ID: nht71-1.11

DATE: 03/29/71

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

TO: American Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 12, 1971, to Mr. Lewis C. Owen of this office concerning an interpretation on your lens assembly, SF-3610703.

Federal Motor Vehicle Safety Standard No. 108 requires a minimum effective projected illuminated area for Class A turn signal lamps of 12 square inches on motor vehicles other than passenger cars and motorcycles. The subject lens assembly used in a turn signal lamp assembly with the opaque ornament does not appear to meet the 12 square inches minimum requirement. The calculations for the area, as determined by the method contained in our October 28, 1970, letter to Mr. E. W. Bernitt, were based on measurements of the ornament, because the detail dimensions were not supplied.

The backup lamp design you discussed in a telephone conversation with Mr. Owen also apparently does not meet the requirements of FMVSS No. 108. If you would like an interpretation on this backup lamp, please furnish information on the design similar to that supplied with the subject letter.

ID: nht72-4.2

DATE: 01/28/72

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Docket 69-7

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: CONVERSATION WITH VOLKS WAGEN REPRESENTATIVE

On Tuesday, January 25, 1972, I received a telephone call from Joseph Kennebeck of Volkswagen of America, Inc., concerning the determination of "rated cargo and luggage capacity weight" under section S8.1.1(a) of Standard 208. Volkswagen determines its cargo and luggage capacity by multiplying the number of designated seating positions by the average occupant weight and subtracting this weight from the gross vehicle weight rating. His question was whether the cargo weight determined in this fashion would be the cargo weight used in those tests in which some seating positions are not occupied. In particular, the third option available to passenger cars between January 1, 1972, and August 15, 1973, provides for a test with occupants only at the front outboard positions, (S4.1.1.3.1), and he asked whether the cargo weight would be as indicated above or some larger weight.

I informed him that Volkswagen could use the cargo capacity as determined with a fully occupied vehicle for all tests in which the vehicle is less than fully occupied, as in S4.1.1.3.1.

ID: nht92-8.20

DATE: March 24, 1992

FROM: Tm Kozy -- Marketing Director, Infini Med

TO: Office of the Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/5/92 from Paul J. Rice to Tm Kozy (A39; Std. 208; VSA 108 (a)(2)(A))

TEXT:

I have a question regarding the use of adaptive aids (hand controls) in cars equipped with air bags. Is it illegal to install a hand control unit that is drilled into the steering column that, according to a bulletin issued by Chrysler Corporation referring to the Federal Motor Vehicle Safety Standard 208, voids the warranty on the air bag as it may render the system inoperative?

On the same subject, I need to know if such a unit were installed on an air bag equipped vehicle, and that same vehicle is resold in, say a year or two, is the seller required by law to notify the next buyer that the warranty on the airbag system has been voided, even though the controls may now have been removed?

We need to know the answers to these questions from a marketing standpoint, and also because I use hand controls myself.

Thank you for any help you can give us regarding this matter.

ID: nht76-3.5

DATE: 04/13/76

FROM: STEPHEN P. WOOD FOR FRANK A. BERNDT -- NHTSA

COPYEE: BUREAU OF MOTOR CARRIER SAFETY

TITLE: FMVSS INTERPRETATION

TEXT: I am writing in response to your March 22, 1976, telephone conversation with Mark Schwimmer of this office concerning the treatment of plastic fuel tanks under Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity.

As Mr. Schwimmer explained, the National Highway Traffic Safety Administration has issued no safety standards that apply directly to fuel tanks. Standard No. 301-75, which applies to entire vehicles, specifies fuel spillage requirements for barrier crash and rollover tests, but does not include a flame envelopment test. In addition to passenger cars and school buses, the vehicles that are subject to the standard are multipurpose passenger vehicles, trucks, and buses with a Gross Vehicle Weight Rating of 10,000 pounds or less.

Standard No. 301-75 applies to new vehicles. In addition, the Federal Highway Administration's Bureau of Motor Carrier Safety has established requirements for certain vehicles in use in interstate commerce. I understand that a fuel tank flame envelopment test is among these. For information concerning such a test, you should communicate with that agency.

For your convenience, a copy of Standard No. 301-75 is enclosed.

ID: nht75-2.5

DATE: 11/25/75

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

TO: E. H. Wallace - Tire Division, OCA

TITLE: FMVSS INTERPRETATION

TEXT: Demonstration of Prototype Tires That are Not Certified as Complying with FMVSS No. 109

This is in response to your inquiry concerning the circumstances under which the demonstration of prototype tires would be permitted. I understand that representatives of Firestone Tire & Rubber Co. are visiting the NHTSA to discuss a newly designed passenger car spare tire which is not certified as complying with Standard No. 109. They wish to mount, on cars which have been driven to the DOT headquarters building on complying tires, samples of the spare tire and then to demonstrate the tire's performance on the local streets.

This demonstration would violate Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, because use of such tires on the public roads would constitute an introduction in interstate commerce of an item of motor vehicle equipment which did not conform with an applicable motor vehicle safety standard. The alternative which you have suggested, mounting and demonstration of the tires on a runway at Bolling Air Force Base or other place out of the public traffic stream, is not prohibited by the Act or by our regulations.

ID: nht90-1.64

TYPE: Interpretation-NHTSA

DATE: March 6, 1990

FROM: Anthony Riani; David Mitchell

TO: To Whom it May Concern

TITLE: None

ATTACHMT: Attached to letter dated 4-4-91 from Paul Jackson Rice to DS America, Inc., Attn: Messrs. Riani and Mitchell (A37; Part 591)

TEXT:

We are interested in importing Volkswagon Beetles' into the United States for retail sale. We have already contacted the Environmental Protection Agency as to their requirements for importing vehicles. We have also contacted the Department of Transport ation by telephone. We were told the vehicle has to be crash tested. These tests are to confirm the speeds at which the car can withstand head-on, rear-end, and side collisions. We were also told about some other problems that were experienced by impo rters in the past. We would greatly appreciate any and all information you could send to us regarding all relevant requirements for cars being imported to the United States. We would also appreciate any information about these problems that the Departm ent of Transportation has on record. We are curious to know if documentation by Volkswagon of Mexico certifying these crash requirements can replace a crash tested vehicle or vehicles. Thank you for your help.

ID: 86-5.20

TYPE: INTERPRETATION-NHTSA

DATE: 09/16/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Skip Maraney

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Skip Maraney National Star Route Mail Contractor Association 324 East Capitol Street Washington, DC 20003

Dear Mr. Maraney:

This responds to your telephone inquiry about whether our regulations would prohibit the installation of a right hand drive steering system in a motor vehicle. We do not have any standards that prohibit the use of a right hand drive steering system. We have, however, issued two safety standards (Standard Nos. 203 and 204) that set performance requirements which apply to any steering system, whether left or right hand drive, installed in new passenger cars and light trucks, buses, and multipurpose passenger vehicles. A copy of each of these standards is enclosed.

You also asked about the agency's regulations on the importation of motor vehicles. I have enclosed a copy of a publication, "Instructions Handbook for Complying with Regulations on Imported Vehicles," which will provide you with information about our importation regulations.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

ID: nht74-5.29

DATE: 03/14/74

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

TO: L and R Enterprises

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 15, 1974, letter asking whether your installation of spotlights through the left A-pillar of passenger cars is subject to Standards 201 and 216.

Standard 201 does not apply to the instrument panel area on the driver's side from the left door to a longitudinal plane 3-1/4 inches to the right of the steering wheel. The left A pillar is within this excluded area.

Your drilling operation may affect roof strength and I have enclosed a copy of Standard 216, our standard on roof crush resistance. Under the National Traffic and Motor Vehicle Safety Act of 1966, it is the responsibility of the person who manufacturers or alters a vehicle to determine whether his vehicle meets the requirements.

Your business is subject to these requirements, however, only if you qualify as an alterer of motor vehicles under 49 CFR 567.7, which is enclosed. The mounting of a spotlight by drilling the A-pillar is a "non-readily attachable" alteration. Such an alteration would be subject to the @ 567.7 requirement only if you mount it "before the first purchase of the vehicle in good faith for purposes other than resale."

2 ENCLS.

CC: HONORABLE JOHN TOWER HONORABLE LLOYD BENTSEN

ID: nht68-4.13

DATE: 08/27/68

FROM: AUTHOR UNAVAILABLE; E. B. Laskin; NHTSA

TO: Cleveland Public Schools

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of July 3, 1968, addressed to Mr. George C. Nield, of the National Highway Safety Bureau has been forwarded to my office for reply.

The installation of dual controls on driver education cars is not per se in violation of the Federal motor vehicle safety standards. However, the secondary equipment must meet the same safety standards established for the primary controls. The secondary steering column must fulfill the same requirements made for the primary column as set forth in Federal Motor Vehicle Safety Standards Nos. 203 and 204. The installation of an additional foot brake must not affect compliance with Standard No. 105. However, duplicate compliance with the control location and identification requirements of Standard No. 101 is not required since the "driver" of such a vehicle remain the person seated behind the primary controls. For the same reason the "driver" mirror requirements of Standard No. 111 apply only with respect to the person seated at the primary controls.

Changes may be made to original equipment when necessary for installation of secondary controls but none of the standards requirements specified may be eliminated or adversely affected by the alteration.

You may make available copies of this letter to dealers and interested parties.

ID: nht71-1.4

DATE: 01/01/71 EST.

FROM: Robert L. Carter; NHTSA

TO: JEEP Corporation

TITLE: FMVSS INTERPRETATION

TEXT: On June 16, 1971, you and Mr. William Fleming of American Motors met with representatives of NHTSA and pointed out that the March 4, 1971, revisions of Standard No. 210 (36 F.R. 4291) had created a situation where seat belt anchorages for side-facing seats of multipurpose passenger vehicles would have to meet strength requirements only for the six-month period from July 1, 1971, to January 1, 1972. This occurred because the March 4 notice, which basically extended the existing standard for passenger cars to other types of vehicles as of July 1, 1972, did not have the exemption for side-facing seat belt anchorages that is contained in the revised standard that goes into effect on January 1, 1972.

The failure to exempt side-facing seats from the anchorage test requirements for the six-month period ending January 1, 1972, was inadvertent. A Federal Register notice will be issued shortly amending Standard No. 210 to correct this discrepancy. I am sending you this letter, which will be placed in the public files, in advance of the notice as an extraordinary procedure in light of the time period involved, to confirm that your vehicles need not meet the strength requirements for seat belt anchorages for side-facing seats apparently contained in Standard No. 210.