ID: nht69-2.49

DATE: 08/18/69

FROM: AUTHOR UNAVAILABLE; S. K. Booth; NHTSA

TO: Cox Trailors Incorporated

COPYEE: CENTRAL FILE(2); ANDERS; COMPTON; LEYSATH; NIELD; 512 CHRON; 510A CHRON; INTERPRETATIONS: STD.108; DYSON (2); CC-2921

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of August 6, 1969, concerning the location of the side marker lamp and reflector on boat trailers manufactured by your company, as discussed by your Mr. Oglesby with Mr. Tyson of this office.

Paragraph S3.2.1.4 of Standard 108 states: "On trailers, the amber front side reflex reflectors and amber front side marker lamps may be located as for forward as practicable exclusive of the trailer tongue." The forward location chosen will be satisfactory if you can provide reasonable justification for not placing it farther forward, that is, closer to the base of the trailer tongue.

We are pleased to be of assistance.

ID: nht69-2.5

DATE: 01/24/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Nissan Motor Corporation in U.S.A.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 6, 1968, to Dr. William Haddon, Jr., Director, National Highway Safety Bureau, requesting a clarification of the requirements for a turn signal pilot indicator as specified in Motor Vehicle Safety Standard No. 108.

With respect to the turn signal pilot indicator only, you are correct in your interpretation that so long as the indicator is the color green, the diameter circle is more than 3/16 inches, and the driver has a clear and unmistakable indication, it is not necessary to apply other test procedures in order to meet the requirements of Standard No. 108.

The above provision in no way excepts turn signal lamps from meeting the requirements of SAR Standard J588d, June 1966.

ID: nht69-2.50

DATE: 09/25/69

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Bennett's Truck Equipment

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of September 10, 1969, in which you asked whether you should certify the trucks that you assemble as a manufacturer or a distributor, and what are the safety standards to which your vehicles must comply.

The answer to your first question is that if you assemble the body to the chassis, you must certify as a manufacturer, regardless of by whom the body or chassis is fabricated. You should note that under the "chassis-cab ruling" (pages 43 and 369 of the enclosed regulations) the chassis-cab manufacturer is required to certify on a temporary label as to the standards to which the chassis-cab will comply when completed.

In response to your second question, I am enclosing a copy of the motor vehicle standards and regulations.

ID: nht69-2.51

DATE: 02/20/69

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

TO: Toyo Kogyo Company, Limited

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 30, 1968 (your reference No. GSAE-26) requesting information to a number of questions related to the Federal Motor Vehicle Safety Standards. I regret that we did not receive your October 5, 1968 letter and that the pressure of work has delayed my answer to your most recent letter.

I am glad to send you the following information:

a. MVSS No. 112 - Headlight Concealment Devices.

1. It is stipulated in S.4.6 that "each headlamp concealment device shall, within an ambient temperature range of -20 to +120 degrees F., be capable of being fully opened in not more than three seconds after actuation of the mechanism described in S.4.3." With regard to the temperature condition at the time of a test, if only the ambient temperature satisfies the cold temperature conditions, is it all right to pay no regard to other conditions, such as the sticking of frost, ice, etc.?

ANSWER: It is only necessary that the ambient temperature conditions (-20 to +120 degrees F.) be satisfied at the time of the test.

b. MVSS No. 114 - Theft Protection.

1. With regard to the stipulation in S.4.2 that "The prime means for deactivating the car's engine or other main source of motive power shall not activate the deterrent required by S.4.1.(b)," we have provided the ignition switch with four stages as shown in the sketch below: our key-locking system is of the mechanism that the system does not activate at the stage "Off", activates only at the stage, "Lock" and satisfies S.4.4. Does this mechanism conform to S.4.2.7

ANSWER: The system as you describe it appears to conform to S4.2; however, the Bureau does not issue approvals of any specific system, and the development of equipment to comply with this requirement is the responsibility of the individual manufacturer.

2. With reference to the stipulation in S.4.1. "Each passenger car shall have a key-locking system that, whenever the key is removed, will prevent ----.", we would like to know whether or not we must provide such a mechanism as the key can be removed only at the stage "Lock" and cannot at the stage "Off".

ANSWER: A locking system having such a position that the key may be removed without activating either the cars' steering lock or its self-mobility lock would not conform to the standard in its present form, since paragraph S4.1 of the standard requires each car to have a key locking system that, whenever the key it removed, will prevent either steering or self-mobility of the car, or both.

c. MVSS No. 201 - Occupant Protection in Interior Impact

1. With regard to the interpretation of the stipulation in S.3.1 " , the deceleration of the head form shall not exceed 80 g for more than 3 milliseconds," when the deceleration wave -- shown in the chart below -- is obtained.

in case DELTA t[1] < 3 milliseconds, we interpret that the standard is satisfied even when delta t[1] +="SIGMA" t[2] t[3] t;> 3 milliseconds.

Is our interpretation correct? (Illustration omitted)

ANSWER: Your interpretation is correct. The standard permits more than one peak that exceed 80g which, cumulatively, may add to more than 3 milliseconds. No single peak may continuously exceed 80g for more than a 3 millisecond duration.

2. When the areas stipulated in S.3.1.1.(d) -- "Areas outboard of any point of tangency on the instrument panel of a 6.5 inch diameter head form tangent to an inboard of vertical longitudinal plane tangent to the inboard edge of the steering wheel," -- are illustrated, which of the following hatched portions in the figures below is in conformity to the stipulation? (Illustration omitted)

ANSWER: Figure (a) is correct for the inboard side. Present requirements do not apply to the area outboard of the steering wheel on the instrument panel.

d. MVSS No. 207 - Anchorage of Seats.

S.3.3 Folding and hinged seats. Except for folding auxiliary seats and seats with backs which are adjustable for occupant comfort only.

1. Is it correct to interpret that the underlined part is referring to seats with backs of reclining mechanism enabling to adjust the angle of the back?

ANSWER: Yes.

2. Or, should we interpret that the seats with reclinable backs come under the hinged seats?

ANSWER: No.

3. a. In the case of car with four doors, if the front seats are those with reclinable backs, these are presumed to be the ones corresponding to (1). Is this interpretation correct?

ANSWER: Yes.

b. In the case of a car with two doors, we would like to interpret that only the reclinable seat backs with folding mechanism enabling the passengers on the rear seat to get in and out are in conformity to (2). Is our interpretation correct?

ANSWER: Yes.

S.3.3.1 The release control shall be readily accessible to the occupant of that seat and to the occupant of any seat immediately behind that seat.

1. The above stipulation is presumed to be laid down for the egress of the passengers on the rear seat. Therefore, when the reclining seats are installed in a four-door car, we would like to consider it unnecessary to pay regard to the underlined part. Is this interpretation correct?

ANSWER: Yes.

2. In the case of a two-door car, if the control which can be easily operated by passengers on the rear seat is installed only on one side (the right side), the passengers on the rear seat can operate the control by moving to the right side. Consequently, we consider it sufficient to install only on the right side the control which is easily accessible to the passengers on the rear seat. Is this interpretation correct?

ANSWER: In the case of a two-door car, for a split back or bucket seat arrangement, where both seat backs fold, a release control should be provided on the outboard side of each folding seat back. If the seat back is split and only one seat back folds, only one release control is required on the outboard side.

e. MVSS No. 210 - Seat Belt Assembly Anchorages

1. We judge that the fastening strength of the seat belt anchorage will change, depending on the shape of the eye bolt attaching the seat belt to the seat belt anchorage point.

If an anchorage is tested by using our designed seat belt assembly and the strength of the anchorage can be assured, we understand that the anchorage fully conforms to the standard, and also understand that it is not necessary to guarantee the owners of Mazda vehicles if they attach a test bolt assembly other than the one designated by us. Is our interpretation correct?

We, of course, will specify in our Operation Manual that the seat belt assembly designated by our company must be used.

ANSWER: Under Paragraph S.5.1 of Federal Motor Vehicle Safety Standard No. 210, anchorages are to be tested by using a Type 1 or Type 2 seat bolt assembly as defined in FMVSS No. 209. If you follow this procedure, using a belt which complies to No. 209, and your anchorages meet the requirements of Standard No. 210, then you are in compliance with this standard.

I must point out that this Bureau does not issue approvals on items of equipment or on vehicle designs. 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 Standards.

ID: nht69-2.6

DATE: 01/16/69

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

TO: Rolls-Royce Limited Motor Car Division

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 8, 1968, requesting a clarification of the 30g horizontal inertia load direction specified in Standard No. 201, as published in the Federal Register on October 25, 1968.

In section S3.3.1(c), "Subject the interior compartment door latch system to a horizontal inertia load of 30g in a longitudinal direction....." means both forward and rearward directions. In addition, the loads specified in S3.3.1(a) are applied in both the inboard and outboard and the up and down directions. This is consistent with similar type requirements in Standard No. 206.

You state that a forward and rearward 30g inertia load requirement is more stringent than the alternative procedure of S3.3.1(b), the barrier test. The Bureau believes, and one large manufacturer so stated in his comments, that the most meaningful test of the ability of an interior compartment door to remain closed is one which considers the distortion and deformation loads that occur in a collision. A barrier or equivalent dynamic test is the best way of realistically evaluating the ability of these doors to remain closed. The Bureau, therefore, believes that the barrier test is as stringent a requirement as S3.3.1(c).

ID: nht69-2.7

DATE: 01/13/69

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Baycraft

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of December 2, 1968, to Mr. William L. Hall, concerning safety glazing in canopies, has been referred to me for reply.

FHWA Ruling 68-1 clarified the requirement that slide-in campers must comply with Standard 205 since they are items of motor vehicle equipment for use in motor vehicles. A copy of FHWA Ruling 68-1 is enclosed.

The same rationale applies to your canopies. Forward facing windows must be laminated safety glass meeting the requirements of Test No. 26 of ASA Standard Z26.1-1966, July 15, 1966. Other windows may be AS1, 2, 3, 4, 5, 6, 7, 10, 11, 2-26, or 3-26.

ID: nht69-2.8

DATE: 02/25/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: General Propulsion

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letters dated January 20 and 28, 1969, in which you supply Certification information.

It is our opinion that the nomenclature, as stated on your certification label for use on the multi-purpose passenger vehicle, does fulfill the requirements of Section 114 of the National Traffic and Motor Vehicle Safety Act of 1966 and the new Certification requirements effective with vehicles manufactured after August 31, 1969. The same label could be altered for use on the van trucks, see paragraph two of Mr. O'Mahoney's letter to you dated February 5, 1969. A copy is enclosed.

The label you propose to use on the chassis-cab does not fulfill the requirements set forth in 49 C.F.R. @ 371.13, formerly 23 C.F.R. @ 255.13, which states in part, "Identifies the Federal motor vehicle safety standards with which its manufacturer states the chassis-cab fully complied for the principal end uses of such vehicle."

Your statement, "This cab-chassis conforms with all applicable Federal motor vehicle safety standards in effect on the date of manufacture shown above for the principal and use intended. End use .," or other structure has adequate information with which to meet his statutory responsibilities. A copy of the Federal Register, Volume 33, Number 250 is enclosed. Chapter III, Subchapter A contains all of the pertinent details.

We trust the reply will be of assistance to you in your desire to comply with existing requirements of the National Highway Safety Bureau.

ID: nht69-2.9

DATE: 03/27/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Gold Cross Ambulance Service Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 18, 1969, to Dr. William Haddon, Jr., requesting information on Federal Motor Vehicle Safety Standards (FMVSS) applicable to ambulances.

If the ambulance is built on a passenger car chassis, all of the FMVSS applicable to passenger cars would apply. However, if the ambulance is built on a truck chassis, the FMVSS applicable to multi-purpose passenger vehicles would apply. There have been no special exceptions granted for ambulances.

Enclosed for your information and guidance are copies of the National Traffic and Motor Vehicle Safety Act of 1966 and the FMVSS established thereunder.

ID: nht70-1.1

DATE: 04/30/70

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

TO: David Sugarman, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of April 16 I enclose copies of Federal Motor Vehicle Safety Standards Nos. 107 (Reflecting Surfaces) and 108 (Lamps, Reflective Devices, and Associated Equipment). Copies of the ASTM and SAE standards cross-referenced in the Federal standards are available from the American Society for Testing and Materials and the Society of Automotive Engineers. You may find particularly helpful SAE Handbook Supplement 19, "SAF Technical Reports Referenced in Federal Motor Vehicle Safety Standards".

The answer to your first question is that Standard No. 108 requires passenger cars manufactured on or after January 1, 1970, to be equipped with a total of 4 side marker lamps and 4 side marker reflectors, one marker and one reflector, amber in color, on each side of the vehicle "as far forward as practicable", and one marker and one reflector, red in color, on each side of the vehicle, "as far to the rear as practicable" Between January 1, 1969 and January 1, 1970 the option of reflectors or markers, or a combination of the two, was permitted. Prior to January 1, 1969 the Federal lighting standard did not apply to passenger cars. I will note in passing that the rear marker lamps on the Monteverd; displayed at the recent New York show were number and must be changed to red before these vehicles are sold. There are no requirements as to size and shape of lamps and reflectors, but the SAE standards applicable to them and incorporated by reference in Standard No. 108 do set forth certain photometric requirements which must be met.

In answer to your second question, Table III of Standard No. 108 requires tail lamps to be red, but permits stop lamps and rear turn signals to be either red or amber. A proposal has been issued however (35 F.R. 106) that stop lamps be red only on passenger cars manufactured on or after January 1, 1971.

You have asked in your third question whether headlamps may be placed in the grill. The answer to this is yes, provided that this location meets the lateral spacing and height above road surface requirements of Table IV of Standard No. 108. Also, headlamps must not be covered by a grille or plastic shield when in use.

Standard No. 107 does not specify a particular color for the horn ring and hub of the steering assembly but it does specify a maximum permissible value for specular glass.

Finally, other than Standard Nos. 205 (Glazing Materials) and 212 (Windshield Mounting) which all passenger cars must meet, there is no "specific safety requirement as to the windshield" for convertibles, and there is no "requirement as to a roll bar".

Sincerely,

Enclosures April 16, 1970

U.S. Department of Transportation Federal Highway Administration

Re: F.H.W.A. Temporary Exemption

No. 69-9 issued to Automobile

Monteverdi Ltd.

September 9, 1969 expiring

August 1, 1971

Gentlemen:

I represent Automobile Monteverdi Ltd. of Switzerland. In furtherance of my letter of April 9, 1970 requesting certain information as to the above, will you inform me as to the following:

1-a)Is there a safety standard requirement with regard to lights on the side of the automobile (front and/or back); if so, is it a requirement for a light or may it be a reflector?

b) Whether it is a requirement for a light or a reflector, is there a requirement as to its size or shape?

2. With regard to rear lights, brake, safety stop and blinker; is there a specific requirement as to the color of such lights, may they be red or orange etc?

3. With regard to headlights, may the manufacturer place headlights in the grill on a two seater model and a convertible model?

4. With regard to the steering wheel is there a specific requirement that the cross bar of a steering wheel be a particular color e.g. black or grey? I know that it may not be chromed.

5. With regard to a convertible model, is there a specific safety requirement as to the windshield, and is there any requirement as to a roll bar?

I would appreciate hearing from you.

Very truly yours,

David Sugarman

ID: nht70-1.10

DATE: 05/22/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Micro Machinery Products

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your comments and suggestions contained in your April 23, 1970, letter to Mr. Douglas Toms concerning motor vehicle Safety.

In your letter, you ask that the Bureau clarify whether a dealer who sells "Micro-siped" tires that do not comply with Standard No. 109 would be subject to a civil penalty. Section 108(a) of the National Trafic and Motor Vehicle Safety Act of 1966 (15 U.S.C.et seq.) prohibits any person from manufacturing for sale, selling or offering for sale any item of motor vehicle equipment unless it is in conformity with Federal Motor Vehicle Safety Standards. The prohibitions specified in the Act, do not apply after the first purchase in good faith for purposes other than resale (108(b)(1)). Therefore, if a dealer offers for sale or sells new tires that have been micro-siped and those tires do not comply with Standard No. 109 he would be subject to a civil penalty of up to $ 1,000 for each tire that did not comply. This penalty provision would not be applicable, however, if the tires to be micro-siped are owned by the user of the tires.

It is noted for your information that section 569.7(c) of the Regrooved Tire Regulation (formerly 369.7(c), copy enclosed) prohibits the sale, offer for sale, or introduction in interstate commerce "siped tires produced by cutting the tread surface of a regrooved or regroovable tire without removing rubber, if the tire cord material is damaged as a result of the siping process, or if the tire is siped deeper than the original, retread, or regrooved groove depth."

Your interest in the motor vehicle safety program is greatly appreciated.