ID: nht94-9.7

TYPE: Interpretation-NHTSA

DATE: January 10, 1994

FROM: Adam A. Freund -- Manager, Testing Services, Standards Testing Laboratories, Inc.

TO: Walter Myers -- Office of Chief Counsel, NHTSA

TITLE: Table II Minimum Static; Breaking Energy (inch pounds) D.O.T. 119

ATTACHMT: Attached to letter dated 4/12/94 from John Womack to Adam A. Freund (A42; Std. 119)

TEXT:

Further to our telephone conversation of this date, please find enclosed a copy of subject matter for your perusal. As we had discussed I believe there is a typo in the highlighted columns marked respectively MOTORCYCLE and ALL 12 INCH OR SMALLER RIM SIZE. If I am correct the first column MOTORCYCLE should show a plunger diameter of 5/16" and the column marked ALL 12 INCH OR SMALLER RIM SIZE should show a plunger diameter of 3/4".

I would appreciate your qualifying my interpretation of above subject matter. If my interpretation is incorrect, please advise me how the respective columns should be marked.

Standards Testing Laboratories, Inc. would greatly appreciate any expedited consideration you may allow us on this request.

ATTACHMENT

(Table omitted.)

ID: nht94-4.53

TYPE: INTERPRETATION-NHTSA

DATE: October 14, 1994

FROM: Randal Busick -- President, Vehicle Science Corporation

TO: Mary Versailles, Esq. -- Office of the Chief Counsel, NHTSA

TITLE: Re: Request for interpretation of FMVSS 208 S7.1.2

ATTACHMT: Attached to 1/5/95 letter from Philip R. Recht to Randal Busick (A43; Std. 208; Std. 210)

TEXT: Dear Ms Versailles:

This is to request a clarification of FMVSS 208 S7.1.2. More specifically, would a seat belt system as shown on the attached drawing be in compliance with S7.1.2 as a so-called "semi-integrated" seat belt?

As shown on the drawing, the inboard lower FMVSS 210 anchorage, n1 is located on the seat frame and thus, as the seat moves fore and aft, the system allows a minimum of two seat belt adjustment positions and the distance between the two extreme adjustmen t positions of the system is more than 5 cm.

n1 The belt which holds the buckle is attached to this inboard anchorage.

We look forward to your response. If you have any questions, kindly contact the undersigned.

Sincerely

Enclosure

(Drawing omitted.)

ID: nht93-7.7

DATE: October 1, 1993 Est.

FROM: Bob Carver

TITLE: None

ATTACHMT: Attached to letter dated 11/22/93 from John Womack to Bob Carver (A41; Part 571; Std. 217)

TEXT:

I'm an engineer at Wayne Wheeled Vehicles, a commercial and school bus manufacturing company. My job here is to see ensure compliance to FMVSS 217, effective May 1994. I have a question for you in which I need an official ruling concerning FMVSS 217 S5.5.3(c):

Each opening for a required emergency exit shall be outlined around its outside perimeter with a minimum 3 centimeters wide retroreflective tape, either red, white, or yellow in color, that when tested under the conditions specified in S6.1 of 571.131 meets the criteria specified in Table 1.

If an emergency roof exit is required, is it necessary to outline it with the retroreflective tape even though it is not visible unless the bus is tilted on its side? Also, Charles Hott at NHTSA said that the width requirement will be revised to 1 inch. Can you confirm this?

Thanks in advance for your prompt consideration and assistance concerning this matter.

ID: nht94-1.16

TYPE: Interpretation-NHTSA

DATE: January 10, 1994

FROM: Adam A. Freund -- Manager, Testing Services, Standards Testing Laboratories, Inc.

TO: Walter Myers -- Office of Chief Counsel, NHTSA

TITLE: Table II Minimum Static; Breaking Energy (inch pounds) D.O.T. 119

ATTACHMT: Attached to letter dated 4/12/94 from John Womack to Adam A. Freund (A42; Std. 119)

TEXT:

Further to our telephone conversation of this date, please find enclosed a copy of subject matter for your perusal. As we had discussed I believe there is a typo in the highlighted columns marked respectively MOTORCYCLE and ALL 12 INCH OR SMALLER RIM SI ZE. If I am correct the first column MOTORCYCLE should show a plunger diameter of 5/16" and the column marked ALL 12 INCH OR SMALLER RIM SIZE should show a plunger diameter of 3/4".

I would appreciate your qualifying my interpretation of above subject matter. If my interpretation is incorrect, please advise me how the respective columns should be marked.

Standards Testing Laboratories, Inc. would greatly appreciate any expedited consideration you may allow us on this request.

ATTACHMENT

(Table omitted.)

ID: nht75-6.33

DATE: 07/10/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Cooney Equipment Company

TITLE: FMVSR INTERPRETATION

TEXT: Your letter of June 17, 1969, to Mr. Donald Morrison of the Bureau of Motor Carrier Safety, concerning switching arrangements for running lamps, has been transferred to this Office for consideration and reply.

Enclosed for your information is a copy of Federal Motor Vehicle Safety Standard No. 108 on lighting requirements for motor vehicles. This standard is applicable to new vehicles manufactured on or after the effective date of January 1, 1969. Special wiring requirements, such as lamp switching arrangements, are included in paragraphs S3.4 through S3.4.7 of the standard.

We do not completely understand your usage of the term "running lights." If you are referring only to tail lamps, your attention is invited specifically to paragraph S3.4.3 of the standard which is quoted as follows: "As a minimum the tail lamps shall be illuminated when the headlamps are illuminated except when the headlamps are being flashed." The switching arrangements for other "running lights," such as clearance lamps and identification lamps, are at the option of the vehicle manufacturer.

Thank you for writing.

ID: nht69-2.21

DATE: 06/05/69

FROM: H.A. HEFFRON -- CHIEF COUNSEL, NHTSA; CONCURRENCE OF TENNEY JOHNSON -- MVSPS

TO: G. M. Hilgendorf, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Frank Coy, Special Assistant to the Under Secretary of Transportation, has asked that I respond to your letter of April 16, 1969, in which you ask whether a station wagon purchased in March of 1968, equipped with two ply tires, violates Federal Motor Vehicle Safety Standard No. 109.

The vehicle you purchased was apparently manufactured prior to April 1, 1968, and therefore, it was not required to be equipped with tires conforming to Standard No. 109. However, even if the standards were applicable, because a tire is labeled "2-ply" it is not necessarily a non-conforming tire. Standard No. 109 does not specifically require tires to have a given number of plies. It does require that irrespective of any ply rating tires pass minimum performance tests. As to passenger cars, Standard No. 110 requires that passenger cars manufactured after April 1, 1968, (1) must be equipped with tires that comply with Standard No. 109; and (2) the vehicle must not place a load on any of the tires greater than the load capacity of the tire specified in Standard No. 109.

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: nht68-3.49

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: nht68-4.1

DATE: 08/15/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Toyota Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 23, 1968, to Mr. George C. Nield, Acting Director, Motor Vehicle Safety Performance Service, concerning the requirements for turn signal and hazard warning signal flashers as specified by Motor Vehicle Safety Standard No. 108.

With certain exceptions, paragraph S3.3 of Standard No. 108 permits the use of combination lamps, reflective devices and items of associated equipment, provided the requirements for each lamp, reflective device and item of associated equipment are met. Therefore, a combination turn signal and hazard warning signal flasher may be used, provided the requirements for each signal (turn and hazard warning) are met.

You are correct in your understanding that Standard No. 108 and basically referenced SAE Standards J590 and J945 do not require operation of the flasher unit with only one signal bulb in the test circuit. The standard test circuit shown in Figure I of SAE Standard J823 indicates a minimum of two signal lamps and one pilot indicator lamp as the lamp load.

Thank you for writing.

ID: nht72-1.33

DATE: 06/27/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Checker Motors Sales Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 25, 1972, asking whether you, as a selling dealer, may install steel-belted radial ply tires on an 8-passenger Checker taxicab. You state that the vehicle is normally delivered to you with tires having the "D" load range.

Federal Motor Vehicle Safety Standard No. 110 (49 CFR 571.110, copy enclosed) requires each passenger car to be equipped at the time of sale to a first purchaser with tires of certain minimum load carrying capacity, based on the weight of the vehicle. Any steel-belted radial ply tire that meets these load carrying requirements with respect to your vehicles may be installed by a selling dealer.

Radial tires of similar or related sizes, but of different manufacture, however, may have different load ratings. We suggest, therefore, that you contact Checker Motor Corporation for their recommendations as to which radial ply tires may be installed on these vehicles without adversely affecting the vehicle's conformity with Motor Vehicle Safety Standard No. 110.