NHTSA's Interpretation Files Search

ID: aiam2470

Dear Mr. Hollis: This responds to Carlisle Tire and Rubber Company's May 7, 1976 request for assurance that certain of its tires are in Compliance with Standard No. 119, *New Pneumatic Tires for Vehicles Other Than Passenger Cars*, and your request for a meeting on the issue of reduced performance requirements for tires used on motor0driven cycles with a maximum speed capability of 30 mph or less. I regret that we have not responded sooner.; The National traffic and Motor Vehicle Safety Act (the Act) (15 U.S.C S1391, *et seq.*) does not permit the assurance of compliance with Standard No. 119 that you request. The act requires 'self-certification' by the manufacturer that each of its products actually complies with all applicable standards (15 U.S.C. SS1397(a)(1)(A), 1403). The NHTSA does not issue 'approvals' for this reason.; With regard to your request for a meeting on the subject of performanc standards for tires used on low-speed motor-driven cycles, I would like to advise you that the NHTSA has decided to reduce some of the performance requirements for these tires. If you believe that a meeting would be desirable before we have issued a specific proposal, please contact Mr. Elwood Driver at the above address (tel. (202) 426-1740) to meet on the technical aspects of this issue.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: nht75-2.13

DATE: 06/04/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: Volvo of America

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of March 24, 1975, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 110, Tire Selection and Rims -- Passenger Cars.

You have inquired whether the placard required by S4.3 of the standard may display information in addition to the items specified in S4.3(a) through (d). The NHTSA has no objection to such placarding, provided that the additional information is set apart from, not placed among, the required items.

ID: nht72-3.3

DATE: 02/04/72

FROM: CHARLES A. BAKER FOR E.T. DRIVER -- NHTSA

TO: Enterprise Sky Park

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 20, 1972, regarding standards for retreaded automobile and truck tires.

Federal motor vehicle safety standards do not apply to aircraft or aircraft equipment.

Standard No. 117 entitled "Retreaded Pneumatic Tires - Passenger Cars," does not apply to the retreading of aircraft tires and does not supersede Advisory Circular 43.13-1. A copy of the standard is enclosed.

We do not have a safety standard for retreaded truck tires at this time.

ID: 2791o

Ms. C. Dianne Black
Engineering Manager
Jaguar Cars, Inc.
600 Willow Tree Road
Leonia, NJ 07605

Dear Ms. Black:

Thank you for your letter of April l4, l988, providing further information about the Jaguar headlamp levelling system discussed in your letters of June and October l987 to which I responded on February 1, 1988.

We support your efforts to call the driver's attention to the fact that the system does not automatically return to the "zero" position from either of the two adjustment positions when those loading conditions no longer exist.

Sincerely,

Erika Z. Jones Chief Counsel

ref:l08 d:8/l/88

ID: nht67-1.8

DATE: 09/21/67

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

TO: Kurzman & Goldfarb

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 29 requesting a verification of the interpretation of Standard No. 205 contained in a letter to you dated August 10 from Max Brand of Mercedes-Benz of North America.

Mr. Brands's understanding that glazing materials manufactured on or after January 1, 1968, for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses must conform to Standard No. 205, but that dealer inventories of prestandard materials manufactured before January 1, 1968, may be used for replacement purposes until exhausted is correct.

ID: nht88-2.80

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: C. DIANNE BLACK -- ENGINEERING MANAGER, JAGUAR CARS, INC.

TITLE: NONE

ATTACHMT: MEMO DATED 4-14-88, TO ERIKA Z. JONES, FROM C. DIANNE BLACK -- JAGUAR, REF: FMVSS 108, HEADLAMP LEVELLING SYSTEM

TEXT: Thank you for your letter of April 14, 1988, providing further information about the Jaguar headlamp levelling system discussed in your letters of June and October 1987 to which I responded on February 1, 1988.

We support your efforts to call the driver's attention to the fact that the system does not automatically return to the "zero" position from either of the two adjustment positions when those loading conditions no longer exist.

ID: nht71-4.50

DATE: 11/17/71

FROM: AUTHOR UNAVAILABLE; J. W. Carson for E. T. Driver; NHTSA

TO: Halfpenny, Hahn & Roche

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of October 18, 1971, and November 1, 1971, to Mr. Douglas Toms, Administrator, National Highway Traffic Safety Administration, concerning the "Panic-Stop" signal system from Donel Corporation.

You are correct in your interpretation that Federal Motor Vehicle Safety Standard No. 108 is not applicable to the "Panic-Stop" system when this system is not installed on motor vehicles as original equipment. The motor vehicle laws and regulations of the individual States, are, however, applicable to the "Panic-Stop" system when sold and used as aftermarket equipment.

ID: aiam3288

Dear Mr. Boyd: This responds to your recent letter requesting confirmation that larg commercial truck tractors do not have to comply with Federal Motor Vehicle Safety Standard No. 216, *Roof Crush Resistance*. You also asked whether large trucks should be designed to comply with the 'belt system' option under Safety Standard No. 208, *Occupant Crash Protection*.; You are correct in your assumption that large commercial trucks woul not have to comply with Safety Standard No. 216 since that standard only applies to passenger cars. You are also correct in stating that trucks with a GVWR greater than 10,000 pounds may meet the seat belt option of Safety Standard No. 208 found in paragraph S4.3.2. Under S4.3.1, manufacturers do have the option of meeting the crash protection requirements of S5 by means that require no action by vehicle occupants (with current technology this means air cushion restraints or automatic seat belts). Further, vehicles manufactured prior to August 15, 1977, were permitted to comply with Safety Standard No. 216 in lieu of the 'roll-over' requirements of Standard No. 208, and for large trucks this would have been a simple test to meet. However, since the vehicle would also have been required to meet the 'frontal' and 'lateral' requirements by automatic means if option S4.3.1 were taken, no truck manufacturers chose to comply with the 'rollover' requirements of Standard No. 208 via the Standard No. 216 option. Rather, seat belts were installed on all large trucks.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0365

Dear Mr. Holland: This is in reply to your letter of May 28, 1971, concerning the markin requirements in the proposed amendment to Standard No. 205, 'Glazing Materials' (Docket No. 71-1, Notice 1). These requirements are only proposed at present, as is their effective date, and do not represent the agency's final decision on the matter. If the agency determines to amend the standard, and before any compliance with new requirements is required, a 'final rule' will be issued that is based on the proposed rule but may differ in some respects from it. The final rule will specify an effective date for these new requirements which, in this instance, will probably be later than the effective date proposed.; You ask whether the effective date of the proposed standard would appl to the manufacture of the glazing, or to the fitting of the material into the vehicle. Standard No. 205 applies to 'glazing materials for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses', and the effective date of any amendment to this standard refers to the date of manufacture of the glazing material, and not to its fitting into the vehicle.; Your second question, whether we will accept your marking without hyphen between the 'DOT' symbol and your code mark, has been answered in our letter to you of May 26, 1971.; I hope this clarifies the situation. Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: aiam2544

Dear Mr. Link: This responds to your February 23, 1977, letter asking whether thre proposed labels satisfy the requirements for label identification found in Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; The National Highway Traffic Safety Administration (NHTSA) does no issue advance approval of compliance by manufacturers with motor vehicle safety standards or regulations. The agency, however, will give an informal opinion as to whether your sample labels appear to comply with the requirements of Standard No. 120. A review of the labels you supplied indicates that you have used a different format than illustrated in our notice of February 7, 1977 (42 Federal Register 7140). For example, the amended Standard No. 120 does not require the words 'with the tires listed below' or even the word 'with' before the tire size. The deletion of such superfluous words from the label requirements of Standard No. 120 resulted from comments by manufacturers, particularly motorcycle manufacturers, that unnecessary words needlessly increase the size of the label.; The example of label information shown in S5.3 of the standard i intended only as a guide to manufacturers. A manufacturer can vary the illustrated format somewhat as long as the requirements of S5.3 are satisfied. Since the additional words on your labels do not obfuscate the certification statement, the labels appear to comply with the requirements of Standard No. 120 and Part 567.; Sincerely, Frank Berndt, Acting Chief Counsel