ID: nht68-1.4

DATE: 01/25/68

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: The Armstrong Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: In our telephone conversation of January 8, 1968, and your letter of January 9, 1968, you requested:

". . . . an early reply whether labels are required, when the information already appears on one sidewall, except the basic label. (Basic label Information - DOT-153) It is also our feeling that the labeling is not a serious requirement to meet minimum safety standards."

This letter confirms my statement in our telephone conversation that Motor Vehicle Safety Standard 109 may be met if the information required in S4.3 of this standard is molded on one or both sidewalls of the tire in lieu of a label until August 1, 1968, after which this information is required on each sidewall.

Sincerely,

THE ARMSTRONG RUBBER COMPANY

January 9, 1968

Roger H. Compton, Director Office of Standards on Accident Avoidance U.S. Department of Transportation Federal Highway Administration

Dear Mr. Compton:

Re: Replies to 1) Our December 5, 1967, Letter Addressed to Mr. L. K. Bridwell

2) Confirmation of Telephone Call (December 15, 1967) Placing Labeling on One Side of Tire by Stencils Molded into the Tire in Lieu of labels

My letter of December 5, 1967, last paragraph, stated as follows:

"We request an early reply whether labels are required, when the information already appears on one sidewall, except the basic label. (Basic Label Information - DOT-153) It is also our feeling that labeling is not a serious requirement to meet minimum safety standards."

On December 15, 1967, our Mr. John A. Diehl called Mr. Schwentker and received a verbal reply by telephone from you that The Armstrong Rubber, Company could proceed without labels if the required information of S4.3 MVSS Standard 109 was molded on one sidewall of the tire in lieu of labels.

We appreciate your position and understand that your staff is not complete. However, we would like to receive a reply in writing or by means of a notice in the Federal Register that the course which you approved and which we are following can be used by all tire manufacturers.

Sincerely,

R. L. Donnelly Secretary

ID: nht68-1.40

DATE: 02/21/68

FROM: EDWIN L. SLAGLE -- DOT NHSB DIRECTOR MOTOR VEHICLE SAFETY PERFORMANCE SERVICE

TO: H. S. BEAGLE -- PRESIDENT ELECTRICAL TESTING LABORATORIES, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 2/20/68 FROM H. S. BEAGLE OF ELECTRICAL TESTING LABORATORIES, INC. TO EDWIN L. SLAGLE OF D.O.T. NATIONAL HIGHWAY SAFETY BUREAU;

TEXT: Dear Mr. Beagle:

Thank you for your letter of February 20 in which you request clarification as to the proper test procedures to be employed in determining compliance of electrically heated automotive glazing with the requirements of Motor Vehicle Safety Standard No. 205 - Glazing Materials.

Since neither Standard No. 205 nor the USASI Standard Z26.1 - 1966, which is referenced in Standard No. 205, specifies special procedures with regard to electrically heated glass, the same procedures required for non-electrically heated glass are appropriate.

Although at present rear window defrosting and defogging are not required, I would be most pleased to review with you your experience as to the effectiveness of this type of glass in meeting requirements such as have been established under Motor Vehicle Safety Standard No. 103.

Sincerely,

ID: nht68-1.41

DATE: 06/10/68

FROM: WILLIAM HADDON -- FEDERAL HIGHWAY ADMINISTRATION

TO: HARRY F. BARR -- VICE PRESIDENT ENGINEERING STAFF GENERAL MOTORS TECHNICAL CENTER GENERAL MOTORS CORPORATION

TITLE: NONE

TEXT: Dear Mr. Barr:

The interpretations of Motor Vehicle Safety Standard No. 105 regarding cable type and bar type brake controls for driver training vehicles described in your letter of May 24 are quite correct. Motor Vehicle Safety Standard No. 105 does not apply to the installation of add-on driver training brake controls following retail sale of a new car. In the case of installation of add-on driver training brake controls in new cars prior to retail sale, the following apply:

a. Motor Vehicle Safety Standard No. 105 does not apply to the add-on brake control itself; however, the installation of such controls must not affect compliance of the regular hydraulic brake system to Motor Vehicle Safety Standard No. 105.

b. Following installation of a mechanical-type add-on brake control, the installing dealer is responsible for determining that compliance of the regular brake system is not impaired by verifying that the add-on control does not interfere with normal driver access to and application of the regular brake pedal.

Although endorsing your understanding of the requirement imposed by Motor Vehicle Safety Standard No. 105, I am not endorsing these brake devices or passing on their safety from a crash standpoint.

I appreciate your interest in driver education and training and your efforts to further traffic safety through this program.

Sincerely,

ID: nht68-1.42

DATE: 05/28/68

FROM: AUTHOR UNAVAILABLE; J. R. O'Gorman; NHTSA

TO: Minnesota Automotive, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 1, 1968, to the Motor Vehicle Safety Performance Service, concerning compliance with the Federal Motor Vehicle Safety Standard No. 105.

Basically, when a car dealer modifies a conforming vehicle, he then assumes responsibility for the vehicle's compliance to all applicable standards if that vehicle is distributed to a purchaser for purposes other than resale. Specifically, if a car dealer installs the Model 7900 Driver Training Brake on a conforming vehicle that he sells, than compliance to the Federal Motor Vehicle Safety Standard No. 105, as well as other applicable standards, is required. In the case where the dealer owns and loans the vehicle with the installed Model 7900, we would hope that he would again comply.

The enclosed literature may be of additional assistance to you in response to your inquiry.

ID: nht68-1.43

DATE: 06/21/68

FROM: ROBERT M. O'MAHONEY -- NHTSA; CONCURRENCE BY GEORGE C. NIELD

TO: Recreational Vehicle Institute, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Bridwell has asked that I reply to your letter of June 4, 1968.

In your letter you refer to (1) an earlier letter dated November 8, 1967, requesting confirmation of your understanding of the application of the motor vehicle safety standards to recreational vehicles; and (2) a Petition for Reconsideration of the Chassis-cab regulation filed March 19, 1968.

With regard to your letter of November 8, as you know from conversations with members of the staff of the Motor Vehicle Safety Performance Service and the Chief Counsel's Office this letter was misplaced. By letter of May 8, you were good enough to send a copy of the letter of November 8, noting that of the eleven questions asked two have not been clarified by some action taken by the Federal Highway Administration. The unanswered questions are quoted and answered below:

Question --- 3. "The inside mirror need not have the field of view prescribed by Paragraph S3.1.1 of Standard No. 111 (even to the point of providing no view of the road behind a truck camper if the camper mounted on the truck obstructs the driver's vision) provided an outside mirror is installed on the passenger's side of the truck cab, as required by Paragraph S3.2.2."

Answer -- You are correct in your understanding of Standard No. 111. Subparagraph S3.2.2 of Standard No. 111 specifies that if the inside mirror required by S3.1 does not meet the field of view requirements of S3.1.1, an outside mirror of substantially unit magnification shall be installed on the passenger's side.

Question --- 10. "Everything said above concerning truck campers applies equally to truck caps, which are enclosures (roof, sidewalls and ends but no floor and usually no built in equipment) mounted on a pick-up truck.'

Answer --- Truck caps which you describe are considered to be in the same category as slide-in campers and are items of motor vehicle equipment for use in motor vehicles. As such truck caps must meet the requirements of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials - Passenger Cars, Multipurpose Passenger Vehicles, Trucks, Buses, and Motorcycles.

With regard to your Petition for Reconsideration filed March 19, 1968, you note in a letter of May 13, 1968 that three matters raised in the Petition are still unanswered and further action is required. The problems you raise, as you know, are complex. The entire problem of the applicability of the standards to vehicles produced in the multi-stage is still under consideration.

ID: nht68-1.44

DATE: 06/03/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Bert's Truck Equipment Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 18, 1968, in which you provided certification information, and presented extra axle modification problems.

Enclosed is a copy of the Federal Motor Vehicle Safety Standards with chassis-cab information from the Federal Register.

Your certification of compliance concerns compliance of the vehicle at the time of your installation or modification. It does not extend to subsequent additions or modifications by others.

With respect to an old truck body mounted on a chassis-cab which is manufactured on or after January 1, 1968, you are required to bring the lighting into compliance. (See Federal Standard 108 applicable for January 1, 1965.

With regard to lighting requirements for trucks, the corner lights, or side marker and clearance lamp requirements are also provided in the foregoing, enclosed standard.

Your letter is being referred to the engineers responsible for standards preparation, and the information is appreciated.

ID: nht68-1.45

DATE: 01/18/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Ander-BTT Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: We are in receipt of your letter dated November 30, 1967, forwarded to us through the Michigan Department of State Police.

This letter is in answer to your inquiry as to whether your mobile home or trailer house is required to comply with the Federal Motor Vehicle Safety Standards. From the brief description of your product we would state that your vehicle would fall into the category of the multi-purpose passenger vehicle.

Enclosed is a copy of the Initial Federal Motor Vehicle Safety Standards. Your attention is directed to Subpart B. This section indicates those safety standards which multi-purpose passenger vehicles are required to comply with.

Also enclosed is a notice published in the Federal Register dated November 4, 1967, stating the Certification Requirement effective January 1, 1968.

If we can provide additional information, please feel free to contact this office.

ID: nht68-1.46

DATE: 01/29/68

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

TO: Messrs. Gilbert; Segall and Young

TITLE: FMVSR INTERPRETATION

TEXT: In answer to your letter of December 15 I am enclosing a copy of the regulations published January 10 governing the importation of motor vehicles subject to the Federal motor vehicle safety standards.

You have advised us that Rolls-Royce prefers to affix the certification required by section 114 of P.L. 89-563 during manufacture of its passenger cars, and to install seat belts after importation of such cars into the United States. The regulations (19 C.F.R. 12.80(b)(iv) will allow Rolls-Royce to do so providing the informational label it prescribes is affixed to the windshield of these cars during shipment.

I hope this is satisfactory to your client.

ID: nht68-1.47

DATE: 01/12/68

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

TO: Headquarters 26th Tactical Reconnaissance Wing (USAFE)

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 21, 1967, to Mr. Lowell K. Bridwell, requesting information on the enforcement of the National Traffic and Motor Vehicle Safety Act of 1966 with reference to vehicles imported by servicemen.

Specifically you have asked:

"a. If (1) A foreign made vehicle, or (2) An American made vehicle, which was purchased prior to 1 January 1968, is imported into the Continental United States subsequent to 1 January 1968, must the vehicle conform to the standards presently established?"

The Federal motor vehicle safety standards affect only vehicles manufactured on or after January 1, 1968. Vehicles manufactured prior to January 1, 1968, need not conform.

"b. Is there any exception for vehicles purchased after 1 January 1968 and imported after that date from the safety standards?"

I enclose a copy of the regulations promulgated jointly by the Department of Transportation and the Department of the Treasury which appeared in the Federal Register on January 10 which govern importation of vehicles. Section 12.80 (b)(1), (b)(2), (b)(3), and (b)(7) set out exemptions which are applicable, generally, to American citizens including servicemen (for whom no special exemption is provided).

Currently we have no information as to which foreign made vehicles will conform to the standards. I agree that information concerning which cars would be helpful to overseas military personnel and I am hopeful that eventually we may be able to implement your suggestion.

For your information, we plan, in the near future, to inaugurate an information program for United States military and civilian personnel overseas. Among those who will be contacted in this regard are the legal assistance officers of each of the Staff Judge Advocates of the Military Services.

ID: nht68-1.48

DATE: 01/12/68

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

TO: Road and Track

TITLE: FMVSR INTERPRETATION

TEXT: In response to your letter of December 19 to Mr. Boaz regarding the proposed regulations governing the importation of motor vehicles and how they affect racing cars, I enclose a copy of the final regulations which are now in effect. You will see that 19 C.F.R. 12.80(b)(7) permits importation of noncomplying motor vehicles for purposes of competition if they are not licensed for use on the public roads.