NHTSA's Interpretation Files Search

Displaying 2171 - 2180 of 2915

Interpretations	Date

ID: aiam1081 Open Mr. T. Hiramine, Director, Takata Kojyo Co., Ltd., No. 10 Mori Building, 28 Sakuragawa-Cho, Nishikubo, Shiba, Minato-Ku, Tokyo, Japan; Mr. T. Hiramine Director Takata Kojyo Co. Ltd. No. 10 Mori Building 28 Sakuragawa-Cho Nishikubo Shiba Minato-Ku Tokyo Japan; Dear Mr. Hiramine: Thank you for your letter of February 24, 1973, to Mr. Franci Armstrong, requesting various interpretations of Standards No. 208 and No. 209, with respect to safety belt systems.; Your first question, referenced to Figure No. 1 of the enclosure wit your letter, relates to the required strength of the webbing in the case where two widths are connected together in an upper torso assembly. Under the webbing strength requirements of S4.2(b) of Standard N0. 209, both pieces of webbing in the upper torso restraint must, individually, meet a 4,000 pound strength test. Under the assembly performance requirements of S5.3(b) of Standard NO. 209, a common pelvic and upper torso restraint must meet a 3,000 pound strength test. The latter would be true regardless of whether sewing or other means is used to make the belt assembly.; Your second question, referenced to Figure 2 of the enclosure, relate to the bolt strength required in the belt assembly anchorage. Under the provisions of S4.1(f), equivalent hardware' is permissible in lieu of the 7/16 inch bolts. In such a case, the tests required under S4.3(c), as prescribed under S5.2(c), would be performed on the entire equivalent hardware, rather than on the individual components (bolts).; With respect to your third question, concerning the acceptability o belts that do not conform to the elongation requirements of Standard No. 209, our reply is that under the present circumstances such webbing would not conform to either Standard No. 208 or Standard No. 209. As a result of the decision by the United States Court of Appeals for the Sixth Circuit in Ford v. NHTSA, belts installed under Standard No. 208's third option in 1973 (S4.1.2.3) will have to conform to Standard No. 209. Unless Standard No. 209 is amended with respect to its elongation requirements, therefore, energy absorbing webbing of the type you describe will not be permitted in 1974 cars.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1843 Open Honorable Herman E. Talmadge, United States Senate, Washington, DC 20510; Honorable Herman E. Talmadge United States Senate Washington DC 20510; Dear Senator Talmadge: This is in response to your letter requesting information concernin correspondence from Mr. James A. Graham, commenting on a proposed amendment to the Federal bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a Federal Register notice (copy enclosed) proposing to reduce the current 5-mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5-mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published March 12, 1975, which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; In his letter Mr. Graham objects to the standard's regulation o surface damage, such as dents, stating that this is not the type of damage which should be addressed by an agency developing safety standards. The surface damage criteria are proposed as part of a standard being promulgated under Title I of the Motor Vehicle Information and Cost Savings Act (Pub. L. 92-513). The Cost Savings Act directs the National Highway Traffic Safety Administration to develop a bumper standard that will obtain the maximum feasible reduction of costs to the public and the consumer. As such, the standard is not to be limited to affecting safety- related damage. Factors such as insurance costs and consumer time and inconvenience are to be considered in the rulemaking as well.; Mr. Graham's comments will be placed in the public docket where the will receive every consideration.; We appreciate your interest and that of Mr. Graham in this area o motor vehicle safety and performance.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam1842 Open Honorable Les AuCoin, House of Representatives, Washington, DC 20515; Honorable Les AuCoin House of Representatives Washington DC 20515; Dear Mr. AuCoin: This is in response to your letter of March 11, 1975, forwarding comment from one of your constituents, Mr. Keith A. Burbidge, on the proposed weakening of the bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a Federal Register notice (copy enclosed) proposing to reduce the current 5 mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would then have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published March 12, 1975 which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Mr. Burbidge appears to be directing his comments to what he believe to be a proposed requirement that vehicles manufactured in the future be equipped with plastic bumper systems. Such an understanding of the proposal is incorrect. The January 2, 1975 proposal was aimed at enabling a reduction in vehicle weight. In the preamble to that notice, the NHTSA cited soft face bumpers as one type of system that could produce a significant weight reduction. However, no proposal was made to require the use of soft face systems. The March 12, 1975 notice reiterates the agency's position that bumpers which are lighter in weight than those currently in mass production could and probably would be developed. The requirements proposed in the March notice, however, ensure that a wide variety of materials could continue to be used in bumper systems.; We have placed Mr. Burbidge's letter in the appropriate docket. Sincerely, James C. Schultz, Chief Counsel
ID: aiam2812 Open Mr. Doug Mills, Rt. 1 Box 149, Tellico Plains, TN 37385; Mr. Doug Mills Rt. 1 Box 149 Tellico Plains TN 37385; Dear Mr. Mills: This responds to your recent letter asking additional question concerning the responsibilities of a person converting a pick-up truck into a dump truck, under Federal motor vehicle safety standards and regulations. This office explained the general responsibilities of a person who alters a certified vehicle in a letter to your associate, Mr. Henry Brown, dated February 1, 1978. You now ask questions regarding specific aspects of the conversion operating and whether they can be accomplished without destroying a vehicle's compliance with safety regulations.; Unfortunately, it is impossible for the National Highway Traffic Safet Administration (NHTSA) to answer your specific questions. It is the responsibility of the manufacturer or vehicle alterer to determine whether his vehicle is in compliance with applicable safety standards and to certify that vehicle. The NHTSA cannot review an alteration procedure such as the one with which you are concerned and state that it can or cannot be done in compliance with Federal regulations. There are no safety regulations which require a specific number of bolts or specific bolt locations, for instance. Likewise, Safety Standard No. 301-75, Fuel System Integrity, is specified only in terms of performance requirements, so the NHTSA cannot tell you whether a modified fuel filler neck will destroy a vehicle's compliance with the standard.; As stated in our previous letter, a person who alters a pick-up truc to convert it to a dump truck must certify that the truck remains in compliance with all applicable safety standards. Further, the person who makes the conversion must assure that the alterations do not result in any 'safety related defects' whether or not there is a specific safety standard that is applicable. Therefore, you must determine for yourself whether the number of bolts you use, the bolt strengths and the bolt locations will result in safety hazards.; I can answer your question number 8 regarding possible liability fo removal and alteration of the truck bumper. The Federal safety standard for bumpers is only applicable to passenger cars, so you may alter a truck bumper with impunity provided the action does not result in a safety related defect.; Sincerely, Joseph J. Levin, Jr., Chief Counsel
ID: aiam3829 Open Mr. Joel S. Premack, Research and Development Laboratories, U.S. Postal Service, Rockville, MD 20852-8101; Mr. Joel S. Premack Research and Development Laboratories U.S. Postal Service Rockville MD 20852-8101; Dear Mr. Premack: This responds to your March 7, 1984 letter to Roger Fairchild of thi office regarding Federal Motor Vehicle Safety Standard (FMVSS) 111, Rearview Mirrors. In particular, you asked whether the covering of the rear and rear-side windows on Postal Service Vehicles would be consistent with the requirements of FMVSS 111.; FMVSS 111 (copy enclosed) establishes requirements regarding rearvie mirror systems on new motor vehicles. New Postal Service vehicles would be required to employ one of three optional mirror systems. The first system is a system permitted for use on passenger cars, and includes an inside rearview mirror with a specified field of view and a plane, driver's side exterior mirror also having a specified field of view. The second permissible system is also a passenger car system and is identical to the first system, except that the inside mirror need not provide the specified field of view and an additional passenger side plane or convex rearview mirror must be provided to compensate for the more restricted field of view of the inside mirror. The third system has two plane mirrors of 19.5 square inches reflective surface area each, one mounted on each side of the vehicle.; Based on the materials you provided with your letter, it appears tha Postal Service DJ-5G Models employ the second system described above. In that case, further reduction of the field of view of the inside rearview mirror would not affect compliance with our standard, since an additional passenger side mirror is provided.; If the proposed covering of the rear windows is to be accomplished as modification to vehicles already delivered to the Postal Service, these modifications may not be subject to FMVSS 111 at all. Modifications to vehicles must be consistent with safety standards only to the extent those modification are performed by a vehicle manufacturer, distributor, dealer, or private motor vehicle repair business which knowingly renders inoperative safety equipment installed on the vehicle. See 15 U.S.C. 1397(a)(2)(A). Thus, if the window covering is done by the Postal Service itself, FMVSS requirements are not applicable.; If you have any further questions on this matter, please feel free t contact us.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam2218 Open Georgette A. Sears, Route 2, Box 133c, Keymar, Maryland 21757; Georgette A. Sears Route 2 Box 133c Keymar Maryland 21757; Dear Ms. Sears: This is in response to your letter of January 6, 1976, requestin information as to the Federal Standards and regulations that are applicable to the manufacture of an '18 inch pull type horse/stock trailer combination.'; Manufacturers of trailers of the type you describe must certify tha their product is in compliance with Federal Motor Vehicle Safety Standard No. 108, Lamps, reflective Devices, and Associated Equipment, 49 CFR 571.108, and Standard No. 120, *Tire Selections and Rims for Vehicles Other Than Passenger Cars, 40 CFR 571.120. Please note, however, that Standard No. 120 is not effective until August 1, 1976, for the rim marking requirements (S5.2), and September 1, 1976, for the remaining requirements, so trailers manufactured before these times will not have to be certified as being in compliance with Standard No. 120.; The procedure for certification is specified in 49 CFR Part 567, an requires the manufacturer to affix a label to his product certifying that it is in compliance with the requirements of applicable Federal regulations. You should check the trailer that you purchase to make certain there is a certification label. Part 567.4(d) specifies that the certification label for trailers shall be affixed to a location on the forward half of the left side, such that it is easily readable from outside the vehicle without moving any part of the vehicle.; There are no Federal regulations concerning the connection of trailer to trucks or other vehicles. Nevertheless, from a safety stand point it is important that you ascertain the hauling capacity of your truck-trailer system in order to avoid overloading that could create potential safety hazards. You should obtain information from the manufacturer concerning the 'tongue weight' of the trailer when fully loaded, and relate it to the gross axle wight ratings of your towing vehicle, found on its certification label on the door or door post. The trailer manufacturer may also have further recommendations as to the capacity of the vehicle needed to tow one of his trailers safely.; Please contact us if we can be(sic) of any further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam3184 Open Mr. Jeffrey Libman, President, Edison Rubber Company, P.O. Box 254, Edison, New Jersey 08817; Mr. Jeffrey Libman President Edison Rubber Company P.O. Box 254 Edison New Jersey 08817; Dear Mr. Libman: This responds to your letter of November 9, 19799, inquiring if it i permissible for you suppliers to cut off the DOT serial numbers on used tires before selling those tires to your company. You stated in your letter that your company buys used tires from several companies. These tires generally either have cuts in the tread or sidewalls or are out of round. Your company then resells the tires to another company, which resells the tires to the public.; The answer to your question is no. The presence of the DO identification number on tires is required by several of this agency's regulations. Our tire identification and record keeping regulation (49 CFR Part 574) requires that each manufacturer place the DOT number on at least one sidewall of each tire that it manufactures. The number serves several purposes. It is indispensable in aiding consumers to identify tires subject to a recall campaign for safety defects and noncompliances with the safety standards. It also aids this agency in enforcing its tire safety standards. Federal Motor Vehicle Safety Standards 109 (Passenger car tires, 49 CFR 571.109) and 119 (Tires for vehicles other than passenger cars, 49 CFR 571.119) require that each tire manufacturer certify that its tires conform to all applicable Federal Safety standards by branding or molding the DOT number on the tire.; Section 108(a) (2) (A) of National Traffic and Motor Vehicle SAfety Ac of 1966, as amended (15 U.S.C. 1397(a) (2) (A)), states that, 'No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on...an item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard...' By removing the DOT identification number from a tire, the person would be knowingly rendering inoperative an element of design on the tire which is included on the tire for compliance with the requirements of a Federal motor vehicle safety standard. Section 109 of the Act (15 U.S.C. 1398) specifies a penalty of up to $1,000 for each violation of section 108.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam2449 Open Mr. Byron Crampton, Truck Body and Equipment Association, 5530 Wisconsin Ave., Suite 1220, Washington, DC 20015; Mr. Byron Crampton Truck Body and Equipment Association 5530 Wisconsin Ave. Suite 1220 Washington DC 20015; Dear Mr. Crampton: This responds to the Truck Body and Equipment Association's November 8 1976, question whether any provision of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other than Passenger Cars, prohibits the certification of a vehicle following the addition of an axle system (typically known as a 'tag' or 'pusher' axle) that is not equipped with tires or rims at the time of sale and delivery to the first purchaser for purposes other than resale.; The answer to your question is no. The requirement of S5.1.1 that '. . each vehicle equipped with pneumatic tires for highway service shall be equipped with tires that meet specified requirements . . . ' prohibits the installation of tires that do not meet certain performance requirements, but it is not a requirement that tires be fitted to every axle of a vehicle prior to certification and sale.; I would like to point out that S 567.4(g)(4) of Part 567 Certification, requires that a gross axle weight rating be assigned to each axle system. Section S5.1.2 of Standard No. 120 specifies that the GAWR be not more than the sum of the maximum load ratings of the tires fitted to the axle in question. While the agency interprets Standard No. 120 to permit the assignment of a GAWR on the basis of tires listed on the certification plate for that GAWR, the assignment of an arbitrarily high (or low) GAWR for purposes such as avoiding a Federal motor vehicle safety standard (such as Standard No. 121, Air Brake Systems), would constitute a violation of S108(a)(1)(D) of the National Traffic and Motor Vehicle Safety Act:; >>>S108(a)(1) No person shall (A) . . . (c) (sic) Fail to issue a certificate required by section 114 of thi title, or issue a certificate to the effect that a motor vehicle or item of motor vehicle equipment conforms to all applicable Federal motor vehicle safety standards, if such person in the exercise of due care has reason to know that such certification is false or misleading in a material respect.<<<; Sincerely, Frank A. Berndt, Acting Chief Counsel
ID: aiam0233 Open Mr. Donald B. Haaversen, 2833 Harriet Avenue, South, Minneapolis, Minnesota 55408; Mr. Donald B. Haaversen 2833 Harriet Avenue South Minneapolis Minnesota 55408; Dear Mr. Haaversen: Thank you for your letter of March 9, 1970, to the National Highwa Safety Bureau, concerning our Federal motor vehicle tire standards.; The only tire standard promulgated to date is Federal Motor Vehicl Safety Standard No. 109, 'New Pneumatic Tires-Passenger Cars' which was effective January 1, 1968. This standard specifies minimum performance for size, strength, endurance, high speed laboratory testing and labeling. For your information, I have enclosed a copy of Standard No. 109 and No. 110 with amendments.; The replies to your specific questions are as follows: >>>1. Question: New American made tires have DOT load ranges, loa capacity and inflation pressures molded into the sidewall. Is this required (that they be permanently marked), or is it sufficient to affix a temporary marking (such as a sticker) with this same information?; Response: Section S4.3 states that this information shall b permanently molded into or onto all new passenger car tires manufactured after August 1, 1968. If the tire was manufactured between January 1, 1968 and July 31, 1968 the labeling requirements may be met by use of a label or tag.; 2. Question: How is load capacity information arrived at? Is it b manufacturer certification, government conducted tests, or some other method?; Response: The load/inflation schedule is calculated by use o empirical formulas and coordinated through the various Tire and Rim Associations as well as the Society of Automotive Engineers.; 3. Question: Is it necessary that these tires be subject to safet tests? These particular tires are already imported by another organization and may already have passed the necessary tests, if any.; Response: The application of the 'DOT' recital to a tire, is the tir manufacturers self certification that his tire conforms to all the minimum performance standards of Federal Motor Vehicle Safety Standard No. 109.<<<; I have also enclosed for your review and information the followin data:; >>>1. U.S. Customs Regulations for Importation of Motor Vehicles an Items of Motor Vehicle Equipment.; 2. Automobiles Imported Into the United States.<<< Sincerely, Rodolfo A. Diaz, Acting Associate Director, Motor Vehicl Programs;
ID: aiam1849 Open Mr. Robert Marx, State Representative, District No. 34, Polk-Benton, House of Representatives, Salem OR 97310; Mr. Robert Marx State Representative District No. 34 Polk-Benton House of Representatives Salem OR 97310; Dear Mr. Marx: This is in response to your letter of March 10, 1975, requestin information concerning correspondence from one of your constituents, Mr. Jim Lee Martin, commenting on a proposed amendment to the Federal Bumper Standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a Federal Register notice (copy enclosed) proposing to reduce the current 5 mph bumper impact requirements to 2.5 mph until the 1970 (sic) model year. The impact requirements would have been increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two ageny- sponsore (sic) studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a Federal Register notice that was published March 12, 1975, which is enclosed (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Mr. Martin has directed his comments to what he believes to be proposed requirement that vehicles manufactured in the future be equipped with plastic bumper systems. Such an understanding of the proposal is incorrect. The January 2, 1975 proposal was aimed at enabling a reduction in vehicle weight. In the preamble to that notice, the NHTSA cited soft face bumpers as one type of system that could produce a significant weight reduction. However, no proposal was made to require the use of soft face (plastic) systems. The March 12, 1975 notice reiterates the agency's position that bumpers which are lighter in weight than those currently in mass production could and probably would be developed. The requirements proposed in the March notice, however, ensure that a wide variety of materials could continue to be used in bumper systems.; Yours truly, Richard B. Dyson, Assistant Chief Counsel