ID: nht74-1.24

DATE: 01/16/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Toyota Motor Sales, U.S.A., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your December 17, 1973, letter to the Administrator of the National Highway Traffic Safety Administration, asking whether a "sling" attachment of the upper end of an upper torso restraint to the roof rail is subject to Standard 210's requirements for seat belt anchorage location.

The ring, webbing, and attachment hardware you describe function together as a seat belt anchorage and as such are subject to the appropriate strength and location requirements of Standard 210. Because the location requirement of S4.3.2 is intended to strictly limit the placement of the fixed point from which a belt passes across an occupant's torso, and because the flexible portion of your sling anchorage duplicates the uninterrupted deployment of an upper torso restraint, only the fixed portion of such a sling anchorage would be subject to S4.3.2's location requirements.

YOURS TRULY,

TOYOTA MOTOR SALES, U.S.A., INC.

December 17, 1973

James B. Gregory Administrator National Highway Traffic Safety Administration

Dear Dr. Gregory:

Attached is a drawing of one of the seat belt systems that we are considering using on some of our models in the near future.

Regarding the "sling" of this system, we interpret as follows:

If the sling is composed of a ring (A), fabric webbing (B), and attachment hardware (C) as depicted in the drawing, only the attachment hardware (C) is subject to the requirement of @ 4.3.2 which specifies that " . . . the seat belt anchorage for the upper end of the upper torso restraint shall be located within the acceptable range . . ." since the nature of the webbing allows the ring (A) and the fabric webbing (B) to move with reasonable freedom, thereby removing them from the (Illegible Word) of anchorage expected in @ 4.3.2.

We believe that our interpretation meets the intent of @ 4.3.2 of Standard 210, but we need the confirmation of the Administration before we start tooling for production.

Your consideration of the above will be greatly appreciated.

Keitaro Nakajima Director/General Manager Factory Representative Office

(Graphics omitted)

ID: nht74-1.25

DATE: 04/22/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Bruck Caulkens, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of April 4, 1974 requesting information concerning the existence of any Federal Motor Vehicle Safety Standards applicable to auxiliary fuel tanks.

The National Highway Traffic Safety Administration has promulgated no motor vehicle safety standard relating to auxiliary fuel tanks. There is, however, a safety standard which imposes performance requirements upon motor vehicles with regard to their fuel systems. Thus, if installation of the auxiliary tank is accomplished prior to the first purchase of the vehicle for purposes other than resale causing the vehicle's fuel system not to be in compliance with the applicable safety standard, the person installing the tank or offering the vehicle for sale would be in violation of @ 108(a) (1) of the National Traffic and Motor Vehicle Safety Act. That would make the installer or seller subject to civil penalties of up to $ 1,000 for each violation.

The National Traffic and Motor Vehicle Safety Act authorizes the Secretary of Transportation to make a determination as to whether or not an item of motor vehicle equipment contains a defect which relates to motor vehicle safety. If he finds that a safety-related defect exists, he may compel the manufacturer to notify purchasers of the hazard. Therefore, even though auxiliary fuel tanks are not the subject of a standard, they still must be safely designed.

For your information, I have enclosed a copy of the Federal Safety Standard relating to motor vehicle fuel systems.

YOURS TRULY,

BRUCE CAULKENS, INC.

April 4, 1974

Lawrence R. Schnieder Chief Council Office of the Administrator -- NHTSA

Enclosed you will find a copy of U.S. Letters Patent #3,433,246 which affords a physical description of a portable, auxiliary fuel tank, designed primarily for stowage and/or transport of gasoline inside the trunk or other enclosed areas of an automobile or similar vehicle.

Briefly, the patented design concept is a small, 2-gallon, metal tank, having a filler spout and cap, on-off spigot, and a pressure relief valve from which a polyethylene or nylon tube provides continuous venting to the outside air.

The tank is easily removable from a harness assembly which holds it firmly in place. The tank must be removed from the vehicle when being filled, thereby eliminating the possibility of spillage into the trunk or enclosed area.

A Polyethylene tube attached to the spigot acts as a flexable carrier for transfer of gasoline/fuel from the auxiliary tank to the main fuel tank.

The tank has been tested by the Ethel Corporation Laboratories, 1600 E. 8 Mile Road, Ferndale, Michigan for Emission Control data and rendered an overall emission vapor factor of less than two (2) grams.

I am attempting to have the auxiliary tank manufactured and, because this will involve a great deal of money to set up (tooling, etc.), the manufacturer and I would like to be assured that the United States Government will not look unfavorably upon our auxiliary tank device.

Mr. Peter Cooley, Research Engineer, Michigan Highway Safety Research Program, Univ. of Mich., Ann Arbor, Michigan, Phone (313) 764-0248, has examined and noddingly (unofficially) approved of our tank device from both principle and practicality of design. Mr. Cooley suggested that the National Highway Safety Administration and the E.P.A. Departments of the Federal Government would not be interested from a control standards point of view because the auxiliary tank device is portable and not intended to be a fixed, permanent installation in an automobile.

We would appreciate receiving a letter from your department stating that due to the "portability" of our tank device, we would not be subject to Federal Control Standards, other than those set forth as generally acceptable standards and laws, local and federal, that regulate gasoline tanks, etc.

Bruce Caulkens President

Enc. (Patent Omitted.)

cc

Mr. Colver R. Briggs Automotive Safety Planning & Research Staff Ford Motor Company

Mr. Joseph Innes Administrative Chief National Highway Safety Administration

Mr. Emmett E. Hixon Automotive Corporate Sales Hercules, Inc.

Mrs. Julie Candler Automobile Editor Woman's Day Magazine

ID: nht74-1.26

DATE: 05/23/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mazda; Toyo Kogyo U.S.A. Representative

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 9, 1974, requesting an interpretation of the test procedure specified in Standard No. 301 (Docket No. 73-20; Notice 2) concerning the operation of the vehicle's fuel pump during testing.

Paragraph S7.1.3 of the standard requires that electrically driven fuel pumps be in operation during the barrier crash tests if they normally operate with the activation of the vehicle's electrical system. If the pump is incapable of functioning with the independent activation of the electrical system and requires the operation of the vehicle's engine, then the pump should not be running during the barrier crash tests.

Based upon the description you provide in your letter, it appears that you should conduct your barrier crash testing without operating the fuel pump.

Yours truly,

ATTACH.

May 9, 1974

Richard B. Dyson -- Assistant Chief Counsel, U. S. Department of Transportation, National Highway Traffic Safety Administration

Dear Mr. Dyson:

Re: MVSS 301 Fuel System Integrity

In section 7.1.3 of Docket 73-20; Notice 2, we can find, "If the vehicle has an electrically driven fuel pump, that normally runs when the vehicles electrical system is activated, it is operating at the time of a barrier crash."

The underline was added to the Docket 73-20; Notice 1.

Although we feel NHTSA has granted our attached comments on February 8, 1974, hereby we confirm it again.

Our electrical fuel pump works only when the engine runs, and usually does not work when the ignition is in "on" position except that the engine works. In other words, our electrical fuel pump is connected to the engine and there's no relation directly from our electrical system in "on" position. Nevertheless, we will find that the vehicle's electrical system without fuel pump is activated, when the ignition is in "on" position and the engine is not in "running."

Our question is as follows: In the above system, we believe we may test the barrier crash without operating the electrical fuel pump. If its not so, we have to test it with another special connection between battery and fuel pump, "only on test."

Your opinion will be highly appreciated.

Always warmest,

Goro Utsanomiya -- Branch Manager, TOYO KOGYO U.S.A. REPRESENTATIVE OFFICE

cc: Mr. Williams; Mr. Makino

February 8, 1974

James B. Gregory -- Administrator, National Highway Traffic Safety Administration

Dear Dr. Gregory:

Although the comment closing date is already over, we would like to submit the following comment, because we have a new problem by further review.

It would be appreciated if you consider this comment.

Sincerely yours,

Gorou Utsunomiya -- Branch Manager,

TOYO KOGYO U.S.A. REPRESENTATIVE OFFICE

cc: R. N. Williams

enc.

DOCKET 73-20, NOTICE NO. 1

COMMENTS OF TOYO KOGYO CO., LTD. ON NOTICE OF PROPOSED RULEMAKING FUEL SYSTEM INTEGRITY PASSENGER CARS, MULTIPURPOSE PASSENGER VEHICLES TRUCKS AND BUSES (OF 10,000 GVWR OR LESS)

Comment

"S.7.1.4 - If the vehicle has an electrically driven fuel pump, it is operating at the time of a barrier crash test" should read as, "S.7.1.4 Ignition switch is at "On" position at the time of barrier crash tests."

Discussion

As you know, electrically driven fuel pumps are used on many cars. As far as we assume, this S 7.1.4 is established so as to minimize possibility of fire at the crash accident because electrical pump will keep working as long as ignition switch is at "On" position.

However, if we develop a system where the electrical fuel pump stops at the moment of impact in spite of ignition switch being in "On" position, this possibility will no longer exist.

As long as S 7.1.4 exists, we have to make the pump work by other means, such as direct connection between battery and pump, when we conduct a compliance test, and this S 7.1.4 will close the way of possibly developing a new safety device. We think that this situation is far apart from the actual one and this test is impractical.

Judging from the fact that there is no requirement, "Mechanical fuel pump is operating", we think S 7.1.4 can be changed. Needless to say, we recognize that we should minimize the possibility of a fire with electrical pumps. We would suggest S 7.1.4 should read, "Ignition switch is at "On" position.

ID: nht74-1.27

DATE: 03/14/74

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

TO: Ichikon Industries, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 25 to Mr. Charles A. Baker of this Office concerning the performance requirements of automotive lamp bulbs.

The answers to your specific questions follow.

"(1) At the present, have we need to comply the performance of bulbs with the requirements including the dimentional specification of SAE (Illegible Word) subreferenced in the current FMVSS 108 as well as lighting devices?"

The answer is no. The lamp bulbs installed in production lamps or lighting devices are not included in the requirements of FMVSS No. 108. The requirements apply only to the lamp assembly (the reflector, lens, and associated components other than the bulb) when tested with a selected lamp bulb that (Illegible Words) and the specifications of paragraphs S4.1.1.19 and S4.1.1.20 of Standard 108.

"(2) In the final rule, which of SAE J573d or J573e is applicable as the subreferenced standard of the bulbs?"

The proposal in Docket (Illegible Word) Notice 3 was in paragraph 57.6 which referenced the 1972 edition of the SAE Handbook. SAE (Illegible Word) was included in this Handbook, and is, therefore, the reference for test bulbs in the proposal.

"(3) Do you have a plan that such consideration will be taken into the rule making for proposed FMVSS 108A?"

No such consideration is necessary, because, as indicated above SAE J573d is only a specification for the test bulbs used for the photometric tests of the lamps.

We trust that these answers are satisfactory; however, please feel free to contact us in case of future questions.

Sincerely,

Not controlled

ICHIKOH INDUSTRIES, LTD.

February 25, 1974

Charles A. Baker -- Acting Chief Division of Lighting and Vision, National Highway Safety Bureau Department of Transportation

Dear Mr. Baker, Subject: Performance Requirements of Automotive Lamp Bulbs

As you awaire, SAE Standard J573, Lamp Bulbs and Sealed Units, was revised from J573d to J573e, and SAE Recommended Practice J1049, Service Performance Requirements and Test Procedure for Motor Vehicle Lamp Bulbs was newly issued on August, 1973 respectively.

These revision and new issue confuse us in respect the conformity to FMVSS 108 in production of the bulbs.

Then we would like to ask you the following questions regarding the interpretation of the current FMVSS 108 and the proposed FMVSS 108A.

(1) At the present, have we need to comply the performance of bulbs with the requirements including the dimentional specification of SAE J573d subreferenced in the current FMVSS 108 as well as lighting devices?

(2) On the otherhand, the final rule for proposed FMVSS 108A (Docket No. 69-19: Notice 3) is expected to issue in early 1974.

In the final rule, which of SAE J573d or J573e is applicable as the subreferenced standard of the bulbs?

(3) We think that SAE J573 was established in the nature of design standard and revised as the specification of bulbs for photometric test of lamps. We think further that SAE J1049 was issued as the survice use of bulbs.

Do you have a plan that such consideration will be taken into the rule making for proposed FMVSS 108A?

Your early reply would be highly appreciated.

Very truly yours,

Yoshio Horii, Manager -- Lighting Engineering Dept.

ID: nht74-1.28

DATE: 07/15/74

FROM: C. BAKER FOR E. T. DRIVER -- NHTSA

TO: Stanley Electric Co., Ltd.

COPYEE: L. C. OWEN

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 27 concerning the location of motorcycle turn signal lamps relative to a combination stop lamp and reflex reflector.

The minimum edge to edge separation distance specified in Table IV of FMVSS No. 108 for motorcycle turn signal lamps is to be measured from the edge of the illuminated surface of both lamps.

The answer to your question 2 is therefore applicable, "2. edge to edge of tail and stop lamp so drawn in sketch C?"

ID: nht74-1.29

DATE: 08/13/74

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. Eric L. Clabourgh

COPYEE: L. OWEN

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your recent letter to the Administrator, National Highway Traffic Safety Administration, concerning the placement of front turn signal lamps on fire trucks.

Federal Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices, and Associated Equipment" (copy enclosed) requires that front turn signal lamps be located "at or near the front and be spaced "as far apart as practicable." We would, therefore, have no objection to moving the front turn signal lamps on the fire truck from the side to the front. Locating the lamps on the front could also reduce the chance of damage to them, which might occur if they were located on the side.

Sincerely,

ATTACH.

Administrator And Counsel N.H.T.S.A. Washington, D.C.

Gentlemen:

I am in need of urgent information deciding a standard, specifically, standard 108, I understand, applies to big trucks. All effective 1-1-68. Soon we, the city of (Illegible Word) town commissioners, will receive a fire truck chassis made by international and the rest by the American fire apparatus co. of (Illegible Word), Iowa.

In a few months it will be delivered and it was bought with (Illegible Words) sharing money.

We are in debate! the Fire (Illegible Text)

(Graphics omitted)

These International beauties won't make the taxpayers see red.

Fires and fire departments come in a lot of different sizes -- and so do international Fire Truck chassis.

There's one to fit your budget, sure, but more important they'll also fit the kind of community you serve and the kinds of fires you fight.

I like the CARGOSTAR(R) top right, a short wheel base lets you turn in tight spots. The cab-over design gives you better visibility, and the cab also tilts forward for quicker, handier engine access. You can get it equipped the way you want it, with power to pump up to 1,250 gallons a minute.

On the left is a customized FLEETSTAR* chassis it comes with GVW ratings from 23,000 to 54,000 pounds and pound for pound it's the most efficient, economical fire-fighter around.

Down front is international's LOADSTAR* it can be customized as an assist-type vehicle, rescue truck pumper, or ladder truck. And this one has an engine and fuel capacity big enough to keep on working till the smoke clears.

(Graphics omitted)

ID: nht74-1.3

DATE: 10/07/74

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

TO: Borg-Warner Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

OCT 7 1974 N40-30(ZTV)

Mr. Mike A. Read Design Engineer, Spring Division Borg-Warner Corporation 700 South 25th Avenue Bellwood, Illinois 60104

Dear Mr. Read:

This is in reply to your letter of September 13, 1974, pointing out discrepancies between our two standards covering motor vehicle hydraulic brake systems, Nos. 105-75 and 122.

We intend to amend Standard No. 122 in the near future to be consistent with Standard No. 105-75. This will clarify that the same interpretation will be given master cylinder reservoir and capacity requirements.

Thank you for pointing this out to us.

Yours truly,

Richard B. Dyson Acting Chief Counsel

ID: nht74-1.30

DATE: 02/15/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Maserati, S.p.A.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 22, 1974, asking whether paragraph S4.3.1 of Motor Vehicle Safety Standard No. 108 precludes the mounting of rear lamps in a transparent "Lexan" panel "not involved in the driver's rearward vision."

Paragraph S4.3.1 states in pertinent part that ". . . each lamp . . . shall be securely mounted on a rigid part of the vehicle other than glazing that is not designed to be removed except for repair . . . ." The "glazing" referred to is the glazing regulated by Standard No. 205, and refers generally to glazing used in windshields, windows, doors, and interior partitions. Accordingly, Standard No. 108 does not preclude the mounting of rear lamps in the "Lexan" panel.

Yours truly,

ATTACH.

OFFICINE ALFIERI MASERATI S.p.A.

January 22, 1974

National Highway Traffic Safety Administration -- Office of Chief Counsel;

Attention: Mr. Vinson

Subject: Request for clarification of MVSS No. 108, Paragraph S.4.3.1.

Gentlemen:

Since we are planning to introduce soon in the United States our new model, the "KHAMSIN" (model 120), we would very much appreciate your clarifying the intent of paragraph S.4.3.1. of Motor Vehicle Safety Standard No. 108 -- "Lamps, Reflective Devices and Associated Equipment."

Paragraph S.4.3.1 of MVSS No. 108 states that "each lamp . . . . . shall be securely mounted on a rigid part of the vehicle other than glazing that is not designed to be removed except for repair, . . .".

As you will see in the enclosed documents, the "KHAMSIN" is a two door GT coupe which embodies, as a new styling concept, a rear end panel made of transparent "Lexan" material. The two rear combination lamps are securely mounted on this Lexan panel.

The Lexan material is a polycarbonate sheet, produced by the General Electric Company under the designation "LEXAN MR-4000". It is especially treated on both sides in order to make it scratch resistant. It is completely collision proof and is classified by the "Underwriters' Laboratories Inc." as the sole transparent antilock-picking material.

The mounting of the rear combination lamps on the rear end panel is described in the enclosed blueprint No. 120 VS 83090 and shown on the 2 enclosed B & W photographs.

This tansparent rear end panel is not involved in the driver's rearward vision and it is transparent only for aesthetic purposes. It is permanently mounted on the vehicle and its replacement constitutes a major repair.

We believe that paragraph S.4.3.1 of Standard No. 108 was intended to prevent mounting of lamps on glazing material which concurs to the driver's vision (such as windows), but since the wording of this paragraph is not clear to us, we would appreciate very much your clarifying if mounting the rear lamps such as it is done on the KHAMSIN does comply with MVSS No. 108.

Thanking you very much in advance for a prompt answer, we remain at your disposal should you need more information on this matter.

Very truly yours,

Bernard Belier -- U.S. Resident Engineer for MASERATI S.p.A.

ID: nht74-1.31

DATE: 02/26/74

FROM: CERSAS FOR E.T. DRIVER, NHTSA

TO: Mack Trucks, Inc.

COPYEE: J. LEYSATH; MR. VINSON

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 4, 1974, concerning the location requirements of front identification lamps on certain solid-waste disposal vehicles.

You describe the vehicles in question as "short BBC low cab-ever-engine type vehicles -- equipped with a large volume body and a hydraulically operated front leader mechanism. This unit lifts containers of waste up and over the front of the cab and empties the waste into the top of the body. To prevent damage to the front of the vehicle and lamps, a protective guard is installed on the front centerline of the vehicle." You further state that "This guard could obstruct the center identification lamp."

You ask whether or not all three of the front identification lamps may be offset from the front centerline of the vehicle to ensure compliance with the visibility requirements of FMVSS No. 108. In accordance with paragraph S4.3.1. Table II of FMVSS No. 106 specifies that the front identification lamps be located "as close as practicable to the top of the vehicle, at the same height, as close as practicable to the vertical centerline." For the vehicles which you have described, it would appear that location of the front identification lamps either left or right of the vertical centerline would meet this requirement.

Sincerely,

ATTACH.

February 4, 1974

E.T. Driver -- National Highway Traffic Safety Administration, Office of Operating Systems

Dear Mr. Driver:

Subject: Request for Interpretation MVSS 108

Section S4.1.1 table I states that three identification lamps are required for vehicles of 80 or more inches overall width.

Section S4.3.1 table II requires that "three amber identification lamps be located on the front as close as practicable to the top of the vehicle, at the same height, and as close as practicable to the vertical centerline".

In addition, Section S4.3.1.1 requires that each lamp be located so that it meets the visibility requirements of applicable SAE Standards and that no part of the vehicle shall prevent the device from meeting the photometric output at any test point specified in any applicable SAE Standard.

Section S4.3.1.1 also states that if motor vehicle equipment prevents compliance, an auxiliary lamp or device meeting the requirement shall be provided.

The solid waste disposal industry use short BBC low cab-over-engine type vehicles (see Attachments 1 & 2) equipped with a large volume body and a hydraulically operated front loader mechanism. This unit lifts containers of waste up and over the front of the cab and empties the waste into the top of the body. To prevent damage to the front of the vehicle and lamps, a protective guard is installed on the front centerline of the vehicle. This guard could obstruct the center identification lamp. (See Attachment 3 through 6)

One of our customers has requested that we supply four identification lamps on the forward side of our MB series vehicle cab near the top so that he can mount a protective guard on the centerline of the cab and still meet the visibility and photometric requirements.

As we discussed during my visit of January 31st, use of four lamps will not be acceptable to the National Highway Traffic Safety Administration as it would defeat the identification function of these lamps for vehicles over 80" in width.

However, it was proposed that all three identification lamps could be moved to one side of the centerline, thereby permitting compliance with the visibility and photometric requirements when the units are in the installed position. This appears to us to be an effective solution to this problem and we, therefore, request your issuance of an interpretation for an installation of this type.

Very truly yours, MACK TRUCKS, INC.; A. M. Fischer -- Asst. to Exec. V.P.- Engineering & Product

Enclosure Omitted.

ID: nht74-1.32

DATE: 05/16/74

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

TO: Lt. Commander Robert H. Weldman, Jr.

COPYEE: LARSON; RANADER

TITLE: FMVSS INTERPRETATION

TEXT: This response to your letter of April 17, 1974, to the Department of Transportation requesting information on standards for (Illegible Word) Lighting systems. We have me record of your (Illegible Words)

In answer to your specific questions --

1. "Are there any federal or state regulations which specify sealed beam headlamps?"

Yes, this requirement has been effective either by Federal or State standards for more than three decades.

2. "Are both acceptable?"

A replacable bulb type headlamp is not acceptable.

3. "Is amber a permissible headlight (Illegible Word)

No, headlight must white light.

4. "Is white mandatory for backup lights?"

Yes, white is mandatory.

Sincerely,

ATTACH.

APRIL 17, 1974

U.S. Department of Transportation,

Attn: Federal Standards for Automobiles.

Dear Sirs,

I wrote you on 12 February 1974 to ask for information on Federal and state standards for automobile lighting systems. I have received no reply, so herewith a repeat of my request: are there any federal or state regulations which specify sealed beam headlamps, or are bulbs acceptable? Is amber a permissible headlight color? Is white mandatory for backup lights?

I will appreciate any information you can give me.

Sincerely,

Robert H. Weidman, Jr. -- LCDR USN,

Box 33 B753, FPO NEW YORK 09540