ID: nht68-1.21

DATE: 04/26/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 19, 1968, to Mr. George C. Nield, requesting a clarification of paragraphs S3.4.4 and S3.4.4.1 of Motor Vehicle Safety Standard No. 108.

In your letter you listed possible brake combinations as follows:

1. A vacuum over dual hydraulic brake system and a hand operated mechanical brake are provided.

2. A full air brake system and a hand operated mechanical brake are provided.

3. A full air brake system with a spring loaded emergency stopping system which is actuated at a pre-determined low air pressure level and a hand operated mechanical brake are provided.

In accordance with the interpretation issued February 27, 1967 (32 F.R. 3390, copy enclosed), on "emergency brakes," the supplementary brake systems included in the above brake combinations are not emergency brakes. Therefore, paragraph S3.4.4 of Standard No. 108 does not require that the stop lamp be actuated upon application of these supplementary brakes.

Thank you for writing.

ID: nht68-1.22

DATE: APRIL 26, 1968

FROM: AUTHOR UNAVAILABLE; William H. Risteen; NHTSA

TO: Halfpenny, Hann and Ryan

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of February 6, 1968, to Mr. Lowell K. Bridwell, has been referred to me for reply.

In regard to your question, "Can a car dealer install equipment for which no standards have been established (such as air conditioning units) on a motor vehicle without violating the National Traffic Motor Vehicle Safety Act of 1966?", we are pleased to provide the following clarification.

The fact that there is not a standard directly applicable to air-conditioners or other items of equipment does not mean the dealer has no responsibility under the Act if he installs these equipment items. Any modification to the vehicle before the first purchase for purposes other than resale, must not alter the existing compliance of the motor vehicle with applicable standards.

In the case of an air-conditioner, if it is installed in the instrument panel or any other part of the interior of a passenger car covered by Standard No. 201, it would have to comply with the requirements of the Standard.

I hope this response clarifies the matter with you.

ID: nht68-1.23

DATE: 11/20/68

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Rolite, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 24, 1968, concerning glazing materials in your recreational vehicles.

FHWA Ruling 68-1, published in the Federal Register on March 26, 1969, (33 FR 5020) specified that campers must meet the requirements of Standard No. 205, Glazing Materials. Copies of FHWA Ruling 6S-1 and Standard No. 205 are enclosed.

We do not have any provision for exempting certain windows from the requirements of Standard No. 205 because of their foldaway position during transport. It is true, also, that your camper could be transported in the erected condition. Therefore, all glazing materials in the camper must meet the requirements of Standard No. 205.

Travel trailers are not included in the application of Standard No. 205; hence, do not have to meet the safety glazing requirements.

Sincerely,

Enclosures

October 24, 1968

Roy Dennison Motor Vehicle Safety Performance Service National Highway Safety Bureau Federal Highway Administration

Dear Mr. Dennison:

I have been in contact with Mr. Walter Peck, Standards Director for the Recreational Vehicle Institute, Inc. and he has recommended that I communicate with you in regards to National Highway Safety Standards on our pick-up camper.

I have enclosed a photograph of one of our trailers and I am sorry, but, we do not have a photograph of our pick-up camper, because this is our first run on a pick-up camper and we do not have our publications ready yet. This, print shows how our trailer collapses into the (down) position. All the windows in our travel trailer are inside and there are no visible outlets when the trailer is down because it was not designed for people to ride in when being towed.

On our pick-up camper the roof also folds to a height of approximately 16 inches over the cab, but we have provided 2 side windows that are of safety glass, which meets the National Highway Safety Bureau standards. The side walls on the camper that fold in have windows and I would like to have an opinion from you as to whether the folding windows, or the windows in the wall that fold in and are encased, would also have to be safety glass.

I realize that ours will be a special consideration, a case that will have to have a special reading from you or someone of your position, connected with the Highway Safety Bureau. I would appreciate any correspondence that you would be willing to offer on this matter. We need something on almost an urgent basis, as you can imagine, so that we comply with all regulations.

I will be waiting for your reply, and if you have any questions, do not hesitate to write.

Sincerely,

ROLITE, INC., Division of Larson Industries, Inc. --

Bob Dahlke Plant Manager

Enclosure

ID: nht68-1.24

DATE: 05/09/68

FROM: SIGNATURE UNAVAILABLE; NHTSA

TO: Counihan, Casey and Loomis

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 4, 1968, to Mr. Edwin L. Slagle, concerning Federal Motor Vehicle Safety Standard No. 205.

Standard No. 205 requires that glazing materials manufactured for use in passenger cars, multipurpose passenger cars, multipurpose passenger vehicles, trucks, buses, and motorcycles for sale in the United States on or after January 1, 1968, meet the requirements of ASA standard 226.1966. In addition, passenger cars, multipurpose passenger vehicles, trucks, buses, and motorcycles manufactured on or after January 1, 1968, for sale in the United States, must contain glazing materials that meet the requirements of ASA Standard 226.1-1966.

The following information is offered in answer to your qeustions:

Q. "We would appreciate your advice as to whether under Section (sic) 205, our members may install windshields manufactured prior to January 1, 1968, and containing a plastic interlayer of 0.015" subsequent to January 1, 1968?"

A. Yes, preformed or presized windshields manufactured prior to January 1, 1968, of 0.015 plastic interlayer may be used as replacement glass in used vehicles after January 1, 1968.

Q. "We would also appreciate your advice as to whether the fact that a glass dealer cuts a windshield to size from material manufactured prior to January 1, 1968, would alter your answer to our first question."

A. A dealer who cuts a windshield to size is considered a manufacturer, hence after January 1, 1968, 0.015 plastic interlayer

[Page 2 Is Missing.]

ID: nht68-1.25

DATE: 04/18/68

FROM: William H. Risteen; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of February 15 and March 8, l968, concerning application of Federal Motor Vehicle Safety Standard Number 205.

Glazing materials used in campers, pickup canopies, and covers must conform to the requirements of Federal Motor Vehicle Safety Standard Number 205.

I am enclosing a copy of [Illegible Word] Ruling 68-1 published in the Federal Register, Volume 33, Number 59 on March 26, 1968, and a copy of the Federal Motor Vehicle Safety Standards (with Amendments and Interpretations through February 15, 1968).

ID: nht68-1.26

DATE: 07/29/68

FROM: DAVID SCHMELTZER FOR ROBERT M. O'MAHONEY -- NHTSA

TO: Anadite Products Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 23, 1958, in which you ask that:

1) We "confirm in writing immediately that all forward facing windows in multipurpose passenger vehicles must be glazed with S-2 laminated with .030 plastic film [and] . . . etched as required in Z25."

2) We confirm that anything less than edges(Illegible Word) specified in J573 [Society of automotive Engineering Recommended Practice J573 'automotive glazing', June 1950] will(Illegible Word) a window with unbanded edges a non-complying article.

3) We forward "the proper instructions for manufacturers who are being undersold due to non-complying competitors."

With regard to your first request, we cannot confirm that all forward facing windows in multipurpose passenger vehicles must be glazed with S-2 laminated with .030 because windshields of multipurpose passenger vehicles must comply with the S-1 requirements. However, your request that slide-in campers be allowed to use S-1 liminated with an .030 plastic film in under consideration, and further reply will be made. You also ask for confirmation that the glazing be etched as required by Z25. This matter is also being considered as part of a rulemaking which would amend the glazing standard to provide for this type of etching.

With regard to your second request, Standard No. 205 presently requires that, except in school buses, expanded edges of glazing materials shall have an edge radius of between one half the nominal thickness of the material and inch. Exposed edges not meating these limits are not in compliance with the standard.

Finally, with the regard to your third request, if you have any additional information available concerning "non-complying competitors" please submit it to the National Highway Safety Bureau, Office of Motor Vehicle Safety Performance Service, 400 5th Street, S.W., Washington, D.C. 20591, and whatever action is considered appropriate will be taken.

Once again we wish to thank you for your active interest in the motor vehicle safety program.

Sincerely,

May 23, 1968

David Schmeltzer U.S. Department of Transportation Federal Highway Administration National Highway Safety Bureau Dear Dave:

This letter will serve as a formal request for information which we discussed in our telephone conversation of May 22.

Please confirm in writing immediately that all forward facing windows in multipurpose passenger vehicles must be glazed with AS-2 laminated with .030 plastic film. Also, confirm that each glass pane must be etched as required in Z26.

One question we did not discuss has to do with windows with exposed edges. At the present time, Standard 205 requires that in all except school buses, windows with exposed edges must be treated in accordance with Society of Automotive Engineering Recommended Practice J673, "Automotive Glazing", June 1960. This includes the window we refer to as a 4" Jalousie. It would be convenient if you could justify written instructions that the radii specified in J673 for edge treatment will be necessary for compliance with Standard 205. The reason for this is that we "webber" (grind to no specific radius but remove enough edge material so that you would not cut your finger if you rubbed it along the edge of each unbanded pane) 4" Jalousie panes and have for many years. The information available from SAE is a little confusing, for it looks like a webbered edge; however, it specifies a radius from 3/16" to 1/4". As you know by now, it is difficult to take some of this Automotive Engineering data and use it without expanding its meaning when concerned with pickup canopies and campers. We are not asking for you to give us any relief or to approve the webbered edge as satisfactory. We concur in your decision that an unbanded edge should have a close tolerance and responsible radius. We only want to ascertain that anything less than edges as specified in J673 will make a window with unbanded edges a non-complying article.

One last point -- please expedite if possible the proper instructions for manufacturers who are being undersold due to non-complying competitors. I have requested this previously.

Sincerely yours,

ANADITE, INC.

PRODUCTS DIVISION --

John E. Orr

Director of Marketing

ID: nht68-1.27

DATE: 06/21/68

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

TO: ATECO Equipment Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter to Mr. Slagle dated March 8, 1968, in which you ask for information as to your company's responsibility under the National Traffic and Motor Vehicle Safety Act and regulations issued pursuant to the Act.

As I understand the description of the modification your company makes to trucks the only standard now in effect that is applicable is Standard No. 205, the glazing standard. Therefore, the glass that you install in place of the original glass in the truck cab would have to comply with this standard.

Your company might also be affected by the enclosed Advanced Notice of Proposed Rulemaking. Your particular attention is directed to Docket No. 2-12 which would, if finalized, make the standard concerning anchorage of seats (No. 207) applicable to trucks.

Sincerely,

Enclosure

March 8, 1968

National Highway Safety Bureau Edwin Slagle, Director Motor Vehicle Safety Performance Service

Dear Mr. Slagle:

I talked to David Schmeltzer who I understand is in the Office of the Chief Council of the Federal Highway Administration. Mr. Schmeltzer advised me to approach you for information concerning matter mentioned in the above subject.

This company is a manufacturer and a distributor of motor truck mounted equipment. We are generally to date and are currently practicing the requirements set forth in Federal Regulation #108 and #111 effective January 1, 1968.

Or to January 1, 1968, we had modified Ford, Model C-600 tilt-cabs by handing the original configuration approximately 15-1/4" longer than standard. We incorporate within this change two (2) one-man seats behind the driver-passenger compartment. One of these seats is located on a right angle behind the driver's seat and faces the street side of the vehicle. Another seat is installed behind the passenger's seat in reverse position to the one mentioned. We did not furnish any escape hatch, yet the glazed opening to which the passengers faced was made larger than the original factory furnished glazing. This glazing was set in rubber and locked in place through the use of standard rubber key locks that are used for this purpose in the motor truck industry. This glazing principle did not offer a push-out convenience, yet we at this time could leave the key lock strip out, thereby offering a convenience of a push-out window. We did not change or modify the factory furnished rear window glass.

We now wish to make similar changes to the equipment that we have described. We have researched all printed material and instructions that have been made available to us, to determine a correct and legal path to follow, but we have not found any information by which we should proceed, therefore we have taken the liberty to approach you for help and advice on this matter.

Attached please find the copy of a sketch of the equipment that we are concerned about, on which we have shown a dotted line vertically on the rear portion of the truck cab to indicate the approximate length that we extended the cabs done prior to January 1, 1968.

We need correct information and printed material or a written testimonial from a proper Federal agency telling us if we can or cannot make these changes to fulfill our obligation to Federal requirements.

We wish to take this opportunity to thank you in advance.

Very truly yours,

ATECO EQUIPMENT COMPANY--

R. A. Moynihan

Sales Manager - Truck Equipment

JWT FILE JWT S.O. David Schmeltzer RAM(Illegible Words)

(Graphics omitted)

ID: nht68-1.28

DATE: 01/01/68 EST.

FROM: H.M. Jacklin, Jr.; NHTSA

TO: Electrical Testing Laboratories, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of July 30, and August 9, 1968, concerning the test of seat belt anchorages which are anchored to a seat.

On the question regarding the test method for applying the loads specified in paragraph $3.1.1, Motor Vehicle Safety Standard No. 207, we would agree with your conclusion to apply the loads at the required different points and directions simultaneously.

On the question of whether bucket seats with seat belt anchorages attached may be tested separately, the applicable paragraph in SAE J787b is 5.2 rather than 5.1 as stated in your letter. There is no test method specified therein relative to this question and accordingly, test of the bucket seat with seat belt anchorages attached may be tested either separately or in sets.

ID: nht68-1.29

DATE: 10/22/68

FROM: Joseph R. Gorman for Francis Armstrong -- NHTSA

TO: Valley Buick Company

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of August 15, 1968, regarding safety standards applicable to the Austrian "Haflinger" vehicle.

This vehicle will be required by the National Traffic and Motor Vehicle Safety Act of 1966 to comply with the Federal Motor Vehicle Safety Standards. Enclosed are copies of the Act and the Standards and amendments through August 1963.

I have reviewed the prospectus you enclosed with your letter and would conclude that the "Haflinger" vehicle meets the definition of a multipurpose passenger vehicle as specified in Section 255.3 of the Initial Federal Motor Vehicle Safety Standards. Accordingly, any vehicle of this type, manufactured after January 1, 1963, must conform to the following Standards which have application to multipurpose passenger vehicles of less than 80 inches overall width:

FMVSS #103 - "Windshield Defrosting and Defogging"

FMVSS #104 - "Windshield Wiping and Washing Systems"

FMVSS #106 - "Hydraulic Brake Hoses"

FMVSS #107 - "Reflecting Surfaces"

FMVSS #111 - "Rearview Mirrors"

FMVSS #205 - "Glazing Materials"

FMVSS #209 - "Seat Belt Assemblies"

FMVSS #211 - "Wheel Nuts, Wheel(Illegible Words)

In addition, vehicles manufactured after January 1, 1969, will be required to comply with:

FMVSS #106 - "Lamps, Reflective Devices, and Associated Equipment"

FMVSS #112 - "Headlamp Concealment Devices"

FMVSS #113 - "Head Latch Systems"

(Illegible Words)

August 15, 1968

National Highway Safety Bureau Federal Highway Administration Department of Transportation Attention George Nield

Gentlemen:-

The early part of this year we arranged to handle a Vehicle named Haflinger, through Overland Vehicle Corp. of North Miami Beach, Florida, the imported. This vehicle is built in Austria. We are attaching a fly covering the specifications.

The Haflingers we have sold were 1967 Models, ie; built prior to January 1, 1963. All have been sold to operators of Ranches, such as the King Ranch. This vehicle is designed for cross-county, off the highway use. It has a maximum speed of forty-seven miles per hour.

The 1967 models we received were equipped with Seal-Beam Headlights, Parking and Stop-Lights. Directional Signals with Amber Side Lights mounted on each side at the front of the vehicle, tail and licence plate lights and windshield wipers.

About ninety days ago we placed an order with Overland Vehicle Corporation for twenty Haflingers accompanied by a letter of Credit. One of the conditions of the Letter of Credit, was that the vehicle would meet the Federal Safety Standards. We have been unable to contact any one during the last thirty days with the Overland Vehicle Corporation, and it appeared they had closed their office in North Miami Beach.

We have now been in communication with the Manufacturer of the vehicle in Austria and they advise that their contract with Overland expires August 31, 1963 and they have offered to sell us direct. This vehicle has created a lot of interest among farmore and ranchers in the area, as well as hunters.

It will be appreciated if you will give us an official ruling as quickly as possible of the Safety Standards necessary to enable us to import this vehicle for sale in the United States.

Thanking you, we are

Yours very truly,

VALLEY BUICK COMPANY -- Carl A. Murphy

ID: nht68-1.3

DATE: 08/22/68

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

TO: E.T.R.T.O.

TITLE: FMVSS INTERPRETATION

TEXT: This in response to your letters of May 24, requesting (1) a footnote to Table 1-A to provide that equivalent millimeter designations may be marked on tire sizes in addition to the dimension sizes in inches; and (2) a footnote to Table 1-C to provide that the tire sizes provided in this table can be marked on the tire by giving the millimeter equivalent either before or after the size designation in inches.

We do not consider that Table 1-A of the standard, as presently written, prohibits equivalent marking in millimeters as long as the conversion from inches to millimeters is exact and the tire meets the size and load carrying requirements shown in Table 1-A.

Similarly, we do not consider that the standard as presently written prohibits the marking of the tire with equivalent millimeter sizes before or after the marking which gives the size of the tire in inches.

In view of the above, a footnote is not considered necessary.