NHTSA's Interpretation Files Search
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ID: aiam0245OpenMr. James Deifster, 914 Willow Run, Covington, KY 41011; Mr. James Deifster 914 Willow Run Covington KY 41011; Dear Mr. Deifster: Your request for information on requirements for camper manufacturer has been referred to this office for reply. The information we have received states that you are a manufacturer of campers, selling them to dealers, and also installing them on trucks.; The National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C S1381 et seq., (copy enclosed) requires manufacturers of motor vehicles and motor vehicle equipment to manufacture their products so that they comply, and to 'certify' that they comply, with applicable Federal motor vehicle safety standards. Camper bodies for both slide-in and chassis-mount camper installation are items of motor vehicle equipment and must comply with Federal Motor Vehicle Safety Standard No. 205, and be certified by their manufacturer that they comply with the standard. I enclose a copy of the standard and the regulations governing certification for your information, Standard No. 205 incorporates by reference the USA Standard Z26.1-1966, 'Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways.' This USAS standard can be obtained for a small fee from the USA Standards Institute, 10 East 40th Street, New York, N.Y. 10016.; If you install slide-in camper bodies on pick-up trucks only, you ar not subject to additional requirements. However, if you install chassis-mount camper bodies onto truck chassis, you are in addition to being a manufacturer of motor vehicle equipment, a manufacturer of motor vehicles, specifically, multipurpose passenger vehicles, and are required to comply with regulations and standards applicable to manufacturers of multipurpose passenger vehicles. Copies of these requirements, which have been promulgated pursuant to the National Traffic and Motor Vehicle Safety Act of 1966 and codified in Chapter 5 (formerly Chapter 3) of Title 49, Code of Federal Regulations, are available from the Government Printing Office, Washington, D. C. 20402, under the title *Federal Motor Vehicle Safety Standards*. The price is $8.00, which includes a subscription for one year to receive copies of amendments.; Because of the relative length and complexity of these requirements, i is difficult to summarize them for you here. Many trade associations have familiarized themselves with them in order to assist their membership in complying with them. If after studying them materials you have specific questions concerning their application to you, we will be pleased to answer them.; I have also enclosed a mailing list questionnaire. If you will complet and return it to the address indicated thereon, you will receive future notices pertaining to those areas you have marked.; Sincerely, Lawrence R. Schneider, Assistant Chief Counsel, Regulation |
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ID: aiam3890OpenConfidential; Confidential; Dear Mr. Confidential: This is in reply to your letter of August 30, 1984, (not received unti October 17, 1984) with respect to questions of compliance of lighting and bumper requirements on a vehicle equipped with a variable height control system.; Standard No. 108 requires that the center of a headlamp lens be no less than 22 inches from the road surface. You stated that this minimum might not be met with respect to certain headlamp configurations when the ignition is off, and the hydraulic pressure in the height control system relaxes, a period of approximately three hours. You believe that compliance with the mounting height requirement should be judged 'with the ignition switch in only the 'on' position,' the apparent point at which the height control system begins to operate.; We believe that the minimum height requirement should be met for an lamp at any time in which it is operated for its intended purpose. Since vehicles at rest do not require use of headlamps, the minimum height would be measured at the point after the ignition is on and when the car begins to travel (your letter implies that the time lag between turning on the ignition and restoration of a complying mounting height is a matter of seconds). On the other hand, the hazard warning signal lamps are frequently operated when the vehicle is stopped, and therefore the minimum mounting height of turn signal lamps, through which they operate, must be met with the ignition off, even if the system requires three hours to deplete itself and lower the vehicle to its minimum height.; We also call to your attention paragraph S4.1.3 which forbids th installation of motor vehicle equipment which impairs the effectiveness of lighting equipment required by the standard, and ask that you consider whether a height control system would change vehicle height, pitch, roll, etc., in response to some external or internal condition, in a manner which would affect the performance of headlamps and other lighting equipment.; You have also asked, in essence, which conditions of operation of th system are appropriate for the pendulum and barrier impact tests of the bumper standard, 49 CFR Part 581. Under Sec. 581.5(c), the suspension system is to remain in adjustment and operate in the normal manner, under Sec. 581.6(c) the engine is operating at idling speed. In our opinion, the vehicle is required to meet the pendulum test of Part 581 in any vehicle use scenario in which the system operates, and the barrier test of Part 581 when the engine is idling.; Finally, you requested confidentiality for all information submitte which pertains to the variable height control system. After carefully reviewing the documents, I have determined that your request should be granted. The release of these documents could cause substantial injury to the competitive position of your company. Therefore, I am withholding from the public your letter which contains a detailed description of the variable height control system currently under consideration. I am also deleting all references to the company name. I will instruct all agency personnel having access to this information to accord it confidential treatment.; I hope that this answers your questions. Sincerely, Frank Berndt, Chief Counsel |
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ID: aiam2782OpenMr. Stan Haransky, Truck Body and Equipment Association, Inc., 5530 Wisconsin Avenue, Suite 1220, Washington, DC 20015; Mr. Stan Haransky Truck Body and Equipment Association Inc. 5530 Wisconsin Avenue Suite 1220 Washington DC 20015; Dear Mr. Haransky: This responds to your February 21, 1978, letter asking whether sectio 567.5(c)(7) of Part 567, *Certification*, requires a manufacturer to use all of the described statements on its certification label.; The answer to your question is no. That section provides that th listed certification statements are to be used as appropriate. Therefore, it is anticipated that a manufacturer will select for inclusion on its certification labels only those certification statements in subparagraph (c)(7) that are appropriate for the certification of its vehicles.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam5047OpenRichard Allison Program Manager The Bott Group, Inc. 32330 Howard Avenue Michigan Heights, MI 48071; Richard Allison Program Manager The Bott Group Inc. 32330 Howard Avenue Michigan Heights MI 48071; "Dear Mr. Allison: This responds to your letter of August 20, 199 requesting an interpretation of Standard No. 216, Roof Crush Resistance. Specifically, you requested 'an interpretation of 1) the proper application and orientation of the test device (S6.2 of this standard) and 2) the distance the test device is allowed to travel (paragraph S4 of this standard), when testing vehicles equipped with roof mounted accessories, such as roof racks (luggage racks).' You believe that there are three possible test conditions. The first condition would conduct the test either without the roof rack installed or with the roof rack removed, and with the test device positioned in accordance with S6.2. The second condition would conduct the test with the roof rack installed, and with the test device positioned using the point of contact established under test condition 1. The third condition would conduct the test with the roof rack installed, and with the test device positioned in accordance with S6.2 to the roof rack. You requested our interpretation as to which is the correct test condition. In addition, you asked if we determined that either test condition 2 or 3 was correct, could the amount of distance traveled before contact with the roof be added to the allowable distance of test device travel under S4. We would conduct our compliance testing for Standard No. 216 with roof mounted accessories such as roof racks removed (your test condition 1). We would do so because the purpose of the test is to measure the strength of the roof, not the strength of roof mounted accessories. Further, as you have noted, conducting the test with roof mounted accessories in place could influence the positioning of the test device. 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, Paul Jackson Rice Chief Counsel"; |
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ID: aiam1907OpenMr. H. (Speedy) Hirai, Technical Representative, Toyo Kogyo Co., Ltd. (Mazda), Representative Office, 23777 Greenfield Rd., Suit 462, Southfield, Michigan 48075; Mr. H. (Speedy) Hirai Technical Representative Toyo Kogyo Co. Ltd. (Mazda) Representative Office 23777 Greenfield Rd. Suit 462 Southfield Michigan 48075; Dear Mr. Hirai: This responds to your April 16, 1975, question whether the tes procedure of S7, 7, 1 of Standard No. 105-75, *Hydraulic brake system*, permits reapplication of the parking brake if the vehicle fails to hold on the required grade after the first application of a force or series of forces. You also ask whether a brake warning indicator which signals a shortlived loss of pressure during a spike stop brake application would conform to S5.3.1(a) (1).; Section S7.7.1 directs (in part) application of the parking brake wit a force or series if forces, release of the service brake which has been holding the vehicle on the required grade, and indicates that in release of the service brake, 'it may be necessary to reapply *it*, if the vehicle moves slightly, to take up the parking brake system slack' (emphasis added).; The word 'it' refers to the service brake system, and not the parkin brake system. This sentence permits application of the service brake only, which has the effect of taking up parking brake system slack due to rotation of the brake shoes and drum prior to bottoming against the anchor pin. This service brake application is intended to provide the best opportunity for a static test of the parking brake.; You state that a differential pressure can occur within the Mazd master cylinder during a spike stop brake application because the piston travels beyond the outlet port to the rear wheel brake lines. This pressure differential causes momentary activation of the brake warning indicator lamp.; The NHTSA would consider in this case that, as a technicality momentary failure of the rear wheel subsystem has occurred because continued braking pressure cannot be applied to the rear wheels. you point out that the system corrects immediately and the signal lamp is extinguished.; From your description of the Mazda system, NHTSA concludes that th activation of the signal lamp conforms to the requirements of S5.3.1(a) (1) as long as it is designed to extinguish as soon as the system corrects and continued brake force could be applied to the read wheels.; Yours truly, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam2628OpenMr. Glenn Taylor, President, Bankhead Enterprises, Inc., 1600 Ellsworth Industrial Drive, N.W., Atlanta, GA 30318; Mr. Glenn Taylor President Bankhead Enterprises Inc. 1600 Ellsworth Industrial Drive N.W. Atlanta GA 30318; Dear Mr. Taylor: This responds to your June 7, 1977, question whether the traile portion of an auto transporter must comply with Standard No. 121, *Air Brake Systems*, if it is manufactured after the current September 1, 1977, termination date for the exclusion of auto transporters from the standard.; As stated in a telephone conversation between you and Mr. Herlihy o this office, the current exclusion for auto transporters terminates September 1, 1977, and either portion of an auto transporter manufactured after that date must comply. Recently, the NHTSA proposed extension of the auto transporter exclusion from September 1, 1977, to January 1, 1979 (copy of proposal enclosed). The comment closing period ended July 11, 1977, and the agency hopes to reach a decision on the proposal in the near future.; Sincerely, Joseph J. Levin, Jr., Chief Counsel |
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ID: aiam0615OpenMr. Yoshiyuki Mizuno, Engineering Representative, Nissan Motor Co., Ltd., Liaison Office in U.S.A., 560 Sylvan Avenue, Englewood Cliffs, NJ 07632; Mr. Yoshiyuki Mizuno Engineering Representative Nissan Motor Co. Ltd. Liaison Office in U.S.A. 560 Sylvan Avenue Englewood Cliffs NJ 07632; Dear Mr. Mizuno: This is in reply to your letter of February 11, 1972, in which yo requested our interpretation as to how seats with varying numbers of adjustment positions are to be adjusted to the position 'midway between the forwardmost and rear most position,' as specified in S8.1.2 of Standard 208.; The intent of the 'midway' provision in S8.1.2 is that the seat must b placed as nearly as possible at the midpoint of its fore and aft travel. Since the standard also provides that the seat is in an adjustment position -- a notch -- there is a possibility that there will not be a notch at the exact center of the range. In such cases, the seat is placed in the notch nearest the midpoint of the seat's travel. In your case A, if the notches are evenly spaced, the middle notch would probably be the nearest to the midpoint and would therefore be used. In your case B, if the two middle notches are not equidistant from the midpoint, the nearest notch would be used. If they are equidistant, the rearmost notch would be used. It is not necessary to make a special notch.; Sincerely, Richard B. Dyson, Assistant Chief Counsel |
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ID: aiam5417OpenWilliam R. Willen, Esq. Managing Counsel American Honda Motor Co., Inc. 1919 Torrance Boulevard Torrance, CA 90501-2746; William R. Willen Esq. Managing Counsel American Honda Motor Co. Inc. 1919 Torrance Boulevard Torrance CA 90501-2746; "Dear Mr. Willen: We have received your 'Petition for Honda Electri Vehicles in accordance with FMVSS 555.6(c)' (correctly, 49 CFR 555.6(c)), dated June 28, 1994. The petition is incomplete in certain respects. It fails to provide the public interest and traffic safety arguments required by 555.5(b)(7). Section 555.6(c)(2)(iii) requires the submission of 'the results of any tests conducted on the vehicle that demonstrate its failure to meet the standard, expressed as comparative performance levels.' You have provided this information with respect to your request for exemption from Standard No. 103 but not with respect to the eight interior components that accompany your request for exemption from Standard No. 302. If you have conducted tests on these components, yuou are required to submit them as part of your petition. In addition, the petition does not state whether the period for which exemption is requested is for one or two years (you may need the latter if the manufacture of the 20 electric vehicles is not completed within a year from the date of grant of the petition). If the vehicles are manufactured outside the United States, Honda may wish to avail itself of the provisions of 49 CFR 591.5(j) which allows a manufacturer to import noncomplying vehicles for purposes of research, investigation, and studies for a period of up to three years (when the temporary importation bond must be paid). After payment of the bond, a manufacturer may request NHTSA for an extension if it requires further time to complete its tests and evaluations. We shall hold your petition in abeyance until we hear further from you. Sincerely, John Womack Acting Chief Counsel"; |
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ID: aiam1454OpenMr. Robert S. Priver, Law Offices of William and Black, 615 South Flower Street, Suite 1111, Los Angeles, CA 90017; Mr. Robert S. Priver Law Offices of William and Black 615 South Flower Street Suite 1111 Los Angeles CA 90017; Dear Mr. Priver: Thank your for your letter of March 29, 1974, requesting informatio and documentation concerning Fuel System Integrity Standards.; The GSA 515/26 Standard which you mentioned was published July 15 1966, and was effective October 13, 1967. This standard was effectively supplanted by Federal Motor Vehicle Safety Standard No. 301 which was effective January 1, 1968. A copy of this original Standard No. 301 is enclosed for your information along with a recent amendment (F.R. 39, 10586, March 21, 1974) that substantially upgrades the requirements of this standard.; We do not consider it appropriate to give advice concerning privat incidents or controversies, beyond what is contained in our regulations and other public issuances. You may find it helpful to contact private-sector groups such as the Society of Automotive Engineers for further information.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs; |
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ID: aiam3469OpenMr. Daniel M. Jaworski, Johnson, Campbell & Moesta, 912 Buhl Building, Detroit, MI 48226; Mr. Daniel M. Jaworski Johnson Campbell & Moesta 912 Buhl Building Detroit MI 48226; Dear Mr. Jaworski: This responds to your recent letter requesting confirmation that th National Highway Traffic Safety Administration (NHTSA) has not issued any safety standards or regulations concerning the use of brake hose as a fuel line in commercial vehicles. Mr. Vernon Bloom of the NHTSA apparently told you that the agency has no standards regarding vehicle fuel lines.; Mr. Bloom is correct in his statement that no Federal safety standard or regulations preclude the use of brake hose as a vehicle fuel line, and that there are no standards directly relating to fuel lines. However, the agency does have a safety standard which indirectly involves fuel lines. Safety Standard No. 301, *Fuel System Integrity* (49 CFR 571.301), specifies performance requirements governing fuel systems on new motor vehicles. The standard specifies the maximum amount of fuel leakage that may occur following a barrier crash test of a new vehicle. Although the individual components of the fuel system, such as the fuel tank, do not have to meet specific requirements, each component obviously must be durable in order for the entire system to meet the general performance requirement of Standard No. 301. Therefore, you should ascertain whether the brake hose you intend to use as a fuel line would compromise a vehicle's ability to comply with that standard.; I would also point out that, although there are no safety standard directly relating to fuel lines, manufacturers are responsible for any safety-related defects which may occur in their vehicles or equipment. Section 151, *et seq*., of the National Traffic and Motor Vehicle Safety Act provide that manufacturers of motor vehicles and motor vehicle equipment must notify owners of vehicles and equipment with safety-related defects and remedy those defects free of charge. Under these provisions, you would be responsible if it were determined that your fuel lines constituted safety-related defects.; Sincerely, Frank Berndt, Chief Counsel |