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ID: aiam0286 Open Mr. Charles W. Dietrich, Head, Traffic Sciences, Bolt (sic) Beranek and Newman, Inc., 50 Moulton Street, Cambridge, MA 02138; Mr. Charles W. Dietrich Head Traffic Sciences Bolt (sic) Beranek and Newman Inc. 50 Moulton Street Cambridge MA 02138; Dear Mr. Dietrich: This is in reply to your letters, both dated December 16, 1970 concerning Motor Vehicle Safety Standard No. 213, Child Seating Systems.' One of these letters enclosed a request for clarification of two provisions of Standard No. 213. This request is presently under review and you should be hearing from the agency concerning it in the near future. You also enclosed in this letter a copy of a page from the 1970 Sears, Roebuck & Co. catalogue showing a child harness that is advertised as not a safety harness,' and ask whether this type of harness is exempt from the requirements of Motor Vehicle Safety Standard No. 209. The agency considers these types of harnesses to fall within the purview of Standard No. 209 and they are required to comply with the requirements for Type 3 seat belt assemblies as specified in S4. of that standard. Enforcement procedures are currently in progress in this area to eliminate those child harnesses that do not comply with the standard.; Your second letter requests that a study conducted by the University o Michigan Highway Safety Research Institute (Contract No. FH- 11-6962), entitled Integrated Seat - Restraint and Child Systems,' be placed in the public docket, and further request that the data films of the dynamic sled test be made available through the Docket.' The report to which you apparently refer has been placed in the general reference section of Docket 2-15. It is entitled Child Seat and Restraint Systems Test Program' but bears the same contact number as the one you request. With reference to your request for data films, these films are presently available for examination by the public through the agency's Research Institute, and information to this effect has been placed in the Docket.; We are pleased to be of assistance. Sincerely, Lawrence R. Schneider, Acting Chief Counsel
ID: aiam2311 Open Mr. David E. Martin, Director, Automotive Safety Engineering, Environmental Activities Staff, General Motors Corporation, General Motors Technical Center, Warren , MI, 48090; Mr. David E. Martin Director Automotive Safety Engineering Environmental Activities Staff General Motors Corporation General Motors Technical Center Warren MI 48090; Dear Mr. Martin: This is in reply to your letter of March 8, 1976, asking for a amendment of S4.1.1.21 of Motor Vehicle Safety Standard No. 108 to allow a plus tolerance of 7.5 percent on maximum wattage requirements for Type 1A and 2A headlamps.; I enclose a copy of an interpretation furnished the General Electri Company which states that such a tolerance is allowed. However, to clarify our intent we plan to amend Standard No. 108 in the near future in the manner that you suggest.; Yours truly, Stephen P. Wood, Assistant Chief Counsel
ID: aiam3150 Open Mr. T. Fujita, Manager, Automotive Lighting, Engineering Department, Stanley Electric Co., Ltd, 2-9-13, Nakameguro Meguro- ku, Tokyo 153, Japan; Mr. T. Fujita Manager Automotive Lighting Engineering Department Stanley Electric Co. Ltd 2-9-13 Nakameguro Meguro- ku Tokyo 153 Japan; Dear Mr. Fujita: This is in reply to your letter of October 17, 1979, asking for a interpretation for Paragraph S4.3.1.7 of Federal Motor Vehicle Safety Standard No. 108.; S4.3.1.7 says in effect that a front turn signal lamp and a low bea headlamp may be closer to each other than 4 inches 'if the sum of the candlepower values of the turn signal lamp measured at the test points within each group listed in Figure 1 is not less than two and one-half times the sum specified for each group for yellow turn signal lamps.'; You have asked whether a motorcycle turn signal lamp should 'satisf the values specified in S4.3.1.7 or half those values'. The answer, is, the values specified in S4.3.1.7. Half those values would be 'less than two and one-half times the sum specified ...' and impermissible under S4.3.1.7.; I hope that this answers your question. Sincerely, Frank Berndt, Chief Counsel
ID: aiam4695 Open Mr. Takahiro Maeda Assistant to the Vice President Engineering Division Yamaha Motor Corporation, U.S.A. P.O. Box 6555 Cypress, CA 90630; Mr. Takahiro Maeda Assistant to the Vice President Engineering Division Yamaha Motor Corporation U.S.A. P.O. Box 6555 Cypress CA 90630; Dear Mr. Maeda: This is in reply to your letter of September 28, l990 requesting an interpretation of Motor Vehicle Safety Standard No. 108. Table IV of the standard establishes a minimum 'edge to edge separation distance' between turn signal lamps and tail or stop lamps installed on motorcycles. You have asked whether the edge in question is the outer edge of the lamp assembly itself, or the edge of the reflector in the lamp. The minimum edge to edge separation distance is measured from the edge of the illuminated surface of one lamp to another, that is to say, from the edge of the effective projected luminous area of one lens to the edge of the effective projected luminous area of the other. It is unclear from the drawing you enclosed of the 'tail/brake lamp' whether the edge of its effective projected luminous area of the lens is at the edge of the reflector, or at the edge of the lamp (as appears to be the case with the 'turn signal'). If the former, the distance is measured between the edge of the tail/stop lamp reflector to the edge of the turn signal lamp assembly as you have initially indicated. Sincerely, Paul Jackson Rice Chief Counsel;
ID: aiam1497 Open Mr. Kenji Shimizu, Mitsubishi Motors Corporation, 24300 Southfield Road, Southfield, MI 48075; Mr. Kenji Shimizu Mitsubishi Motors Corporation 24300 Southfield Road Southfield MI 48075; Dear Mr. Shimizu: This responds to your verbal request to Mr. Herlihy of this office fo a determination that a 3-point, continuous loop, Type II seat belt assembly would meet the requirements of S4.1.2.3.1(a) of Standard No. 208 if its emergency-locking retractor were mounted at the outboard floor anchorage instead of at the roof rail. The belt is routed from the fixed upper torso end, through a slip-fitting latch and pelvic section, to the retractor.; Assuming the belt assembly meets any other adjustment requirement o S4.1.2.3.1, it would conform to S7.1 of Standard No. 208 and S4.1(g) of Standard No. 209 with the emergency-locking retractor mounted at the outboard floor anchorage. The upper torso restraint would 'adjust by means of an emergency-locking retractor' within the meaning of S7.1 as long as the continuous loop permitted slack from the floor-mounted emergency-locking retractor to reach the upper torso portion of the assembly.; Yours truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam3500 Open Mr. G. R. Dufresne, Assistant Vice President, Textile Services Division, United States Testing Company, Inc., 14415 Park Avenue, Hoboken, NJ 07030; Mr. G. R. Dufresne Assistant Vice President Textile Services Division United States Testing Company Inc. 14415 Park Avenue Hoboken NJ 07030; Dear Mr. Dufresne: This responds to your July 24, 1981, letter directed to our Office o Enforcement in which you ask whether it would be permissible to test for compliance with Standard No. 302, Flammability of Interior Materials, in a manner different than that prescribed in the standard. The standard states that a 14-inch long section of material shall be burned in a test oven until the flame reaches within 1 1/2 inches from the end of the material. You state that for some fabrics this requires a test that can extend to 10 minutes. In a test of this length, the test oven can cause the glass front of the oven to break. You suggest that the test be discontinued after five minutes, and the burn rate calculated.; The test requirements of the standard are provided to show how th agency will test for compliance. However, it is not compulsory that a manufacturer adhere to every facet of the test procedures if it can satisfy itself that its product will comply with the standard by testing in another manner. As you know, the standard requires only that the burn rate of a material not exceed four inches per minutes. A 14-inch long section of material that has not burned completely to its end in five minutes obviously would not exceed the 4-inch per minutes burn rate. Accordingly, we do not see any reason that you could not terminate the test five minutes after the starting point specified in paragraph S5.3(e) of the standard.; Sincerely, Frank Berndt, Chief Counsel
ID: aiam1028 Open Mrs. Gussie Peer, 149 Willow Avenue, Staten Island, NY 10305; Mrs. Gussie Peer 149 Willow Avenue Staten Island NY 10305; Dear Mrs. Peer: Your recent letter to the National Transportation Safety Boar concerning bus window glass has been referred to me for reply.; Safety glazing in buses is regulated by Federal Motor Vehicle Safet Standard No. 205. In general, the windows in the vicinity of passengers may be either laminated safety glass or tempered safety glass, or rigid plastics, if the windows are readily removable. Hence, the Federal standard does not prohibit manufacturers from using glazing materials that perform as you suggest.; In the past few years, manufacturers have expressed interest i providing passengers with protection from missiles thrown at buses. I expect to see an increase in the use of materials that conform with your suggestion.; I am enclosing a summary of the Federal Motor Vehicle Safety Standard for your information.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;
ID: aiam3015 Open Mr. H. Miyazawa, Director, Automotive Lighting, Engineering Department, Stanley Electric Co., Ltd., 2-9-13, Nakameguro, Meguro-ku, Tokyo 153, Japan; Mr. H. Miyazawa Director Automotive Lighting Engineering Department Stanley Electric Co. Ltd. 2-9-13 Nakameguro Meguro-ku Tokyo 153 Japan; Dear Mr. Miyazawa: This is in reply to your letter of April 28, 1979, asking two question with respect to certification of lighting equipment by use of the DOT symbol, as permitted by S4.7.2 of Federal Motor Vehicle Safety Standard No. 108.; Your first question is whether disassembled parts such as lenses screws, or bulbs must also be certified as conforming to all applicable Federal motor vehicle safety standards. The answer is no, only the completed lamp assembly must be so certified.; You have also asked 'in the case of lamp lens incorporated with refle reflector do we have to label the DOT label on this reflex reflector certifying it meets FMVSS?' The answer is yes. Although the lamp lens is not a required equipment item and not certified since it is only part of a lamp, the reflex reflector incorporated in it must be certified since the reflector is an item required by Standard No. 108.; I hope this answers your questions. Sincerely, Frank Berndt, Acting Chief Counsel
ID: aiam1182 Open Mr. Gorou Utsunomiya, Branch Manager, 23777 Greenfield Rd., Southfield, Michigan 48075; Mr. Gorou Utsunomiya Branch Manager 23777 Greenfield Rd. Southfield Michigan 48075; Dear Mr. Utsunomiya: This is in reply to your letter of June 11, 1973, regarding th application of section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C S1403) to Motor Vehicle Safety Standard No. 107, 'Reflecting Surfaces'. You refer to language in a letter dated April 10, 1973, from this agency to Mr. Kazushi Sakashita of Toyo Kogyo., Ltd., in which we indicated that certification of replacement vehicle parts pursuant to section 114 is required only with respect to parts to which a safety standard specifically applies.; Standard No. 107 applies to motor vehicles--passenger cars multipurpose passenger vehicles, trucks, and busses (paragraph S2 of Standard No. 107)-- and not to items of motor vehicle equipment. Consequently the certification of conformity to the standard required by section 114 is accomplished by the label affixed to each vehicle in accordance with 49 CFR Part 567, 'Certification'. That label represents a certification of conformity to all standards, including Standard No. 107, applicable to the vehicle. There is no requirement that the individual components listed in S4 of the standard, i.e. the windshield wiper arms and blades, the inside windshield moldings, the horn ring and hub of the steering wheel assembly, and the inside rearview mirror frame and mounting bracket, be certified independently.; Your truly, Richard B. Dyson, Assistant Chief Counsel
ID: aiam1478 Open John F. McCuen, Esq., Kelsey-Hayes Company, Romulus, MI; John F. McCuen Esq. Kelsey-Hayes Company Romulus MI; Dear Mr. McCuen: This will acknowledge receipt of Kelsey- Hayes' petition to ad 'after-stop' to the description of the temperature range in S6.1.8.1 of Standard No. 121 and S7.4.2.1.2 of Standard No. 105a.; The temperature range is in fact intended to describe the after-sto temperature of the brakes, and the language of the sections will be clarified in the future.; Yours truly, Richard B. Dyson, Assistant Chief Counsel