ID: nht72-1.7

DATE: 07/27/72

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 20, 1972, to Mr. Toms concerning general reference material in support of the proposals contained in Docket No. 70-27. Hydraulic Brake Systems. You ask that the NHTSA place in the file "The supporting data upon which the test sequence is based as well as the data used to determine the performance values based on the sequence."

The proposed test sequence is based primarily upon the test sequence of standard No. 105, which is that of SAE Recommended Practice J937 incorporated by reference. Parking brake lightly loaded vehicle, inoperative brake power assist unit, and partial failure tests not included in J937, were placed in the sequence in the order that appeared, in the judgment of agency personnel, most likely to provide realistic and undistorted results. The sequence, of course, is subject to revision on the same basis in the forth-coming final rule. General reference material in the Docket includes data from braking tests of eighteen 1970 automobiles, NBS Technical Note 557, "The Brake Pedal Forces Capability of Adult Females," and SAE 720032, "Evaluation of the Use of Automotive Braking Systems During a 7300 Mile Cross-Country Trip."

ID: nht72-1.8

DATE: 04/11/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: GGO Group, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 3, 1972, to Mr. Schneider asking whether your Gemini Tow Control System would come under our regulations, and whether you would be considered a brake manufacturer.

The Federal motor vehicle safety standard covering vehicle hydraulic brake systems, Standard No. 105, applies only to passenger cars (not directly to equipment manufacturers), and does not cover the hydraulic braking relationship between towing and towed vehicles. For that reason the Gemini system would not be regulated by Standard No. 105. There are no Federal standards applicable to a tow control system per se.

We would, however, view you as a "manufacturer," and the product you have described as "motor vehicle equipment," within the remaining of the National Traffic and Motor Vehicle Safety Act of 1965.

ID: nht72-1.9

DATE: 11/06/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Paul Utans

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of October 9, 1972, you enclosed a master brake cylinder cover ("Exhibit A"), and a reservoir label ("Exhibit B"), both produced by Alfred Teves, and asked our views as to their conformity with the lettering size and contrast requirements of paragraph S3.4.3 of Motor Vehicle Safety Standard No. 105a.

These sample items appear to conform to the lettering requirements, with the exception that the cylinder cover of Exhibit A is the same color as the raised lettering, and does not provide a contrasting background as required by the standard.

ID: nht72-2.1

DATE: 07/18/72

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

TO: Consumers Union

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 28, 1972, forwarding to us a report to be published in the August issue of Consumer Reports, which raises numerous issues concerning child restraints and the efficacy of Motor Vehicle Safety Standard No. 213, "Child Seating Systems." You contend, based on testing you performed, that the static performance tests of the standard are meaningless, and that dynamic tests should be adopted.

We agree that a dynamic test should be included in the standard, and we discuss below our efforts and intentions in this regard. We also believe, however, that devices which conform to Standard No. 213 provide significant impact protection for children which is not available otherwise, and that the present standard has served a useful purpose in the development of effective child restraints and the removal from the marketplace of marginal products. We have pursued a vigorous enforcement policy with respect to the standard which has discovered and corrected numerous cases of noncompliance.

The 1,000-pound static test imposed by Standard No. 213 was determined by the NHTSA to be an adequate first step in the development of standards for child seating systems. This determination was based, in part, on the state of the art of the development of these devices, and the financial resources of the affected industry. The limitations of the static test have been known for some time, and in the NHTSA Program Plan for Motor Vehicle Safety Standards, published in October 1971, the NHTSA made clear its intention to develop a dynamic test to measure the performance of all child restraint devices.

We believe the most effective way to utilize a dynamic test is to couple it with realistic injury criteria that reflect the ability of children to withstand crash impacts. This is the approach taken for adults by Standard No. 208, Occupant Crash Protection. Although we have developed adult injury criteria as part of our work on that standard, further work must be done to correlate these criteria with the protection needed for children.

Rather than delay dynamic testing until this work is completed, however, the NHTSA plans to propose interim dynamic tests using other performance criteria which are presently being developed through research at the University of Michigan. We are also sponsoring othe research on the problem of the development of realistic child dummies. Another problem in the development of a dynamic test for child seating systems, or any other performance requirements for them, is that the performance of the child seat is in large measure dependent upon the design and construction of the vehicle in which it is placed. Because manufacturers can market these devices economically only if they are suitable for large numbers of vehicles, an endless number of variables occur, with a resultant difficulty in prescribing reasonable "worst case" test conditions.

We are presently working to provide answers to these questions, and are hopeful that the research projects presently under way will provide data in the near future on which we can proceed. You mention that you will be submitting to us a petition for rulemaking regarding the standard. We request that you also submit to us any data which you have available, including data from your testing program, which might assist us in solving these problems.

ID: nht72-2.10

DATE: 03/14/72

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Hance; Caston; Hefner and Green

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 25, 1972, concerning the certification of new trailers which your client manufactures. You state that some of those trailers are shipped (to customers) equipped with used tires that are intended primarily to be used to ship the trailers to their destination, and ask whether these tires should be taken into account in the values for GVWR and GAWR on the certification label.

We do not consider that temporary tires attached to a vehicle for purposes of shipment should be refelcted in the GVWR and GAWR on the certification label, if these tires are not intended to be part of the completed vehicle. Consequently, we would expect trailers certification as vehicles for which no tires have been provided. In such a case, the complete vehicle manufacturer, as indicated in the preamble to the Certification regulations (April 14, 1971, 36 F.R. 2054) must still bear responsibility and certify the vehicle, even though he does not install the tires with which the vehicle will ultimately be equipped. We suggest that one manner in which this could be accomplished by the manufacturer is to list GAWR and GVWR for the optional tire sizes which he recommends in accordance with the amendment to the Certification regulations published December 10, 1971 (35 F.R. 23571). The manufacturer should make it clear to the purchaser of the vehicle that the temporary tires should be replaced when the vehicle is put into use.

We are pleased to be of assistance.

ID: nht72-2.11

DATE: 11/21/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Mobile Aerial Towers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to the questions you asked in your letter of October 24, 1972, to Mr. Wells of the Federal Highway Administration concerning compliance with Standard No. 108 of trucks to which mobile aerial towers are mounted.

"1. The aerial tower is considered a load rather than part of the vehicle to be included in determining the overall length. Correct?"

Correct.

"2. Are amber intermediate side marker lights and/or reflectors required on the body?"

If the overall length of the vehicle is 30 feet or more, intermediate side marker lamps and reflectors are required, and they must be located at or near the midpoint between the front and rear side marker lamps and reflectors.

"3. Are amber side marker lights and/or reflectors required on the body?"

Front amber side marker lamps and reflectors are required to be mounted as far to the front as practicable on a vehicle. Generally, this is somewhere on the front fender, though in some configurations a manufacturer might determine that a location on the truck body is as far to the front as practicable.

"4. Are amber clearance lights and/or reflectors required on the front of the body?"

Yes. Front clearance lamps are required to indicate the overall width of the vehicle and to be mounted "as close to the top [of the vehicle, exclusive of load] as practicable."

"5. If a unit is over 30 ft. long, will amber side marker lights and reflectors suffice also as amber intermediate side marker lights and reflectors?"

No, they will not. As the above answers indicate, the location requirements are different for front and intermediate side markers.

ID: nht72-2.12

DATE: 08/30/72

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Albert Hammerstein

TITLE: FMVSS INTERPRETATION

TEXT: Your Broadview, Illinois, Subsidiary recently forwarded to us a copy of your December 17, 1971, letter concerning aiming adjustment tests as specified in SAE Standard J580a. A search of our files does not reveal that your letter was previously received by this Office.

Specifically, your concern is the interpretation of a requirement which is specified in SAE J580a as follows:

"2. The mechanism, including the aiming adjustment, must be so designed as to prevent the unit from receding into the lamp body or housing when an inward pressure of 50 lb is exerted on the outer surface of the lens."

Our interpretation of the above requirement is that no visible receding of the sealed beam unit is permitted when the inward pressure is applied on the outer lens surface. Testing for compliance to the requirements of FMVSS No. 108, which references SAE J580a, is conducted on the basis of this interpretation.

In the upcoming Notice of Proposed Rule Making (NPRM) on FMVSS No. 108 (Docket 69-19), we are considering the feasibility of specifying more objective type requirements on this aspect of aiming adjustment tests for headlamps. You will no doubt be interested in commenting on the proposed requirements after issuance of the NPRM.

ID: nht72-2.13

DATE: 11/20/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: The Grote Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 18, 1972, to Mr. Schneider asking for an interpretation of paragraph S4.3.1.3 of Motor Vehicle Safety Standard No. 108. You have enclosed photographs of boat trailers marked to show your understanding of the language "as far forward as practicable" and ask for our views.

Table II and Table IV of Standard No. 108 require that front side reflex reflectors and lamps on trailers, including boat trailers, be located as far to the front as practicable, Recognizing that a literal interpretation of the standard would require that these devices be installed on the trailer tongue and that in many instances it would be impracticable to do so, the NHTSA added paragraph S4.3.1.3 to allow a location as far forward as practicable exclusive of the trailer tongue." The intent of the regulation is that the device be mounted as far to the front of the vehicle as the manufacturer determines is practicable, and a definition of "trailer tongue" is immaterial for this purpose. If the angled portion of the frame is deemed "practicable", and the device is located there, it must be mounted, as you suggested, in a position such that it meets the photometric requirements at the specified angles with respect to the vehicle.

ID: nht72-2.14

DATE: 10/30/72

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Peterson Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of September 1, 1972 and September 27, 1972, calling our attention to contradictory provisions of 49 CFR @ 571.108, Motor Vehicle Safety Standard No. 108, and 49 CFR @ 393.22, a regulation of the Bureau of Motor Carrier Safety.

We confirm your interpretation that the Motor Carrier Safety Regulations prohibit the inclusion of a clearance lamp in the same shell or housing as a taillamp or identification lamp, while Paragraph S4.4.1 of Standard No. 108 allows use of the same shell or housing as long as the clearance lamp is not optically combined with a taillamp or identification lamp. Although identical regulations are preferable from a manufacturer's standpoint, section 103(g) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 USC 1381 et seq.) allows the Bureau of Motor Carrier Safety to promulgate or maintain "a safety regulation which imposes a higher standard of performance [than the safety standards] subsequent to . . . manufacture." The Bureau views its regulation as establishing a higher standard of performance since, in its opinion, separate housings lessen the likelihood that, at a distance, marking and signaling functions will be confused. If you feel that 49 CFR @ 393.22 should be amended to be identical with Paragraph S4.4.1 of Standard No. 108, you should so petition the Bureau.

We also confirm that, if the rear identification lamps are located at the extreme height of the vehicle, Paragraph S4.3.1.5 of Standard No. 108 would allow clearance lamps, whether separate or in the same housing as other lamps, to be located at a height less than "as close as practicable to the top of the vehicle."

ID: nht72-2.15

DATE: 07/11/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Barry Kulik

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 14, 1972, to Mr. Armstrong asking whether combination turn signal and hazard warning signal flashers conforming to Federal requirements effective January 1, 1973, may be installed in vehicles manufactured before that date.

The answer is yes. Motor Vehicle Safety Standard No. 108 was amended on December 28, 1971 to allow use of flashers manufactured to conform with Standard No. 108a. I enclose a copy of the amendment for your information.