ID: nht67-1.15

DATE: 02/27/67

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr. M.D.; NHTSA

TO: Edward K. Kennedy, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 10, 1967.

Motor Vehicle Safety Standard No. 105 applies only to new passenger cars manufactured January 1, 1968, or later. Although the National Traffic Safety Agency intends to issue additional standards in the future that apply to items of motor vehicle equipment, most of the initial Motor Vehicle Safety Standards issued January 31, 1967, apply to vehicles only, as the application paragraph of each standard specifies.

Please do not hesitate to call upon us if we can be of further service to you.

ID: nht67-1.16

DATE: 06/19/67

FROM: AUTHOR UNAVAILABLE; G. C. Nield; NHTSA

TO: S.I.C.A. Peugeot

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 20, 1967, concerning the clarification of several requirements of Motor Vehicle Safety Standard No. 105.

The bulb for the emergency brake system effectiveness indicator may also be used for the hand brake indicator light. Further, the means for establishing the electrical contact for testing the emergency system indicator bulb may be the hand brake lever.

This clarification is not considered as a change in the requirements of the standard as issued. All characteristics required for the indicator light must be met.

ID: nht67-1.17

DATE: 08/07/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Kar Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Dr. Haddon asked me to thank you for your letter of June 19 concerning certification procedures for your product.

Apparently our reply of June 14 did not reach you prior to your sending your second letter. I have enclosed a copy of this answer for your reference. This reply was based on the assumption that your KAR Safety Mirror was not original equipment but rather would be sold in the aftermarket.

Your second letter asks three questions. The first question states that the KAR Safety Mirror will be original equipment on a new Camper being introduced in 1968 and asks what steps, if any, must be taken to certify said mirror for this specific purpose. The answer to this question is that the certification obligation contained in Standard No. 111 applies to the vehicle and it is therefore the vehicle manufacturer who will have to certify that the vehicle needs all applicable standards including Standard No. 111. Question No. 2 concerns the transfer of mirrors from cars now equipped with the KAR Safety Mirror, and question No. 3 concerns the certification requirements on 1963 models where the owner installs the KAR Safety Mirror as an after purchase add on piece of equipment. The answer to both of these questions, of course, is that there is no certification requirement at this time for the mirror, as such, as an item of motor vehicle equipment.

Thank you again for your interest in motor vehicle safety.

June 19, 1967

William Haddon, Jr., M.D., Administrator National Traffic Safety Agency

Under date of May 19, 1967, I wrote to you asking for guidance in submitting the KAR Safety Mirror to the proper local authority for certification under the provisions of the National Traffic & Motor Vehicle Act of 1966. The absence of a reply, to this date, would indicate you have not had sufficient time to implement this prodigious and important program. However, at the risk of being importunate, I earnestly inquire for answers to the conditions presented herein; namely,

1. The KAR Safety Mirror will be original equipment on a new Camper being introduced in 1968. What steps, if any, must be taken to certify said mirror for this specific purpose?

2. A number of owners now having cars equipped with the KAR Safety Mirror will trade for 1968 models and will transfer said KAR Safety Mirror to the new car immediately 'after purchase'. Is prior certification required under these circumstances? If so, how do we proceed?

3. Will prior certification be required for the KAR Safety Mirror when owners of 1968 models buy outright and install said KAR Safety Mirror directly 'after purchase' of the new car?

We would appreciate your comment and reply to these questions at the earliest practical moment.

Alan Axtell, President

cc Honorable George Murphy

cc Honorable Warren G. Magnuson

Will Scott Ford Motor Company

I see no objection to your request of June 28, 1967, to ship the outside mirrors loose in your Econoline models until reaching dealer destination. Since the mirror is shipped and the mounting holes are drilled at the factory, the installation of the mirror by the dealer is purely a routine dealer service.

Sincerely,

William Haddon, Jr., N.B.

DR. WILLIAM HADDON JR DIRECTOR NATIONAL HIGHWAY SAFETY BUREAU FEDERAL HIGHWAY ADMINISTRATION WASHINGTON D C 20591

PARAGRAPH S3.2.1.1 OF STANDARD NUMBER 111 SPECIFIES THAT AN OUTSIDE REAR-VIEW MIRROR QUOTE SHOULD BE INSTALLED UNQUOTE ON APPLICABLE VEHICLES. IT HAS JUST BEEN BROUGHT TO MY ATTENTION THAT FORD ECONOLINE MODELS ARE SHIPPED WITH OUTSIDE MIRROR LOOSE IN VEHICLE. THIS PRACTICE IS FOLLOWED BECAUSE OF RESULTING INSUFFICIENT CLEARANCE FOR LOADING ON LOWER LEVEL OF HAULAWAY VEHICLES IF MIRROR IS INSTALLED AT FACTORY. ECONOLINES EQUIPPED WITH MIRRORS COULD, OF COURSE, BE SHIPPED ON UPPER HAULAWAY LEVEL ONLY BUT SHIPPING DELAYS AND FREIGHT PENALTIES THAT WOULD RESULT FROM UNDERUTILIZATION OF EQUIPMENT MAKE SUCH A PLAN UNREASONABLE.

WE DRILL MIRROR MOUNTING HOLES AT FACTOR TO INSURE THAT MIRROR IS IN FACT, INSTALLED BY DEALER PRIOR TO CUSTOMER DELIVERY. WOULD THIS BE ACCEPTABLE TO BUREAU OR WILL IT BE NECESSARY TO CLASSIFY THESE UNITS AS IMCOMPLETE VEHICLES SORRY TO BOTHER YOU WITH THIS DETAIL WHEN BUREAU HAS FAR MORE IMPORTAND SUBJECTS UNDER CONSIDERATION REGARDS

WILL SCOTT FORD MOTOR AUTOMOTIVE SAFETY DIRECTOR CENTRAL OFFICE BLDG DEARBORN MICH

ID: nht67-1.18

DATE: 06/16/67

FROM: AUTHOR UNAVAILABLE: Robert M. O'Mahoney; NHTSA

TO: Peugeot, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: In answer to your letter of May 26, concerning Federal Motor Vehicle Safety Standards Nos. 208 and 210, your interpretation is correct: a four-passenger automobile (such an the Peugeot 404) must have two Type 2 seat belt assemblies for the front seat passengers if the windshield header is within the head impact area, two Type 1 or Type 2 sent belt assemblies for the front seat passengers if the windshied hender is not within the hand impact area, and two Type 1 seat belt assemblies for the rear seat passengers. However anchorages for Type 2 seat belt assemblies are required in the rear to enable the owner to install Type 2 seat belt assemblies should he desire to afford his rear seat passengers this means of protection.

May 26, 1967

Mr. O'Mahoney National Traffic Safety Agency United States Dept. of Commerce

Regarding our telephone conversation of May 26, I am in need of legal interpretation concerning Standards 208 and 210.

According to Standard 208, paragraph S3.1.1, Type 2 seat belt assembly should be installed in each outboard passenger car in the front seat position, including the windshield, within the impact area, which, in my mind includes the front seats only. Thus, the rear seats should have only Type 1 (lap belt).

From Standard 210, table 1, it seems to clearly indicate that we must have seal belt anchorages for a Type 2 seat belt in outboard seats in the rear, but it does not expressly state that the Type 2 seat belts should be installed in the outboard seats in the rear.

Would you kindly let me know if my interpretation is correct: on a 4-passenger car, we should have Type 2 seat belts in the front, Type 1 seat belts in the rear, but anchorages in the rear for Type 2 and Type 1 seat belts.

Thank you very much in advance for your reply.

Henri B. Combe Executive Vice President

ID: nht67-1.19

DATE: 12/22/67

FROM: AUTHOR UNAVAILABLE; William Haddon Jr. M.D.; NHTSA

TO: McIntosh Inc.

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of November 3, 1967, to Mr. Lowell K. Bridwell, requesting clarification on certain aspects of the Motor Vehicle Safety Act.

In answer to your specific questions, please be advised that the supplier of a component of a motor vehicle is a manufacturer within the meaning of the Motor Vehicle Safety Act. However, he is not obligated to certify that the item of motor vehicle equipment he manufactures complies with the standard unless he is supplying that item to a distributor or dealer, and then only if there is an applicable Federal Standard.

As regards identification of parts, there is no specific requirement under the Act.

With reference to the entire matter of keeping of records under Section 112(c), this Bureau has under study an appropriate program based on evaluation of certification experience during the next few months that will load to specific regulations. It is contemplated that these regulations will have an effective date of January 1, 1969.

If there is any other information you would like, I hope you will let me know.

ID: nht67-1.2

DATE: 06/19/67

FROM: WILLIAM HADDON, JR. -- M.D. FOR LOWELL K. BRIDWELL, NHTSA

TO: E. W. Kintner

TITLE: FMVSS INTERPRETATION

TEXT: Re: Your Request for Interpretation -- Initial Federal Motor Vehicle Standard No. 105

This is in response to your letter of May 29 on behalf of Minnesota Automotive, Inc., requesting an interpretation of Initial Federal Motor Vehicle Standard No. 105 such as would allow the installation of a one-way check valve hydraulic parking brake system as a supplement to the friction type system required by that Standard.

Standard No. 105, by its own terms, applies to passenger cars and not to any other category of motor vehicle. As to passenger care either of the statements set forth in your letter in correct and you may so inform your client. This Standard does not proclude or prohibit the installation of one-way check valve hydraulic brake systems on passenger care which, of course, must be also equipped with parking brakes meeting the requirement.[Illegible Word] $ 4.3 of that Standard.

Since this interpretation is fairly obvious it is not suitable for publication in the Federal Register.

Thank you for the support expressed in your letter.

Sincerely,

May 29, 1967

Lowell K. Bridwell Federal Highway Administrator Federal Highway Administration U.S. Department of Transportation

Re: Request for Interpretation -- Initial Federal Motor Vehicle Standard No. 105

Dear Mr. Bridwell:

Minnesota Automotive, Inc., which I serve as counsel, has authorized me to submit a Request for Interpretation of Initial Federal Motor Vehicle Standard No. 105 to your office for clarification of the permissible use of brake lock safety devices as a parking brake system, in addition to the safety equipment required by that standard.

Minnesota Automotive, located in Mankato, Minnesota, manufactures a line of hydraulic brake products, including a one-way check valve hydraulic parking brake which connects into the primary braking system hydraulic unit and shoes. This device, without interfering with normal brake service, will fit any vehicle on the road having a hydraulic braking system, and when actuated will effectively convert the system into a powerful, reliable parking brake lock. Where a dual service brake is employed, two of these devices can be used, one geared to each hydraulic system. These devices serve as important supplements to the standard parking brake system of the vehicle.

The hydraulic brake lock is designed to meet the needs of heavy duty and high frequency parking brake usage. I might mention parenthetically that the brake locking devices manufactured by Minnesota Automotive are no longer under patent; other automotive equipment manufacturers have marketed and are marketing safety brake lock products using the one way check valve principle.

Problems have arisen in the marketing of these safety products, particularly with respect to vehicles currently subject to the jurisdiction of the Interstate Commerce Commission, because of that agency's safety regulation on parking brakes. Specifically, Section 193.41 of the ICC Motor Carrier Safety Regulations provides that the "parking brake or brakes, shall . . . remain in the applied condition . . . despite . . . leakage of any kind. . . ." Since the brake locking device in connected into the service brake hydraulic system and consequently will not function if there is leakage in the latter, many potential users of the device have construed the ICC regulation as prohibiting the use of such a device, even when installed in addition to a parking brake system meeting the requirements of the regulation.

A potential difficulty is again presented by Paragraph S4.3 of Initial Standard No. 105, as well as related standards which may be developed by the Bureau in the future. Standard No. 105 requires a "parking brake system of a friction type with a solely mechanical means . . . "Although we would agree that neither this language nor the above noted standard necessarily implies that safety locks are not permitted, the marketing resistance based on the existing ICC regulation indicates the need for clarification in this area.

In view of this experience, we respectfully request an interpretation as to whether Initial Standard can be construed as follows:

1. Paragraph S1 of Initial Standard No. 105, which sets out the purpose and scope of the standard, is not to be construed as prohibiting the use of hydraulic holding devices, such as one way check valves, in hydraulic brake systems, in addition toparking brakes which meet the requirements of Paragraph S4.3: or alternatively,

2. The requirement of Paragraph S4.3 that a parking system of a friction type with a solely mechanical means be provided does not preclude the installation of hydraulic holding devices, such as one way check valves, in addition to the mechanical parking brakes.

Because of the desirability for all manufacturers producing these safety devices of an official position establishing the propriety of using such one way check valve brake locks, we further request that any interpretation to this effect be published in the Federal Register.

On behalf of Minnesota Automotive, I want to take this opportunity to assure you of our complete support of your efforts in attempting to meet the challenging goal of developing meaningful vehicle safety standards. We congratulate you on the significant progress made thusfar.

Should you require any additional information with respect to our Request for Interpretation, please do not hesitate to contact me.

Sincerely,

Earl W. Kintner -- ARENT, FOX, KINTNER, PLOTKIN & KAHN

ID: nht67-1.20

DATE: 10/02/67

FROM: AUTHOR UNAVAILABLE; George C. Neild; NHTSA

TO: Patton, Blew, Verrill, Krand and Boggs

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of August 10, 1967, you requested clarification of the application of Motor Vehicle Safety Standard No.(Illegible Word) to boat trailers.

Although a boat trailer does in some respect resemble a "pole trailer," it does not completely conform to the definition of a "pole trailer," as stated in Section 235.3 of the Initial Federal Motor Vehicle Safety Standards. This section states in part that a "pole trailer" is for transporting long or irregularly shaped loads such as poles, pipes, or structural members capable generally of sustaining themselves as(Illegible Word) between the supporting connections. The single load (a boat) on the boat trailer does not appear to meet these stated provisions of the definition.

The primary purpose of clearance and identification lights is to identify a vehicle that is 80 or more inches in overall width, regardless of the height of the vehicle. It should be noted, in this respect, that a "height-above-road-surface"(Illegible Word) for location of the lights is not specified in Standard No.(Illegible Word). Nevertheless, we have initiated a study to further determine the applicability of identification lights to best trailers.

With regard to your several questions on the use and location of side marker lights, it appears that each trailer model must be considered individually, particularly with respect to the front side marker lights. As you suggested, the extreme rear of the transverse marker provides a possible location for the rear side marker light. On those trailer models having a long transverse marker, it appears possible to locate the front side marker light on the extreme front side of the transverse marker. For those models having an extremely short transverse marker, it appears that a location as far forward as possible, exclusive of the trailer tongue, would meet the requirements of the standard.

Thank you for your interest in the motor vehicle safety standards.

ID: nht67-1.21

DATE: 05/15/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Fire Apparatus Manufacturers Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Your March 7, 1967, letter to Dr. William Haddon, Jr., requested that you be advised regarding the applicability of lighting requirements, as spacified in the Initial Motor Vehicle Safety Standards to fire apparatus.

With exception as noted in Section 255.7, page 2409 of the Federal Register, Volume 32, Number 23, dated February 3, 1967 (copy enclosed), the lighting requirements will be applicable to fire apparatus. Initial Standard No. 108 covers lighting requirements for vehicles (as specified therein) that are 80 or more inches wide overall and becomes effective January 1, 1968. A Notice of Proposed Rule Making (see page 2418) of enclosed Federal Register includes a Proposed Amendment to Standard No. 108 and a Proposed Initial Standard No. 112, covering vehicles (as specified therein) that are less than 80 inches wide overall. It is anticipated that the proposed Amendment and Initial Standard No. 112 will also become effective on January 1, 1968.

Thank you for your interest in the Motor Vehicle Safety Standards.

FIRE APPARATUS MANUFACTURERS ASSOCIATION, INC.

March 7, 1967

Dr. WILLIAM HADDON, JR. -- NHTSA

We have an inquiry from one of our members as to whether or not all of the lighting standards under the Initial Federal Motor Vehicle Safety Standards as published in the Federal Register Volume 32, Number 23, Part II dated Friday, February 3, 1967 will apply to fire apparatus.

Will you please advise us on this matter so that we may inform our members.

Thank you for your prompt attention.

C. L. Koepenick Secretary-Treasurer

ID: nht67-1.22

DATE: 11/27/67

FROM: AUTHOR UNAVAILABLE; Andrew K. Ness; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 10, 1967, in which you requested a clarification of the use of the term "combined optically" as used in Motor Vehicle Safety Standard No. 188, Sections S8.3(c) and S3.4.4.3.

S3.3(c) Lamp Combinations and Equipment Combinations. Two or more lamps, reflective devices, and items of associated equipment may be combined if the requirements for each lamp, reflective device, and item of associated equipment are Met, except that --

(c) No clearance lamp may be combined optically with any taillamp or identification lamp.

This means that no clearance lamp may be combined to use a lense that is common to any other lamp such as a taillamp or identification lamp. The clearance lamp shall have a unique lense.

S3.4.4.3 Stoplamps that are combined optically with turn signal lamps need not be operable when the combination is in use as a turn signal or as a vehicular hazard warning signal.

This means that stoplamps that have a lense that is common with the turn signal lamps do not have to be operable when the combined stoplamp and turn signal lamp is used primarily as a turn signal or as a hazard warning signal. Stoplamps need not be operable when the combined stoplamp and turn signal lamp unit is used as a hazard warning or turn signal indicator.

We trust these comments will be of assistance in clarifying your problems.

ID: nht67-1.23

DATE: 08/10/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Thermo King Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 11, 1967, regarding the applicability of the Federal Motor Vehicle Safety Standards to accessories which are purchased for installation after procurement of the car and, in particular, Safety Standard No. 201.

Standard No. 201, "Occupant Protection in Interior Impact -- Passenger Cars," applies only to vehicles as originally equipped and does not apply to accessories such as "after market" auto air conditioners. However, the public would certainly benefit from the maximum degree of conformance that may be feasible on after market installations.

It is sincerely regretted that a written response to your first request was not received by you and trust that you were not inconvenienced.

March 14, 1967

Dr. William Haddon Department of Commerce

As manufacturers of "after market" auto air conditioners, the National Traffic and Motor Vehicle Safety Act as passed on January 23, 1967, is of concern to us. Does this Safety Act apply to manufacturers of accessories which are purchased by the car owner after he receives the car? The case in point is a car owner which purchases an "add-on" auto air conditioner; must this accessory comply with Standard 201?

Recently one of our Engineers (Mr. D. Gregerson) contacted your office (Clayboure) and received verbal "no" answers to the above questions. Your aides mentioned that this could be confirmed by requesting it by letter. We would appreciate this confirmation when convenient for you.

Very truly yours,

L. L. Willis Vice President - Engineering