ID: nht89-3.43

TYPE: INTERPRETATION-NHTSA

DATE: 11/21/89

FROM: MICHAEL S. KMIECIK

TO: NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 05/30/90, DN A35 STD 215, FROM STEPHEN P. WOOD -- NHTSA TO MICHAEL S. KMIECIK; Alpha I GTO, Ferrari on Rice (article omitted)

TEXT: I would like to purchase several of these kits and produce a few cars for resale. I need an interpretation of Safety Standard 581. If Datsun is produced before Sept. 1, 1976 are used does this kit meet the requirements of Safety Standard 215. Also cou ld you please send me a copy of Safety Standard 215 and Safety Standard 108.

ID: nht73-1.38

DATE: NOVEMBER 23, 1973

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

TO: Mr. James C. Martin

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 9 to the U. S. Department of Transportation concerning the operation of 4-way flashers and brake lights on a 1972 Toyota.

Since there is no requirement that the hazard warning signal (4-way flashers) be capable of operating independently of the stop signal, it is permissible for the stop signal to override the hazard warning signal. In fact, these signals on most passenger cars and multipurpose passenger vehicles manufactured in the United States operate similarly.

ID: nht89-1.76

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 18, 1989

FROM: WILLIAM SHAPIRO -- MGR., PRODUCT COMPLIANCE, VOLVO CARS OF NORTH AMERICA TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: REQUEST FOR INTERPRETATION, OUR LETTER JULY 11,1988

ATTACHMT: ATTACHED TO LETTER DATED 4-16-90 TO WILLIAM SHAPIRO FROM STEPHEN P. WOOD; (A35; STD. 210). ALSO ATTACHED TO LETTER DATED 7-11-88 TO ERIKA Z. JONES FROM WILLIAM SHAPIRO.

TEXT:

Enclosed is a copy of our July 11, 1988 letter re: FMVSS 210.

We would appreciate your reply as soon as possible because our engineering department is awaiting an answer.

Thank you for your attention.

Enc.

ID: nht80-1.41

DATE: 03/26/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: David Williams

TITLE: FMVSR INTERPRETATION

TEXT: I would like to clarify my remarks of March 17, 1980, with respect to the applicability of Federal motor vehicle safety standards to imported vehicles.

In that letter I implied that there was a prohibition against importing cars that didn't meet Federal standards and that such vehicles had to comply with standards in effect on the date of importation. Actually, a nonconforming vehicle may be imported under bond if it will be brought into compliance within 120 days of entry with all applicable standards in effect on the date of its manufacture.

ID: nht71-5.33

DATE: 12/27/71

FROM: R. L. CARTER -- NHTSA; SIGNATURE BY E. DRIVER

TO: American Safety Belt Council

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 3, 1971, regarding seat belt buckle requirements.

Your interpretation that push-button buckles are not mandatory on seat belts offered for sale as replacement parts after January 1, 1972, is correct. Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, specifies that seat belts, installed in passenger cars after January 1, 1972, must have latch mechanisms that release by push-button action. It does not apply to replacement belts.

If we can be of further assistance, please do not hesitate to contact us.

ID: nht90-1.47

TYPE: INTERPRETATION-NHTSA

DATE: FEBRUARY 19, 1990

FROM: ANTHONY T. GREENISH -- U.N.D.P.

TO: U.S. DEPT. OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-25-90 TO ANTHONY P. GREENISH FROM STEPHEN P. WOOD; (A35; PART 591) TEXT:

I am presently contemplating purchasing a car in Europe and importing it when I return to the United States in July 1990. The two models I have in mind are:

1. The BMW model 324 d Diesel

2. The Honda model Accord 1.6 Ix

Any information you can provide as to how these cars rate as to motor vehicle safety standards would be very welcome.

ID: nht89-3.41

TYPE: INTERPRETATION-NHTSA

DATE: NOVEMBER 21, 1989

FROM: MICHAEL S. KMIECIK

TO: NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED APRIL 8, 1990 TO MICHAEL S. KMIECIK FROM STEPHEN P. WOOD; (A35; VSA 108(a)(2)(A); GRAPHICS OMITTED. TEXT:

I would like to purchase several of these convertible kits and produce a few cars for resale. I need to know the safety standards that apply to convertibles 1978 and older. I would also request an interpretation as to whether this conversion kit meets these standards. The main safety features of this kit seem to be:

1. reinforce windshield pillar with steel.

2. 1 in. steel tubing welded to shock towers.

3. 2 x 3 x 1-1/2 in. channel iron over the original unibody frame rails.

ID: nht93-1.9

DATE: January 14, 1993

FROM: Jay Lee -- President, Pacific Agritrade Inc.

TO: Jackson Rice -- NHTSA, Department of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 3-26-93 from John Womack to Jay Lee (A40; Std. 208; VSA 108(a)(2)(A))

TEXT: We would like to import air bags for cars and light trucks from Korea. This air bag can be installed very easily and we are interested in having this product tested by your department.

Please advise us on what procedures we need to take to have this product tested and approximately how long it will take.

We are also interested in knowing what we can claim after we pass your tests.

ID: nht67-1.15

DATE: 02/27/67

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr. M.D.; NHTSA

TO: Edward K. Kennedy, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 10, 1967.

Motor Vehicle Safety Standard No. 105 applies only to new passenger cars manufactured January 1, 1968, or later. Although the National Traffic Safety Agency intends to issue additional standards in the future that apply to items of motor vehicle equipment, most of the initial Motor Vehicle Safety Standards issued January 31, 1967, apply to vehicles only, as the application paragraph of each standard specifies.

Please do not hesitate to call upon us if we can be of further service to you.

ID: aiam4477

"Dear Mr. Mikoll: This responds to your recent request for confirmatio of your understanding that school buses with a gross vehicle weight rating (GVWR) of 10,000 pounds or less would comply with the existing requirements of the safety standards if those buses were equipped with a new occupant protection device your company is considering producing. As explained below, this device could not be installed in small school buses as a substitute for safety belts at those seating positions. Assuming those seating positions are equipped with safety belts, the seating positions could also be equipped with this device if the addition of the device does not prevent the safety belts from complying with the requirements of the safety standards. The new device you are considering producing is a 'safety bar.' This bar consists, in part, of two curved metal poles in planes that are parallel to the longitudinal centerline of the bus. These curved poles are joined by three cross members that are parallel to the seat and are covered with padding. The padded surface is angled at the top slightly back from the vertical. The curved metal poles are attached to the outside of the seat in front of the seat whose occupants will be protected by the 'safety bar,' so that the padded surface extends over the entire width of the seat whose occupants it is designed to protect. When the seat whose occupants are to be protected by this 'safety bar' is unoccupied, the padded surface rests approximately on the latitudinal centerline of the seat. When an occupant wishes to be seated, he or she must lift the 'safety bar' and then sit down. The 'safety bar' will then rest on the occupant's thighs. Additionally, a special strap that resembles a very long seat belt assembly must be fastened around the safety bar to hold it in position in the event of a crash. The crash protection requirements for school buses with a GVWR of 10,000 pounds or less are set forth in S5(b) of Standard No. 222, School Bus Passenger Seating and Crash Protection (49 CFR /571.222). That section provides that these school buses must be capable of meeting the requirements of Standard No. 208, Occupant Crash Protection (49 CFR /571.208) as it applies to multipurpose passenger vehicles, at all seating positions other than the driver's seat. The requirements of Standard No. 208 that apply to multipurpose passenger vehicles with a GVWR of 10,000 pounds or less are set forth in section S4.2 of Standard No. 208. That section specifies that multipurpose passenger vehicles with a GVWR of 10,000 pounds or less shall meet the requirements specified for passenger cars in either S4.1.2.1, S4.1.2.2, or S4.1.2.3 of Standard No. 208. Each of these three subsections of S4.1.2 requires each rear designated seating position to be equipped with a safety belt. S4.1.2 gives manufacturers the option of substituting a protection system 'that requires no action by vehicle occupants' for a safety belt at any or all rear designated seating positions. Your proposed 'safety bar' requires two specific actions by vehicle occupants, i.e., lifting the bar so that the seat can be occupied and buckling the strap to hold the bar in place. Therefore, the 'safety bar' could not be considered a protection system that 'requires no action by vehicle occupants,' for the purposes of S4.1.2 of Standard No. 208. Accordingly, each rear designated seating position in small school buses equipped with this 'safety bar' must also be equipped with safety belts. Assuming that these seating positions were equipped with safety belts, the installation of 'safety bars' in small school buses would be a voluntary action on the part of the school bus manufacturer. NHTSA has said in several prior interpretation letters that the systems or components installed in addition to required safety systems are not required to meet Federal safety standards, provided that the additional components or systems do not destroy the ability of required systems (the safety belts in this case) to comply with the Federal safety standards. If this is the case, the 'safety bars' could be provided as a supplement to safety belts on small school buses. To install these 'safety bars' in any new school bus, the manufacturer would have to certify that a bus with the 'safety bars' installed complied with the impact zone requirements set forth in S5.3 of Standard No. 222. Thus, if any part of the 'safety bar' was within the head protection zone or leg protection zone, the 'safety bar' would have to be certified as complying with the applicable requirements of S5.3. Additionally, the manufacturer would have to certify that the school buses with these 'safety bars' installed complied with Standard No. 217, Bus Window Retention and Release (49 CFR /571.217). Standard No. 217 requires school buses to be equipped with emergency exits of a minimum size. This means the 'safety bars' could not obstruct emergency exits located adjacent to seats. If you decide to manufacture these 'safety bars,' your company will be a manufacturer of motor vehicle equipment within the meaning of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.). As such, you will have several responsibilities, including the responsibility specified in sections 151-159 of the Safety Act (15 U.S.C. 1411-1419) to conduct a notification and remedy campaign if your company or the agency determines either that the safety bar contains a defect related to motor vehicle safety or that it does not comply with an applicable safety standard. A copy of an information sheet is enclosed, which describes briefly this and other statutory and regulatory responsibilities of manufacturers and explains how to obtain copies of our regulations. Please let me know if you have any further questions or need additional information. Sincerely, Erika Z. Jones Chief Counsel Enclosure";