ID: nht70-2.21

DATE: 08/11/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Recreational Vehicle Institute Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of July 23, 1970, in which you asked for the Bureau's interpretation of the phrase, "designated seating position that includes the windshield header within the head impact area."

The phrases "designated seating position" and "head impact area" are both defined in the general Definitions section of the standards, 49 CFR 571.3. The remaining substantive phrase, "windshield header," is not defined in the standards. It is intended to refer to the portion of the interior of the vehicle immediately above the top of the windshield, usually but not necessarily a strip of molding separating the glass from the interior roof.

ID: nht68-2.44

DATE: 12/17/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Perley A. Thomas Car Works, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 19, 1968, to Mr. E. Leysath of this Bureau, concerning a clarification of the requirements of paragraph S3.4.3 of Federal Motor Vehicle Safety Standard No. 108.

As you indicated, paragraph S3.4.3 of initial Standard No. 108, which was published in the Federal Register on February 3, 1967, required that tail lamps, license plate lamps, and side marker lamps be illuminated when the headlamps are illuminated. The effective date of the initial standard was January 1, 1968. However, on December 16, 1967, an amendment to the initial standard was published in the Federal Register. This amendment delayed the effective date of paragraph S3.4.3 until May 1, 1968, and in addition revised that paragraph to require, as a minimum, that the fail lamps be illuminated when the headlamps are illuminated. Therefore, the requirements of paragraph S3.4.3 were not applicable to vehicles manufactured during the period of January 1, 1963 through April 30, 1968. During that period, selection of the lamp switching arrangement was at the option of the vehicle manufacturer.

Thank you for writing.

ID: nht68-2.45

DATE: 05/31/68

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

TO: Oshkosh Truck Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of January 15 and March 25, 1958, to the National Highway Safety Bureau, concerning the applicability of Federal Motor Vehicle Safety Standard No. 108 to snow removal and heavy duty on-off highway vehicles manufactured by Oshkosh.

Standard No. 108 requires that headlamps be mounted not more than 54 inches above the road surface. Since your snow removal vehicles may be used in hauling operations as a secondary function, and since your heavy duty vehicles are used on the public roads, they are required to be equipped with headlamps located in accordance with Standard No. 108. Additional headlamps mounted on the cab roof or elsewhere on the front of the snow removal vehicle is permitted by the standard.

With reference to your heavy duty vehicles, headlamps located in the bumper, with adequate openings in front of the headlamps; or headlamps located below the bumpere, with protective shields around the headlamps would be permitted by Standard No. 108.

With respect to the requirements of Standard No. 108, we 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. The certification information that you have provided us in your letter of January 15 is in accordance with our requirements.

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

ID: nht68-2.46

DATE: 07/22/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Dompster Brothers, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 28, 1968, to Mr. James R. O'Gorman, Acting Director, Office of Performance Analysis, requesting comments on the lamps, reflective devices and associated equipment on your container handling equipment.

The lamps and reflectors shown on your drawing A-B4333 through A-B4339 enclosed in your Engineering Bulletin No. 1 dated May, 1965, appear to be in conformance with the requirements of Standard No. 1 (Illegible Word) Since no dimensions are included on your drawings, we can only assumes that the locations are as specified in the standard.

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

ID: nht68-2.47

DATE: 05/20/68

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

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 16, 1968, your reference 61.A218. A1115, to the National Highway Safety Bureau concerning applicability of Federal Motor Vehicle Safety Standards 108 and 205 to compers.

Your questions along with our corresponding answers are listed below: uestion: 1. Do Federal Standards Nos. 108 and 205 apply to Camper bodies which are not manufactured as a part of a vehicle but which may be purchased separately and later installed on a pickup truck by its owner? Answer: The enclosed Notice of Making Regarding Compare affirms the applicability of Federal Standard No. 205 to camper bodies. Federal Standard No.

108 is a standard applicable to chassis cabs and to complete motor vehicles. Question: 2. Do Federal Standards Nos. 108 and 205 apply to campers which are sold by the pickup truck dealer as part of a new vehicle even though the camper body itself is actually a load on the pickup and is designed to be recovered from the pickup when the owner decides to transport other types of loads? Answer: The applicability of Federal Standard No. 205 is covered in the enclosure. Federal Standard No.

108 is a requirement upon the dealer who sells a motor vehicle. If the vehicle is designed for more than one configuration in use, the dealer must provide that both configurations are in compliance with Federal Motor Vehicle Safety Standards.

The enclosed information on the National Traffic and Motor Vehicle Safety Act of 1966 are provided to further assist you.

ID: nht68-2.48

DATE: 09/27/68

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr.; NHTSA

TO: United States Senate

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 13, 1968, calling my attention to Mr. Paul Johnston's comments and suggestions on the requirements for school bus signal lamps as specified in Motor Vehicle Safety Standard No. 108.

As Mr. Johnston pointed out, Standard No. 108, effective January 1, 1969, provides for optional use of either the eight-lamp or four-lamp signal system. This optional provision was adopted after careful consideration of the comments and recommendations which were received in response to the Notice of Proposed Rule Making as published in the Federal Register on February 3, 1967. The "Minimum Standards for School Buses", as published by the National Conference on School Transportation, and the regulations governing minimum standards for school buses in various states were also considered during development of the optional provision for signal lamp systems. Results of our studies and investigations indicated that approximately forty states were using either the four-lamp or eight-lamp signal system. Other states were using the adopted system with only minor variations in the installation and operational requirements.

Standard No. 108, effective January 1, 1969, was published in the Federal Register on December 16, 1967. Under the procedural rules of the Federal Highway Administration, any person adversely affected by this order may petition the Administrator under Part 216, Subchapter B, Section 216.31 or Section 216.35, published in the Federal Register on November 17, 1967, a copy of which is enclosed. No petition of the adopted requirements for school bus signal lamps has been filed.

Although we do not dispute the safety benefits which Mr. Johnson claims for a six-lamp system, I must emphasize that our long-range objective is the adoption of one nationwide system. Even with the presently adopted systems, a motorist could be faced with the problem of interpreting two sets of signals during a very short time period. This problem will become more prevalent with the anticipated increase in rapid interstate traffic. To permit the use of a third optional system, six-lamp or other, would further complicate the situation.

Standard No. 108 applies only to new school buses manufactured on or after January 1, 1969. Retrofitting of buses presently in operation is not required. Since Iowa's fleet of buses is presently equipped with a six-lamp system, it appears that considerable data on the effectiveness of this system could be accumulated from this fleet during the next several years, or until such time that a single nationwide system is proposed. We will be pleased to carefully review and consider any such data which Mr. Johnson can provide in the future.

In summary, it is the position of this Bureau that the provision of Standard No. 108 permitting optional use of either the four-lamp or eight-lamp signal system is reasonable, practicable and in the interest of highway safety. Therefore, we do not believe that a change in this provision to permit optional use of a third or six-lamp system is justified.

We have reviewed our files with respect to the written and personal contacts Mr. Arthur Roberts, Director of Pupil Transportation, has had with this Bureau.

This review indicates that the correspondence from Mr. Roberts was submitted in response to the Notice of Proposed Rule Making on Standard No. 112 (subsequently combined with Standard No. 108) as published in the Federal Register on February 3, 1967. It is not the practice of the Bureau to reply individually to the numerous responses received from published rule making notices, which often run to thousands of pages. However, a summary of the comments represented by the responses and the disposition of these comments is presented in the preamble to Standard No. 108 as published in the Federal Register on December 16, 1967. With respect to Mr. Roberts visit on May 7, 1968, the topics of discussion related primarily to the technical requirements of Standard No. 108 and other information relative to the merits of converting Iowa's school buses to either the four-lamp or eight-lamp system. Our understanding was that Mr. Roberts received the information he was seeking at the time of his visit and that no follow-up correspondence was necessary on our part.

ID: nht68-2.49

DATE: 09/04/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: General Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 1, 1968, to Messrs. Eugene Laskin and J. E. Leysath of this Bureau, requesting comments on the Distributors Association's bulletins on lamps, reflective devices and associated equipment required by Motor Vehicle Safety Standard No. 108.

The five bulletins adequately illustrate the requirements of Standard No. 108 to the vehicles shown except as follows:

(1) Pages 1, 3, and 4 -- The statement "Identification, clearance and side market lights and side and rear reflectors are not required unless vehicle with body is 80 or more inches wide overall" should be changed, because Table III of Standard No. 108, effective January 1, 1969, specifics requirements for side marker lights and side and rear reflex reflectors on vehicles less than 80 inches wide.

(2) Page 2 -- The numbers indicating clearance and identification lamps in lower right view should be reversed, i.e., 10 and 11, respectively. Also, the turn, tail and stop lamps do not appear to be located as far apart as practicable.

(3) Page 4 -- The front clearance lamps mounted on the chassis cab are optional, because those on the van body meet the requirements of Standard No. 103.

(4) Page 5 -- (a) Identification and clearance lamps are not required if vehicle width is under 80 inches. (b) Two red reflectors are required on the rear of the vehicle.

(5) General, all pages -- Paragraph S3.1.1.6 permits vehicles less than 80 inches overall width manufactured before January 1, 1970, to be equipped with a combination of two side marker lamps and side marker reflectors on each side instead of two each as specified in Table III.

(6) General, Pages 1 through 4 -- Parking lamps are not required on vehicles that are 80 inches or were in overall width.

With respect to the requirements of Standard No. 108, 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 hat the assembled vehicle meets the requirements of the standard.

ID: nht68-2.5

DATE: 05/14/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Northern California Ready Mixed Concrete and Materials Association

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 8, 1968, to Mr. George Nield, concerning the location requirements for clearance lamps as specified by Federal Motor Vehicle Safety Standard No. 108.

Enclosed is a copy of the Federal Motor Vehicle Safety Standards (with amendments and interpretations through February 15, 1968). Standard No. 108 appears on page 39 of this publication. The location requirements for clearance lamps are included in Table II (page 50), of the standard. Since the requirements specify locations as near as practicable to the upper left and right extreme edges of the vehicle, the exact locations will vary, depending upon the design and utilization of the vehicle on which the lamps are mounted. When the rear identification lamps are mounted at the extreme height of the vehicle, rear clearance lamps may be mounted at optional heights. I would also point out that Standard No. 108 is applicable to new vehicles manufactured for sale on or after the effective date of the standard.

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.

Thank you for writing.

ID: nht68-2.50

DATE: 04/16/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Hercules Galion Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 15, 1968, to the Director, National Highway Safety Bureau, concerning your interpretation of the requirements of Motor Vehicle Safety Standard No. 108.

The lamps and reflectors shown on your drawing(Illegible Words) dated March 8, 1968 appear to be in conference with the requirements of Initial Standard No. 108; however, since no dimensions are specified on your drawing, we can only assume that the locations are as specified in the standard.

The certification requirements for complete vehicles incorporating chassis and bodies manufactured prior to and after January 1, 1968, are correctly stated in the information bulletin attached to your referenced letter and dated March 15, 1968.

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 Standard No. 108.

ID: nht68-2.6

DATE: 05/14/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 16, 1968, to Mr. Lowell K. Bridwell, Administrator, Federal Highway Administration, requesting a clarification of the electrical circuity arrangements that may be used to meet the requirements of paragraph S3.4.3 of Motor Vehicle Safety Standard No. 108.

Truck-tractors wired in accordance with your customers' orders stating, "the brown trailer circuit shall be connected to the headlamp switch and the black trailer circuit shall be energized through a seperate switch," will meet the requirements of paragraph 53.4.3, provided the trailer circuits conform to SAE Standard J560a. With this circuitry, your responsibility as a truck-tractor manufacturer would be fulfilled, regardless of the number of trailers that are towed by the truck-tractor.

Thank you for writing.