ID: nht88-2.27

TYPE: INTERPRETATION-NHTSA

DATE: 05/17/88

FROM: GERALD PETERSON -- TARACO ENTERPRISES INC

TO: ERIKA JONES -- N.H.T.S.A.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 09/02/88 FROM ERIKA Z JONES TO GERALD PETERSON; REDBOOK A32, STANDARD 202; LETTER DATED 08/28/87 FROM CARL C CLARK TO JERRY PETERSON; LETTER DATED 09/29/86 FROM DALE T FANZO TO DIANE STEED

TEXT: Dear Ms. Jones:

My name is Gerald Peterson and I would like to introduce you to a new safety product that our company produces called the Truck Hed-rest. This product is designed to help protect the head of the driver and passenger of a truck in an accident when their head is snapped back against the rear window of a vehicle. A brochure, a description of the product and safety information is enclosed.

I am very concerned about the safety of trucks and would like you to send me any information on petitions filed, concerning the safety problems on trucks.

I have done extensive testing on our product and feel it to be a terrific and inexpensive product.

I look forward to hearing from you in the very near future. If you have any questions please call me anytime.

ENCLOSURES

THE ORIGINAL

TRUK -- HEDREST

* Tested and fits into NHTSA guidelines, for rear end collisions up to 50 MPH D.O.T. to help protect against possible neck and head injuries.

* Inexpensive.

* Mounts to truck rear window or van bulkhead.

* Hi-lo temperate velcro mounting material.

* Attractive and easy to install, removes easily with the Velcro(tm).

* Use with sliding rear window.

* Washable and adjustable.

* Use as seat cushion.

* Use as a cushion when canoeing.

* Kneeling pad.

* Five colors: Burgundy, Tan, Black, Blue and Brown.

* Passes MVSS-302 Test for fire and toxic fumes.

* Customized company logo can be imprinted on the Hedrest.

DON'T BE CAUGHT WITHOUT THE PROTECTION OF TRUK-HEDREST IN YOUR TRUCK OR VAN

Taraco Enterprises, Inc. would like to introduce you to a new safety product that our company produces called the Truk-Hedrest. This product is designed to help protect the head of the driver and passenger of a truck or van in an accident when their hea d is snapped back against the rear window or bulkhead of a vehicle. It gives the person added protection that could prevent injuries to your employees and could save your company medical and injury-related expenses. This is the first after-market head p rotection devise of its kind on the market today.

The Truk-Hedrest is easily attached to the back window of a vehicle with Velcro(tm) and therefore can be taken off at any time. A brochure describing the Truk-Hedrest is enclosed along with a general description of the product, some of its features, the safety testing done and a current price sheet. Please read through all the materials to get a good understanding of what the Truk-Hedrest is and how it can protect your employees or yourself.

If your company would like to know more about the Truk-Hedrest and the added protection it can give your employees, please give me a call at (612) 228-3417. I will be glad to provide you with a sample of our product along with other literature on it. A video tape which shows the extent of injuries that can occur to the driver or passenger of a vehicle if their head hits against the back window or van bulkhead is also available.

Thank you for your consideration.

Sincerely yours,

Jerry Peterson President

SAFETY TESTING

The Hedrest was tested extensively under the following conditions to determine to a certain extent the safety it provided to a person's head in a vehicle that was rear ended. These tests were performed by TEI with Gerry Peterson using NHTSA guideline s.

A bowling ball weighing approximately 10 pounds (which is the approximate weight of a human head as per the National Highway Traffic Safety Administration guidelines) was dropped onto the rear window of a truck. The distance the ball was dropped vari ed to simulate the velocity a head would hit the rear window. The test was designed to see at which levels the head was most likely to break the rear window tempered glass. Without the Hedrest on the glass, the bowling ball broke the glass at a height o f 7.5 feet or a contact velocity of 15 mph. With the Hedrest on the rear window glass, the bowling ball was dropped from a height of 25 feet or 54 mph contact velocity and the rear window did not break, indicating that the chance of head injuries should decrease or not be as extensive. The reason the window did not break was because the Hedrest displaced the force of the blow throughout the entire perimeters of the Hedrest and tempered the blow. The test showed the added protection the Hedrest can giv e to the driver or passenger of a vehicle.

Another interesting fact about how dangerously exposed the head is, is the high impact that can occur when the head hits the glass at just 35 MPH. The force of impact or contact velocity of a head hitting the rear window at 35 MPH without any protect ion would equal approximately 100 G's at the point of impact and extensive injuries could and probably will result.

Illbruk Manufacturing Co. who helped develop the Hedrest also tested the Hedrest for fire hazard and toxic fumes. The Hedrest passed the MVSS-302 test in both of these areas. Also, different materials were tested to determine which would produce the be st and safest Hedrest.

TRUK-HEDREST

Specifications

The Truk-Hedrest is made of a soft yet firm foam material covered by a micro-thin layer of a special plastic. The plastic coating protects the Hedrest, allows it to be washed, and gives it a long life. The Hedrest measures 14 inches horizontally and 8 inches vertically so that if the vehicle is hit at an angle there still should be enough room to protect a person's head.

The Hedrest is attached to the back of the window of a vehicle by three pieces of Velcro(tm) that are placed in three strategic places so that the Hedrest will not interfere with the opening of a split window on the back of a truck. One-half of the Velcr o(tm) is attached to the back of the Hedrest and one is attached to the glass on the rear window. This allows the Velcro(tm) to be separated and the Hedrest removed if desired. The adhesive on the Velcro(tm) pieces is made to withstand drastic temperat ure changes and will not fall off.

The Truk-Hedrest also passes the MVSS-302 test for fire and toxic fumes. It has also been tested under NHTSA guidelines for collisions up to 50 mph.

The Hedrest does not claim to prevent all injuries to the head of a driver or passenger in a collision but rather it is designed to help protect the head by helping to reduce the extent of injuries that can occur when an accident occurs.

ID: nht88-2.28

TYPE: INTERPRETATION-NHTSA

DATE: 05/18/88

FROM: HIROSHI KATO -- ASSISTANT VICE-PRESIDENT MMC SERVICES INC

TO: ERIKA JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION U.S. DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 09/21/88 TO HIROSHI KATO FROM ERIKA Z JONES, REDBOOK A32, STANDARD 201

TEXT: Dear Ms. Jones:

This letter serves to request an interpretation of the requirements of 49 CFR Part 571.201; Occupant Protection in Interior Impact for the "one-piece" instrument panels and console assemblies in the passenger vehicle interiors shown in the enclosures.

We request that these enclosures be treated confidentially under the provisions of 49 CFR Part 512; Confidential Business Information. An affidavit attesting to the confidentiality is also enclosed.

Section S3.1 of FMVSS 201 requires that the deceleration of the head foam impacted into the instrument panel within the head impact area must not exceed 80g continuously for 3 ms. The console assembly is exempted from this head impact areas as described in S3.1.1.

In your letter to Tsuyoshi Shimizu of our office dated October 27, 1986, you defined the instrument panel to be the vehicle structure below the windshield used to mount a vehicle's gauges. Gauge is described in 49 CFR 571.101; Definitions under S4. to m ean a display that is listed in S5.1 or in Table 2 and is not a telltale. Specifically, gauges are listed in S5.1 as the speedometer, turn signal, gear position, brake failure warning, fuel, engine coolant temperature, oil, high beam, and electrical cha rge. Table 2 adds the following gauges: malfunction in anti-lock or brake systems, odometer, and automatic gear position.

Based on this definitions, we determine the instrument panel to be areas where gauges are mounted which communicate critical vehicle functions to the driver. In contrast, the console assembly is where less essential functions are located, heater control panel, radio, ashtray, etc., which aid in occupant comfort.

Based on this judgment, we have delineated the separation of the instrument panel and console assembly on the enclosed diagrams just above the heater control panel (highlighted by a solid-slashed line). View Z on the same attachments shows the "setback" area which makes this boundary line clearer. While 49 CFR 571.103, Windshield Defrosting and Defogging Systems specifies performance criteria for the defroster and although we consider the defroster a necessary safety function, it is not a gauge and, th erefore, is not included as part of the instrument panel.

I ask for your confirmation of this interpretation and the acceptability of our indicated separation of the instrument panels and console assemblies on the enclosed diagrams. If you have any questions, please call me at (313) 353-5444.

Sincerely,

ENCLOSURES (6)

ID: nht88-2.29

TYPE: INTERPRETATION-NHTSA

DATE: 05/19/88

FROM: SPENCER A. DARBY -- SATE-LITE MFG CO

TO: JOAN TILGHMAN -- NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: REQUEST FOR INTERPRETATION OF FMVSS 125

ATTACHMT: ATTACHED TO LETTER DATED 11/07/88 FROM ERIKA Z JONES TO SPENCER A DARBY, REDBOOK A32, STANDARD 125; TELECOPY DATED 08/30/88 FROM SPENCER A DARBY TO JOAN TILGHMAN RE 2166

TEXT: Dear Ms. Tilghman:

Sate-Lite Manufacturing Co. is one of the countries leading manufacturers of FMVSS 125 complaint Emergency Warning Triangles, and has been so since 1974. In a recent engineering review of the current FMVSS 125, some serious concerns have arisen, and I w ould appreciate your interpretation of the three areas stated below.

We understand that the applicable law requiring the three bi-directional emergency reflective triangles to be carried by vehicles over 80" wide used in" interstate commerce is a requirement of the Federal Highway Administration. And we further understan d that the triangles when used must be in conformance to FMVSS 125 as administered by NHTSA.

QUESTION #1: If the FHA requires three triangles, and since Para S5.1.5.(c) requires that "Figure 3" be included in the instructions for erection, why does Figure 3 show a passenger vehicle with only one triangle erected? For years Sate-Lite has placed the generally accepted diagrams for the over 80" tractor-trailer rig on either a divided highway, or a two lane highway on the inside of the container for the three triangles, as well as on the lower arm of the individual triangle, (see enclosed samples) per the S5.1.5.(c) requirement and is now concerned about the correctness of this practice. When used by the trucking industry, are these currently used diagrams correct, and in compliance with the requirements of S5.1.5?

QUESTION #2: More and more single triangles are being used in a non-required manner by passenger cars, especially the European imports. For this application, Sate-Lite has included on the inside cover of the single triangle container the "Figure 3" diag ram for proper erection of a single triangle when used by a passenger car. However, the triangle itself does not have the single triangle placement diagram for lack of room on the moldings. It is our opinion that since the single triangle is not regula ted for under 80" vehicle width usage, and since the usage by a passenger car owner is voluntary, the diagram does not have to be on the triangle itself. Is this a correct assumption?

QUESTION #3: Should not FMVSS 125 be amended to include a "Figure 4" for over 80" vehicles on a dividend highway, and a "Figure 5" for over 80" vehicles on a two lane highway? And if amended, should not Para S5.1.5 be revised to include specific ere ction requirements depending on the type vehicle?

As a major supplier of the Emergency Warning Triangles to the industry, we are naturally concerned. Our sales are to a few OEM Lighting manufacturers, or representatives, who then resell them to the ultimate consumer. We have no control over the end us age, and would not know if it were to be used as required by the FHA on over 80" wide trucks, or individually by the driver of an automobile or van. I can see problems arising if we were required to manufacturer two or three versions of the triangle, di ffering only in the erection diagram molded into the lower arm. Please advise

If I have raised more questions than I have asked, please feel free to call me at 312-647-1515 and we can discuss them of the phone.

Thank you for your kind assistance.

ENCLOSURE

ID: nht88-2.3

TYPE: INTERPRETATION-NHTSA

DATE: 04/20/88

FROM: GEORGE ZIOLO -- DOT PAPERWORK PROCESSOR

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: HEADLAMP COMBINATIONS - REQUEST FOR CLARIFICATION, FMVSS 108

ATTACHMT: ATTACHED TO LETTER DATED 09/12/88 TO GEORGE ZIOLO FROM ERIKA Z JONES; REDBOOK A32, STANDARD 108;

TEXT: Dear Ms. Jones:

I assist graymarket automobile importers in conforming their vehicles.

Some foreign models come equipped with four headlamps two of which are 7" diameter and two 5 3/4" diameter.

My clients modify them by installing two Type 2D1 (7" dia) high & low beam units outboards, and two Type 1C1 (5 3/4" dia) high beam units inboards.

OVSC (NEF-32) rejects such installations because they are "nonconforming" "headlighting systems". It is my opinion that such rejection is without basis.

As I understand it, the FMVSS are "minimum standards". S4.1.1 confirms this by requiring that "...each vehicle...be equipped with at least the number of lamps...specified in Tables I and III,...."

My clients' installation of two Type 2D1 lamps satisfies the minimum requirement specified in Table III.

My clients' installation of two Type IC1 lamps in addition to the two Type 2D1 lamps is not counter to a "headlighting system" as I can find in the standard. In addition, S4.4 appears to permit such combination.

While it may have been necessary to ensure symmetry in headlighting systems combinations in motorcycles by way of S4.1.1.34, where Table III calls for only one lamp, such clarification relative to vehicles other than motorcycles is obviously not needed s ince symmetry in such will be natural.

I therefore kindly request that you determine whether or not FMVSS 108 allows lamp combinations as outlined above and advise me at your earliest convenience. The cited lamp combinations are desired by my clients for reasons of appearance. Also, modificat ion of such vehicles to delete the 2D1 (7") lamp in lieu of a 2C1 (5 3/4") lamp is costly, including replacement of the entire front grille.

Sincerely,

FEDERAL REGISTER VOL 52, NO 208 10/28/87 NHTSA 49 CFR PART 571 (DOCKERT 87-15 NOTICE 1) FEDERAL MOTOR VEHICLE SAFETY STANDARDS, VEHICLE CLASSIFICATION (TEXT OMITTED)

ID: nht88-2.30

TYPE: INTERPRETATION-NHTSA

DATE: 05/19/88

FROM: RAYMOND M. MOMBOISSE -- IMMIGRATION AND NATURALIZATION SERVICE GENERAL COUNSEL

TO: BWAYNE VANCE -- DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 10/18/88 FROM ERICA Z JONES TO RAYMOND M MOMBOISSE; REDBOOK A32; 571.7 (A) SECTION 101(3)

TEXT: Dear Mr. Vance:

We request a waiver from the National Highway Traffic Safety Administration, Department of Transportation (DOT), exempting the Hummer vehicle from the Federal Motor Vehicle Safety Standards (FMVSS) when purchased directly from the manufacturer, AM Genera l Corporation. We are requesting a waiver on behalf of the Border Patrol.

The Hummer is a four-wheel drive vehicle currently manufactured by AM General Corporation for the U.S. Army. The Border Patrol intends to use Hummers to fulfill our traditional and expanded law enforcement missions, especially in the area of drug interd iction. The Hummer's high performance level will give Border Patrol a distinct advantage both in high-speed cross-country pursuits of drug or alien smugglers, and in routine patrolling.

Border Patrol's fleet of about 3,000 vehicles includes nearly 1,500 four-wheel drive vehicles. The Border Patrol currently has about five Hummers, and hopes to purchase approximately 100 Hummers over the next two years.

There are three main reasons why we are requesting a waiver from DOT. The main reason is that we wish to enhance the Hummer with a central tire inflation system (CTI) which can only be done by AM General Corporation as an assembly line item. Secondary reasons are that the Hummer will only be used on public highways approximately 30% of the time, and that buying directly from AM General Corporation will save about $ 5,000 per vehicle. Each reason will be developed below.

The major reason for requesting a waiver is that we need to modify the Hummers to include a CTI. The CTI is a patented feature only available as an assembly line item from AM General Corporation.

The CTI works simply and effectively. The CTI allows the driver to individually and quickly adjust tire pressures while traveling. The ability to adjust quickly tire pressures enhances

control over tire traction and therefore increases vehicle stability. For example, the tire pressures could be adjusted from 10 to 16 psi for typical off-road use over rough terrain. The tire pressures can also be raised from 20 to 24 psi for dirt roads to indirectly increase vehicle speed. The tire pressures can be increased to 32 psi for highway use.

The CTI is critical to carry out our law enforcement missions, both in terms of the types of terrain and conditions covered, and the range of topography within each type of terrain and conditions. Many of the areas patrolled by Border Patrol are inacces sible by commercially-available four-wheel drive vehicles. However, the performance characteristics of the Hummer as modified to include the CTI enables the Hummer to travel over these varied terrains, conditions and topographies.

The Border Patrol routinely patrols eight thousand miles of extremely varied types of terrain and conditions on the United States borders with Mexico and Canada. The terrain and conditions range from deserts to rocks to deep snow to forests.

In addition, the topography and conditions within each type of terrain vary enormously. For example, a typical mountain terrain may have greatly varying topographies or conditions requiring the following unique vehicle characteristics:

1. the ability to ascend or decent a 60% grade, including stopping and restarting on the grade;

2. the ability to traverse a 40% side slope;

3. the ability to negotiate a twenty-two inch vertical step from a complete stop;

4. the ability to ford a thirty inch stream of fresh water or salt water; and

5. the ability to clear the ground by eighteen inches with an approach angle of 60 degrees and a departure angle of 45 degrees.

The high performance characteristics of a fully-equipped Hummer with a payload of 3,500 pounds easily accommodate these varied terrains, conditions, and topographies.

The Hummers will only be used on public highways approximately 30% of the time. The Hummers will generally only be used on public highways to travel between stations and assigned duty areas. Thus, the Hummers use on public highways will be relatively mi nimal.

The Border Patrol's existing Hummers were first purchased by the U.S. Army pursuant to a contract and are in conformity with the specifications. Since the U.S. Army is now selling these vehicles to the Border Patrol, the vehicles are now used military v ehicles. Per 49 C.F.R. Sec. 571. 7(a) and (1), these Hummers are not subject to the DOT FMVSS.

However, purchasing the Hummers directly from the manufacturer will reduce the total cost by about $ 5,000 per vehicle. Vehicles purchased from the U.S. Army are more expensive because the amortized development costs are spread through the contract term . If we purchase the 100 Hummers we hope to purchase, then buying directly from the manufacturer will save the Border Patrol a total of approximately $ 500,000.

Please contact Elizabeth M. Jarrell at (202) 633-1260 upon receipt of our requests. Thank you.

ID: nht88-2.31

TYPE: INTERPRETATION-NHTSA

DATE: 05/20/88

FROM: JERRY SWISHER -- COOPER TIRE AND RUBBER COMPANY

TO: OFFICE OF CHIEF COUNSEL -- NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION U.S. DEPARTMENT OF TRANSPORTATION

TITLE: REQUEST FOR OPINION

ATTACHMT: ATTACHED TO LETTER DATED 08/26/88 TO JERRY SWISHER FROM ERIKA Z JONES, REDBOOK A32, STANDARD 109

TEXT: Gentlemen:

Cooper Tire & Rubber Company (Cooper) is a manufacturer of passenger, light truck and truck tires, which are sold and distributed to independent tire dealers through Cooper's own sales and distribution system and also sold to private brand customers f or distribution and sales through their own systems.

One of our private brand customers has inquired as to whether Cooper can manufacture and sell to them tires which would have:

1. No identification on the sidewall as to the name of the manufacturer or brand name owner, other than Cooper's assigned DOT letters. This tire would meet all the requirements of 49 CFR 571.109 S4.3(a) through (g) and 49 CFR 574.5; however, it woul d not have permanently molded on the upper sidewall the name "Cooper", the private brand owner's name, nor any other general trade name, trademark or identifying name. Each tire would have in the lower sidewall near the bead area, and visible after the tire was mounted, three different names, approximately one-quarter inch (1/4") in height, with each name appearing, for example, at the 2 o'clock, 6 o'clock and 10 o'clock positions on the tire. These names would be placed in such a manner that they woul d not interfere with the labeling or markings required under 49 CFR 571.109.

2. In the alternative, our private-brand customer makes the request as in 1. above, except that some generic connotation, such as, for example, "All Season" or "Performance" would also be molded on the upper sidewall.

The reason for the request from our private brand customer is that, in addition to its direct marketing, the private brand customer has two subsidiaries, and each of the three markets tires under a different name. They are seeking a generic tire with out prominent identification, but one which would contain all three names, thus making it marketable by any one or all three of the entities.

We request your opinion in reference to 1. and 2. above as to whether either would be in violation of, or in non-compliance with, 49 CFR Parts 571 and 574.

If you have any questions pertaining to the above, please feel free to contact me.

Very truly yours,

ID: nht88-2.32

TYPE: INTERPRETATION-NHTSA

DATE: MAY 24, 1988

FROM: ROBERT G. YORKS -- VICE PRESIDENT AND GENERAL MANAGER, AUTOMOTIVE BUSINESS GROUP, TRUCK-LITE

TO: KATHLEEN DEMETER -- ASSISTANT CHIEF COUNSEL FOR GENERAL LAW, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO MEMO DATED 8-1-88, TO ROBERT G. YORKS, FROM ERIKA Z. JONES, STD 108, REDBOOK A32; ALSO ATTACHED MEMO UNDATED, TO ROBERT G. YORKS, FROM KATHLEEN DEMETER

TEXT: Pursuant to your letter of April 28, 1988 (copy attached), we are rescinding our request for confidential treatment of this interpretation.

Please proceed with your analysis, without restriction.

Attachment

ID: nht88-2.33

TYPE: INTERPRETATION-NHTSA

DATE: 05/26/88

FROM: A. J. ACKLEY -- MARTEK CORP.

TO: JOAN TILLGHMAN, LEGAL COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12/08/88 FROM ERIKA Z JONES TO A J ACKLEY; REDBOOK A33, STANDARD 125; LETTER DATED 06/10/88 FROM A J ACKLEY TO ERIKA Z JONES; OCC - 2151

TEXT: Dear Ms. Tillghman:

We are in the process of submitting a proposal to an account utilizing the red safety triangle. All of the elements of the device will follow the standards as set by the D.O.C. What we propose is using their logo in the center - see drawing. This woul d revolve (to eliminate a windshield) and add to the reflective quality of the device.

Do you see any legal problem with the concept?

Thank you.

ENCLOSURE

ID: nht88-2.34

TYPE: INTERPRETATION-NHTSA

DATE: 05/27/88

FROM: TEVES, ALFRED -- TEVES TECHNICAL SERVICE

TO: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TITLE: BRAKE FLUID RESERVOIR DESIGN ACCORDING TO FMVSS 105 REQUEST FOR INTERPRETATION

ATTACHMT: OCTOBER 9, 1981 LETTER FROM BERNDT TO KAWANO, OCTOBER 3, 1988 LETTER FROM JONES TO BURKARD, EBNER, AND TEVES, FEBRUARY 3, 1981 LETTER FROM KAWANO TO BERNDT, JULY 10, 1974 LETTER FROM DYSON TO NAKAJIMA, AND MAY 24, 1988 LETTER FROM TEVES TO GREG ORY

TEXT: during his visit at NHTSA on May 17th, 1988 Mr. Ebner presented our new brake system to your experts.

We request an interpretation of S 5.4.2 (reservoir capacity) and S 5.3.1/b (Fluid level indicator) of FMVSS 105, with respect to the proposed brake fluid reservoir shown in the attachment.

Essential is the existence of an ancillary brake unit in this new brake system. This ancillary brake unit serves the brake circuits 1 and 2 directly.

Compared with a conventional reservoir the proposed brake fluid reservoir's distinctive feature is the exit for the ancillary unit.

This ancillary unit serves the brake circuits 1 and 2. When the brake pedal is released, the used brake fluid will flow back to the reservoir. This unit does not cause any additional fluid volume.

Teves interprets standard 105 S 5.4.2 and S 5.3.1/b) as follows:

1. The total minimum capacity of a reservoir shall be equivalent to the fluid displacement resulting when all the wheel cylinder or caliper pistons serviced by the reservoir move from a new lining, fully retracted position to a fully worn, fully applied position.

2. Reservoir systems utilizing a portion of the reservoir for a common supply to two or more subsystems, individual partial compartments shall each have a minimum volume of fluid equal to at least the volume displaced by the master cylinder piston servi cing the subsystem, during a full stroke of the piston.

3. The total amount of the fluid shall be solely available for the brakes.

4. The ancillary unit shall not use brake fluid for other purposes than for the brake circuits.

5. A drop in the level of brake fluid in any master cylinder reservoir compartment to less then the recommended safe level specified by the manufacturer ot to one-fourth of the fluid capacity of that reservoir compartment, which ever is greater.

The ancillary unit does not diminish the built in safety features of the reservoir. In case of a circuit failure, volume 1 resp. volume 2 remains still available for the brakes and the fluid level indicator lamp gives a warning to the driver.

In case of a fluid leakage in the ancillary unit, the unit is switched off. The fluid level indicator lamp and additional a separate warning lamp gives a warning to the driver. The fluid volumes 1 and 2 remain in the reservoir and are fully usable fo r applying the brakes with the master cylinder.

Accordingly, we believe that the proposed brake fluid reservoir described in this letter and presented to your experts fulfils the requirements S 5.4.2 and S 5.3.1 (b) of FMVSS 105.

We ask that you confirm our interpretation at your earliest convenience.

FMVSS 105, S 5.4.2: V = V[1] + V[2] + V[3] + V[4] V: GREATER OR EQUIVALENT TO FLUID DISPLACEMENT RESULTING WHEN ALL W/C MOVE FROM A NEW LINING POSITION TO A FULLY WORN LINING POSITION. MAX V[4] FLI V[3] V[1] V[2] BRAKE BRAKE ANCILLARY UNIT CIRCUIT 1 CIRCUIT 2 SERVICING BRAKE CIRCUIT 1+2

FMVSS 105, S 5.3.lb V[1] + V[3] >/- 0.25 (V[1] + V[3] + V[4]) V[2] + V[3] >/- 0.25 (V[2] + V[3] + V[4])

V[1] VOL. DISPLACEMENT EQUIVALENT TO A V[2] >/- FULL STROKE OF THE RELATED M/C-PISTON. TEVES MASTER CYLINDER RESERVOIR DESIGN ACCORDING TO FMVSS 105 3-34513-07

ID: nht88-2.35

TYPE: INTERPRETATION-NHTSA

DATE: MAY 31, 1988

FROM: M. ARISAKA -- MANAGER, AUTOMOTIVE LIGHTING, STANLEY ELECTRIC CO., LTD.

TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: MEMO DATED 8-10-88, TO M. ARISAKA, FROM ERIKA Z. JONES-NHTSA, STD 108

TEXT: We would like to know about the installation of an additional Rear Reflex Reflector (RR).

We are planning to install the additional Rear RR at the center portion of the rear face of cars in addition to present two Rear RRs required by FMVSS No. 108 Table III. (See attached drawing.)

The additional Rear RR will never impair the effectiveness of other lighting equipment required by FMVSS No. 108 Table III.

Kindly let us know your advice whether the above mentioned additional Rear RR is allowed or not.

We are looking forward to your reply.

Present two Rear RRs required by FMVSS No. 108 Table III

The Additional rear RR