ID: nht68-3.24

DATE: 04/16/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: R.J. Townsly

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of February 23, 1968, to the Department of Transportation, in regard to information pertaining to importation into the United States of a right hand drive Canadian manufactured vehicle.

If your vehicle was manufactured prior to January 1, 1968, the Federal Motor Vehicle Safety Standards would not apply, however, if built after January 1, 1968, full compliance to Federal Safety Standards is necessary.

While it is not clear from your letter, the status of your visa, or how long you wish to have the car in the United States a solution to your problem may be provided by the regulations governing the importation of motor vehicles subject to the Federal Standards which became effective January 10, 1968. You will see from 19 CFR Section 12.80 (b) (v) of the regulations enclosed that a non-resident of the United States may import a non-confirming motor vehicle for personal use for a period of not more than one year, and that it may not be resold in the United States.

The National Highway Safety Bureau has not been informed of the manner in which vehicles of Canadian manufacture, including those with right hand drive, do not comply with the Federal Standards. It would be best to communicate directly with the Canadian manufacturer as to the extent of modification necessary should you not come with the 12.80 (b) (v) exception.

If we can be of further assistance, please let us hear from you.

ID: nht68-3.25

DATE: 04/22/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Badger Auto Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your cooperation and response to the Federal Highway Administration request regarding the "Certification Requirements."

The information you have provided will be very useful to us; however, in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with information as to where your tag will be located on your vehicles and also the serial identification system as requested in order that vehicles manufactured (complete) after January 1, 1968, can be identified.

In regard to your question as to whether there is an exception to the law regarding the placement of the three light markers at the rear of your vehicle because of the limited space on your rear frame, the answer is there is no exception and adherence is required. One possible solution to your problem might be to mount an additional bracket to mount the cluster of lights. This is only a suggestion and you may be able to arrive at a more practical arrangement.

Trusting this information answers your questions.

ID: nht68-3.26

DATE: 04/24/68

FROM: AUTHOR UNAVAILABLE; G. C. Nield; NHTSA

TO: The Standard-Triumph Motor Company, Limited

TITLE: FMVSS INTERPRETATION

TEXT: This letter is in response to your February 29, 1968, request for approval of equivalent rims for use in the following tire and rim combinations:

A. Bias Ply Tires

1. 5.20-13 on 4 1/2J rim.

2. 5.60-13 on 3 1/2J rim.

B. Radial Ply Tires

1. 145-13 on 3 1/2J rim.

2. 145-13 on 4 1/2J rim.

3. 185-15 on 4 1/2J rim.

On the basis of the supporting information submitted, your request for approval of the equivalent rims and proposed tire combinations listed above is granted.

ID: nht68-3.27

DATE: 04/24/68

FROM: AUTHOR UNAVAILABLE; R. M. O'Mahoney; NHTSA

TO: Fiat Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reference to your letter of March 21, 1968, concerning Federal Motor Vehicle Safety Standard No. 202.

The standard does not preclude the use of a head restraint which, when not in use, can be fully retracted into the seat back.

MOTOR COMPANY, INC.

March 21, 1968

March 21, 1968

Robert O'Mahoney Federal Highway Administration

With reference to Federal Safety standard 202 issued on Federal Register Vol.33 of February 14, 1968, we would appreciate your confirming to us whether a head restraint which, when not in use, can be fully retracted into the seat back is acceptable.

Would you please clarify this to us.

Thanking you for your cooperation in this matter, we remain,

G. Gabrielli Technical Manager

ID: nht68-3.28

DATE: 04/24/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Schein Body and Equipment Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of February 29, 1968, to Dr. William Haddon, Jr. concerning the location of lamps and reflectors on your dump semi-trailers and equipment loaders.

Initial Motor Vehicle Safety Standard No. 108 requires that the side reflex reflectors be mounted not less than 15 inches nor more than 60 inches above the road surface. To meet this requirement, the front side reflex reflectors on your dump semi-trailers may be mounted below the side rail of the body. If necessary, a protective shield or housing could be provided to prevent the reflector from being damaged by rocks and mud.

With respect to the location of rear clearance lamps on your dump semi-trailers, Standard No. 108 requires that these lamps be located as near as practicable to the upper left and right extreme edges of the vehicle, except that optional heights are permitted when the rear identification lamps are mounted at the extreme height of the vehicle. Your photograph does not show identification lamps on the rear of your trailer; however, it does not appear that these lamps could be mounted at the extreme height of the vehicle, since the tail gate is often removed. In this case, the rear clearance lamps must be located as near as practicable to the upper left and right extreme edges of the vehicle. It appears that clearance lamps located immediately forward of the rear post of a point not obscured by the covering tarpaulin would meet this requirement of the standard. A combination clearance and rear side marker lamp at that location would also be permitted by the standard.

On your tilt type and roll-back equipment loaders, location of tail, stop, turn signal, and identification lamps 30 inches from the extreme rear of the platform, and location of the rear clearance lamps and rear reflectors 44 inches from the extreme rear of the platform, appear to be in accordance with the location requirements of Standard No. 108.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

ID: nht68-3.29

DATE: 04/24/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Finderne Engine Co., No. 1, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 8, 1968, to the National Highway Safety Bureau, concerning the applicability of lighting requirements to fire trucks.

We agree that the front identification lamps might be slightly obscured while the stationary and rotating red and amber lights are flashing. However, when these lights are not flashing, the identification lights would clearly identify a vehicle that is more than 80 inches in overall width. Therefore, identification lights will be required on your fire truck. The same reasoning can be applied to clearance lights and compliance is also required.

The enclosed literature may be of additional assistance to you in response to your inquiry.

We trust this information will be of assistance to you in your desire to comply with existing safety standards.

ID: nht68-3.3

DATE: 12/30/68

FROM: AUTHOR UNAVAILABLE; H. M. Jackson, Jr.; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of October 23, 1968, requesting the addition of the 5-inch alternative rim size for use with the 155-13/6.15-13 tire size designation.

In your request you cited a letter from the German Rubber Industry stating that "for passenger car tires in addition to the rims specified in the German Industrial Standards (DIN) also the use of the next large size rims is permissible." The subject of the foot note in the German standard was discussed by my staff in conversations with Mr. Von Polhemus. When the Federal Motor Vehicle Safety Standards were written, it was the intent to accept the German Industrial Standards (DIN) of 1967 for all tire and rim combinations listed based on established usage. We did not intend to apply foot notes from any 1967 reference materials to the present or future tire and rim combinations.

However, on the basis of the data submitted indicating compliance with the requirements of Federal Motor Vehicle Safety Standards No. 109 and No. 110 and other information submitted in accordance with the procedural guidelines set forth in the Federal Register, Volume 33, No. 195, page 14969, dated October 5, 1968, the 5J alternative rim size for the 155-13/6.15-13 tire size designation will be listed within Table I of Appendix A to Standard No. 110. This change will be published in the Federal Register in the near future.

The addition of this new alternative rim size to the table is accomplished through an abbreviated procedure consisting of the publication in the Federal Register of the petitioned alternative rim size. If no comments are received, the amendment became effective after 30 days from the date of publication. If comments objecting to amendments are received, additional rule making pursuant to Part 216 of the Procedural Rules for Motor Vehicle Safety Standards will be considered.

ID: nht68-3.30

DATE: 05/01/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Truck Equipment, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 6, 1968, to Mr. Lowell K. Bridwell, Federal Highway Administrator, in which you inquired about certification responsibility for lighting on your truck bodies.

Federal Motor Vehicle Safety Standard No. 108 on lighting applies to motor vehicles, not to motor vehicle equipment such as truck bodies.

When the body is mounted on the chassis cab, the lighting requirements of Federal Standard No. 108, not certified by the manufacturer, must be fulfilled.

Certification must be provided to the dealer when the chassis cab is completed for the dealer. A dealer selling to the final purchaser need not certify, but is responsible for lighting to be in compliance with Federal Standard No. 108, for that part of the lighting (or other standards) which have not been previously certified.

Trusting this information answers your questions.

ID: nht68-3.31

DATE: 04/30/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: R.M. Falconer

TITLE: FMVSR INTERPRETATION

TEXT: In reply to your second inquiry concerning importation of foreign manufactured vehicles, the recent amendment to the Customs regulations answers your question on alien residents importing vehicles not meeting safety regulations.

Quote Section b, Part 12.80 of Chapter 1, Title 19:

5. The importer or consigner is a non-resident of the United States, importing such vehicle or equipment item for personal use or for the purpose of making repairs or alterations to the vehicle or equipment item, for a period not exceeding one year from the date of entry, and that he will not resell it in the United States during that time.

If the importer or consignee files with the entry, in duplicate, a verified declaration to the above, a vehicle may be imported.

A copy of form, HS-7, entitled, "Importation of Motor Vehicles and Motor Vehicle Equipment Subject to Federal Motor Vehicle Standards" is enclosed.

As stated in my original letter, vehicles manufactured prior to January 1, 1968, need only a statement to that effect for importation into the United States.

For custom duties on such a transaction of importing a car, I refer you either to the foreign car manufacturing representative or the Office of the Commissioner of Customs, Treasury Department, Washington, D. C.

This office will be glad to provide further assistance if required.

ID: nht68-3.32

DATE: 05/02/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Weslock Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of April 22, 1968, to Mr. Bridwell has been referred to me for reply.

You state that it is your understanding that the proposed rule making in Docket 2-16 will require door locks on trailers and mobile homes to be so constructed "as to be recessed flush on exterior doors." Federal motor vehicle safety standard No. 206, Door Latches, Hinges, and Locks - Passenger Cars, was originally issued on January 31, 1967 and became effective on January 1, 1968. An amendment to this standard was issued on April 24, 1968 with an effective date of January 1, 1969.

Neither the standard as presently written or the proposed amendment in Docket 2-16 is applicable to trailers and mobile homes. Moreover, there is no provision either in the standard or in the proposed amendment which requires that door locks must be so constructed "as to be recessed flush on exterior doors," even as to those motor vehicles to which the standard applies presently or to which it is proposed to apply in Docket 2-16. For your information, we are enclosing a copy of the recent amendment to Standard No. 206 as attachment No. 1, and a copy of the proposed amendment for Docket 2-16 as attachment No. 2.

In view of the foregoing, you may wish to reconsider your request that we forward to you the comments contained in Docket 2-16. The cost to you for forwarding those comments would be fifty cents a page and the number of pages contained in Docket 2-16 is considerable. Since your understanding of the thrust of Docket 2-16 is not correct, your request for an extension of time to May 25, 1968 is denied.

WESLOCK COMPANY

April 22, 1968

Federal Highway Administration Room 316, Donohoe Building 6th & D Street, S. W. Washington, D. C. 20591

Attention: Lowell K. Bridwell Federal Highway Administrator

Although we have not received Docket 2-16, an amendment to Standard 206, we are told that all interested persons have until April 25, 1968 to file comments.

As manufacturers of locks for trailers and mobile homes, we have reason to believe we are affected by Docket 2-16. By hearsay, we understand that this Docket will require that locks be so constructed as to be recessed flush on exterior doors.

If our understanding is correct, we fear that we, and many other lock manufacturers, may be seriously damaged by this requirement. We respectfully request an extension of time until May 25, 1968 to file comments and shall appreciate your sending us Docket 2-16 for study.

May we also suggest that serious consideration be given to the danger of entrapment in trailers arising from the use of locks which do not open automatically upon turning of the inside knob. To prevent loss of life, it may be wise to require panic-proof locks; that is, those which unlock and open merely by turning the inside knob and which do not depend upon the performance of some precedent operation.

Sincerely,

Ernest Cipriano President