ID: nht68-3.43

DATE: 07/25/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 2, 1968, to Mr. George C. Nield, Acting Director, Motor Vehicle Safety Performance Service, concerning requirements for combination clearance and side marker lamps.

Paragraph S3.3 of Motor Vehicle Safety Standard No. 108 permits the combination of two or more lamps providing the requirements for each are met. Table 1 in SAE Standard J592b gives the photometric requirements for both the clearance and side marker lamps, and Section J of the Standard permits their combination providing the combination complies with both clearance and side marker minimum candlepower requirements. Section J also defines the H-V axis of the combination as parallel with the longitudinal axis of the vehicle when checking clearance lamp test points, and normal to this vehicle axis when checking side marker test points.

Your table of minimum candlepower requirements for the Type 2 combination lamp meets J592b and therefore Standard No. 108 providing you define the H-V axis as that of the side marker lamp. The requirements for the Type 1 combination as specified in your table will not meet J592b or Standard No. 108 unless you change H-10, -20, -30, -45, -60, -80 and -90, both 1, and R to H-15, -25, -35, -45, -55, -65, -75 and -90, both L and R, and define the H-V axis as a line through the center of the lamp at a 45 degree angle to the longitudinal axis of the vehicle.

Your mounting instructions are considerably more restrictive than those implied in J592b and Standard No. 108. Actually, no additional mounting instructions are necessary, because any mounting which meets the minimum candlepower requirements of Table 1 in J592 and your table with the suggested revisions would meet the requirements of Standard No. 108.

ID: nht68-3.44

DATE: 07/26/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Toyota Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 27, 1968, in which you requested clarification of the term "optically combined" as applied to motor vehicle lights.

"Optically combined" in this context means that the same lens area is used for more than one function such as tail and stop lights or stop and turn signal lights or tail, stop and turn signal lights. The normal means used to accomplish this "optically combined" lamp has been to incorporate a single dual-filament bulb with a reflector and lens.

Since the design of your Toyota Crown combination stop, tail and turn signal lamp is such that a different part of the lamp area is used for the turn signal lamp, we do not interpret it to be optically combined with the tail and stop lamp.

The concurrence of the above interpretation with yours and that of the California Highway Patrol should not be construed to be an approval of your design. The results of recent research on lighting and signaling reviewed by this Bureau indicate that signal lights should be separated 4 1/2 to 5 inches minimum (centerline to centerline separation.) Although no dimensions are specified on your drawing it appears to be approximately full scale with a separation distance of 2 1/2 inches between the stop and turn signal lamps. The steady-burning stop lamp may therefore "wash out" or significantly reduce the effectiveness on the turn signal lamp. Federal Motor Vehicle Safety Standard No. 108 does not require a minimum separation distance between signal lights; however, upon completion of our present research contracts on rear lighting and signaling, we may consider such a requirement in the future.

ID: nht68-3.45

DATE: 07/29/68

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

TO: Lotus Cars Limited

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Bridwell has asked that I reply to your letters dated November 18 and July 3 which ask if Motor Vehicle Safety Standard No. 201 requires your company's "Elan Convertible" to have sun visors.

The National Highway Safety Bureau recognizes that the requirement for every passenger car to have two sun visors of energy-absorbing material with mountings that have no rigid material edge radius of less than 0.125 if statically contactable by a 6.5 inch diameter head form, may create a problem for manufacturers of certain types of vehicles. However, the requirement will, on balance, contribute to the safety of the general public.

Compliance with the requirement can and should be made in a manner so as to increase occupant protection.

LOTUS

JULY 3, 1968.

Lowell K. Bridwell, Federal Highway Administrator US Department of Transportation,

Federal Motor Vehicle Safety Standard Number 201: Sunvisors

We despatched a petition to you on 28th November 1967, requesting that we be permitted to substitute increased header padding for the sunvisors stipulated in F.M.V.S.S. 201 on our model: ELAN CONVERTIBLE.

On 19th January we sent further information to back up our earlier submission. We felt, for reasons given in our letter of 28th November 1967, that the spirit of F.M.V.S.S. 201 would be met, on this particular model, better, by increased padding, than by the addition of sunvisors.

We would be extremely grateful for some indication of your view of our petition.

B.A. Luff General Manager

ID: nht68-3.46

DATE: 07/31/68

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

TO: Associazione Nazionale Fra Industrie Automobilistiche

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 3 to the National Highway Safety Bureau asking "whether the solution given in the enclosed drawing N. 591-1559 of Ferrari is in line with the requirements" of Federal motor vehicle safety standard No. 211.

This standard states that "wheel nuts, hub caps, and wheel discs for use on passenger cars . . . shall not incorporate winged projections". The Ferrari plan appears to incorporate such a projection, even though it is recessed. Accordingly the proposed solution by Ferrari does not meet the requirements of Federal standard No. 211.

ASSOCIAZIONE NAZIONALE FRA INDUSTRIE AUTOMOBILISTICHE

U.S. Department of Transportation Federal Highway Administration National Highway Safety Bureau

June 3 1968

Motor Vehicle Safety Standard n. 211

Reference is made to your letter of December 21st 1967 and we wish to thank you very much for the explanations about the standard N. 211.

Further we would appreciate it very much your letting us know whether the solution given in the enclosed drawing N. 591-1559 of Ferrari is in line with the requirements concerning "wheel nuts, hub caps and wheel discs".

Thanking you in advance, we remain

Faithfully Yours,

(Illegible Word) Direttore (Francesco Palazzi)

ID: nht68-3.47

DATE: 07/31/68

FROM: R.M. O'MAHONEY -- NHTSA; SIGNATURE BY MR. SCHMELTZER

TO: E.L. Mobley

TITLE: FMVSR INTERPRETATION

TEXT: Your letter of July 19 to Mr. Vinson of my staff presents your problem regarding two Volkswagens which have been conditionally admitted to the United States pursuant to 19 C.F.R. @ 12.80(b)(2)(iii) and (c). You state "we want to do whatever is necessary to secure an unconditional release of the cars."

As the Acting District Director of Customs informed you in his letter of July 18, @ 12.80(c) requires that the importer submit to the Bureau of Customs:

". . . a statement verified by the importer or(Illegible Word) that the vehicle . . . described in the declaration filed by the importer has been brought into conformity with applicable safety standards, and identifying the manufacturer, contractor, or other person who has brought such vehicle . . . into conformity with such standards and describing the nature and extent of the work performed."

Production of statements for the two Volkswagens containing the information required by @ 12.80(c) should allow a release of the vehicles and a termination of the bond. As Customs further informed you, these statements are forwarded to the Highway Administration for evaluation. This means that, if questions arise about the conformance work, you will be asked to provide us with the name and addresses of the owners of these vehicles.

I enclose a copy of the standards currently applicable to passenger cars. Two of the three items you mentioned are only a small portion of the overall requirements of the standards. With reference to these items you will note that "seat belts" are covered by three Federal standards: No. 208 requiring installation of upper torso and pelvic restraints, No. 209 specifying conformance of assemblies, and No. 210 specifying detailed requirements for anchorage points. The requirements of Paragraph S 3.1 of Standard No. 201 does not per se require a "padded dash"; conversely there is no assurance that the padding of a previously bare dash panel will bring a non-conforming vehicle into conformity. "Back-up lights" is a Federal requirement only for passenger cars manufactured on or after January 1, 1969.

I hope this answers your questions.

ID: nht68-3.48

DATE: 08/05/68

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

TO: Luis M. Neco

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 25, 1968, concerning the motor vehicle safety requirement for head restraints and your proposed specification for the installation of transparent partitions separating the front and rear compartments of taxicabs.

A head restraint will be required on all passenger cars manufactured after December 31, 1968. Our findings based on passenger vehicle collision research clearly indicate the use of head restraints to be one of the most effective safety measures that can be provided for the driver and front seat passenger. For your information, I am enclosing a copy of a news release on this subject and a report entitled "Backrest and Head Support Design for Rear-End Collision Protection" published by the SAE, January 10, 1968.

I appreciate the problem of driver assault. However, we do not believe the deletion of a proven safety device is an appropriate way to resolve the problem. A positive approach, and one that is practical, would be to develop a suitable partition, and we know of no reason why this can not be accomplished practically, with head restraints and shoulder belts installed. The partition design should provide the current level of safety for(Illegible Word) occupants. I refer here to the use of laminated safety glass with energy absorbing characteristics of today's windshields in a frame that would retain the glass during a collison and that is not hazardous to head impact.

Giving consideration to all the factors involved, we are convinced that head restraints offer significant benefits in reduced "whiplash" injuries, and are certain that you can resolve the partition problem to accomplish both your objective of protecting the driver from others, and of reducing his chances of injury in a crash.

ID: nht68-3.49

DATE: 08/05/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 1, 1968, to Mr. George C. Nield, concerning a clarification of paragraph S 3.4.3 of Federal Motor Vehicle Safety Standard No. 108.

Paragraph S 3.4.3 specifies that, as a minimum, the taillamps shall be illuminated when the headlamps are illuminated, except when the headlamps are being flashed. The phrase "except when the headlamps are being flashed", permits the vehicle manufacturer to use a separate switch or flasher for illuminating the headlamps only when it would not be appropriate or in the interest of safety to simultaneously illuminate the taillamps and headlamps. In addition to the examples cited in your letter, such devices could also be used for flashing the headlamps on public transit vehicles to indicate an emergency situation.

Since the subject matter of S 3.4.3 is taillamps and since Federal Standard No. 108 is otherwise silent as to headlamp flashing, this matter appears to be within the purview of the California vehicle code.

Thank you for your continued interest in the motor vehicle safety standards.

ID: nht68-3.5

DATE: 12/31/68

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

TO: Brixtax (London) Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 9, 1968, in which you inquire about the certification responsibilities of equipment manufacturers under the National Traffic and Motor Vehicle Safety Act of 1966.

You state that it is your understanding that a vehicle manufacturer has the responsibility to certify the entire vehicle, including equipment that is produced by other manufacturers and covered by Federal safety standards, as complying with the applicable standards, and that the basis on which that manufacturer satisfies himself that equipment from suppliers conforms to the standards is a matter of his own discretion. I consider that statement to be essentially correct, with the caveat that the manufacturer must be able to show, under @ 108(b)(2) of the Act, that "he did not have reason to know in the exercise of due care" that any included equipment was nonconforming. What constitutes "due care" must be determined in light of all the circumstances of a particular case. You are also correct in your understanding that approval by the States has no relevance to the question of compliance with this Federal law.

Finally, regardless of certification requirements all equipment must conform to applicable standards, and certification by the equipment manufacturer is required if the equipment is ultimately sold in the aftermarket.

I am pleased to be of assistance.

ID: nht68-3.50

DATE: 08/05/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Kawasaki Motorcycle Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 21, 1968, to Mr. George C. Nield, Acting Director, Motor Vehicle Safety Performance Service, concerning the mounting of the front side reflex reflector on motorcycles.

Mounting the front side reflex reflectors just below or immediately ahead of the front of the fuel tank, as shown in the brochures on your models C2TR. and F3, appears to satisfactorily meet the requirements of Federal Motor Vehicle Safety Standard No. 108. The front side reflex reflectors shown in the brochure on your model W2TT do not appear to be located as for forward as practicable. A location corresponding to that shown for models C2TR and F3 also appears practicable for the model W2TT.

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 the way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

ID: nht68-3.6

DATE: 06/07/68

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

TO: Toyota Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 25, 1968, concerning Federal Motor Vehicle Safety Standards Numbers 111, 291, and 206. I hope these interpretations will answer your questions:

Standard No. 111:

Question 1. Your interpretation is not entirely correct. Your Figure 1 shows only six directions the 90-pound force can be applied; whereas, the force may be applied from any intervening location from within the solid wedge in the 180 degrees forward are inserted within the six lines you show in your Figure 1. S3.1.2.2 requires that the mirror is to be subjected to this test force. This may be applied to the center of the mirror or to any other location on the mirror surface.

Question 2. The test force may be applied as shown in your Figures 2(a), (b), and (c) but not as shown in Figure 3. As stated above, the test force must be applied to the mirror itself, not to the mirror support.

Question 3. As stated above, the 90-pound force may be applied as shown in your Figure 2(c) since it would not be possible, in this case, to obtain the maximum 45 degrees angle due to design of the mirror system.

Standard No. 201:

Since S3.4.2(b) of Standard No. 201 does not specifically state the thickness of energy-absorbing material required to cover the folding armrest, the armrest shown in your sketch on page 5 appears to be permissible. It does seem advisable, however, in future designs to either provide a greater thickness of energy-absorbing material or increases the potential area of contact with the underlying steel support by providing a wider flange and turning the edge inward.

Standard No. 206:

The inertia lond requirements of S3.3.3 refer to S3.3 - Door Latches only, and do not include the lock. Door lock requirements are specified separately in S3.1. Therefore, the door latch system requirements must be met without a lock engaged.

April 25, 1968

Dr. William Haddon, Jr., Director

National Highway Safety Bureau

We have questions on interpretation of Standards No. 111, No. 201, and No.

206.

Your kind cooperation would be very much appreciated if you answer the following questions.

Standard No. 111 S3.1.2.2

Question 1.

S3.1.2.2 specifies that " when the mirror is subjected to a force of 90 pounds in a forward or sideward direction in any plane 45 degrees above or below the horizontal". We interpret that direction of a force which should be applied to the mirror means any one of the six directions shown in Fig. 1, and that the force should be applied to a universal joint of the mirror or to a center of the mirror. Is this interpretation right?

Question 2.

As actual procedures of applying a force we use methods shown in Fig. 2 and 3, whether we use Fig. 2 method or Fig. 3 method depends on vehicle models. We think Fig. 2 method simulates actual application of a force better than Fig. 3 method, although direction of a force applied to the mirror by a head form will be different from 45 degrees (less than 45 degrees) when a head form approaches the mirror in Fig. 2 (a). If we use Fig. 3 method, we can always apply 45 degree force. Are those Fig. 2 and 3 methods permissible?

Question 3.

In applying a force using a head form, in some cases, it is impossible to apply 45 degree force due to shape of the mirror and mirror support. In this case, is it permissible to apply a force of as big as possible but less than 45 degree direction as shown in Fig. 2 (c)?

Standard No. 201 S3.4.2 (b)

We need clarification of "covered with energy absorbing material." In Fig. 5 and 6 we show a structure of folding armrest of Toyota Crown model. In Fig. 4, if force F is applied to the armrest as shown, fixtures of the armrest as shown A is comparatively easily deformed. However, a portion encircled in Fig. 5 BB crossection has only 5 mm thick cover of urethane foam rubber. Is this structure permissible?

Standard No. 206 S3.5.3

Is it permissible to lock the door latch system before we apply an inertia force of 30g to the door latch system?

Thank-you,

Toyotaro Yamada Manager

Fig. 1 (Graphics omitted)

Fig 2(a) Downward applied Force (Graphics omitted) Fig 2(b) Upward applied Force (Graphics omitted)

Fig 2(c) Downward applied Force. (Graphics omitted)

Fig 3 (Graphics omitted)

Fig 5 Armrest Installation (Graphics omitted)

Fig 6 Armrest Structure (Graphics omitted)

crossection CC. (Graphics omitted)

crossection AA (Graphics omitted)

crossection BB (Graphics omitted)