ID: 86-1.6

TYPE: INTERPRETATION-NHTSA

DATE: 01/06/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: D. Moens -- Sales Engineer, Van Hool N.V. (Belgium)

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. D. Moens Sales Engineer Van Hool N.V. Bernard Van Hoolstraat 58 B-2578 Lier Koningshooikt, Belgium

This responds to your October 10, 1985 letter to this agency requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus Window Retention and Release. You asked whether FMVSS No. 217 allows the use of sliding roof emergency exits. The answer to your question depends on the location of the release mechanism and the direction in which the mechanism operates relative to the surface of the closed exit. As explained below, if the release mechanism falls in the area of high force application, i.e., the area of the bus in which high operating forces may be used, then the answer to your question is no.

According to your letter, you provide two roof hatches on your buses, in the front and rear of the vehicles, although the front roof hatch is not needed to meet the unobstructed openings requirement of Standard No. 217. The roof hatches would slide open rather than push out, and would be opened by a handle which is located in the region of high force application as shown in Figure 3B of the standard.

Standard No. 217 requires buses to be equipped with emergency exits and specifies requirements that all emergency exits must meet. Paragraph S5.2.1 of Standard No. 217 provides that a roof exit may be installed on buses with gross vehicle weight ratings of more than 10,000 pounds when the bus configuration precludes installation of an accessible rear exit. The roof exit must meet the requirements of paragraphs S5.3 through S5.5. Under S5.3.2, the direction of required force application in the high force access region is straight and perpendicular to the exit surface. Since your exit is designed so that the force is applied parallel to the exit surface, it does not comply with S5.3.2.

Of course, your roof emergency exit must meet all applicable requirements in FMVSS No. 217. You should note that under S5.3.1, a roof exit must provide for a release mechanism, located within the regions depicted in Figure 3B of the standard. The release mechanism must be operated by one or two force applications which comply with S5.3.2. Further, S5.5 sets certain identification requirements for roof emergency exits.

You stated that the roof exit installed in the forward half of the bus does not need to be counted to satisfy the unobstructed openings requirement of Standard No. 217. Exits that are not labeled or intended as emergency exits need not meet the emergency exit requirements of FMVSS No. 217.

You asked what consequences would follow if we determine that your sliding roof exit does not comply with FMVSS No. 217. That standard was issued under the National Traffic and Motor Vehicle Safety Act. The Act requires manufacturers to comply with all applicable safety standards. It also requires them to notify purchasers of their motor vehicles of safety-related defects and failures to comply with the safety standards, and to remedy such defects and noncompliances without charge. Violations of the Act's requirements are punishable by civil fines of up to $1,000 per violation, with a maximum $800,000 for a related series of violations. Under the regulations set forth in Part 556 of Title 49 of the Code of Federal Regulations (copy enclosed), manufacturers may petition NHTSA for an exemption from the Act's notice and remedy requirements if they believe that the defect or noncompliance is inconsequential as it relates to motor vehicle safety. However, if the agency denies such a petition, all duties relating to notice and remedy of the defect or noncompliance contained in the Vehicle Safety Act are continued in force against the manufacturer.

Mr. Sebastian Messina of the New Jersey Department of Transportation has contacted us concerning the sliding emergency exits on your buses. We are sending him a copy of this letter for his information.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

NHTSA Chief Council Mr. Jeffrey R. Miller 400 7th Street SW Washington DC 20590 USA

VIA AIR MAIL

AFDELING: Eng. Dept. BIN TELEF: 419 ONZE REF: DM/cb/13.979 B-2578 LIER - KONINGSHOOIKT: 10.10.85

Dear Sirs,

Re.: Emergency roof hatch Ref: Standard no. 217, Bus window retention and release

Van Hool are Belgian bus and trailer manufacturers, with a production capacity of 1500 buses and 4000 trailers and semi-trailers a year. For your information you will find enclosed a general presentation leaflet.

After the information we got by phone from the New Jersey D.O.T. with the statement that they will not accept our sliding type emergency roof hatches anymore, we would like to make clear to you the functioning of our type of roof hatches, Please find enclosed some copies explaining the system. We do not intend to tell what is right or wrong or express our displeasure, nor do we have doubts about the objectivity of the New Jersey D.O.T. However an investigation from your side of our system and a judgement would be appreciated as we have to deal with other States which rely on the Federal decisions and Standards.

Two completely finished buses and one almost finished bus are ready to be shipped to the USA; they are still equipped with the sliding type emergency roof hatches. So if your judgement should be negative we would like to get a derogation for those 3 buses because in the meantime they will already be shipped to the U.S.A.

Please also note that, in case of a negative judgement, we have yet studied other types of American made roof hatches, for future deliveries.

We thank you for an early reply and remain,

Yours sincerely,

N.V. VAN HOOL

D. MOENS Sales Engineer Enclosures - explanation of functioning

Explanation of functioning

1. The 2 roof hatches are situated in the centre of the roof, one in the first half of the bus and one in the rear half, in the access region for high forces (magnitude of not more than 60 pounds).

In fact we only need the rear one to replace the rear exit.

But as we use them also for ventilation we are mounting 2.

2. The roof hatch can be opened manual by s single occupant and one motion, sliding backwards, parallel to the exit surface.

3. Magnitude: 56 pounds.

4. The free unobstructed opening is: 31 inches x 21 inches.

ID: 86-1.7

TYPE: INTERPRETATION-NHTSA

DATE: 01/06/86

FROM: J.L HENDRICKS -- PRODUCT ENVIRONMENTAL MANAGER, CUMMINGS ENGINE COMPANY INC

TO: ERIKA JONES -- OFFICE OF CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/04/86, TO J.L. HENDRICKS FROM ERIKA Z. JONES, REDBOOK A29; PART 573.7

TEXT: Dear Ms. Jones:

Cummins Engine Company, Inc. manufactures both on and off-highway heavy-duty diesel engines and related engine products. Cummins is a non-integrated engine manufacturer and, therefore, has no control over which chassis or engine combination the Original Equipment Manufacturer (OEM) will select as the final vehicle configuration.

The problem I wish to address, and solicit assistance from your office, deals with the difficulty of non-integrated engine manufacturers identifying ultimater purchasers as required by 49 CFR, Part 573, 573.7 "Purchaser and Owner List," during safety defect campaign.

Cummins Engine Company recently experienced a voluntary safety recall campaign (NTSA 85E-016) regarding a potential defective assembly of a fuel pump throttle lever. During Cummins' attempts to survey state registration records we have discovered that the State of Connecticut requires a formal declaration of vehicle identification numbers (VIN'S) and justification regarding the reason for conducting a search of justification regarding the reason for conducting a search of their vehicle registration files. Additionally, this process requires the services of a third party agent who, by some contractual agreement, obtains the registration information, and after approval of the specific authority, develops appropriate information and analysis computer tapes for re-sale.

Cummins primary concern does not deal with the reasons each state may have in designing security measures for vehicle registration; on the contrary, we respect the right of individual privacy and the measures each state may use to safeguard their private citizens. However, we are concerned about the additional length of time required to notify each owner under Connecticut's present system.

Unlike light-duty passenger car owners, which tend to be stationary, heavy-duty truck owner/operators can be very mobile in their operations and registration practices. Often times the owner/operator has either moved their operations to take advantage of various freight markets, or has transferred ownership for many diverse reasons. In many instances we cannot provide the respective state bureau of motor vehicles with a current owner name at the time we are soliciting information due to lead time constraints and the mobility of owner/operators.

In an attempt to improve our ability to notify consumers during safety recall campaigns, Cummins is requesting that your office forward a letter to the state of Connecticut Bureau of Motor Vehicles and solicit their assistance in negotiating with Cummins, a program that could mutually protect their citizenry and enable us to maintain an on-going system to obtain vehicle registration on a timely basis.

Cummins would also appreciate a review of all states' policies regarding the accessibility of vehicle registrations. Preferably Cummins would encourage each state Department of Motor Vehicles to allow direct negotiations between them and manufacturers, without the delay of third party agents. However, that is a level of detail for negotiation with each of the respective states.

The following Connecticut contact person and address is being provided for your disposition:

Letter to: Honorable Benjamin A. Muzio

Commissioner Department of Motor Vehicles 60 State Street Wethersfield, CT 06109

Copy to: Honorable Peter Russo Assistant Commissioner

Because of the potential safety exposure to our trucking patrons during safety recall campaigns, we request your response to this issue as soon as possible.

Sincerely,

ID: 86-1.8

TYPE: INTERPRETATION-NHTSA

DATE: 01/13/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Robert R. Gregg

TITLE: FMVSS INTERPRETATION

TEXT:

January 13, 1986 Mr. Robert R. Gregg Metzeler Motorcycle Tire Agent Gregg, Inc. 144 Railroad Avenue Suite 215 Edmonds, WA 98020 Dear Mr. Gregg: This responds to your letter to Steve Kratzke of my staff, seeking an interpretation of Standard No. 119, New Pneumatic Tires for Motor Vehicles Other Than Passenger Cars (49 CFR Part 571.119). Specifically, you asked if a motorcycle could have its maximum load capacity labeled on the sidewall as follows: At 60 MPH Max load lbs. at psi cold. Such labeling would violate Standard No. 119, as explained below. Section S6.5 of Standard No. 119 requires that certain information be labeled on the sidewall of all tires to which the standard applies. Section S6.5(d) requires the maximum load rating and corresponding inflation pressure to appear on all motorcycle tires as follows: Max load lbs at psi cold. No speed rating or restriction may be given in conjunction with the maximum load rating on the sidewall of the tire. That rating, as its name implies, is intended to alert consumers to the tire's maximum capabilities. A manufacturer may label a speed restriction on its tires to alert consumers to the tire's maximum speed if that maximum is 55 miles per hour (mph) or less. Section S6.5(e) permits speed restrictions of 55 mph or less to be labeled on the sidewall of the tire as follows: Max speed mph. However, this provision of Standard No. 119 would not allow you to assign a speed restriction of 60 mph to these motorcycle tires. First, no speed restriction in excess of 55mph may be assigned to any tires; see Table III in Standard No. 119. Second, all motorcycle tires are subject to the high speed test, regardless of any speed restrictions; see S6.3 of Standard No. 119. During the high speed test, the tire is subjected to speeds up to and including 85 mph. Parenthetically, I should add that even if speed restrictions of more than 55 mph were allowed, this particular tire would not be a candidate for a speed restriction of 60 mph. You stated in your letter that these tires actually are assigned an H speed rating. Under the speed rating system used in Europe, an H speed rating on a motorcycle tire means the tire is capable of being used at speeds up to 130 mph. Assuming you have used the speed rating accurately, there is no basis for implying that these tires are not capable of speeds greater than 60 mph.

As stated above, the purpose of the maximum load ratings is to alert consumers to the tire's maximum capabilities. The agency knows that the maximum load that can safely be carried by a tire varies with the speed at which the tire is driven. Allowing tire manufacturers to specify a maximum load based on an artificial speed restriction of 60 mph would result in the tires being overloaded if the consumer were to exceed 60 mph. Overloaded tires are substantially more likely to experience a tire failure than properly loaded tires. Since the purpose of the labeling requirements in Standard No. 119 is to provide consumers with technical information necessary for the safe operation of the tires, the standard does not permit tire manufacturers to provide information that will result in the tires being overloaded whenever an artificial speed restriction is exceeded. If you have any further questions or need more information in this area, please contact Mr. Kratzke at this address or by telephone at (202) 426-2992. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.9

TYPE: INTERPRETATION-NHTSA

DATE: 01/21/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Finbarr J. O'Neill

TITLE: FMVSS INTERPRETATION

TEXT:

January 21, 1986 Finbarr J. O'Neill, Esq. General Counsel Hydundia Motor America 7373 Hunt Avenue P.O. Box 2669 Garden Grove, CA 92642-2669 Dear Mr. O'Neill: This responds to your letter asking about the requirements of FMVSS No. 101, Controls and Displays, concerning the color of the highbeam telltale. You stated that while Table 2 of the standard indicates that a manufacturer has the option of choosing a green or blue telltale, your review of competitive vehicles shows that virtually all have chosen blue telltales. You asked whether NHTSA has taken any position as to whether one color is preferable to the other. You also asked for comment on whether NHTSA has taken any position as to whether one color is preferable to the other. You also asked for comment on whether NHTSA has any reasonable anticipation of changing this requirement. I would note that in the past NHTSA required the highbeam telltale to be blue. That color was selected primarily to promote international harmonization of standards regulating vehicle controls and displays. Blue is the color requirement of the International Standards Organization, the Economic Commission for Europe, and the European Economic Community. On January 21, 1982, NHTSA amended Standard No. 101 to permit green as an alternative to blue (47 FR 2996). The purpose of the change was to allow the use of light emitting diode technology, which at that time could not produce the color blue. While we do not have a preference as such as to how manufacturers choose to meet our standards, we would note that use of the color blue tends to promote international harmonization. On September 12, 1985, NHTSA published in the Federal Register (50 FR 37240) a notice of proposed rulemaking to amend FMVSS No. 101. Among other things, the proposal concerns color requirements for electronic displays. See 50 FR 37244. We have enclosed a copy of the notice for your convenience. I hope this information is helpful. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-2.1

TYPE: INTERPRETATION-NHTSA

DATE: 02/28/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Steward Stanley

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Steward Stanley Junge Baking Company 3102 Ohio Place Joplin, MO 64801

Dear Mr. Stanley:

This responds to your letter dated November 8, 1985, inquiring whether Federal motor vehicle safety standards and regulation apply to electric vehicles. They do so apply.

This agency administers the National Traffic and Motor Vehicle Safety Act of 1966, as amended, 15 U.S.C. 1391, et seq. (the Act). Under the Act. NHTSA issues Federal motor vehicle safety standards and regulations for motor vehicles and their equipment. Under section 102(3) of the Act, a motor vehicle means "any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails. Therefore, since electric vehicles are "drawn by mechanical power," they must comply with Federal requirements.

Enclosed are an information sheet for new manufacturers, a form for ordering copies of safety standards and regulations, and a copy of 49 Part 555. Under Part 555, manufacturers of motor vehicles may apply for a temporary exemption from these safety standards, for a period up to three years, if the exemption would facilitate the development or field evaluation of a low-emission motor vehicle and would not unreasonably degrade the safety of such vehicle. A copy of a report prepared by this agency. "Applicability of Federal Motor Vehicle Standards to Electric and Hybrid Vehicles," is also enclosed.

I hope this information is helpful to you.

Sincerely,

Erika Z. Jones Chief Counsel Enclosures

Administrator Nat'l. Highway Traffic Safety Adm. 400 Seventh Street, S. W. Washington, D. C.

I am told that your office has no rules or regulations (other than bodies be equipped with seat belts) as pertains to Electric Vehicles.

If it is true I would appreciate you confirming that otherwise I would like to have a copy of that provision that deals with such vehicles.

Thanks in advance for your cooperation.

Stewart Stanley 3102 Ohio Place Joplin, Mo. 64801

SMS:vb

ID: 86-2.11

TYPE: INTERPRETATION -NHTSA

DATE: 04/01/86

FROM: WILLA BLACK KENNEDY, -- STAFF JOINT INTERIM COMMITTEE ON PUBLIC TRANSPORTATION ARKANSAS BUREAU OF LEGISLATIVE RESEARCH

TO: ERICA JONES -- CHIEF COUNSEL OFFICE OF THE CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/25/86, TO WILLA BLACK KENNEDY, FROM ERIKA Z. JONES, REDBOOK A29, HSPS 17

TEXT: Dear Ms. Jones:

The Joint Interim Committee on Public Transportation of the Arkansas General Assembly has established a special subcommittee to conduct a study of the need for laws regulating maintenance and licensing drivers of used buses being purchased by nonprofit organizations and churches for transportation of their members. For the purpose of this study, the term "old buses" or "used buses" shall mean buses of the type used by public and private schools for the transportation of children, and buses owned and used by bus companies and municipal and interurban transit authorities for the transportation of persons for hire, which have been acquired by private individuals, firms or group and which are operated for the transportation of persons, other than the members of their own families, upon the public highways and streets of this State.

Section one of this study is stated as follows:

"Whereas, it is unclear whether current regulations of the Department of Transportation apply to buses being utilized for non-commercial purposes to transport the members of nonprofit organizations and churches; and ..."

Would you please provide a written interpretation regarding this section so that it may be presented to the committee. Specifically, do current Department of Transportation regulations dealing with school buses or transit buses apply to the used buses in these modes (school/transit) that are sold and are being utilized for non-commercial purposes to transport the members of nonprofit organizations and churches?

I would appreciate your expeditious response to this request so that I may proceed with the committee study. Thank you for your assistance.

Sincerely,

ID: nht75-3.37

DATE: 11/21/75

FROM: AUTHOR UNAVAILABLE; G.G. Mannella for James B. Gregory; NHTSA

TO: National Association of Motor Bus Owners

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letters of November 12 and 13, 1975, in which you requested that the National Highway Traffic Safety Administration immediately suspend the effectiveness of Standard No. 121, Air Brake Systems, with respect to buses, without waiting until the end of a comment period. In a notice published November 13, 1975, 40 FR 52856, this agency proposed such a suspension with a 30-day comment period ending December 15, 1975.

Secretary Coleman has made clear his commitment to allowing adequate time for public comment on rulemaking actions. The normal minimum time for public comment on Department of Transportation actions has been established as 45 days. In this case, because of the special urgency of the matter, the period was reduced to 30 days. I believe we all recognize that this action is a significant one, affecting the performance and cost of most of the transit and intercity buses in the country. In these circumstances, it is our judgment that the 30-day period is the minimum that can be justified for comment by the interested public, and your request is therefore denied.

We also recognize, as you have pointed out, that for this short period there may be some uncertainty and some interruption of normal activities within the affected industries. We will make every effort to reach and announce a decision as soon as possible after the end of the comment period.

Sincerely,

ATTACH.

NATIONAL ASSOCIATION OF MOTOR BUS OWNERS

November 13, 1975

Honorable James B. Gregory -- Administrator, National Highway Traffic Safety Administration, Department of Transportation

Dear Dr. Gregory:

This will supplement my letter of November 12, 1975, in regard to the problems created by failure to make effective immediately the suspension of Motor Vehicle Safety Standard No. 121 requirements respecting the brake anti-lock system on buses.

We understand why the National Highway Traffic Safety Administration does not want to deny any opponent of the proposed suspension an opportunity to be heard. Also, we are sure NHTSA does not want to halt sales of buses for six weeks or so, to disrupt bus manufacturing schedules, to cause temporary lay-offs of employees, or to require purchasers of buses to choose between taking immediate delivery of a needed bus or saving some $ 1,300.00 by postponing acceptance of delivery. These are the consequences of failure to make the suspension effective immediately.

We offer the following solution which, in our opinion, will fully protect the rights of any protestant of suspension if one should appear.

We suggest the suspension be made effective immediately, provided, the manufacturer and purchaser of any bus sold between now and January 1, 1976, agree in writing to the installation of the anti-skid device on or before January 8, 1976, if the National Highway Traffic Safety Administration concludes that suspension of the MVSS-121 requirement is unwarranted.

Since NAMBO members will be attending their Annual Meeting in Phoenix beginning Saturday, November 15, I am turning this matter over to NAMBO's General Counsel, Drew L. Carraway, Esq. of the firm of Rice, Carpenter and Carraway. Mr. Carraway will be in touch with your General Counsel's office to ascertain whether our proposal is satisfactory and advise those of us in Phoenix of your decision on this important matter.

Sincerely yours,

Charles A. Webb -- PRES.

cc: Frank A. Berndt (Acting Chief Counsel); Richard Dyson (Chief Counsel's Office)

NATIONAL ASSOCIATION OF MOTOR BUS OWNERS

November 12, 1975

Honorable James B. Gregory -- Administrator, National Highway Traffic Safety Administration, Department of Transportation

Dear Dr. Gregory:

ON November 11, 1975, the National Highway Traffic Safety Administration issued a proposed amendment of Motor Vehicle Safety Standard No. 121, Air Brake Systems, 49 CFR 571.121, to suspend, until January 1, 1977, service brake stopping distance requirements as they apply to buses.

In its tentative findings the Administration correctly noted that the present anti-lock system in buses is "characterized by malfunction that warrants its deactivation on all vehicles on which it is installed while a correction is fully developed" and that "a situation wherein purchasers of new buses are required to pay for anti-lock systems which are to remain deactivated for an indefinite period is inappropriate. NAMBO agrees with these findings.

The publication of this notice of proposed amendment of MVSS No. 121 creates a further problem for bus manufacturers since potential bus buyers will not purchase buses manufactured prior to whatever date the NHTSA may publish a final rule in the Federal Register due to the problems created by the anti-lock components as well as their cost.

Therefore, NAMBO urges the Administration to authorize the suspension of installation of potentially defective anti-lock components in buses pending a decision on the proposed amendment to MVSS No. 121.

The Annual Meeting of our Association begins on Sunday, November 16, in Phoenix, Arizona, at which time we will discuss and prepare a detailed explanation of the problems which would be created if the suspension cannot be made effective immediately. Our letter will be hand delivered to you on Thursday, November 20, with a copy to Mr. Richard Dyson of the Chief Counsel's Office.

Sincerely yours,

Charles A. Webb -- PRES.

cc: Richard Dyson

ID: nht75-3.38

DATE: 11/24/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Hon. J. P. Murtha - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 5, 1975, request for the criteria necessary for construction of testing equipment used to demonstrate compliance with Standard No. 121, Air Brake Systems.

The motor vehicle safety standards, including Standard No. 121, are established as requirements that vehicles must be capable of meeting if tested by the National Highway Traffic Safety Administration (NHTSA). However, the standards are not developed as demonstration procedures that detail methods a manufacturer would use to establish that its products comply. The development of actual test protocols to determine that products conform to the requirements is the responsibility of the regulated industry and the associated industries that service them.

Thus the Thiele Corporation, as a manufacturer of air-braked vehicles, may choose whatever test method gives it an adequate basis for certification that its products comply (15 U.S.C. @ 1397 (a)). Test equipment has been developed by several commercial sources, and Thiele can choose proper systems by consulting with the manufacturers of the brake components it uses. As for specifications for a test track, actual road tests are not necessary to establish compliance with Standard No. 121 where other reasonable means, such as engineering calculations coupled with laboratory tests, can be used to the same effect. Supplier warranties and instructions are one of the primary means by which smaller assemblers ascertain that their products conform.

Sincerely,

ATTACH.

CONGRESS OF THE UNITED STATES

House of Representatives

November 5, 1975

Richard B. Dyson, Chief Counsel -- National Highway Traffic Safety Administration

Dear Mr. Dyson:

Mr. William Wells of Thiele, Inc., a private truck building company, has requested that I inquire about the requirements for testing equipment under the Motor Vehicle Safety Standard 121 that went into effect in March of 1975.

Mr. Wells is interested in testing his own vehicles rather than bringing them to a professional testing track. Will you please inform me, in writing, what the criteria are for a company to build its own testing equipment in order to conform with the safety standards.

Thank you for your assistance in this matter.

Sincerely,

JOHN P. MURTHA -- Member of Congress

ID: nht75-3.39

DATE: 09/10/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Duo-matic Importers LTD.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Duo-matic's August 19, 1975, question whether Standard No. 121, Air Brake Systems, applies to an air brake coupler device that connects air brake hoses from a truck to the trailer it tows.

The answer to your question is no. Paragraph S3 (Applicability) of Standard No. 121 states that the standard applies to trucks, buses, and trailers equipped with air brake systems (with some stated exceptions). The standard therefore applies only to vehicles, and does not apply to motor vehicle equipment such as the Duo-matic coupler device.

SINCERELY,

August 19, 1975

Richard B. Dyson Assistant Chief Council Office of the Chief Council Federal Highway Administration

Refer to: A: Your letter N-40-30(MIS) dated 6-3-75

B: Motor Vehicle Safety Standard #121 as amended S5.3.3 Brake Actuation Time. With attached amendments of 11-12-74, 1-7-75, 1-17-75, 3-4-75, 3-21-75, 3-26-75, 5-15-75, and 6-11-75.

C: Duo-Matic Double Quick Release Coupling for Semi-Trailers (452-803)

D: Duo-Matic Double Quick Release Coupling for Towing Trailers (452 802)

The question is if Reference B above applies to our Wabco Westinghouse Duo-Matic coupler, which replaces the Glad Hand coupling now in use.

Your interpretation would be very much appreciated. We have enclosed two copies each of references C & D.

H. Melvin Strand, President

ID: nht75-3.4

DATE: 11/05/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: General Electric Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 8, 1975, to Ed Leysath of this agency concerning wattage requirements for Type 1A and 2A headlamps.

Your specific question is whether the wattage specifications in Federal Motor Vehicle Safety Standard No. 108 for Type 1A and 2A headlamps are design wattages or maximum wattages.

Paragraph S4.1.1.21(b) of Standard No. 108 specifies that, "Each Type 1A headlamp shall be designed for a maximum of 50 watts. Each Type 2A headlamp shall be designed for a maximum of 60 watts for each filament." (Emphasis added.) It follows, therefore, that the 50 - and 60-watt values are design wattages. You are correct in your interpretation that a tolerance of approximately 7.5% applies to these values, and that an ampere value of 4.20 for a 50-watt filament and 5.02 for a 60-watt filament is permitted. The 7.5% tolerance as you know is the average actual maximum wattage (as opposed to design wattage) rating of headlamps listed in Table 2 of SAE Standard J573 as determined by multiplication of the maximum amperage times the design volts.

Sincerely,

ATTACH.

GENERAL ELECTRIC COMPANY

July 8, 1975

Ed Leyseth -- National Highway Traffic Safety Administration, Department of Transportation

Subject: FMVSS 108 - Section 4.1.1.2.1

Dear Mr. Leyseth,

On March 26, 1975 I wrote to Bill Eason and requested an interpretation of the wattage requirements of the rectangular headlamp system. (copy enclosed). To date we have heard nothing and we urgently need your reply.

I would appreciate your help in providing us with your interpretation as quickly as possible.

Very truly yours,

Frank W. Bowers -- Manager, Product Reliability

attach: copy of 3/26/75 letter March 26, 1975

William Eason -- National Highway Safety Administration, Department of Transportation

Subject: FMVSS 108 - Section 4.1.1.21

Dear Mr. Eason:

I have heard that the Department of Transportation has interpreted Section 4.1.1.21(6) of FMVSS as far as the wattage limitation on Type 1A and Type 2A rectangular headlamps is concerned.

It is my understanding that the 50 watt limit on the Type 1A and the 60 watt limit on the 2A apply as design maximums and that a tolerance of approximate 7.5% applies to these values. This, then, would permit a max. ampere value of 4.20 for a 50 watt filament and 5.02 for a 60 watt filament. If a 40 watt filament is used than its max. amperes would be 3.36.

I agree with this interpretation and understand that these are the figures that SAE is proposing.

I would appreciate it very much if you would confirm that this interpretation is correct since design and certification of the product depends upon an accurate interpretation of the standard.

Thanks very much for your help in this matter.

Very truly yours,

F. W. Bowers -- Manager, Product Reliability

bcc: R. G. Burnor #1200