ID: nht92-1.38

DATE: 12/07/92

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: RICHARD HORIAN -- PRESIDENT, WOODLEAF CORP.

ATTACHMT: ATTACHED TO LETTER DATED 11-6-92 FROM RICHARD HORIAN TO PAUL J. RICE (OCC 7980)

TEXT: This responds to your two letters of November 6, 1992, with respect to the allowability under Federal regulations of the "Sudden Brake Indicator Hazard Light." As you describe it, "when a driver engages in hard braking, a circuit activates a separate lighting system to warn other drivers to pay special attention to a potentially hazardous situation."

This system will not utilize any of the existing rear lights on a vehicle, and will consist of a single lamp or pair of lamps, either mounted separately, or in the same housing as the center high-mounted stop lamp. The system will be red or amber in color, and either steady burning or flashing. The system is activated only when a predetermined threshold of pressure is reached upon depression of the brake pedal.

Supplementary lighting systems such as the one you have described are permissible as original motor vehicle equipment under Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment if they do not impair the effectiveness of the lighting systems required by the standard, or if there is no provision of the standard that affects them. Paragraph S5.4 of Standard No. 108 specifically prohibits the physical combination of the center highmounted stop lamp with any other lamp or reflective device, thus your system could not be used in a common housing with the center light (see copy of enclosed letter to Mr. S. Suzuki on this subject). However, if the system is mounted separately, under the circumstances you have presented, we do not believe that there would be any direct impairment of the required rear lights, or indirect impairment such as might be created when confusion may result upon simultaneous operation of the supplementary light and any required light.

As the letter to Mr. Suzuki indicates, passenger cars manufactured before September 1, 1985, were not required to be equipped with the center lamp. This means that your light could be combined in the same housing as a center lamp intended for installation on vehicles manufactured before September 1, 1985, but it could not be part of a replacement center lamp intended for use on vehicles manufactured subsequently. In addition, with the exception just noted, installation of the system on a vehicle in use would not appear to affect the safety functioning of any safety system necessary for continued conformance of the vehicle, it would appear that your system is acceptable for sale and installation in the aftermarket as well. However, the individual States have the authority to regulate lamps for vehicles in use, and we suggest that you contact the American Association of Motor Vehicle Administrators (AAMVA) for an opinion as to whether the system is permissible under State laws. AAMVA's address is 4600 Wilson Boulevard, Arlington, Va. 22203.

ID: 1993y

Mr. Taylor Hong
President, Fair Sun Industrial Co., Ltd.
P.O. Box 36-570
Taipei, Taiwan

Dear Mr. Hong:

This is in reply to your letter with reference to motor vehicle flashers that you wish to sell in the United States.

You have asked the following questions:

l. "How do we get DOT approval?" 2. "Should ask for an application forms from you and sent one lot of samples for your test?"

The Department has no authority to "approve" flashers, and no laboratory of its own in which it tests them. Under our law, the National Traffic and Motor Vehicle Safety Act, the manufacturer of the flashers, not the Department, determines in the first instance whether or not they comply with the SAE materials incorporated into Federal Motor Vehicle Safety Standard No. l08. If the manufacturer is convinced that they comply, it certifies that the flashers meet Standard No. l08, either with a statement on the container in which the flashers are shipped, a tag attached to each flasher, or a DOT symbol on the flasher itself. From time to time, the Department buys flashers for testing. In this manner, the Department has discovered that a number of those manufactured in Taiwan have not met Federal requirements, and lacked the required certification. In some instances, civil penalties have been imposed against the manufacturer or importer of the flashers.

3. "We may send samples to any other Laboratory and get an approval?"

To aid you in reaching a conclusion whether the flashers are designed to conform with Standard No. 108, you may send samples to any test laboratory you wish. Although the standard deems a flasher compliant if not less than 17 of 20 flashers tested meet the requirements, we caution you that you should not accept such a result as a guarantor of compliance. Because of the tolerances involved in production of flashers, we believe that a manufacturer wishing to ensure that at least 17 of 20 flashers will pass whenever the government tests them should design its flashers to achieve a higher level of compliance with durability and performance requirements than the minimum acceptable number of 17. Once a higher level is reached, a manufacturer should ensure that the flashers will continue to meet Standard No. l08 over time. Accordingly, we urge flasher manufacturers to test their products periodically as an assurance that a minimum of 17 out of every 20 continue to meet the performance and durability requirements specified.

Although you have no obligation to obtain "approval" from the Department, there are two requirements that manufacturers of flashers must meet before offering their products for sale in the U.S. You must designate an agent for service of process (49 CFR 551.45) and file an identification statement (49 CFR Part 566). I enclose a copy of these regulations for your information.

If you have any further questions we shall be pleased to answer them.

Sincerely,

Stephen P. Wood Acting Chief Counsel

Enclosures

/ref:108 d:9/l3/89

ID: nht80-1.37

DATE: 03/18/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Aeroquip Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your January 17, 1980, letter asking whether the performance requirements of the parking brake sections of Standard No. 121, Air Brake Systems, permit the use of a common piston for both the service and parking brakes.

In our August 9, 1979, Federal Register notice (44 FR 46850), we stated that the performance requirements of the parking brake system must be achieved with any single leakage-type failure in the service brake system, including a ruptured diaphragm. The use of the diaphragm example was intended only to clarify a question that had been raised by a commenter to the notice proposing the parking brake amendment. The diaphragm example does not limit the requirement that any single leakage-type failure of a component of the service brake system must not affect the performance of the parking brake system.

With respect to your question, you state that a piston does not fail in the sudden manner of a diaphragm. Although this may be accurate, it is not the correct approach for interpretation of the performance requirements of the parking brake sections of the standard. If your parking brake system would comply with the requirements of the standard once the piston in the service brake system has failed, then you would be permitted to use a common piston. If, on the other hand, a failure of the service brake piston would cause the parking brake system to fail the requirements, a common piston would not be allowed.

SINCERELY,

AEROQUIP CORPORATION JACKSON, MICHIGAN 49203

January 17, 1980

Roger Tilton Office of Chief Counsel National Highway Traffic Safety Administration

Re: (Docket No. 75-16; Notice 26) FR Vol. 44, No. 155, page 46850 Thursday, August 9, 1979

Dear Mr. Tilton:

The following statement in regard to the performance of emergency-parking brakes applied by air pressure rather than by spring force appears in the subject Federal Register:

"Thus, the prescribed performance must be achieved with any type of failure in the service brake system, including a ruptured diaphragm".

This statement makes it plain that the service and emergency-parking brake systems may not share a common diaphragm.

Since it is not dealt with in the ruling and because a piston brake does not fail in the complete and usually sudden manner of a diaphragm, we are interpreting the ruling to allow the use of a common piston, assuming all requirements of the ruling are met.

Would you please confirm our assumption at your earliest convenience. You may contact me at (517) 787-8121. Thank you for your cooperation.

C. Crissy Manager, Mechanical Products

ID: nht89-3.26

TYPE: INTERPRETATION-NHTSA

DATE: 11/01/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: KARL-HEINZ FABER -- VICE PRESIDENT PRODUCT COMPLIANCE SERVICE AND PARTS MERCEDES-BENZ OF NORTH AMERICA, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 08/09/89 FROM MERCEDES BENZ OF NORTH AMERICA TO STEPHEN P. WOOD; REQUEST FOR INTERPRETATION, FMVSS 108, LAMPS, REFLECTIVE DEVICES AND ASSOCIATED EQUIPMENT; OCC 3823

TEXT: Dear Mr. Faber:

This is in reply to your letter of August 9, 1989, with respect to the interpretation of the word "headlamp" as it appears in paragraph S7.2 of Motor Vehicle Safety Standard No. 108.

In pertinent part, this paragraph specifies that certain markings shall be placed on the lens of each headlamp, with "each headlamp" to be marked with the voltage and part or trade number. Noting that "headlamp" is not a defined term but "replaceable bu lb headlamp" is, you have asked for confirmation that marking the lens, the reflector, or the light source with the voltage would be in compliance with paragraph S7.2.

The agency intends that the voltage be indicated on the exterior of the headlamp. If the manufacturer does not wish to put it on the lens, Standard No. 108 will permit, as of December 1, 1989, voltage marking to be on an exterior part of the headlamp bo dy, but not on the light source.

I hope that this answers your question.

Sincerely

ID: 8023-2

Mr. Terry Wagar
Technical Services Bureau
State of New York
Department of Motor Vehicles
Division of Vehicle Safety Services
The Governor Nelson A. Rockefeller Empire State Plaza
Albany, NY 12228

Dear Mr. Wagar:

This responds to your letter asking about the repair of glazing in in-service motor vehicles that were originally designed to comply with Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR 571.205). You were specifically concerned about the safety of a repair process known as "Ultra B-O-N-D" which you explained involves injecting a liquid through a crack in a windshield. The repaired area is then exposed to a lamp, scraped with a razor blade, and cleaned. You explained that after this process is completed, the crack is "not as visible."

By way of background information, the National Traffic and Motor Vehicle Safety Act (Safety Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards applicable to new motor vehicles and new motor vehicle equipment. Pursuant to this authority, the agency has issued Standard No. 205, which establishes performance requirements for all windows (called "glazing" in the Standard) in new motor vehicles and for all new replacement windows for motor vehicles.

The Federal motor vehicle safety standards do not apply to vehicles and motor vehicle equipment after their first sale to a consumer. The Safety Act does include a provision that prohibits manufacturers, distributors, dealers and motor vehicle repair businesses from "rendering inoperative" any device or element of design installed on or in a motor vehicle in compliance with an applicable Federal motor vehicle safety standard. However, that provision does not require those entities, in repairing a damaged vehicle, to restore it to its original level of performance.

The States do have the authority to regulate motor vehicle repairs and the condition of in-service vehicles, and this agency encourages them to take steps to ensure the safe operating condition of vehicles-in-use. (The Federal Highway Administration has in-service requirements for commercial motor vehicles used in interstate commerce.) I regret that we are unable to provide any information concerning the safety of the "Ultra B-O-N-D" process. We suggest that, in developing criteria for the condition of in-use glazing, including the permissibility of certain types of repairs, that you consider such factors as whether particular damage, even after repair, would adversely affect driver visibility, would likely become more serious during normal use (e.g., a small crack becoming a large crack), would reduce the ability of the windshield to retain unrestrained occupants in the vehicle, or would otherwise adversely affect vehicle safety. In addition, if the windshield is so extensively damaged that it cannot be repaired using the "Ultra B-O-N-D" process, and must be replaced, the new windshield should be installed in accordance with the vehicle manufacturer's instructions. In the event of an accident, an improperly installed windshield may allow unrestrained occupants to be ejected from the vehicle with resulting personal injury.

I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.

Sincerely,

John Womack Acting Chief Counsel

ref:205 d.1/22/93

ID: nht93-1.15

DATE: January 22, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Terry Wagar -- Technical Services Bureau, State of New York, Department of Motor Vehicles, Division of Vehicle Safety Services

TITLE: None

ATTACHMT: Attached to letter dated 11/16/92 from Terry W. Wagar to Paul J. Rice (OCC 8023)

TEXT:

This responds to your letter asking about the repair of glazing in in-service motor vehicles that were originally designed to comply with Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR S 571.205). You were specifically concerned about the safety of a repair process known as "Ultra B-0-N-D" which you explained involves injecting a liquid through a crack in a windshield. The repaired area is then exposed to a lamp, scraped with a razor blade, and cleaned. You explained that after this process is completed, the crack is "not as visible."

By way of background information, the National Traffic and Motor Vehicle Safety Act (Safety Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards applicable to new motor vehicles and new motor vehicle equipment. Pursuant to this authority, the agency has issued Standard No. 205, which establishes performance requirements for all windows (called "glazing" in the Standard) in new motor vehicles and for all new replacement windows for motor vehicles.

The Federal motor vehicle safety standards do not apply to vehicles and motor vehicle equipment after their first sale to a consumer. The Safety Act does include a provision that prohibits manufacturers, distributors, dealers and motor vehicle repair businesses from "rendering inoperative" any device or element of design installed on or in a motor vehicle in compliance with an applicable Federal motor vehicle safety standard. However, that provision does not require those entities, in repairing a damaged vehicle, to restore it to its original level of performance.

The States do have the authority to regulate motor vehicle repairs and the condition of in-service vehicles, and this agency encourages them to take steps to ensure the safe operating condition of vehicles-in-use. (The Federal Highway Administration has in-service requirements for commercial motor vehicles used in interstate commerce.) I regret that we are unable to provide any information concerning the safety of the "Ultra B-0-N-D" process. We suggest that, in developing criteria for the condition of in-use glazing, including the permissibility of certain types of repairs, that you consider such factors as whether particular damage, even after repair, would adversely affect driver visibility, would likely become more serious during normal use (e.g., a small crack becoming a large crack), would reduce the ability of the windshield to retain unrestrained occupants in the vehicle, or would otherwise adversely affect vehicle safety. In addition, if the windshield is so extensively damaged that it cannot be repaired using the "Ultra B-0-N-D"

process, and must be replaced, the new windshield should be installed in accordance with the vehicle manufacturer's instructions. In the event of an accident, an improperly installed windshield may allow unrestrained occupants to be ejected from the vehicle with resulting personal injury.

I hope this information is helpful. Please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information.

ID: 77-4.49

TYPE: INTERPRETATION-NHTSA

DATE: 12/12/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Robert D. Scifres

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of October 27, 1977, asking whether the use of two rearview mirrors in one mounting is permitted if one of the mirrors fails to meet Federal requirements.

Safety Standard No. 111, Rearview Mirrors (49 CFR 571.111), requires each passenger car to have an outside rearview mirror of unit magnification (plane mirror) on the driver's side of the vehicle. Paragraph S4.2.1 of the standard specifies the field of view that must be provided by this outside mirror. Provided the vehicle is equipped with one mirror that meets the requirements of paragraph S4.2.1, the use of additional, non-complying, mirrors is not precluded by the standard, even if the mirrors are in the same mounting with the complying mirror.

Please contact us if you have any further questions.

Sincerely,

ATTACH.

October 27, 1977

TO: U.S. Department of Transportation -- National Highway Traffic Safety Administration

FROM: Robert D. Scifres

SUBJECT: Request for interpretation - Motor Vehicle Safety Standard No. 111, S3.2.1.1

As can be seen in the attached drawing(Exhibit I), this outside rearview mirror for passenger cars incorporates the use of two mirrors located in one assembly. One mirror(A) would conform in all respects to the current standards. The second mirror(B) would conform to all standards except as it relates to the field of vision. In itself the height would not provide the required reflected field of vision, but in conjunction with mirror (A) would provide an expanded field of vision to the extent the "blind spot" would be eliminated. Each mirror is adjustable both horizontally and vertically, allowing the driver to adjust each to give him the maximum reflection.

While the standards do not specifically nor indirectly state a single faced mirror only will be allowed; and although paragraph (1) of 32 F.R. 2413, dated February 3, 1967 relates to a "supplemental" mirror in addition to the inside and outside mirrors; and subsequent revisions do not change the above, I strongly feel an interpretation is in order.

My request comes about because of a very near accident involving me when I started to change lanes on a high speed highway. After checking both inside and outside rearview mirrors, I started to pull into the next lane to my left. Only because the driver of the vehicle behind me was alert prevented a serious accident. I have discussed this situation with about one hundred fifty of my acquaintences and almost all have experienced the same thing in one degree or another with several actually having an accident and three involved in rear end collisions because they had turned their head to make sure about the blind spot only to ram the rear of the cars in front of them.

In view of the standards as written, I feel an interpretation should be given and I shall appreciate an early response to this request

(Graphics omitted)

EXHIBIT I

Fig 1

ID: nht90-1.88

TYPE: INTERPRETATION-NHTSA

DATE: MARCH 29, 1990

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TO: J. BRETTSCHNEIDER -- ROBERT BOSCH GMBH

TITLE: NONE

ATTACHMT: LETTER DATED 8-31-89 TO RICHARD VAN IDERSTINE, NHTSA, FROM J. BRETTSCHNEIDER, ROBERT BOSCH GMBH, ATTACHED.

TEXT:

This is in reply to your letter to Mr. Van Iderstine of this agency, with reference to the performance of the impact test according to SAE J1383. I regret the delay in responding.

You state that according to paragraph 4.10.3 of J1383, the impact test is conducted along the mechanical axis, and that paragraph 2.14 of SAE J579 defines the mechanical axis as perpendicular to the aiming plane through the geometric center of the lens. With respect to this, you have asked two questions: "where is the geometric center of a lens without aiming pads?", and "where is the geometric center of a lens which moreover covers two compartments, one for the lower beam and one for the upper beam?"

First, we must advise you that the impact test of J1383 is not required for any headlamp covered by Federal Motor Vehicle Safety Standard No. 108. The impact test that is required for integral beam and replaceable bulb headlamps is specified in section S8.8, and we shall answer your questions with respect to its provisions.

S8.8 states in part that "one impact shall be delivered to the center of the lens on the mechanical axis." This language originated in 1983 with the adoption of specifications for replaceable bulb headlamps, when a headlamp was not permitted to incorporate more than one light source. Thus, the lens center and mechanical axis were coincident. Now that Standard No. 108 permits two standardized replaceable light sources in a headlamp, there are two mechanical axes. We also note that lamps may now use Vehicle Headlamp Aiming Devices, and thus have lenses without aiming pads. As we understand your concern, you appear to be uncertain as to the location of the impact for the test of section S8.8.

After reviewing your letter, we have concluded that the language "on the mechanical axis" is a redundancy. Thus, the impact should be applied on the center of the lens, without reference to the mechanical axis. We consider the center of the lens to be the intersection of the lens and a line which is parallel to the longitudinal axis of the vehicle and passes through the centroid of the projected lens area as viewed on a plane perpendicular to the longitudinal axis of the vehicle.

We shall be pleased to answer any further questions you may have.

ID: nht76-1.41

DATE: 02/24/76

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

TO: Layton Paving Equipment Specialists

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 14, 1976, asking whether your company's paver product must comply with the requirements of Federal motor vehicle safety standards and regulations, particularly Standards No. 119 and 120.

The National Highway Traffic Safety Administration (NHTSA) issues safety standards and regulations for "motor vehicles." Section 102(3) of the National Traffic and Motor Vehicle Safety Act defines a motor vehicle as a vehicle "manufactured primarily for use on the public streets, roads, and highways." Thus, a motor vehicle is a vehicle which the manufacturer expects will use public highways as part of its intended function. The primary function of some vehicles is of a mobile, workperforming nature, and, as such, their manufacturer contemplates a primary use of the highway. Mobile cranes, rigs, and towed equipment such as chippers and pull-type street sweepers that travel at a normal highway speed are examples in this area. These motor vehicles qualify as trucks or trailers. As such they are subject to the Federal motor vehicle safety standards and regulations. On the basis of the information you have sent us your company's towed paver appears to be in this category of vehicles, and would therefore be considered a "motor vehicle."

There are some vehicles which are excepted from the motor vehicle classification despite their use on the highway. Highway maintenance and contruction equipment, lane stripers, self-propelled asphalt pavers, and other vehicles whose maximum speed does not exceed 20 mph and whose abnormal configuration distinguishes them from the traffic flow are not considered motor vehicles. Your company's paver would not appear to qualify in this category of vehicles since, as a towed paver, it would travel at a speed greater than 20 mph, at least when moving between job sites.

Consequently, your product must comply with the requirements of the Federal standards and regulations. Standard No. 119, New Pneumatic Tires for Vehicles Other than Passenger Cars, does not directly impose any duty on you, because it applies to tires rather than vehicles. However, the NHTSA has recently issued Federal Motor Vehicle Safety Standard No. 120, Tire Selection and Rims for Vehicles Other Than Passenger Cars (copy enclosed). This standard does require, effective September 1, 1976, that your vehicles be equipped with tires that conform to Standard No. 119 and are of sufficient load rating.

In addition to compliance with the safety standards and regulations, you must ensure that your product does not contain a defect relating to motor vehicle safety. Vehicles containing such defects are subject to the notification, remedy, and civil penalty provisions of the National Traffic and Motor Vehicle Safety Act. For example, a vehicle equipped with tires that are designed for speed-restricted use would probably be considered to contain a safety-related defect if the vehicle is expected to travel at higher speeds.

Please contact us if we can be of any further assistance.

YOURS TRULY,

LAYTON

PAVING EQUIPMENT SPECIALISTS

January 14, 1976

Frank A. Berndt, Chief Counsel National Highway Traffic Safety Administration

RE: Motor Vehicle Standards 119 and 120

Pursuant to your request we are writing you with reference to the above two standards and as to whether or not they apply to the construction machinery we manufacture. To make it easier for you and your staff to review our request, I am enclosing herewith five items which are labeled "Exhibit A" through "D."

Exhibit A shows the tires that we are using as an undercarriage for our paver. These tires are specially designed and manufactured to our specifications, size 530/450 x 6 inches, six-ply safety rib. This is a full six-ply tire and not merely a six-ply rated tire, and has a manufacturer's rating of 680 lbs. per tire at a reasonable rate of speed. The maximum weight that our equipment would display would not exceed 450 lbs. per tire. Over the past 11 years we have manufactured and sold approximately 4,100 units and to date have not experienced any problems.

Exhibit B illustrates the special construction of the walking beam assembly on which the tires are mounted.

Exhibits C and D illustrate the paver in its entirety and also show it being attached to a vehicle for transportation. I think we should clarify what we mean by mobility because of the towing assembly. The paver is designed so that it may be transported from one job to another by virtue to the towing assembly and rubber-tired undercarriage, therefore making it more flexible for contractors and municipalities to plan their jobs, etc., and is not intended as a vehicle for extended highway use inasmuch as the vehicle will be towed less than 10% of the time and in a small vicinity. We have two companies that supply our industrial tires for this equipment: General Tire and Rubber Company and Goodyear Tire and Rubber Company.

Mr. Berndt, we ask that you review the enclosure and consider the following requests: 1) To have our equipment and its components described therein to be classified as construction machinery, and 2) an opinion and/or waiver to be issued which allows the equipment to be used as it has in the past since this is the only type of tire that can be used for our equipment.

If you need additional information or technical data, please feel free to contact Mr. Jack Layton, president and general manager, Mr. John Newcomb, manufacturing manager and chief engineer, at (503) 85-4888.

I sincerely appreciate your courtesies when I talked to you on the phone and can assure you our company will be grateful for anything you might do to help expedite our request.

Earl C. Sievers Finance Manager

ID: nht69-2.17

DATE: 10/16/69

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

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

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your recent submittal of data to the National Highway Safety Bureau, concerning the addition of the belted-bias tire construction as a new category within Table I of Appendix A of Federal Motor Vehicle Safety Standard No. 109. Your submittal was not accompanies by a cover letter.

The National Highway Safety Bureau realizes that this construction of motor vehicle passenger car tires warrants consideration within Standard No. 109. We do not believe, however, that the introduction of additional tables to the standard is needed to cover belted-bias tires. The tables within the standard are becoming voluminous and the variety of size designations are confusing to the consumer.

During the recent ISO/TC 31 meetings in Rome, Mr. W. W. Jordan, Chief of the Tire Branch discussed briefly with members of your organization our philosophy on the standardization of the tire size designations and load inflation schedules. We have been working closely with the American Tire and Rim Association in further developing the alphanumerical system for tire size designations. We believe we are approaching a workable, standardized solution to the problem. In this light, we understand that members of E.T.R.T.O. visit the United States at regular intervals and we would like to extend an invitation to your organization to have a representative meet with us to review this matter and your petition in detail.

The National Highway Safety Bureau, at the present time, does not plan to differentiate belted-bias type tire construction from other constructions, consequently, we will delay action on your petition until we have the opportunity to discuss it with your representative.