ID: nht75-2.13

DATE: 06/04/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: Volvo of America

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of March 24, 1975, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 110, Tire Selection and Rims -- Passenger Cars.

You have inquired whether the placard required by S4.3 of the standard may display information in addition to the items specified in S4.3(a) through (d). The NHTSA has no objection to such placarding, provided that the additional information is set apart from, not placed among, the required items.

ID: nht75-2.14

DATE: 08/19/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of April 10, 1975, requesting an interpretation of S4.3, the placarding requirement, of Federal Motor Vehicle Safety Standard No. 110, Tire Selection and Rims -- Passenger Cars.

You have proposed a format for presenting vehicle capacity weights which is designed to accommodate, with a single placard, several different model configurations. The NHTSA has no objection to this format, provided that the weights listed are correct.

Sincerely,

ATTACH.

VOLKSWAGEN OF AMERICA INC.

April 10, 1975

Mark Schwimmer, Esq. -- Office of the Chief Counsel, National Highway Traffic Safety Administration

Subject: N40-30 (MPP)

Dear Mr. Schwimmer:

This is in reference to our telephone conversation of Monday, April 7, concerning the format of our Standard 110 label. I am also referring to Mr. Dyson's letter of January 17, 1975, in which he suggested that we list on the same label alternate vehicle capacity weights applicable to models with or without optional equipment as long as we initially displayed the lowest vehicle capacity weight for the vehicle.

Our marketing representatives feel that the initial listing of the lowest weight may have competitive disadvantages in the small car market and have proposed a format which contains the vehicle capacity weight for each model configuration. I have enclosed for your review a copy of the new format which we plan to use and would appreciate your opinion concerning its acceptability pursuant to S4.3 of FMVSS 110.

Sincerely,

Gerhard P. Riechel -- Attorney

Enc.

(Graphics omitted)

ID: nht75-2.15

DATE: 04/21/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: Dominion Auto Accessories Limited

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 20, 1975, inquiring as to the permissibility of selling your "Panamirror" in the United States as aftermarket equipment.

Motor Vehicle Safety Standard No. 111, Rearview Mirror, provides minimum performance requirements for rearview mirrors on passenger cars and multipurpose passenger vehicles. According to the standard, the inside rearview mirror must furnish the driver with a specified field of view to the rear of substantially unit magnification. Any vehicle manufactured for sale, sold, or introduced into interstate commerce must be equipped with an inside rearview mirror that meets the designated level of performance. It appears that the "Panamirror" would not satisfy the requirements of the provision, because it is convex in structure and therefore would not provide a view of substantially unit magnification.

If the mirror were installed on a vehicle as aftermarket equipment (after the vehicle's first purchase for purposes other than resale) in such a way as to render inoperative the inside rearview mirror, section 108(a) (2) (A) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563) as amended (Pub. L. 93-492) would apply where the installation was accomplished by a manufacturer, distributor, dealer, or motor vehicle repair business. The section prohibits the named parties from knowingly rendering inoperative a system installed in compliance with an applicable motor vehicle safety standard.

ID: nht75-2.16

DATE: 07/15/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

ID: nht75-2.17

DATE: 12/04/75

FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA

TO: FILE

TITLE: FMVSS INTERPRETATION

ID: nht75-2.18

DATE: 09/22/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bridgestone Tire Company of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of May 22, 1975, concerning truck tires which do nt conform to Federal Motor Vehicle Safety Standard No. 119 and which are intended for export to Middle Eastern and African countries.

49 CFR Part 571.7(d) and Section 108(b)(5) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, specify that no Federal Motor Vehicle Safety Standards apply to

a motor vehicle or item of motor vehicle equipment intended solely for export, and so labeled or tagged on the vehicle or item itself and on the outside of the container, if any, which is exported.

Therefore, tires which you manufacture for sale directly to a truck manufacturer who will mount them on trucks which will be driven directly to the port of export need not comply with Standard No. 119. When shipped to the truck manufacturer, the tires must bear a label or tag indicating intent to export. Such a label must also appear on the outside of the container, if any, in which the tires are shipped. A label need not remain on the tires after they have been mounted on the trucks, provided that the trucks bear similar labels.

Sincerely,

ATTACH.

BRIDGESTONE TIRE COMPANY OF AMERICA. INC.

May 22, 1975 Ref. No.: YT-926

Office of the Chief Counsel -- National Hwy. Traffic Safety Admin.

Subject: FMVSS No. 119

Dear Sir:

We have an inquiry on the following size tires to be equipped on new trucks for exporting to the Middle Eastern and African countries by a truck manufacturer: 400-500 1100-20 14PR 150-200 1100-22 14PR 400-500 1100-24 14PR

Since the tire usage condition in these countries is completely different from that of the U.S.A., we have been supplying specially designed tires to them which do not comply with the FMVSS No. 119.

Therefore, we would like to supply the same type of tires now being supplied to the Middle Eastern and African countries to the truck manufacturer strictly for export.

In such a case, will you adopt an exception to FMVSS No. 119 on those tires?

The trucks will be driven without cargo to the ports of Newark or Baltimore after manufacture in Allentown, Pennsylvania.

I would greatly appreciate a reply regarding this matter, as soon as possible.

Very truly yours,

Y. Toyoda -- Manager, Engineering Dept.

CC: M. Otsubo - T. Sato; 734-Tokyo; S. Nakajima-File

ID: nht75-2.19

DATE: 09/19/75

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

TO: Champ Corporation

TITLE: FMVSS INTERPRETATION

TEXT: I am writing in response to your July 14, 1975, letter concerning the classification of your rough terrain fork lift trucks for the purposes of the Federal motor vehicle safety standards. A copy of our September 5, 1975, letter on this subject to Congressman Danielson is enclosed. We hope it clarifies the status of your products.

Yours truly,

ATTACH.

July 14, 1975

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

Atten: Richard B. Dyson -- Assistant Chief Counsel

Re: D.O.T. 119 and 120

Dear Mr. Dyson:

Thank you for your answer to our letter of April 10. I was also pleased to be able to talk to Mr. Ted Herlhy in your absence last week.

We sincerely believe that the Champ lift truck should not be classified as a motor vehicle for purposes of these rulings because of the distinctive configuration and the intended use. Since it is necessary to incorporate automotive type transmissions into the Champ product to make it function as a tractor in rough terrain, these same components do permit the Champ to operate at speeds in excess of 20 MPH. These speeds would be reached if the Champ were driven down the highway in fourth gear. However, this is both impractical and possibly dangerous. The Champ is not intended to be driven on the public streets or highways. It is, however, intended to be towed occasionally from work site to work site. In these cases, the Champ is equipped with towing brakes; stop, tail and turn lights; and mud flaps.

The Champ models which would use off the road tires are designed for either construction work or agriculture. As such, their performance is limited to off the road functions. Such periods of operation may vary from weeks to months to permanent assignments.

In 28 years of manufacturing and selling Champs, we find no records of an upset caused by a blown off the road drive tire. While being towed empty it carries approximately 1/3 of its rated tire loading. Twelve and fourteen-ply tires are used for added safety.

To rule out the use of off the road tires in our construction models would eliminate the production of the major portion of our business. Such a blow would be disastrous.

Should you feel we could better present our case if we were to visit your office, we would be most happy to do so.

Please contact us if you would like additional information.

Sincerely, CHAMP CORPORATION; Mike M. Simovich -- President

(Brochure Omitted)

ID: nht75-2.2

DATE: 12/16/75

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

TO: Engineering Services

COPYEE: M. I. SCHWIMMER

TITLE: FMVSS INTERPRETATION

TEXT: In response to your November 24, letter concerning the relationship between Federal Motor Vehicle Safety Standards Nos. 109 and 119, I am enclosing a copy of a prior interpretation letter on the same subject, which was sent to Mr. C. D. McCarty of the B. F. Goodrich Company on October 15, 1975.

ID: nht75-2.20

DATE: 08/25/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Firestone Tire & Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: I am writing to confirm the interpretation of Federal Motor Vehicle Safety Standard No. 119, New pneumatic tires for vehicles other than passenger cars, which was given to you by Mark Schwimmer on April 16, 1975.

Your letter of February 26, 1975, explained that:

(i) Firestone would produce 100 tires in size D50C-16.5 for use on one of the prototype vehicles in the Urban Mass Transit Administration's Trans-Bus program;

(ii) these tires would be certified as being in compliance with Standard No. 119; and

(iii) D50C-16.5 is a new size, not appearing in any existing tire and rim organization publications.

In such cases, S5.1(a) of the standard requires tire and rim matching information to be furnished to dealers of the manufacturer's tires. Your letter suggested that, because Firestone does not expect the tire to be sold through any dealers, this requirement would be inapplicable. As Mr. Schwimmer explained, that interpretation is incorrect. S5.1 of Standard No. 119 applies to all new bus tires, including prototypes manufactured for prototype vehicles. Therefore, you must furnish the matching information to all dealers of Firestone non-passenger-car tires.

Sincerely,

ATTACH.

February 26, 1975

Mark Schwimmer, Attorney -- Office of Chief Counsel, National Highway Traffic Safety Adm.

RE: TIRES FOR UMTA TRANS BUS PROGRAM

Dear Mr. Schwimmer:

As I advised you in our telephone conversation, Firestone has the contract to produce tires for the prototype vehicles being tested by UMTA currently. We have received an order for an additional 100 tires in size D50C-16.5 for use on the prototype manufactured by The Rohr Industries. Since these tires will be produced after March 3rd, they will be certified by Firestone as being in compliance with FMVSS 119.

Size D50C-16.5 is a new size and is not included in any list showing tire and rim matching information. FMVSS 119 specifies in Section S5.1(a) that where such information is not published in the documents listed it is to be supplied to dealers and to NHTSA.

By copy of the attached letter to the Tire Division, NHTSA, we are supplying the necessary information to NHTSA. However, since we have orders for only 100 tires to be used only on the prototype vehicle and since it is our understanding from the prime contractor that the test will be terminated at the end of this year, thereby precluding any possibility of this size being sold for this purpose through any dealers, we are not planning to send copies of the tire and rim matching information to our dealers.

May I have your confirmation that we will be acting within your interpretation of FMVSS 119 in this matter?

As you know, the testing of the three prototype buses is under the control of UMTA. It is not anticipated that any additional tires will be needed for the other two prototypes, however, if the prime contractors should order additional tires it would most likely be under the same conditions as the order received from Rohr Industrial and we would follow the same procedure as it is agreed will be acceptable with the D5OC-16.5 tires.

In view of the fact that an order has been placed with us, it would appear that the prime contractor anticipates a need in the near future. Therefore, we would appreciate your prompt attention to this matter.

Sincerely, A. J. DiMaggio -- QUALITY ASSURANCE, FIRESTONE

February 26, 1975

The Tire Division National Highway Traffic Safety Adm.

Gentlemen:

Pursuant to Section S5.1(a) Motor Vehicle Safety Standard 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, this is to advise that tire size D50C-16.5 is to be used with a 6.0 x 16.5 rim.

This size tire is not listed in any of the publications of the organizations listed in FMVSS 119.

Very truly yours, A. J. DiMaggio -- QUALITY ASSURANCE, FIRESTONE

ID: nht75-2.21

DATE: 10/03/75

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

TO: High & Walters

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your August 11, 1975, request for information on regulations concerning the matching of innertube sizes with motorcycle tire sizes. Federal Motor Vehicle Safety Standard No. 119 (copy enclosed) specifies performance and labeling requirements for motorcycle tires manufactured after March 1, 1975. There are no Federal regulations, however, containing requirements for proper matching of tubes with tires.

Yours truly,

Enclosure

HIGH & WALTERS -- ATTORNEYS AT LAW

August 11, 1975

Department of Transportation 400 - 7th Street SW Washington, D.C. 20590

TIPE SAFETY REGULATIONS

Madam or Sir, would you please inform this office how we might obtain any regulations of the Department of Transportation relating to proper tube sizes for particular tire sizes.

We are interested specifically in motorcycle tire regulations with regard to the size of the innertube for a given tire size.

Thank you in advance for your assistance with regard to this matter.

JAMES P. WALTERS