ID: nht71-4.37

DATE: 11/02/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: REBCO

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 24, 1971, concerning the retention of records of the names and addresses of first purchasers of retread tires that you manufactured prior to October 13, 1971, the date you went out of the retread business.

Under the Tire Identification and Record Keeping Regulation you are required to maintain the names of first purchasers three years from the time the sale is reported to you or your designee. Therefore, as to those tires manufactured between May 22, 1971 and the date you went out of business, October 24, 1971, you are required to maintain, or have maintained for you the names and addresses of the first purchasers for three years after this information is recorded by you or your designee.

ID: nht71-4.38

DATE: 11/02/71

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

TO: American Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your recent telephone inquiry as to whether the recent amendment of Standard 215, Exterior Protection, requires that vehicles meet the photometric requirements of Standard 108 after being subjected to the Standard 215 impacts.

S5.3.1 of Standard 215 reads:

"Each lamp or reflective device, except license plate lamps, shall be free of cracks and shall comply with the applicable requirements of Motor Vehicle Safety Standard No. 108."

S4.3.1.1 of Standard 108 reads in relevant part:

"Each lamp and reflective device shall be located so that it meets the visibility requirements specified in any applicable SAE Standard or Recommended Practice. In addition, no part of the vehicle shall prevent the device from meeting the photometric output at any test point specified in any applicable SAE Standard or Recommended Practice." (Emphasis supplied.)

Thus, although the actual photometric tests may be considered "bench tests", that is, tests whose procedures include removing the devices from the vehicle, the above provision of Standard 108 requires that the configuration of the vehicle external to the devices not prevent them from meeting the photometric requirements. The test procedures themselves require the devices to be placed

in their actual orientation on the vehicle. Therefore, the provision in Standard 215 that the lamps and reflective devices shall meet all the requirements of Standard 108 after the impacts includes the photometric requirements.

ID: nht71-4.39

DATE: 11/03/71

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

TO: Patton; Blow; Virrill; Brand & Boggs

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 12, 1971, in which you made several requests with respect to the Tire Identification and Record Keeping (49 CFR Part 574) and Certification (49 CFR Part 567) regulations.

1. You suggested that the Tire Identification and Record Keeping regulation be amended to provide that where tires are not shipped on or in a vehicle, the vehicle manufacturer's record keeping obligation be limited to three years from the date of sale. We will take this request into consideration, and let you know when a decision is made. It appears that since the minimum time would apply to all vehicle manufacturers, such a requirement should appear in a regulation other than Part 574.

2. You requested the deletion of the requirement that information on the certification label be placed "in the order shown." We have previously denied petitions relating to the order of information on the label (36 F.R. 19593), and this request is also denied. The requirement that the label information be placed in a definite order has been in effect for over two years, and has been found to enhance the readability and hence the usefulness of the label. Now that further numerical information is to be required on the label, we consider that it will be even more important that this requirement be maintained.

3. You requested "an interpretation that a multi-column label or a label in two parts each with an information column, will meet the requirements of [Part] 567," because of the space limitations on some trailers. As long as the information appears in the order specified in the regulation, the NHTSA has no objection to a multi-column label or a label in two parts.

4. Finally, you requested that a trailer manufacturer be allowed to use up his existing supply of labels, by affixing a supplementary label with the additional required information. As stated above, we have decided to adhere to the requirement that the information on the label be in the order specified, although it may be in more than one column or part. To the extent that the action requested would allow a manufacturer not to conform to that requirement, the request is denied. Although the deviation might appear small, it would seriously detract from the integrity and enforceability of the regulation to allow incidental nonconformity without amending the requirement. The other vehicle manufacturers have undoubtedly already incurred costs similar to those cited by your client, and it would be distinctly unfair not to enforce the regulation evenhandedly as to all parties.

ID: nht71-4.4

DATE: 08/16/71

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

TO: Truck Equipment & Body Distributor Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 28 requesting a clarification of paragraph S4.3.1.1 of Standard No. 108. This paragraph requires the installation of auxiliary lighting equipment, if the required lighting equipment is prevented from conforming to photometric output and visibility values by motor vehicle equipment such as snow plows, street sweepers, etc. You ask, in essence, whether auxiliary lamps must be provided in two situations: when the motor vehicle equipment is sold with but not attached to the vehicle, and when no equipment is sold with the vehicle but the vehicle is equipped with a hoist upon which equipment may be mounted.

With respect to the first situation, compliance should be determined with the equipment attached which(Illegible Word) the vehicle at the time it is sold. As for the second situation, compliance of a vehicle which is equipped at time of sale with hoists or mounting brackes only, and for which equipment will be provided at a time subsequent to sale, should be determined with the vehicle in its as-sold condition.

ID: nht71-4.40

DATE: 11/05/71

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Truck-Lite Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 14, 1971, to Mr. Lewis Owen of this Office concerning an interpretation regarding your Truck-Lite No. 127 License plate light.

The requested interpretation concerns the 8 degree incident light angle specified in SAE J587, "License Plate Lamps," as follows:

"When a single lamp is used to illuminate the plate, the lamp and license plate holder shall bear such relation to each other that at no point on the plate will the incident light make an angle of less than 8 deg to the plane of the plate."

Since the 8 degree incident light angle is also a requirement of Federal Motor Vehicle Safety Standard No. 108, all license plate lamp designs must conform to it. It is our position that the angle be measured from the optical center of the lens; therefore, the Electrical Testing Laboratories' position is valid. That is, the incident light angle of your lamp, without the paint shield and when mounted as it will be installed on the vehicle, is below the 8 degree minimum requirement.

ID: nht71-4.41

DATE: 11/05/71

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: General Motors Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 19, 1971, in which you asked whether the second and third options of Standard 208 require anthropomorphic test devices to be placed for the frontal crash tests only in the front designated seating positions, and not in the rear positions.

The answer is yes. The second and third options pose no requirements for testing that require dummies in the rear positions, hence dummies should be placed only in front positions. In the period from January 1, 1972 to August 15, 1973, they should in fact be placed only in the front outboard positions.

You also suggested that "if Option 1 is used, a test device must be at each designated seating position." This statement is true, in a strict sense. But the general requirements for the periods before August 15, 1975 (S4.1.1 and S4.1.2) explicitly allow the "mixing" of options, so that if belts are provided for the rear seating positions they may be considered as fulfilling option two or three, without dummies positioned there for the crash tests. In other words, dummies must be positioned in the rear seating positions only if and when the manufacturer elects to fulfill option one for the rear positions.

ID: nht71-4.42

DATE: 11/06/71

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Truck-Lite Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 15, 1971, to Mr. Lewis Owen of this Office concerning the coating of Lexan lenses.

Plastic lenses used in the required lamps are required by Federal Motor Vehicle Safety Standard No. 108 to meet SAE J576, which specifies no loss of surface luster and no surface deterioration. This Agency does not have the authority to "waive" any requirements of a Federal motor vehicle safety standard.

If you believe that motor vehicle safety does not demand requirements of this severity, you may submit a petition asking for an appropriate amendment of Standard No. 108.

ID: nht71-4.43

DATE: 11/08/71

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Commercial Rubber Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 14, 1971, in which you ask whether matrices (or molds) must be relettered to a new identification code mark when the ownership of a company is transferred from father to son. The son may continue to use the existing number if he will write a letter to us stating that he is the new owner, the date on which he became the new owner, that he wishes to continue to use the same identification code mark, and that he assume all responsibility under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C 1381 et. seq) for tires manufactured with the identification mark on or after the date he assumes ownership of the company. This letter should also refer to the name of the old company and should include any changes being made in company name, address and types of tires being retreaded.

With the above procedure the matrices would not have to be relettered. We will change our records to conform to the information contained in the letter.

ID: nht71-4.44

DATE: 11/10/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Toyota Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: As indicated to you in the November 1 meeting in Mr. Laskin's office, the seat belt retractor demonstrated by Toyota and shown on page 9 of the attachment to your letter is considered by the National Highway Traffic Safety Administration to be an automatic locking retractor. The classification of a retractor is determined by its operation, not by its design, and the Toyota retractor, however unconventional in design, operates in the manner prescribed for automatic locking retractors.

With respect to the test procedure of S5.3(a)(6), it is the intent of the test to load the seat belt assembly in a manner that represents the type of tension encountered in use. It is our opinion that the test set up shown on page 9 of the attachment to your letter is a correct application of the procedure to the Toyota retractor.

Please advise us if we can be of further assistance.

ID: nht71-4.45

DATE: 11/10/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 25, 1971, concerning steps you plan to take to comply with the Certification regulations (49 CFR Part 567), which were amended on October 8, 1971 (36 F.R. 19593). You indicate that you plan to affix, in addition to the required Certification label containing the vehicle's gross vehicle and gross axle weight ratings, an additional "vehicle identification data plate" which would be attached to the driver's door panel inside the cab. This plate will specify an axle capacity for each axle and an additional gross vehicle weight rating, but here the figures will reflect the vehicle's maximum potential capability. The axle capacities on the vehicle identification plate will be the axle manufacturer's ratings, and added together will be the maximum allowable gross vehicle weight rating. It appears from your letter that you intend using the maximum potential capability of the vehicle as a substitute for listing gross axle and vehicle weight ratings for all available tire and wheel combinations, which was proposed as an option for manufacturers in a notice published on October 8, 1971 (36 F.R. 19617). Your question is whether, under the Certification regulations, you may affix the vehicle identification plate in addition to the required Certification label.

While we agree that a legitimate purpose may be served by the information you wish to provide on the vehicle identification plate, we consider that the manner in which you have chosen to furnish this information is inconsistent with the Certification regulations. Specifically, the inclusion of two different figures under the heading "Gross Vehicle Weight Rating" conflicts with the requirement that a single figure be provided. The figure on the vehicle identification plate may be frequently higher than that on the Certification label, and if followed might result in vehicle overload. Also, the summing of the axle manufacturer's ratings to arrive at a "gross vehicle weight rating" is not

wholly consistent with the definition of that term in 49 CFR @ 568.3, which calls for a manufacturer's figure based on the capacity limitations of the vehicle's tires, rims, suspension system and other components, as well as its axles.

If you wish to provide information based on the vehicle's axle capability, we prefer that it not be represented as a vehicle or axle weight rating, but that it be described as the axle manufacturer's rating of the axles.