ID: nht72-3.45

DATE: 08/23/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Fairchild Semiconductor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 26, 1972, on the subject of the situations in which S7.4.3 of Motor Vehicle Safety Standard No. 208 permits operation of the engine starting system, notwithstanding the ignition interlock requirements of S7.4.1 of the standard.

Your first question is whether the engine may be restarted if the ignition switch is turned off after the driver has left the seat. Our reply is that restart would not be permitted except within a period of three minutes after the switch has been turned off. There is no sequential relationship between the operation of the switch and the driver's leaving the seat, so that the starting system will have to become inoperable if the driver has left the seat and has turned the ignition off, regardless of whether he turned the switch before or after leaving the seat.

Your second question is whether the engine may be restarted if the ignition switch is turned off, then on, and then the driver leaves his seat. Our reply is again that restart would not be permitted. S7.4.3 refers to operation "if the ignition has not been turned off". Once the ignition has been turned off, turning it on again will not revive the restart mode unless the engine is actually started again and then stopped with the ignition "on".

We have forwarded your check for a Federal Register subscription to the Superintendent of Documents. Enclosed you will find a copy of Notice 20, as you requested.

ID: nht72-3.46

DATE: 03/17/72

FROM: J.E. LEYSATH FOR E.T. DRIVER -- NHTSA

TO: U.M. Electrical Distributers Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 6, 1972, concerning warning buzzers for the automobile industry.

The National Highway Traffic Safety Administration has issued two safety standards which specify warning requirments. These requirements are given in Paragraph S4.4 of Standard 114 and Paragraph S7.3.1 of Standard 208. A copy of these two standards are enclosed for your review and further information.

You will note that these standards do not stipulate minimum requirements for the warning devices, and, at the present time, we have no plans to specify such requirements. The data sheet, however, which you enclosed will be useful to us should we specify such requirements in future amendments to these standards.

We appreciate your writing to us, and if we can be of any further service, please let us know.

ID: nht72-3.47

DATE: 10/13/72

FROM: CHARLES H. HARTMAN FOR DOUGLAS W. TOMS -- NHTSA

TO: Mr. Jesse R. Hollins

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your petition of August 15, 1972, as supplemented by your brother's letter of August 28, 1972, requesting our consideration of your seat belt warning system as a substitute for the warning and interlock systems currently specified in Motor Vehicle Safety Standard No. 208.

As we understand the operation of your system, one of its operating modes resembles the mode presently specified in S7.3.1 of the standard. Your system provides for the operation of a warning signal when the ignition is "on" and the seat belts at occupied front positions have not been operated. Section S7.3.1, considered by itself, would permit such a system, even though that section does not require the warning to operate unless the engine is operating and the vehicle is in a forward gear.

However, your system does not meet the requirement of S7.3.3 that the warning not operate when the vehicle is idling with the transmission in park or neutral position and the belts have not been operated. The argument presented in your brother's letter is that the sudden operation of the warning system when the transmission is placed in a forward gear would be an annoyance to occupants and would result in circumvention of the system.

The NHTSA position is that the convenience of being able to sit unbuckled in a parked car without the warning is such that this "quiet" period should continue to be required. It may be that some occupants will be bothered when the warning begins to sound as they place the car in gear. However, we are persuaded that the current system would be less likely to be circumvented than a system that has no period of non-operation.

The other operating mode of your system has no direct counterpart in Standard 208. As you describe it, returning the ignition to the "off" position will activate the warning system, even after removal of the key, until the belts are returned to their stowed positions. Our letter of August 17, 1972, explained that this will not conform to the requirement of S7.3.2 that the warning must not operate when the belts at occupied front positions have been operated.

We recognize that there are other possible alternative to the required interlock system as a means of encouraging seat belt usage, and several have been suggested. We consider it important, however, that these systems work in a substantially uniform manner, for maximum public safety, acceptance and convenience. On the basis of all the material we have received to date, including yours, we have decided that our present requirements represent the best combination for the alternative to passive restraints in the period 1973-1975. I therefore must deny your petition to substitute your system, or allow it as an alternative, for the interlock system.

ID: nht71-3.17

DATE: 06/08/71

FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY DAVID SCHMELTZER

TO: British Leyland Motors Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 20, 1970, requesting an interpretation of the Tire Identification and Record Keeping Regulation (49 C.F.R. 574).

The proposals you described in your letter, paragraphs 1 and 2, will certainly meet the minimum requirements of the regulation and are perfectly acceptable. The regulation requires that a record be kept of the type of tire shipped on or in the vehicle. It does not require that the individual tire identification number be(Illegible Word) with the name and address of the purchaser.

If a vehicle dealer sells a vehicle equipped with tires which were not shipped on or in the vehicle, the vehicle dealer is considered a tire dealer under section 574.9(b) and as such, he is required to record the name and address of the first purchaser along with the tire identification number, and forward this information to the tire manufacturer. However, the tire manufacturer may designate someone else to maintain the required records by section 574.7. Therefore, it would be acceptable to have your vehicle dealers forward the required information to you instead of to the tire manufacturer, if the tire manufacturer designates you to maintain the records of tires installed on your vehicles.

If we can be of any further assistance, please feel free to write.

ID: nht71-3.18

DATE: 06/09/71

FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL; SIGNATURE BY DAVID SCHMELTZER

TO: Lynd-Talin Tire Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 10, 1971, concerning the Tire Identification and Record Keeping Regulation. Please accept my apology for not responding earlier.

The National Highway Traffic Safety Administration considers each enforcement case on an individual basis. If a retreader could demonstrate that good faith attempts had been made to obtain the tin plate by May 22, 1971, and due to circumstances beyond his control he was unable to mark tires manufactured after May 22, 1971, with the required information, we would certainly take this into consideration before beginning any enforcement action.

ID: nht71-3.19

DATE: 06/10/71

FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY DAVID SCHMELTZER

TO: Triplex Safety Glass Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 28, 1971, concerning the marking requirements in the proposed amendment to Standard No. 205, "Glazing Materials" (Docket No. 71-1; Notice 1). These requirements are only proposed at present, as is their effective date, and do not represent the agency's final decision on the matter. If the agency determines to amend the standard, and before any compliance with new requirements is required, a "final rule" will be issued that is based on the proposed rule but may differ in some respects from it. The final rule will specify an effective date for these new requirements which, in this instance, will probably be later than the effective date proposed.

You ask whether the effective date of the proposed standard would apply to the manufacture of the glazing, or to the fitting of the material into the vehicle. Standard No. 205 applies to "glazing materials for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses", and the effective date of any amendment to this standard refers to the date of manufacture of the glazing material, and not to its fitting into the vehicle.

Your second question, whether we will accept your marking without a hyphen between the "DOT" symbol and your code mark, has been answered in our letter to you of May 26, 1971.

I hope this clarifies the situation.

ID: nht71-3.2

DATE: 05/14/71

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: J. A. Kackney & Sons, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 3, 1971, to Mr. Julian E. Leycath of this Administration, concerning the installation of supplementary stop and rear turn signal lamps on your van type delivery bodies.

Installation of the supplementary stop and rear turn signal lamps, in the manner described in your letter and as shown on your drawings 69C-81, and 69C-41 (enclosed with your letter). would not impair the effectiveness of lamps, reflective devices, and associated equipment required by Federal Motor Vehicle Safety Standard No. 108 and would not be prohibited by that standard.

Standard No. 108 presently specified that the required stop lamps be mounted at a height "not less than 15 inches nor more than 72 inches". No mounting heights are presently specified for the required rear turn signal lamps. Effective January 1, 1972, the mounting height of required rear turn signal lamps will be "not less than 15 inches nor more than 83 inches". These limitations on mounting heights for the required lamps are not applicable to supplementary stop and rear turn signal lamps.

ID: nht71-3.20

DATE: 06/21/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: D. R. Elder

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to a carbon copy of a letter you sent to Mr.(Illegible Word) Office of Consumer Affairs and Public Information of the National Highway Traffic Safety Administration, concerning the Tire Identification and Record Keeping regulations (49 CPR Part 574).

In the last paragraph of your letter you state that the regulation "has absolutely no bearing on the manufacture and (Illegible Word) of of any off-highway vehicles such as, wheeled form or industrial tractors, wheeled motor scrapers, tractor drawn scrapers, garden tractors, "terre tigers", wheeled agricultural equipment, lift trucks, etc.", (emphasis added). This appears to be a broadening of the interpretation given to you by Mr.(Illegible Word). This letter is to make it clear that the regulation applies unless the product you manufacture is not a motor vehicle within the definition of the National Traffic and Motor Vehicle Safety Act. Enclosed is a copy of the Act. Your specific attention is directed to the definition of a motor vehicle found in Section 102(3).

While vehicles used primarily for-off-rond purposes are not considered motor vehicles within the meaning of the Act, I suggest you request an interpretation from this office (enclosing brochures) concerning the specific vehicles you manufacture.

ID: nht71-3.21

DATE: 06/24/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: 707 Tire Service Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of June 15, 1971, concerning the Tire Identification and Record Keeping Regulation (49 CFR Part 574).

As stated in the interpretation published in the Federal Register of May 28, 1971, under section 113(f) of the National Traffic and Motor Vehicle Safety Act, "it is the tire manufacturer who has ultimate responsibility for maintaining the records of first purchasers".

Under the Act and the Regulation, we have no authority to require a tire manufacturer to choose someone as his designee. I have asked Goodyear's counsel for their position with regard to the possible use of tire dealers customer's lists and was forwarded a letter dated June 8, 1971, from the Goodyear Tire and Rubber Company which sets forth the company's policy with regard to the prohibition in the regulation. I enclose the letter for your information.

ENCLOSURE

ID: nht71-3.22

DATE: 06/30/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Fiat Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 19, 1971, in which you request an interpretation of the applicability of Federal Motor Vehicle Safety Standard No. 206 to the right side door of the Fiat City Taxi Car. I apologize for the delay in responding to your letter.

Your questions and their answers are set forth below. Questions 1 and 2 have been reversed to facilitate discussion.

"Can this door be classified as a sliding door?" Yes, if, as it appears, the mechanism attaching the right side door to the vehicle is a sliding device rather than a hinge system.

"Can the outside door handle release control be inoperative and the door opened only from the inside." Yes, since the right side door is a sliding door, rather than a hinged door, it is not subject to the door lock requirements specified in S4.1.3 of the Standard.

"Which are the loads, the direction and location of the load, and the test procedures to be followed to demonstrate that this door conforms to the Standard 206." The performance requirements and demonstration procedures which apply to sliding doors are specified in S4.3 and S5.3, respectively. S4.3 requires that the track and slide combination or other supporting means for the right side door not separate when a total transverse load of 4,000 pounds is applied, with the door in the closed position. Compliance of the right side door with S4.3 is required by S5.3 to be tested by applying an outward transverse load of 2,000 pounds to the load bearing members at the opposite edges of the door. The total force applied would be 4,000 pounds. S5.3 requires that the testing be done either in the vehicle or with the door retention components in a bench test fixture.

"Can this door have only a fully latched position?" Yes. Standard No. 206 does not specify any requirements for latches on sliding doors.

Please write if I can be of any further assistance.