ID: nht73-5.23

DATE: 09/20/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Auto Safety Research Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 27, 1973, which requests information on the requirements of Standard 206, Door Locks and Door Retention Components, and suggests that door locking mechanisms should prevent operation of the inside and outside handles latch release controls) of both front and rear doors.

The standard presently requires that engagement of the front-door locking mechanism on passenger cars, multi-purpose passenger vehicles, and trucks render the outside door handle (latch release control) inoperative. On passenger cars and multipurpose passenger vehicles, engagement of the rear-door locking mechanism must render both inside and outside handles inoperative. Your suggestion that inside front door handles also be rendered inoperative was proposed in 1967 as an initial standard, but it was determined at that time that ease of escape in the event of accident made one-step operation of the door more desirable. It was concluded that the vehicle operator would have sufficient control over children in the front seat to permit such override operation.

We are still interested in the best arrangement of locking mechanisms and override at the various seating positions. At the moment, available accident data does not justify further rulemaking. Your comments will be fully considered in the event we decide to take further action.

AUTO SAFETY RESEARCH CENTER

June 27, 1973

U.S. Department of Transportation

Dear Sir;

We were under the impression that, since about 1968, an automobile door, once locked, could not be opened from either the outside or inside, unless it was subsequently unlocked, and that there were Federal regulations to this effect. However, at least on some 1973 cars, the doors can be opened from the inside, even while locked, and a number of people have come to us both surprised and concerned that children and others can open a supposedly locked door.

Please advise us if there is indeed a Federal regulation concerning door lock operation. If there is no regulation to the effect that the door handles, both inside and outside, are rendered inoperative when the door is locked, then may we suggest that, from a safety standpoint, such a regulation should be adopted as soon as possible.

Sincerely,

Delbert A. Russell, Jr. Director

ID: nht73-5.24

DATE: 09/21/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. John Holzer

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 7, 1973, requesting information concerning possible regulatory action involving plastic or gas filters.

Although we have no regulation concerning gasoline filters, the law under which our regulations are promulgated requires that where possible, our standards be based on performance rather than design requirements. This gives the automotive manufacturers maximum flexibility in conforming with the requirements and provides freedom to select whatever design he prefers in order to meet the requirements of the standard.

Our current fuel system requirements are contained in Federal Motor Vehicle Safety Standard No. 301, Fuel Tank Filler Pipes and Fuel Tank Connections, which was effective January 1, 1968. A copy of this standard is enclosed for your information. We have recently issued an amendment to the standard and a proposed amendment which are intended to substantially upgrade fuel systems of motor vehicles between September 1, 1975 and September 1, 1977. Copies of these rulemaking actions are enclosed for your information (38 F.R. 22397 and 22417).

Motor vehicle manufacturers are free to choose the components and designs which they consider most appropriate to their performance requirements. It is quite possible that certain components cannot be used as original equipment because of periodic regulatory actions; for example, a manufacturer may consider a glass fuel filter hazardous when he is attempting the preservation of fuel system integrity incidental to a 30 mile-per-hour, fixed barrier collision.

We would suggest that contact be made with the automotive manufacturers and original equipment manufacturers for a more complete answer to your question.

If we can be of any further assistance, please do not hesitate to contact us.

Sincerely,

September 7, 1973

Department of Transportation National Highway Traffic Safety Administration

Dear Mr. Secretary,

I would like to know if your department has or will propose any motor vehicle safety standards in the area of plastic or glass gas filters.

I am a distributor of these products and I have heard they will be outlawed or restricted in use in 1974. My name and address are,

John Holzer 217-18 64th Ave. Bayside, New York 11364 Sincerely yours,

John Holzer

ID: nht73-5.25

DATE: 10/14/73

FROM: AUTHOR UNAVAILABLE; E. T. Driver for R. L. Carter; NHTSA

TO: R. Debesson - E.T.R.T.O.

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your(Illegible Words) 71, dated September 14, 1973,(Illegible Word) that the(Illegible Words) designation in incorrectly stated in Appendix A of Standard No. 109, Table(Illegible Words) will be changed to(Illegible Words) will make the necessary correction in the next quarterly(Illegible Word)

The National Highway Traffic Safety Administration(Illegible Words)(Illegible Lines) on or about October(Illegible Words) April 1, and July 1 of each year. It is anticipated that your(Illegible Words) will be published in the Federal Registra on or about January 1, 1974.

The addition of(Illegible Words) designations to the table is accomplished through(Illegible Words) publication in the(Illegible Words)(Illegible Line)(Illegible Lines) pursuant to(Illegible Words) motor vehicle standards will be considered.

ID: nht73-5.26

DATE: 10/11/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Robertson Tank Lines, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 30, 1973, requesting a DOT code number for retreaded tires you manufacture. It appears from your letter that the tires you retread are truck tires intended solely for your company's own use.

Any tires retreaded by and solely for use by Robertson Tank Lines are exempt from NHTSA recordkeeping requirements and a code number is not required. As truck retreads are not subject to any Federal motor vehicle safety standard, you are also not required to place a "DOT" symbol on them. If you retread passenger car tires, however, you are required to place a "DOT" symbol on the tire sidewall (indicating conformity to Federal Motor Vehicle Safety Standard No. 117).

ROBERTSON TANK LINES INC.

August 30, 1973

Tire Identification and Recordkeeping Dept. National Highway Traffic Safety Administration

Dear Sir:

The attached form is our request for a tire retread D.O.T. number. Tires produced in our shop will be for our fleet use, with no resale of our tires or services.

Our main office address is:

Robertson Tank Lines, Inc. P.O. Box 1505 Houston, Texas 77002

Retread shop address:

Robertson Tank Lines, Inc. Maintenance Terminal 2401 Battleground Rd. Deer Park, Texas 77536

Thank you for your consideration in handling this matter.

Best Regards,

Donald Gary Hayes

cc: Bob Partain

Date: August 29, 1973

Tire Identification and Recordkeeping National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Gentlemen:

I hereby apply for a Retread Tire Identification Code Mark as a manufacturer of retread tires.

The following information is offered:

Retread Plant

Name:(Illegible Words)

Street:(Illegible Words)

City & State: DEERPARK(Illegible Word)

Zip Code: 77536

Telephone No. 479-3451 EXT 52

Main Office

Name:(Illegible Words)

Street:(Illegible Words)

City & State: Houston, Texas

Zip Code:(Illegible Word)

Telephone No: 623-0000

Types of Tires Retreaded

Truck:

Applicants Signature:(Illegible Words)

ID: nht73-5.27

DATE: 10/18/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson for L. R. Schneider; NHTSA

TO: Schultz, Evans and Burns

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 28, 1973 to Secretary Brinegar, concerning outside rear view mirrors.

The existing standard (No. 111) on Rearview Mirrors, is found in Title 49, Code of Federal Regulations @ 571.111. Paragraph S3.2 establishes requirements for outside mirrors. This standard applies to all passenger cars and multipurpose passenger vehicles manufactured since January 1, 1968, and establishes requirements for original equipment mirrors. It does not apply to mirrors manufactured for the aftermarket.

SINCERELY,

SCHULTZ, EWAN AND BURNS

September 28, 1973

Claude S. Brinegar, Secretary of Transportation

Dear Sir:

I am anticipating a possible suit against one of the American automotive manufacturers. The basis of this suit would be the dangerous design and manufacture of an outside side view mirror.

Pursuant to the Federal Traffic and Motor Vehicle Safety Law Chapter 38 USCA @ 1392(a), your office is to establish motor vehicle safety standards. I would greatly appreciate all standards promulgated by your office pertaining to side view mirrors which were in effect for the 1973 model year.

Yours truly,

William C. Burns

ID: nht73-5.28

DATE: 03/05/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Sekurit-Glas Union GmbH

TITLE: FMVSR INTERPRETATION

TEXT: We have received your letter of February 22, 1973, submitting material to our Docket 70-7, Fields of Direct View.

Under our procedural regulations 49 CFR @ 553.21, all submissions to a regulatory docket must be in English. We are placing your letter in the docket, but if you wish to have your report entered we must receive an English translation.

YOURS TRULY,

U.S. DEPARTMENT OF TRANSPORTATION National Highway Traffic Safety Administration

February 22 1973

Gentlemen:

We apologize for replying so late to your letter dated September 26th 1972 about our comments to Docket 70-7 (Notice 2).

Most of the tests which are mentioned in details in our comments have been realized by our company and have therefore no official signification. Concerning this matter detailed investigations have been conducted by the Medical Superintendent of the "Augenabteilung und der verkehrsmedizinisch-ophthalmologischen Untersuchungsstelle am(Illegible Word) Krankenhaus Othmarsche (Hamburg)" Priv.-Doz. Dr. Gramberg-Daniclsen. Owing to printing and editing reasons these investigations will be published in April 1973 only, in the "Klinische Monatsblatter fur Augenheilkunde" by Ferdinand Enke. In order to avoid a further waste of time we send you, enclosed, a copy of this manuscript, which shows that the thickness of the wires does not affect the driver.

We hope that this information will be helpful in your analysis of comments to the above mentioned Docket.

Sincerely, SEKURIT-Glas Union GmbH.

Encl.

ID: nht73-5.29

DATE: 10/24/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Franklin J. Kivel

TITLE: FMVSR INTERPRETATION

TEXT: Your request for information on odometer laws was forwarded to us by the Office of Consumer Affairs.

There is at this time no Federal law that requires odometers to be sealed. The Motor Vehicle Information and Cost Savings Act, which we administer, prohibits altering, resetting, or disconnecting odometers except for lawful repair. It does not, however, require sealed odometers and automobile manufacturers do not normally seal odometer units. Some manufacturers incoporate anti-tampering features which stain the odometer drum with ink or that destroy its gears if an attempt is made to reverse its direction.

The Act does require disclosure of a vehicle's actual and recorded mileage by a seller before its transfer to a buyer. We are presently conducting a study of the Act's effectiveness.

ENC. - REGULATION & ACT

ID: nht73-5.3

DATE: 09/12/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Richard Hrejsa

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of June 4, 1973, requesting information on remedies for a transferor's failure to make an accurate odometer disclosure statement. I apologize for our delay in replying.

Title IV of the Motor Vehicle Information and Cost Saving Act, Public Law 92-513, (1) prohibits the resetting or altering of an odometer to change the miles indicated on it, and (2) establishes a requirement that a transferor (seller) make a written odometer disclosure to his transferee (buyer) at the time of sale. These provisions of the law were in effect when you purchased your car in May 1973.

The two remedies for violations of the law are (1) a private civil action for $ 1,500 or treble damages by a subsequent purchaser of the car, and (2) a suit by the United States Attorney to restrain further violations of the Act. This second remedy is normally utilized only in a case of repeated violations.

If the dealer who sold you the car altered or reset the mileage after January 18, 1973, you may have a civil action against him. Also, if it is as it appears in your letter, the dealer made a false and incomplete mileage disclosure to you after March 1, 1973, which may also make him civilly liable to you. His purchase of the car in October 1972 has no bearing on his disclosure obligations to you.

You may wish to consult with an attorney about your rights in this matter. Enclosed are a copy of the Act and implementing regulations for your information.

ENCLS.

ID: nht73-5.30

DATE: 10/26/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 25, 1973, asking whether the fuel spillage measurement specified in Standard No. 301 is an average rate of one onunce per minute (your Item A) or an actual rate. (Your Item B)

Your item B is correct. Fuel spillage shall not exceed one ounce per minute in any one of the fifteen minutes of the observed period.

YOURS TRULY,

NISSAN MOTOR CO., LTD.

September 25, 1973

Lawrence Schneider Chief Council National Highway Traffic Safety Administration

This is to ask your interpretation regarding the test procedures of MVSS 301 Fuel System Integrity published in Federal Register, Vol. 38, No. 160 (Docket No. 70-20) on August 20, 1973.

We feel that the fuel spillage requirement following cessation of vehicle motion of S.5.4 has the following two meanings:

A) The calculated fuel spillage rate.

Total amount of fuel spillage (oz.)

B) The measured fuel spillage rate every minute. All of the collected fifteen one-minute timed samples shall not exceed one ounce per minute.

We would like to know which definition is correct understanding. Your prompt reply would be greatly appreciated.

Very Truly Yours,

Tatsuo Kato

ID: nht73-5.31

DATE: 10/19/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Jordan Research Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 18, 1973 asking for an interpretation of Standard No. 108. You understand that "the stop lamps must light when applying the automobile brakes and/or when applying the trailer brakes individually." You tell us of a product that gives a driver "manual control of the trailer brakes [but] does not light the stop lamps in this mode."

Paragraph S4.5.4 of Standard No. 108 requires that "the stop lamps on each vehicle shall be activated upon application of the service brakes." This section of Standard No. 108 requires that stop lamps on new motor vehicles be wired in this manner. The standard does not apply after the vehicle is purchased, and thus does not prohibit a vehicle owner from modifying the wiring of his vehicle by adding the Electronic Trailer Brake Control. Such an addition, however, might be precluded under State law.