ID: nht69-1.14

DATE: 03/03/69

FROM: DEAN F. NIEDERNHOFER FOR CLUE D. FERGUSON -- NHTSA

TO: Splintex Belge

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of January 16, 1969, and February 3, 1969, concerning safety glazing in motor vehicles.

Referring to your request to use marking as described in the second paragraph of your letter, I believe you have confused the two-digit manufacturer's code number specified in Docket 23 with the model number specified in Section 6 of USASI Standard 226.1-1965.

Federal Motor Vehicle Safety Standard No. 205, Glazing Materials incorporates USASI Standard 226.1-1955 by reference. Marking of the glazing materials must comply with Section 6, Marking of Safety Glazing Materials. Included in this marking is the requirement for a model number related to a detailed description of a specific glazing material. The example,(Illegible Word), is a model number assigned by you in accordance with foot note #24 at the bottom of page 29 of(Illegible Word) Standard 226.1-1986.

The two-digit manufacturer's code number that follows the "LOT" symbol is used, at the option of the glass manufacturer, as an alternative method of complying with that certification requirements specified in Standard No. 205. This "DOT" symbol followed by a two-digit manufacturer's code number should be added to the marking you should in your letter.

Following are my answers to the questions asked in your letters

Question (1) Must we add the symbol "DOT" somewhere in the above marking"?

Question (2) Can you agree with the proposed marking without taking into consideration that our clear laminated M.I.B glass has been approved, or are was compelled to submit our coloured glass to a laboratory and ask for a new approval?

Question (3) If you extend our AS.1-M.11 approval to the said AS3-26 type, as we hope, is this extension valid for all the American States, including those affiliated to the A.A.M.V.A.? If so, do you advise all the States of this extension or shall we do it?

Answer to Question (1) Only if you wish to avail yourself of the alternative method of certification specified in Standard No. 205 Amendment (33 P2 14152).

Answer to Questions (2) and (3) The approval of glazing materials to which you refer is a State approval independent of the U.S. Federal government. Those questions should be directed to the individual States or A.A.N.V.A. for answer.

I am taking the liberty of assigning a two-digit manufacturer's code number to your company on the assumption that you wish to avail yourself of the alternative method of certification.

Splintex Balge S.A. is assigned number 24. This number should appear after the characters "DOT" when you certify your glazing materials by the alternative means published in the Federal Register, Vol. 33, No. 183 - Thursday, September 19, 1968, (enclosed).

I am sorry for the delay in answering your initial letter.

Sincerely,

Enclosure

SPLINTEX BELGE

Societe Anonyme

January 16, 1969

Director of the National Highway Safety Bureau.

FEDERAL HIGHWAY ADMINISTRATION

Department of Transportation.

Gentlemen,

We are manufacturers of safety glass, namely for the automobile industry, and have had several safety glass types approved, the last ones being:

1/4" mm thick H.I. laminated: Splintex Gilly HI/AS1-M11.

7/32" mm thick H.I. laminated: Splintex Gilly HI/AS1-M12.

We supply a constructor of busses with laminated glass pieces placed along edges of the roof, as shown on the attached picture. This laminated glass is 1/4" thick and is composed of a H.I. interlayer but also two coloured ones with finally just 2 light transmittance. We have in hand information you sent to our customer (Title 23 - Chapter II/Dockets n degree 23 and 29 - Notice(Illegible Word) May we beg you, on this ground, if we may use, for the described glass, an AS3-28 marking with a two digit code number, for example M15; if so, our marking would be

SPLINTEX Height in accordance with U.S.A.S.I.

GILLY Height in accordance with U.S.A.S.I.

AS.3-26-M.15 requirements.

LAMINATED

Our other questions are:

1) Must we add the symbol "DOT" somewhere in the above marking?

2) Can you agree with the proposed marking without more, taking in consideration that our clear laminated H.I. 1/4" glass has been approved, or are we compelled to submit our coloured glass to a laboratory and ask for a new approval?

3) If you extend our AS.1-M.11 approval to the said AS3-26 type, as we hope, is this extension valid for all the American States including those affiliated to the A.A.M.V.A.? If so, do you advise all the States of this extension or shall we do it?

As this is a very important and urgent question, we beg you for a prompt air-mail answer and hope you will give us full details about the other steps we should have to undertake.

Awaiting your kind news and thanking you beforehand for all your help, we remain, Gentlemen,

Very truly yours.

LINTEX BELGE

Societe Anonyme

Director of the National Highway Safety Bureau,

FEDERAL HIGHWAY ADMINISTRATION

Department of Transportation.

Gentlemen,

We beg to remind you our letter dated 16th. January concerning the marks we should put on safety glasses for roof of busses and an eventual approval of this glass material.

As we have an order from a customer, bus constructor who exports vehicles to the U.S.A., it is of the utmost urgency for us to be able to answer our client's questions and requirements.

We apologize for our insistance but hope you will understand our trouble and answer us promptly.

We thank you again and remain, Gentlemen,

Very truly yours.

ID: nht69-1.15

DATE: 03/04/69

FROM: DEAN F. NIEDERNHOFER FOR CLUE D. FERGUSON -- NHTSA

TO: P.O.B. Manufacturing Company

COPYEE: R. O'MAHONEY

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 21, 1960, concerning glazing materials.

I am enclosing a copy of Federal Motor Vehicle Safety Standard No. 205 and, since you manufacture and distribute sealing compounds, a copy of Federal Motor Vehicle Safety Standard No. 212.

ASA Standard Z26.1-1966, incorporated by reference in Standard No. 205, can be obtained at a cost of $ 3.50 from the United States of America Standards Institute, 10 East 40th Street: New York 10016.

SAR Recommended Practice J673A, August 1967, incorporated by reference in Standard No. 205, can be obtained from the Society of Automotive Engineers, Inc., Two Pennsylvania Plaza, New York, New York, 10001.

We are in the process of changing paragraph S.3.2 of Standard No. 205. You may want to keep up with future amendments to these and other standards, therefore, I am enclosing a copy of form HS-13, Mailing List Questionnaire and subscription information for the Federal Register. Either or both of these will enable you to receive information in your areas of interest in all future motor vehicle safety rulemaking actions.

Sincerely,

February 21, 1969

Federal Highway Administration

Dept. of Transportation

Attention: Standards Dept.

Gentlemen:

We are manufacturers and distributors of sealing and glazing compounds for the transportation industry.

In view of this we would appreciate receiving a copy of Standard 205 (glazing materials) or information as to where and how we may obtain some.

Thank you for your courtesies and cooperation.

Sincerely, Jack Flyn--

P.O.B. Manufacturing Company

ID: nht69-1.16

DATE: 05/21/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Amorada Glass Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 25, 1969, forwarded to me by the Federal Trade Commission.

A windshield classified as a second by the manufacturer must nevertheless meet the requirements of Motor Vehicle Safety Standard No. 205 (Glazing materials).

If you have any information indicating that windshields marked seconds do not comply with the standard I would appreciate your sending me such information with the names of the manufacturers and dealers selling the windshields so that the Bureau can further investigate the matter.

Sincerely,

National Highway Safety Bureau, Federal Highway Administration, Department of Transportation,

Attention: Robert Brenner,

Acting Administrator.

Gentlemen:

The enclosed copy of a letter, dated April 22, 1969, from Mr. Richard R. Miller, President, Amerada Glass Company, Elk Grove Village, Illinois, referring to the installation of unsafe windshield glass is forwarded for appropriate consideration by your Bureau under applicable motor vehicle safety standards.

Mr. Miller has been advised of this referral.

With best wishes, I am

Sincerely yours,

Hugh B. Helm --

Chief, Division of Advisory Opinions,

Bureau of Industry Guidance,

Federal Trade Commission

Enclosure

April 22, 1969

Federal Trade Commission

Gentlemen:

Having received a copy of Steven John Fellman's letter of April 7, 1969, directed to your offices, regarding the installation of "seconds" windshields by members of the National Glass Dealers Association, I wish to advise the availability of further information on this matter for your immediate consideration.

"B" line insurance firms in many parts of the country are well aware of the availability of "seconds" and prepare their purchase orders accordingly. It is a known industry fact that the three largest independent manufacturers of curved windshields allow sales of "seconds" windshields only to their largest and preferred customers, those giving them the major share of the replacement business in their area.

This practice definitely discriminates against the small, legitimate buyer unable to buy the lower cost "second" from the independent manufacturer, distributing only through his selected distributor.

I feel very strongly that the Department of Transportation should be advised that the installation of rejects deceives the public, and provides unsafe windshields due to distortion, double vision and imperfections in the glass which would normally be considered rejects and destroyed by those original equipment windshield manufacturers who do not sell windshields considered to be unsuitable for original equipment or replacement installation sales.

A thorough review of practices indicated above should be made without delay. Your reply will be awaited with genuine interest.

Very truly yours,

AMERADA GLASS COMPANY --

Richard R. Miller, President

ID: nht69-1.17

DATE: 04/18/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Auto Test Division, Consumers Union of U.S., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of March 17, 1969, and March 26, 1969, pertaining to certain child restraint devices and whether or not they are covered by Federal Motor Vehicle Safety Standard No. 209. Your specific questions and our corresponding answers are as follows:

Question No. 1: Which of the commercially available devices must comply with the Type 3 requirements of Standard No. 209, which must not?

Answer No. 1: Child restraint devices must comply with the Type 3 requirements of Standard No. 209 if, by visual examination of the design and the advertising thereof, they are sold as being a Type 3 seat belt assembly. By definition, a Type 3 seat belt assembly is a combination pelvic and upper torso restraint for persons weighing not more than 50 pounds or 23 kilograms and capable of sitting upright by themselves, that is children in the approximate age range of 8 months to 6 years.

Question No. 2: How does one tell whether a given device is covered or not?

Answer No. 2: If the manifested purpose of any belt, strap, webbing or similar device is to secure a person in a motor vehicle in order to mitigate the results of any accident, then the belt has to comply with the applicable portions of Standard No. 209. There is a distinct difference between a "child seating system" and a seat belt used to restrain a child. "Child seating system" means an item of motor vehicle equipment for seating and restraining a child being transported in a passenger car. This child seating system is not covered by Standard No. 209, but will be covered by a future standard No. 209, but will be covered by a future standard.

Question No. 3: Is the criterion (that a given device must comply) whether or not the maker claims that the device offers protection against impact injury?

Answer No. 3: Whether or not the maker of a child restraining belt claims that the device offers protection against impact injury is not the criterion upon which the compliance interpretation is based. (Reference Answer No. 2.)

Further investigation is needed before we can provide an answer to your question pertaining to which specific manufacturers of the belts that you tested are in violation.

To assist you in your project on child restraint devices, we are enclosing the latest copy of Federal Motor Vehicle Safety Standard No. 209 and the copy of the Notice of Proposed Rule Making on child restraint systems.

We trust that we have been of assistance to you.

Sincerely,

Enclosures: F-38 and 49 C.F.R. Part 371, Docket No. 2-15, Notice No. 2

March 17, 1969

Frank Armstrong Office of Performance Analysis National Highway Safety Bureau U.S. Department of Transportation

Dear Frank:

Consumers Union has under way a project on child restraint devices. As I told you briefly on the phone a couple of weeks ago, the question has come up, which of the commercially available devices must comply with the Type 3 requirements of Standard 209, which must not? How does one tell whether a given device is covered or not? Is the criterion whether or not the maker claims that the device offers protection against impact injury? I talked to Joe O'Gorman about this problem at some length, but he was not able to provide an answer.

I hope that you, or someone in your office, can throw some light on this question for us.

Sincerely yours,

CONSUMERS UNION OF U.S. INC.

Auto Test Division--

Joseph N. Ulman Jr.

Automotive Safety Engineer

cc: Morris Kaplan

March 26, 1969

Frank Armstrong Office of Performance Analysis National Highway Safety Bureau U.S. Department of Transportation

Dear Frank:

On March 21, I received a phone call from Joe O'Gorman in response to my letter of March 17 to you requesting advice on how to tell whether any given child restraint device is governed by the Type 3 requirements in Standard 209. I believe Joe now has a clear understanding of our question, and he is trying to obtain an answer.

In the meantime, we would like to amplify for you the information on child restraint devices that appeared on pages 169 and 170 of our April issue. The 15 devices listed as failing to meet the 2000-pound load requirement were sold with safety claims as follows: DEVICES WITHDISCLAIMER:

Penney's No. 0858

Sears No. 1507

Tommee Tippee WP 207

Tommee Tippee WP 205 SP

DEVICES MAKING NO SPECIFIC SAFETY CLAIM:

Auto Babe

Ward's No. 6053 "Tiny World Safety Belt"

Wizard No. 5480 "All Purpose Safety Strap. . ."

DEVICES MAKING SOME CLAIMS:

Hollywood 495 C

497 C "1000-lb. test." "Secures against sudden stops." ". . .allows for. . .with perfect safety."

Kiddie King KKB-1 "Child's Auto Safety Belt." "Protects your child against sudden stops."

Kiddie King KKB-2 "Child's Safety Harness and Belt." "Protection. . .in Autos. . ." ". . .Maximum of safety."

Safety Guard B 12 "Auto Safety Strap." "For protection, comfort, safety." "Will protect children on short stops."

Safety Guard B 112 "Child's Auto Safety Strap." "Exceeds SAE Safety Specifications." "Protection against short stop danger."

Safety Guard B 1212 "Safety Harness Strap." "Protect your child from short stops." ". . .exceeds S.A.E. Safety Specifications."

Toidey SC-3 "Auto Harness." "Keeps little explorers safe." ". . .webbing withstands over 2000 pounds pull."

Our question: Which of these devices are Type 3 restraints; and thus which of them are, according to our static tests, in violation of Standard 209?

We shall appreciate any information you can supply us.

Sincerely yours,

CONSUMERS UNION OF U.S. INC.

Auto Test Division-- Joseph N. Ulman Jr.

Automotive Safety Engineer

cc. Morris Kaplan

David Tallman

ID: nht69-1.18

DATE: 02/11/69

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Payne, Barlow and Green, Attorneys at Law

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 23, 1969, to William Haddon, Jr., M.D., requesting information on Federal standards for child restraint devices.

I am enclosing a copy of Federal Motor Vehicle Safety Standard No. 209, "Scat Belt Assemblies - Passenger Cars, Multipurpose Passenger Vehicles, Trucks and Buses" which includes requirements for a Type 3 seat belt assembly for persons weighing not more than 50 pounds and capable of sitting upright by themselves.

The technical requirements of the present standard No. 209 were previously included in "Standard for Seat Belts for Use in Motor Vehicles (15 CFR Part 9; 31 F.R. 11528)" which was incorporated by reference in the initial Standard No. 209. I am also enclosing copies of these previous documents.

We are in the process of developing a standard for child car seats and I am enclosing a copy of a recently issued Notice of Proposed Rule Making on this subject. It is important to note that this is only a proposed regulation and the requirements may be modified somewhat when the final rule is published. However, this proposed rule indicates those safety features which are considered to be important for a child car seat.

There are no other existing Federal standards on child restraint systems for use in motor vehicles.

Sincerely,

January 23, 1969

William Haddon, Director National Highway Safety Bureau Department of Transportation

Dear Dr. Haddon:

I am seeking information regarding Federal Standards for Child Restraint Devices and will appreciate your furnishing same to me as soon as it is convenient for you.

I am attempting to measure the adequacy of a particular device that apparently contributed to a child's injury that occurred on May 15, 1968. I do not know the date of manufacture of this device but it is important that I obtain an itemization of minimum standards that have applied for several years.

Sincerely,@@53:426

ID: nht69-1.19

DATE: 12/02/69

FROM: AUTHOR UNAVAILABLE; David E. Wells; NHTSA

TO: Attorney General; The Virgin Islands of the United States

TITLE: FMVSR INTERPRETATION

ID: nht69-1.2

DATE: 08/22/69

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: S. Hoffman, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: This in further response to your letter of July 14 enclosing an engineering drawing of a hub cap "incorporating a decorative device designed to create an impression of spinning at the center of the wheel during operation of the vehicle", and requesting an interpretation of Federal Motor Vehicle Safety Standard No. 211 with respect thereto.

Standard No. 211 specifies the requirement that hub caps, wheel nuts, and wheel discs shall not incorporate winged projections. That in the sole requirement of this Standard. The drawing submitted by you depicta a hub cap which, in our judgment, incorporates a winged projection. The Standard does not regulate vehicle width, and thus your observation that "it would not broaden or extend the front (or top or rear) profile of automobiles . . ." is not a factor to be considered.

I enclose the engineering drawing you furnished us.

ID: nht69-1.20

DATE: 10/25/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Truck Body and Equipment Association, Inc.

TITLE: FMVSS INTERPRETATION

ID: nht69-1.21

DATE: 08/29/69

FROM: WARREN M. HEATH -- COMMANDER ENGINEERING SECTION CALIFORNIA HIGHWAY PATROL

TO: ROBERT BRENNER -- ACTING DIRECTOR NATIONAL HIGHWAY SAFETY BUREAU

COPYEE: GAIL STRADER -- SAFETY SERVICES DIV. DEPT. REV.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/29/69 FROM CHARLES A. BAKER -- NHTSA TO WARREN M. HEATH

TEXT: Dear Dr. Brenner:

A vehicle manufacturer has notified us that their 1970 model vehicles will be equipped so that the sidemarker lamps will flash when the turn signal switch is activated. The flashing will occur on the side contemplated for the turn.

An interpretation is requested as to whether or not Section S3.5 of Federal Motor Vehicle Safety Standard No. 108 would permit the flashing of sidemarker lamps simultaneous with the turn signal lamps on the side to which a turn is contemplated.

Very truly yours,

ID: nht69-1.22

DATE: 09/12/69

FROM: CHARLES A. BAKER -- NHTSA OFFICE OF STANDARDS ON ACCIDENT AVOIDANCE MOTOR VEHICLE SAFETY PERFORMANCE SERVICE

TO: WARREN M. HEATH -- COMMANDER, ENGINEERING SECTION DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

TITLE: NONE

ATTACHMT: LETTER DATED 08/29/69; FROM WARREN M. HEATH TO ROBERT BRENNER -- NHTSA

TEXT: Dear Mr. Heath:

Thank you for your letter of August 29, 1969, to Dr. Robert Brenner, Acting Director, National Highway Safety Bureau, concerning the flashing of sidemarker lamps when the turn signal switch is activated.

Paragraph S3.5 of Federal Motor Vehicle Safety Standard No. 108 permits the flashing of sidemarker lamps simultaneously with the turn signal lamps on the side to which a turn is contemplated.

Sincerely,