ID: aiam3384

Dear Mr. Davis: This responds to your November &, 1980, letter to Mr. Kratzke of m staff, in which you requested information concerning the legality of using welded mobile home axles and mobile home tires on trailers.; We have no regulations concerning the axles which may be used o trailers. However, the use if mobile home tires on new trailers would violate Federal Motor Vehicle Safety Standard No. 120 (49 CFR S571.120). For your information, I have enclosed a copy of this standard. Section S5.1 of the standard requires all new trailers equipped with tires for highway service to use tires that comply with either Standard No. 119, *New Pneumatic Tires for Use on Motor Vehicles Other Than Passenger Cars*, or Standard No. 109, *New Pneumatic Tires--Passenger Cars*, tires which have the label 'For Mobile Home Use Only' have been expressly exempted from the performance requirements of Standard No. 119. Because of the exemption, these tires may only be used on mobile homes. Therefore, the use of these tires on new trailers would render the trailers in violation of Standard No. 120. A manufacturer using these tires on a new trailer would face a fine of up to $1,000 for each mobile home tire used, pursuant to the provision of section 108 and 109 of the national Traffic and Motor Vehicle Safety Act as amended (15 U.S.C. 1397 and 11398). If you are aware of any such violations, the agency would appreciate any information you could supply.; As I Have stated above, we have no regulations specifying performanc requirements for the axles on trailers. If you have any further questions or need any further information on this subject, please contact Mr. Kratzke at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel

ID: nht87-3.19

TYPE: INTERPRETATION-NHTSA

DATE: 11/03/87

FROM: J. MARK SMITH -- LYNCO PRODUCT

TO: NHTSA

ATTACHMT: ATTACHED TO MEMO DATED 8-26-88, TO J. MARK SMITH, FROM ERIKA Z. JONES, STD 302, STD 201

TEXT: Lynco Products is considering marketing the storage console-armrest for trucks and automobiles as shown in the sketch below. Would this product require D.O.T. approval? If so, does this meet the standards?

STORAGE CONSOLE-ARMREST

* LIGHT-WEIGHT WOOD FRAME CONSTRUCTION (2-3 POUNDS)

* FABRIC COVERED (ENTIRELY)

* 1 1/2" THICK FOAM PADDED TOP

* CONCEALED HINGES

* CONSOLE REMOVABLE, NOT ATTACHED TO SEAT OR FRAME

ID: nht92-9.22

DATE: February 5, 1992

FROM: Frederick Harris -- Proprietor, Frederick Harris Associates

TO: National Highway Traffic Safety Institute

TITLE: None

ATTACHMT: Attached to letter dated 4/3/92 from Paul J. Rice to Frederick Harris (A39; Std. 302; VSA 102(4))

TEXT:

I am planning to put on the market a cloth device containing light weight plastic items useful to a baby while in an automobile. The cloth item will be adjacent to but not touching a child sitting or laying in a nearby safety seat.

Please advise what national safety standards/regulations may apply to such a device from the viewpoint of need to be fire-safe, or any other safety considerations.

ID: nht94-4.25

TYPE: INTERPRETATION-NHTSA

DATE: September 7, 1994

FROM: Vincent A. Ugoletti -- Chief Engineer, Great Lakes Communications, Inc.

TO: Chief Counsel, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO LETTER DATED 11/14/94 FROM PHILIP R. RECHT TO VINCENT UGOLETTI (A42; STD. 208; STD. 207; STD. 209; STD. 210; STD. 302)

TEXT: Great Lakes Communications, Inc. is currently in the process of turning a conversion van into a production van. One of our requirements for the production van is for the front seats of the van to swivel. The company wishes to maintain the federal safet y requirements for the seats. If your administration could please provide us with the federal safety standards requirements for swivel front seats in a van so we could convert our van a.s.a.p.

ID: 12261GM.fix

Mr. Milford R. Bennett
Director, Safety Affairs & Regulations
General Motors Corporation (GM)
Mail Code 480-111-S56, Box 9010
Engineering Building 1-11
30200 Mound Rd.
Warren, MI 48090-9010

Dear Mr. Bennett:

This responds to a question you had in a petition for rulemaking concerning a "uniform child restraint anchorage" (UCRA) system that your company developed for attaching add-on child seats in vehicles. You ask whether the UCRA system may be installed prior to completion of the requested rulemaking. The answer is yes.

The UCRA system consists of two lower anchorages near the intersection of the vehicle seat back and cushion (the "bight" line), and an upper tether anchorage. The lower anchorages are each equipped with a latchplate that is smaller than and incompatible with the latchplate provided in seat belt systems for adult passengers. Child seats would be manufactured to have equipment that is compatible with the UCRA system, such as small buckles and a tether to attach to the small latches at the vehicle seat bite line and top tether anchorage.

Your company, as a member of the American Automobile Manufacturers Association, along with specified companies of the Association of International Automobile Manufacturers and the Juvenile Products Manufacturer's Association, petitioned the National Highway Traffic Safety Administration (NHTSA) to require vehicle manufacturers to provide a UCRA system in their vehicles, and require child restraint manufacturers to provide child seats that are "compatible with both the UCRA system (used alone) and the existing vehicle seat belt systems (used alone)."

Among other things, the petition asks whether "1) the proposed UCRA system can be incorporated into future vehicles, and 2) compatible CRSs can be offered for sale, provided the CRS and vehicle belt systems continue to comply with current Federal Motor Vehicle Safety Standard (FMVSS) requirements." From various conversations between Jack Havelin and Dick Humphrey of GM and George Mouchahoir and Deirdre Fujita of NHTSA, we understand you to ask whether the UCRA system may be installed on

vehicles, and compatible componentry installed on child seats, before completion of the requested rulemaking on UCRAs, if the vehicles and child seats meet the standards currently applying to them.

Our answer is the UCRA may be installed. The preamble for the 1979 final rule adopting dynamic test requirements in Standard 213 (44 FR 72131) addressed the issue of "vehicle specific" child restraints, i.e., "systems uniquely designed for installation in a particular make and model which do not utilize vehicle seat belts for anchorages." 44 FR at 72136. The agency emphasized in the preamble that standardizing all child restraints, including vehicle specific ones, by requiring them to be capable of being secured to a vehicle seat by a lap belt is an important way to prevent misuse. However, the agency also stated:

[S]ince vehicle specific child restraints can provide adequate levels of protection when installed correctly, NHTSA is not prohibiting the manufacture of these devices. The new standard requires them to meet the performance requirements of the standard when secured by a vehicle lap belt. As long as child restraints can pass the performance requirements of the standard secured only by a lap belt, a manufacturer is free to specify other 'vehicle specific' installation conditions." 44 FR 72131, 72136; December 13, 1979.

We believe that the system you describe is a "vehicle specific" system similar to that discussed in the preamble. While the discussion quoted above pertained to vehicle specific child seats, by implication the child seat could be attached to the vehicle in a way other than by use of a lap belt. Generally speaking, our standards do not prohibit manufacturers from voluntarily installing items and features on their vehicles or equipment that are not regulated by the safety standards. The only limit is that the vehicle or equipment must meet applicable safety standards when equipped with the voluntary items and features, and must contain no safety-related defect.

Thus, the UCRA system you wish to voluntarily install would be permitted, provided that the vehicle meets all standards currently applying to the vehicle, e.g., standards for seat belt assemblies and anchorages, occupant crash protection and seat strength. Components may be voluntarily installed on a child seat to make the seat compatible with a UCRA, provided that the child seat can pass all requirements of the standard, including the requirement that the seat meet the dynamic test requirements when secured only by a lap belt.

However, please note the following concerns. First, under S5.6 of Standard 213, child seat manufacturers are required to provide step-by-step instructions for securing the child restraint in vehicle-specific applications, as well as providing such instructions for securing the child restraint when it is used in vehicles for which no vehicle-specific installation is recommended.

Second, under NHTSA's defect authority, manufacturers must ensure that their design and production of the UCRA system does not result in unsafe attachments between vehicle and child seats.

Third, assuming that NHTSA issues a rule specifying requirements for a universal child restraint attachment system, such a rule could have requirements that differ from those suggested in your petition. Manufacturers would be responsible for ensuring that UCRA systems installed on vehicles and child seats on or after the effective date of the rule comply with the adopted requirements.

If you have any further questions, please do not hesitate to contact Ms. Fujita at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel

ref:213
d:8/27/96

ID: nht91-6.4

DATE: September 18, 1991

FROM: Robert A. Nordmeyer -- Nordic Associates

TO: NHTSA Administrator, Rule Making Department

TITLE: None

ATTACHMT: Attached to letter dated 11-13-91 from Paul Jackson Rice to Robert A. Nordmeyer (A38; Std. 201; Std. 302)

TEXT:

We are developing an after market sun visor for a client (illustrations attached).

Would you please advise me if there are any federal sanctions governing the design, maximum viewing area that may be blocked by such a device, minimum force required to secure the visor in the extended or retracted position and minimum amount of padding on edges of the visor.

If you have any questions regarding this issue, I can be reached by phone at (818) 347-1597 or Fax (818) 883-3342.

ATTACHMENT

Six drawings of sun visors. (Graphics omitted)

ID: aiam2339

Dear Mr. Currie: #This is in response to your March 24, 1976, lette concerning the application of the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to thermoplastic tubing of 1/8 inch nominal outside diameter that is used in 'auxiliary air equipment rather than the brake system itself. #You have pointed out that it is difficult to label tubing of this diameter with letters that are 1/8 inch high, and requested an amendment of the standard to permit the labeling of such brake hoses with letters that are 1/16 inch high. #Because the tubing that you have described is not manufactured for use in the brake system itself, it is not 'brake hose' as that term is defined in Standard No. 106-74 and is therefore not subject to any of the standard's requirements. In fact, although the standard does not prohibit the manufacture of air brake hose of 1/8-inch outer diameter, we are unaware at this time of the existence of any hose or tubing of that diameter that meets the definition of 'brake hose'. Therefore, the conformity or nonconformity of the tubing in question is a matter of private contract between Parker Hannifin Corporation and those truck manufacturers that are requesting conformity. #In consideration of the possibility that 1/8-inch outer diameter tubing may in the future be used in brake systems, however, there NHTSA has decided to grant your petition to reduce to 1/16 inch the minimum required lettering height on brake hoses of such diameter. Accordingly, a proceeding respecting the issuance of a notice of proposed rulemaking has been commenced. #You should understand that our commencement of a rulemaking proceeding does not signify that the requested amendment will necessarily be issued. A final decision concerning the issuance of a proposal to amend the standard will be made on the basis of all available information developed in the course of the proceeding, in accordance with statutory criteria. #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs;

ID: aiam5253

"Dear Mr. Bennett: This is in reply to your letter of October 7, 1993 to Howard Smolkin concerning information labels for vehicles covered by NHTSA temporary exemptions (49 CFR Part 555). Paragraph 555.9(b) requires that a windshield or side window label containing an advisory statement be affixed securely to each exempted vehicle. You have concluded that this label is intended to notify prospective purchasers that the vehicle has been exempted from compliance with certain Federal motor vehicle safety standards. Because General Motors (GM) does not intend to sell its recently exempted GMEV, it believes that it is not required to place the label on its vehicles. Section 123(b) of the National Traffic and Motor Vehicle Safety Act (the Act) (15 U.S.C. 1410(b)) specifies that ' t he Secretary may require that written notification of an exemption be delivered to the dealer and first purchaser for purposes other than the resale of such exempted motor vehicle in such manner as he deems appropriate.' NHTSA chose to exercise this discretionary power through promulgating paragraph 555.9(b) requiring windshield and side window labels on exempted vehicles, commenting that ' t he window label appears to be the most appropriate way of providing written notification of exemptions to dealers and first purchasers' (37 FR 25534). We read in The New York Times on October 14, 1993, that GM will build 50 Impacts (presumably the exempted GMEVs) 'and lend them for two to four weeks to 1,000 drivers around the country over the next two years, with the help of 14 utilities.' If these cars are made available through GM's dealer network, then we believe that the label should nevertheless be provided even if the vehicle is not sold, and that it should remain affixed until the vehicle is first lent or leased through the dealer. Although subsequent users of the GMEV will not have access to the temporary label in order to evaluate the risk they assume by accepting temporary use of a nonconforming motor vehicle, the permanently affixed exemption certification label will furnish this information should they care to consult it. Sincerely, John Womack Acting Chief Counsel";

ID: aiam0860

Dear Mr. Nishibori: This is in reply to your letters of August 8, and August 28, 1972 requesting interpretation of Motor Vehicle Safety Standard No. 302, 'Flammability of Interior Materials'.; In your August 8th letter, as we understand your first question, yo ask whether the adhesive, sound-proofing material used on the floor panels of your cars should be tested together with the few insulating fibers which become embedded in this material when the insulation which covers the sound- proofing material is removed. The Standard provides a list of the interior components which must meet its requirements and the manner in which those components are to be tested. Since the sound-proofing material you have described would not be considered a floor covering and it is not otherwise included in S4.1 of the Standard, it is not subject to the requirements.; You ask further whether the 'seal screen' you glue peripherally on th inner, door panels to prevent water from penetrating the interior of the door must meet the requirements of the Standard. The 'seal screen', as you describe it, does not appear to be part of the panel and, accordingly, it would not be subject to the Standard.; In your August 28th letter, you ask whether the procedure you have fo testing the 'jute' insulating material used under the floor carpet of your cars conforms to the requirements of Standard No. 302. You state that this procedure includes removing the insulation and testing its top surface, which you designate as 'surface B', rather than testing its bottom surface, which you designate as 'surface A'. We are not sure what you mean by testing a 'surface', the Standard refers to a test for the entire specimen. You may be concerned with whether the specimen is oriented upward or downward. Under the Standard, the test specimen for each component is to be tested 'so as to provide the most adverse results'. Accordingly, the relevant test result is the most adverse one achieved in any horizontal orientation, either upward- or downward-facing. The fact that you remove the insulating material so as not to raise the nap on its bottom surface is consistent with existing test procedures.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam4874

Dear Mr. Salsman: This responds to your letter of April 16, l99l asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it relates to the 'Braking Intensity Array' that you have invented. The device is an array of nine rear lamps which include a high mounted stop lamp. The center lamp responds to pressure on the brake pedal. If 'actual braking' occurs, then the lamps adjacent to the center lamp 'will respond appropriately with the adjacent lights lighting under mild braking force', and the remaining pairs of lamps lighting as the braking force increases. You have assured us that the center lamp meets all requirements of Standard No. 108, and that the remaining lamps in the array are controlled by a separate device and will not operate independently. As we see it, the acceptability of your invention under Standard No. 108 is not dependent upon any of the five sections of the standard that you quote. The four pairs of lamps that flank the designed-to-conform center stop lamp are 'additional lamps' within the meaning of S5.1.3, which prohibits the installation of any additional lamp as original equipment if it 'impairs the effectiveness of lighting equipment required by' Standard No. 108. Whether impairment exists is a determination to be made by the person installing the lamp as original equipment, either the manufacturer or the dealer prior to the vehicle's first sale. In this instance, it does not appear to us from your description of the array that it would impair the effectiveness of the center lamp or other stop lamps on a vehicle. We would be concerned if the size of the array is such that the interior rear view mirror could not meet the field of view requirements of Standard No. lll Rearview Mirrors, however, if the field of view is not met, the standard allows, as an alternative, the installation of an exterior rear view mirror on the passenger side. Although your array may be permissible under Federal law, it remains subject to regulation by the individual States in which it is used. We are unable to advise you on State laws and suggest you consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203. Sincerely, Paul Jackson Rice Chief Counsel;