NHTSA's Interpretation Files Search

ID: nht94-6.37

DATE: April 12, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Adam A. Freund -- Manager, Testing Services, Standards Testing Laboratories, Inc. (Massillon, OH)

TITLE: None

ATTACHMT: Attached to letter dated 1/10/94 from Adam A. Freund to Walter Myers (OCC 9556)

TEXT:

This responds to your letter addressed to the attention of Walter Myers of my staff in which you asked whether Table II of Federal Motor Vehicle Safety Standard (FMVSS) No. 119, New pneumatic tires for vehicles other than passenger cars, contains certain errors.

You pointed out in your letter that Table I of FMVSS 119 specifies a plunger diameter of 5/16 inch for motorcycles, and 3/4 inch for 12-inch or smaller rims other than motorcycles. Table II, on the other hand, leaves blank the plunger diameter space, in the motorcycle column, but lists 5/16 inch plunger diameter in the 12-inch or smaller rim column. You indicated your belief that the inconsistency is due to a typographical error in those columns of Table II and asked us to confirm your interpretation.

Your observation is correct. A November 13, 1973 rule adopting Tables I and II (38 FR 31299) (copy enclosed) specifies the 5/16-inch diameter plunger for motorcycle tires, and the 3/4-inch diameter plunger for 12-inch or smaller tires and 17.5- inch or smaller light truck tubeless tires. Accordingly, the plunger diameter for the motorcycle column in Table II should read 5/16. Similarly, the 12-inch or smaller column in the current Table II is in error in specifying a plunger diameter of 5/16 inch. The correct plunger diameter for that column in Table II should be 3/4 inch to correspond with the plunger diameter specified for 12-inch or smaller rims in Table I.

Thank you for bringing this error to our attention. The agency will issue a correction to avoid any further confusion.

ID: nht94-2.33

TYPE: Interpretation-NHTSA

DATE: April 12, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Adam A. Freund -- Manager, Testing Services, Standards Testing Laboratories, Inc. (Massillon, OH)

TITLE: None

ATTACHMT: Attached to letter dated 1/10/94 from Adam A. Freund to Walter Myers (OCC 9556)

TEXT:

This responds to your letter addressed to the attention of Walter Myers of my staff in which you asked whether Table II of Federal Motor Vehicle Safety Standard (FMVSS) No. 119, New pneumatic tires for vehicles other than passenger cars, contains certain errors.

You pointed out in your letter that Table I of FMVSS 119 specifies a plunger diameter of 5/16 inch for motorcycles, and 3/4 inch for 12-inch or smaller rims other than motorcycles. Table II, on the other hand, leaves blank the plunger diameter space, in the motorcycle column, but lists 5/16 inch plunger diameter in the 12-inch or smaller rim column. You indicated your belief that the inconsistency is due to a typographical error in those columns of Table II and asked us to confirm your interpretation.

Your observation is correct. A November 13, 1973 rule adopting Tables I and II (38 FR 31299) (copy enclosed) specifies the 5/16-inch diameter plunger for motorcycle tires, and the 3/4-inch diameter plunger for 12-inch or smaller tires and 17.5- inch or smaller light truck tubeless tires. Accordingly, the plunger diameter for the motorcycle column in Table II should read 5/16. Similarly, the 12-inch or smaller column in the current Table II is in error in specifying a plunger diameter of 5/16 inch. Th e correct plunger diameter for that column in Table II should be 3/4 inch to correspond with the plunger diameter specified for 12-inch or smaller rims in Table I.

Thank you for bringing this error to our attention. The agency will issue a correction to avoid any further confusion.

ID: nht91-7.1

DATE: November 7, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: William Engel -- Assistant Chief, Covington (Kentucky) Fire Department

TITLE: None

ATTACHMT: Attached to letter dated 8-13-80 from Frank Berndt to L. Steenbock; Also attached to letter dated 2-11-88 from Erika Z. Jones to Joanne Salvio (Std. 206); Also attached to letter dated 9-16-91 from William Engel to Paul Jackson Rice (OCC 6504)

TEXT:

This responds to your letter asking whether Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components, requires door locks on fire trucks. Safety Standard No. 206, which applies to all passenger cars, multipurpose passenger vehicles and trucks, does not exclude fire trucks. Thus, new fire trucks are covered by the standard's general requirement that "components on any side door leading directly into a compartment that contains one or more seating accommodations shall conform to this standard." (S S4)

Standard No. 206 does not apply, however, to certain types of doors which are often found on fire trucks. Since your letter did not provide any details about the design of the specific doors to which you refer, I am unable to determine whether any of the doors on those fire trucks would be subject to Standard No. 206's requirements. For your information, I have enclosed two letters from this office which discuss the applicability of Standard No. 206 to specific doors on fire trucks in more detail. The two letters are an August 13, 1980 letter to Mr. Steenbock and a February 11, 1988 letter to Ms. Salvio. The National Highway Traffic Safety Administration has not adopted any amendments to Standard No. 206 that affect the accuracy of the information contained in these letters. I have also enclosed a current copy of Standard No. 206.

I hope this information is helpful. Please contact Elizabeth Barbour of my staff at this address or by telephone at (202) 366-2992 if you have further questions.

ID: 9043

Mr. Tom DeLapp
Executive Coach Builders, Inc.
One Executive Blvd.
Springfield, MO 65802

Dear Mr. DeLapp:

This responds to your letter of August 18, 1993, concerning a modification you wish to make on limousines manufactured by your company. You wish to modify the hinge assembly controlling forward and reclining movement of the front seat to provide access to the area between the front of the privacy panel and the back of the front seat. (The area contains auxiliary fuse panels and relays.) The modification would involve removal of a metal pin in the hinge assembly, allowing the seat to articulate forward to a greater degree. You asked whether Standard No. 207, Seating Systems, prohibits the removal of a limiting pin or limits forward movement of a seat back.

Standard No. 207 specifies strength and other performance requirements for seats in passenger cars, multipurpose passenger vehicles, trucks, and buses. Section S4.3 of Standard No. 207 contains requirements for hinged or folding seat backs, except for passenger seats in buses or a seat adjustable only for its occupants. Section S4.3(a) requires a self-locking device for restraining the hinged or folding seat back. Section S4.3.2 contains performance requirements for this restraining device.

Section S4.3 does not limit the degree of movement of a hinged or folding seat back. Thus, you may remove the limiting pin if removing it only increases the degree of movement of the seat. However, the seat must still meet the requirements of S4.3 with the pin removed. Accordingly, the seat must have a self-locking device that can withstand the force applications specified in S4.3.2.1 and acceleration specified in S4.3.2.2.

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

Sincerely,

John Womack Acting Chief Counsel ref:207 d:10/25/93

ID: nht70-1.36

DATE: 01/22/70

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

TO: Pacer Performance Products

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 31, 1969 requesting information about the Federal Motor Vehicle Safety Standards and their applicability to wheels manufactured by Pacer. We have enclosed a copy of the April, 1969, edition of the Federal Motor Vehicle Safety Standards, along with amendments relevant to your inquiry.

You have requested information as to how you can comply with Standards No. 109 and 110. These Standards, as you will notice, are applicable to new passenger car tires add to wheels and tires mounted on new passenger cars, so that if a wheel manufactured by Pacer is placed on a passenger car before the car is sold to the first purchaser, the wheel and the tire must conform to the requirements of Standards No. 109 and 110. To comply the tire and rim must meet the performance requirements of Standard 109, and the rim must be able to retain a deflated tire during a stop from 60 miles per hour, as required by paragraph S4.4.1(b) of Standard No. 110. There are no other requirements applicable to wheels and rims as such.

The National Highway Safety Bureau issues no certificate of compliance, although it maintains surveillance over product safely through its own testing program. The Gregon manufacturer to whom you refer may have requested the Bureau's opinion as to whether a particular wheel design would violate Standard No. 211, a standard applicable to wheel nuts, wheel discs and hub caps as items of motor vehicle equipment which prohibits certain tyres of hazardous projections on wheels. In response to such requests, the Bureau has occasionally issued interpretations of Standard No. 211, but these are in no way equivalent to a certificate of compliance.

I trust this information will be helpful to you. Should you have additional questions, please advise us and we will try to provide further clarification.

ID: nht71-3.24

DATE: 07/02/71

FROM: E.T. DRIVER -- NHTSA; SIGNATURE BY JOHN CARSON

TO: Bandag Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 30, 1971, and to confirm opinions given by members of this office(Illegible Words) phone coversation with you.

Under the National Traffic and Motor Vehicle Safety Act and regulations issued pursuant to it the treadless casing you import is not considered to be a completed tire until the tread is applied. Therefore, the Bandag dealer applying the tread is considered to be the tire manufacturer and the Korean manufacturer of the casing does not have to put his own "DOT" number on the casing.

Since you expect many of your dealers will be using this process, in order not to unduly expand the new manufacturer's list, all your dealers are to use your assigned code number "DOT" for the grouping representing the manufacturer's assigned code and their own three symbol retreader's code in the third grouping which is normally considered the optional code:

Your dealers, as manufacturers of the tires are responsible for maintaining the records of the first purchaser of the tires they manufacturer.

I believe Docket No. 70-12, Notice No. 9 (36 P.R. 9869) answers your question concerning the location of tire identification numbers.

Mr. M. Groosman U.S. Factory Representative Automobiles Peugeot

This is in reply to your letter of June 22 requesting an interpretation of Paragraph S4.2 of Motor Vehicles Safety Standard No. 101.

You may mark your windshield wiper control, and lighting - windshield washing control in the manner indicated in your letter. We do not consider the washing control a wiping control requiring identification as such merely because the wiper is momentarily activated when the washer system is in operation.

Lawrence R. Schneider Acting Chief Counsel

ID: nht92-6.33

DATE: May 27, 1992

FROM: Frederick H. Grubbe -- Deputy Administrator, NHTSA

TO: Phil Gramm -- United States Senator

COPYEE: Washington Office

TITLE: None

ATTACHMT: Attached to letter dated 5/5/92 from Stephen Newmark to Jerry Curry

TEXT:

This responds to your Memorandum attaching correspondence from your constituent Stephen Newmark of Tarrant County. Mr. Newmark, Vice-President of Lonestar Classics, Inc., states that his company "has requested an exemption" from this agency "for the purposes of manufacturing kit cars," and asks your help "in determining whether our exemption will be granted or whether the National Highway Traffic Safety Administration (NHTSA) requires further information." He also states that "the timing of NHTSA's response is critical to our moving ahead."

Mr. Newmark FAXED the Administrator on May 5, 1992, about the possibility of obtaining an exemption, and followed up with a telephone call to the Office of Chief Counsel on May 15. As we understand it from that conversation, the business plan intended by Lonestar is to sell and deliver a certain number of unassembled components to purchasers who will complete the assembly of the vehicle by providing the engine, drive train, and suspension. We informed Mr. Newmark orally that, given these facts, Lonestar is not considered to be a "manufacturer" of motor vehicles under the National Traffic and Motor Vehicle Safety Act. Because of this, Lonestar is not required to ensure the compliance of the completed vehicle with the Federal motor vehicle safety standards, and, hence, no exemption is required for it to implement its business plan.

We informed Mr. Newmark of your interest in his behalf, and that our response to you would also serve as a reply to his FAX of the 5th to the Administrator. For this reason we are providing him a copy of this letter.

ID: 18592.wkm

Mr. G. S. Edington
General Manager
KUMHO Technical Center
3500 Embassy Parkway, Suite 150
Akron, OH 44333

Dear Mr. Edington:

This responds to your letter to this agency regarding the metrication of Federal Motor Vehicle Safety Standard (Standard) No. 119, New pneumatic tires for vehicles other than passenger cars. You referred to the final rule published in the Federal Register on May 27, 1998, (63 FR 28912) in which we changed paragraph S6.5(d) to require that the maximum load ratings and corresponding maximum inflation pressures be shown in metric numbers, followed by English numbers in parentheses, effective May 27, 2003. You asked whether you could continue to show the load ratings and inflation pressures in English units, followed by metric units in parentheses after the May 27, 2003 effective date. The answer is no.

Standard No. 119, subsection S6.5, Tire markings, specifies the labeling that is to be placed on tire sidewalls, the placement of the markings on the sidewalls, and the measurements of the required markings. Paragraph (d) requires that the maximum load rating and the corresponding tire inflation pressure of the particular tire be shown as follows:

For tires rated for single and dual load:

ID: 15215.wkm

Mr. Carlos Fracaroli
Pirelli
Av. Alexandre de Gusmâo
487-09110-900
Santo André, SP Brasil

Dear Mr. Fracaroli:

Please pardon the delay in responding to your letter in which you inquired about tolerances in the ambient temperature requirements of Federal motor vehicle safety standard (FMVSS) No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars (49 CFR 571.119), and 49 CFR 575.104, Uniform Tire Quality Grading Standards. You stated that you found no such tolerances in the standards and asked how you should calibrate your laboratory if none exist, since ambient temperatures can oscillate 5 degrees Fahrenheit (F).

You are correct that the above standards do not provide for tolerances with respect to the testing temperatures of tires. All of our FMVSSs specify minimum performance requirements. Thus, manufacturers must design and build the products to meet or exceed the specified performance. Since increased temperature is generally detrimental to tire performance, manufacturers must ensure that each tire meets the required performance at the temperature specified in the standard, in this case, 95 degrees F. Given the variability in laboratory equipment as you correctly noted, however, the agency allows an ambient temperature tolerance in our compliance testing of +0F-10F. The +0F ensures that the actual temperature will never oscillate above 95F. That upper limit ensures that we do not exceed the requirements of the standard, which would invalidate the test. For your information, please find enclosed extracts from this agency's Laboratory Procedures for Tire Testing and Data Reporting, DOT publication No. TP-119-04, May, 1988, applicable to FMVSS No. 119, and Laboratory Procedures for Tire Temperature Resistance Testing, DOT publication No. TP-UTQG-H-01, May 25, 1979, applicable to the UTQGS. Both publications are available from this agency, ATTN: NAD-40.

I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact this office at this address or by Fax at 011-202- 366-3820.

Sincerely,
John Womack
Acting Chief Counsel
Enclosures
ref:119#575
d.10/8/97

ID: nht87-1.38

TYPE: INTERPRETATION-NHTSA

DATE: 02/23/87

FROM: C.M. MEHTA -- AUTOLITE [INDIA] LIMITED

TO: NHTSA

TITLE: DOT APPROVAL ON HEADLAMPS/DRIVING LAMPS ETC FOR MARKETING IN USA

ATTACHMT: ATTACHED TO LETTER DATED 06/17/87 FROM ERIKA Z. JONES -- NHTSA TO C.M. MEHTA, REDBOOK A30, STANDARD 108

TEXT: Dear sirs,

Kindly refer to our letter No. 1476 dated 9.1.87 whereby we introduced ourselves as a reputed manufacturer and exporter of all types of Automobile Headlamp Assembly, Semi Sealed Beam Units, Fog Lamps etc., under trademark 'AUTOPAL'. We had requested you to send us following informations:

1. Details of DOT/SAE approval required in marketing our Headlamp Units 7", 5 3/4" (Round) and Rectangular small and large. (We had already sent you an illustrated catalogue of our products with the above letter).

2. Can we market these lamps as referred in Para No. 1 fitted with 9004, 9005 and 9006 Bulbs. If there is any specifications/technical details available with you, please send us a copy.

3. We understand that the use 9004, 9005, 9006 bulbs are permitted on Headlamps with lens and Reflectors made of Plastic. Kindly advise, if we can use these Reflector made of metal?

4. Details of approval required for High Beam Driving Lamps to be used for off-road vehicles.

5. The details of specifications for Driving Lamps to be used on Cars, Trucks etc.

In addition to the above, we further request you to please provide us the following specifications immediately by airmail:-

I) SAE-F-80 FRONT FOG LAMPS II) SAE-J-79 MOTOR CYCLE HEADLAMPS III) SPECIFICATION FOR DRIVING LAMPS USING H3 BULB.

Kindly send us the above informations/specifications urgently. If there is any charges for technical details/specifications, please inform us and send us your Proforma Invoice to cover the cost of the same when it will be remitted to you.

Awaiting to hear from you soon.

Thanking you, we remain

Yours faithfully,