ID: nht72-1.48

DATE: 03/10/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Irvin Industries Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 23, 1972, in which you list information you wish to label on child seats you will manufacture, and ask whether the information as presented will comply with Motor Vehicle Safety Standard No. 213. You state that a label containing the model number, date of manufacture, and the company's name and place of business will be permanently affixed to the product, while a separate legend, containing other information, will be molded on the bottom of the seat in raised letters at least 3/32 inches high.

The labeling scheme you wish to use would conform to paragraph S4.1 ("Labeling") of Standard No. 213, providing, of course, the blank spaces for model number and date of manufacture are appropriately filled in. We would suggest, however, that that part of the molded legend beginning" . . . and there is a minimum of 19 inches vertical clearance between this seating . . .", to the end of that provision be simplified to be more understandable to an ordinary consumer.

WE ARE PLEASED TO BE OF ASSISTANCE.

ID: nht72-5.29

DATE: 08/21/72

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of July 5, 1972, requesting an opinion as to how manufacturers may take into account a vehicle's speed capability in establishing GAWR.

The Certification regulations do not specify particular speed criteria for establishing weight ratings. As a minimum, however, we believe the speed chosen should reflect the maximum speed at which it is reasonable to expect the vehicle to be driven. In the case where a vehicle is subject to some low-speed uses, such as seasonal use as a snow plow, we believe the figure on the certification label should be based on that use of the vehicle in which its expected speed is greatest. The regulations do not provide for variable ratings based on speed.

Finally, you ask whether cautionary labels dealing with GAWR and GVWR figures may be installed in the cab. The NHTSA does not object to the use of such labels. They may be used, as appropriate, to indicate permissable use of higher loads in low-speed applications.

ID: nht90-1.99

TYPE: Interpretation-NHTSA

DATE: April 5, 1990

FROM: Richard E. Portors -- Vice President and General Manager, Royale Limousine Manufacturers

TO: Zachary R. Fraser -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-30-90 from P.J. Rice to R.E. Portors (A36; Std. 108)

TEXT:

Please give me an advisory on my understanding of requirement 571.108 - S4.1.1.41 high mounted stop lamps section (a) projected area of not less than 4 1/2 square inches.

The 90 Cadillac stop lamps measure 6 sq. inches of area. When installing a boomerang TV antenna the shaft area displaces 1.125 sq. inch of area, this would leave an exposed area of 4 7/8" of light and would exceed the minimum requirements of section (a) . Also, section (b) would not be affected by the boomerang. Without window glazing, section (c) would not be affected either. I feel the boomerang antenna positioned properly would not affect the requirements of 571.108.

Please advise me on your findings as soon as possible.

Attached is a copy of the Federal Register, section 571.108, 49 CFR Ch. V (10-1-85- Edition), page 218 (text omitted)

ID: nht92-4.48

DATE: August 6, 1992

FROM: R.J. Misorski -- Director, Maintenance & Repair, Maersk Inc.

TO: Legal Council, NHTSA

COPYEE: A. Petrizzo, W. Drozd

TITLE: None

ATTACHMT: Attached to letter dated 8/21/92 from Paul J. Rice to R.J. Misorski (A39; Std. 108)

TEXT:

Attached is a copy of the Federal Register outlining your rule change that went into effect December 1, 1991.

The new rule now requires a minimum of 12 square inches of lens area for rear stop or turn signals on vehicles over 80" wide, regardless of the separation between lamps. We feel that equipment manufactured prior to December 1991 would be exempt from this ruling. Our interpretation of this new rule is that it only applies to equipment that is manufactured after December 1, 1991.

We would highly appreciate if you could confirm our understanding in writing in order that we may ensure compliance with our equipment fleet.

Attachment

Copy of page 20158 of the 5/15/90 Federal Register pertaining to 49 CFR Part 571, Federal Motor Vehicle Safety Standards; Lamps, Reflective Devices, and Associated Equipment (action: final rule). (Text omitted)

ID: nht88-4.22

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/88 EST

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: M. IWASE -- TECHNICAL ADMINISTRATION DEPT. - KOITO MFG. CO. LTD.

TITLE: NONE

TEXT: This is to provide you with a clarification of my letter to you dated March 16, 1988. Your second question was whether the minimum edge to edge separation distance between turn signal lamps and tail/stop lamps is required on a rear lighting array for mo torcycles. I responded that "The answer is yes, and the separation distance you have depicted in your drawings appears to comply with this requirement."

In actuality, the agency has required this separation only where a single motorcycle stoplamp/taillamp is mounted on the vertical centerline, and not when dual lamps are mounted on either side of the vertical centerline, the configuration depicted in you r letter of January 25, 1988. Therefore, I am advising you that there is no legal requirement that the 4-inch separation distance be maintained in the configurations you depicted, and that we appreciate your continuing efforts to understand and comply w ith Federal Motor Vehicle Safety Standard No. 108.

I enclose a copy of a letter from this Office dated November 21, 1984, which explains our views on motorcycle rear lighting configurations in more detail.

Enclosure

ID: nht76-2.50

DATE: 02/09/76

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Gillig Brothers School Bus Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your request for information concerning methods of ensuring the compliance of school buses with the barrier crash test requirements of Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity.

Standard No. 301-75, while establishing minimum performance levels, does not specify any particular design requirements for school bus fuel systems. A manufacturer is free to design his vehicles in the manner that he believes most appropriate to ensure compliance. To this end, you may find helpful information in a study by Dynamic Science entitled School Bus Safety Improvement Program. The NHTSA cannot assure you, however, that following the suggestions contained in the study will guarantee that your school buses will comply with the standard.

The study is filed in the NHTSA's public docket as document number 75-03-GR1. Copies may be obtained by writing to:

Technical Reference Branch National Highway Traffic Safety Administration Room 5108 400 Seventh Street, S.W. Washington, D.C. 20590

You should refer to the following publication numbers: HS 801-615, -616, and -617.

ID: 9792

Eric T. Stewart, Engineering Manager
Mid Bus
3555 St. Johns Road
P.O. Box 1985
Lima, OH 45802-1985

Dear Mr. Stewart:

This responds to your letter of March 17, 1994, regarding a final rule published November 2, 1992 (57 FR 49413) amending Standard No. 217, Bus Emergency Exits and Window Retention and Release. You requested clarification of the width requirement in S5.5.3(c) for retroreflective tape.

You are correct that there was a discrepancy concerning the size of the tape caused by the metric conversion in the final rule. Enclosed is a copy of a July 7, 1993 letter to Mr. Thomas D. Turner of the Blue Bird Body Company which discusses this issue. As explained in that letter, we plan to issue a correction notice of the November 2, 1992 rule that would specify a minimum size of 2.5 cm for the tape. Until the correction is issued, we will not take enforcement measures regarding tape size against a manufacturer who uses 1 inch wide retroreflective tape.

I hope you find this information helpful. If you have any other questions, please contact us at this address or by phone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

Enclosure

ref:217 d:4/l/94

ID: nht81-1.13

DATE: 02/11/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Toyoda Gosei Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Katsuhiko Yokoi Assistant Manager - Tech. Dept. Toyoda Gosei Co., Ltd. 1, Nagahata, Ochiai, Haruhi-mura Nishikasugai-gun Aichi-pref., 452 JAPAN

Dear Mr. Yokoi:

The answers to the questions in your letter of January 20, 1982, are "yes" to both questions.

1. The "adjacent layers" referenced in Federal Motor Vehicle Safety Standard (FMVSS) No. 106, paragraphs S7.3.7, are (a) the inner tube and braided layer and (b) the braided layer and outer tube.

2. The adhesion requirements are met if both the tensile strengths measured between (a) the inner tube and braided layer and (b) that between the braided layer and the outer cover are equal to or greater than 8 lbs/inch as determined using the FMVSS No. 106 procedure. It should be noted that the 8 lbs/inch value is an absolute minimum value as indicated in paragraph S8.6.4(a) standard.

A copy of FMVSS No. 106 is included for your information.

Sincerely,

Vernon G. Bloom Safety Standards Engineer

Enclosure FMVSS No. 106

ID: nht80-1.14

DATE: 02/08/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: American Honda Motor Co. Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 18, 1979, requesting an interpretation as to whether the VIN plate samples you enclosed with your letter comply with the requirements of Standard No. 115, Vehicle identification number.

You enclosed two proposed VIN plates in your letter, one for automobiles and one for motorcycles. The VIN plates themselves and the preprinted lettering which appears on them seem to conform to the requirement of Standard No. 115. The lettering is clear and indelible, as required by S4.3, in that it cannot be removed without damage to the surface on which it is printed. Further, the plate when riveted to the vehicle would be considered to be permanently affixed in that it cannot be removed without damage (S4.3). The type face utilized for the lettering consists of capital, cans characters with a minimum height of 4 mm as required by S4.3.1.

The letters stamped on the automobile VIN plate, "SL5322AS000001", can hardly be seen, and would not appear to meet the requirements of S4.3 and S4.4.

ID: nht94-3.9

TYPE: INTERPRETATION-NHTSA

DATE: May 27, 1994

FROM: Keith E. Smith -- Piper & Marbury

TO: John G. Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attachment dated 8/18/94: Letter from John Womack to Keith E. Smith (VSA 102(4))

TEXT: As I discussed yesterday with Ken Weinstein of your office, by this letter I seek a declaratory statement, in the form of a letter from the National Highway Transportation Safety Administration ("NHTSA"), that automotive and/or motorcycle braking systems are considered by NHTSA to be "safety devices". I do not desire, nor do I expect NHTSA to make any declaration regarding the safety of a particular braking system.

It is my understanding that the primary purpose of the National Highway Transportation Safety Act (the "Act") is to promote public safety by establishing motor vehicle safety standards. Such standards, as provided in the regulations promulgated under the Act at 49 CFR @@ 571.105 and 571.122, provide minimum safety guidelines by which braking systems are evaluated. Therefore, by implication, it would seem that automotive and/or mortorcycle braking systems must be considered by NHTSA to be "safety de vices".

If the above representations are correct, I would appreciate a letter confirming so. If you should have any questions regarding this matter, please do not hesitate to contact me.