius of curvature for the convex mirror. This ensures that the image size in the convex mirror will be adequate and distortion will not be excessive.

3. A stringent maximum permissible variation in the radius of curvature over the surface of the convex mirror. This requirement, which is more stringent than the European requirement in this area, also ensures that convex mirrors will have low distortio n.

4. A warning etched on the convex mirror that objects shown in the mirror are closer than they appear. This requirement ensures that the driver who may not be familiar with convex mirrors will not be misled by the image size of the convex mirror and the apparent distance to the object.

Hence, we agree with Mr. Botelho that the area he has identified are potential problems unique to convex mirrors. However, our standard includes special requirements for convex mirrors to minimize the potential problems identified by Mr. Botelho and oth er potential problems that were identified in research studies of convex mirrors. We are not aware of any data showing that convex mirrors that comply with those special requirements present any unacceptable problems for drivers.

I hope this information is helpful. If you have any further questions or need any additional information on this subject, please let me know.

Sincerely,

ENCLOSURE

ID: nht89-1.76

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 18, 1989

FROM: WILLIAM SHAPIRO -- MGR., PRODUCT COMPLIANCE, VOLVO CARS OF NORTH AMERICA TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: REQUEST FOR INTERPRETATION, OUR LETTER JULY 11,1988

ATTACHMT: ATTACHED TO LETTER DATED 4-16-90 TO WILLIAM SHAPIRO FROM STEPHEN P. WOOD; (A35; STD. 210). ALSO ATTACHED TO LETTER DATED 7-11-88 TO ERIKA Z. JONES FROM WILLIAM SHAPIRO.

TEXT:

Enclosed is a copy of our July 11, 1988 letter re: FMVSS 210.

We would appreciate your reply as soon as possible because our engineering department is awaiting an answer.

Thank you for your attention.

Enc.

ID: nht89-1.77

TYPE: INTERPRETATION-NHTSA

DATE: 04/20/89

FROM: HENRY J. NOWAK -- CONGRESS

TO: JOHN STONER -- CONGRESSIONAL RELATIONS OFFICER DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/27/89 FROM STEPHEN P. WOOD -- NHTSA TO HENRY J. NOWAK -- CONGRESS; REDBOOK A33; PART 571; LETTER DATED 04/14/89 FROM EUGENIA M. PIERAKOS AND JAMES L. PIERAKOS -- SNOWFIGHTING EQUIPMENT AND CONSULTING OF BUFFALO INC; SPECIFICATIONS DATED 03/01/89 EST, FROM JAEGER INDUSTRIES INC, JAEGER PL SERIES, TYPICAL BODY SPECIFICATIONS; SPECIFICATIONS DATED 01/06/89 FROM JAEGER CANADA EQUIPMENT LIMITED; PURCHASE SPECIFICATIONS DRAFT PL SERIES POWER LOADING CURBSIDE AND DRAFT PIC KUP OF SOURCE SEPARATED RECYCLABLE MATERIALS; CHASSIS; CAB; BODY

TEXT: Dear Mr. Stoner:

Enclosed is a self-explanatory letter from a constituent concerning a Canadian firm's difficulties in obtaining the federal regulations which certain imported equipment must meet.

I would appreciate it if you reviewed the enclosed material and provided the needed technical information. Your timely consideration of this matter is greatly appreciated.

With best wishes and kindest regards,

Sincerely,

ID: nht89-1.78

TYPE: INTERPRETATION-NHTSA

DATE: 04/20/89

FROM: GAY M. ARTHUR

TO: TAYLOR VINSON -- NHTSA OFFICE OF CHIEF COUNCIL

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/24/89 FROM STEPHEN P. WOOD -- NHTSA TO GAY M. ARTHUR; REDBOOK A33 [2]; STANDARD 108

TEXT: Dear Mr. Vinson,

I am requesting clarification on the restrictions (if any) for the exterior roof on passenger cars. More specifically, I'd like to know if detachable, lighted novelty items are legally allowable on passenger cars.

In addition, if your office knows of specific restrictions by state, i.e., size or color, lighted or not, etc., I would also appreciate that information as well. If there is any cost for the photocopies, please let me know and I would be happy to send i t to you. Enclosed you will find a self-addressed stamped envelope for your use.

Thank you for your time and consideration in this matter, and for your prompt reply.

Sincerely,