ID: nht88-3.51

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 14, 1988

FROM: AL CUNNINGHAM -- CHIEF ENGINEER WESTBAR CORPORATION

TO: ERIKA JONES -- CHIEF COUNSEL D.O.T.

TITLE: INTERPRETATION OF SAE DEFINITIONS AS THEY APPLY TO FMVSS 108

ATTACHMT: LETTER DATED NOV. 3, 1988 TO AL CUNNINGHAM, CHIEF ENGINEER, WESTBAR CORPORATION, FROM ERIKA Z. JONES, CHIEF COUNSEL, NHTSA

TEXT: We are writing your office requesting official clarification of definitions referred to in SAE J588e as it applies to FMVSS 108. The definition in question is, 2.2 "Multiple Compartment Lamp" and the term used in 3.1 "Single Compartment Lamp".

With this request, we are furnishing two lamps as examples, one identified as 3504 exp. and the second as 3504. The first sample (3504 exp.) has a housing with back and four sides containing a two filament bulb with a single lens covering face of hou sing. This lamp photometrically complies to the basic requirements of a class "A" tail, stop and turn lamp. Would the sample submitted as described above be defined as a single compartment lamp?

The second sample has a housing with a back, two sides and one end, containing one #57 bulb and one #1157 (2 filament) bulb. This housing is closed with two red lenses, one on the end and one on the face with an additional clear lens on bottom side. This lamp also complies to all standards of a class "A" tail, stop and turn lamp plus side marker clearance, license plate illuminator and class "A" reflex side and rear. Would the sample, as submitted and described, be defined as single compartment la mp?

Thank you for reviewing our requests. We look forward to receiving your interpretation of these definitions as they apply to our questions and samples furnished.

Enclosures - 2 samples

ID: nht88-3.52

TYPE: INTERPRETATION-NHTSA

DATE: 09/14/88

FROM: WENDELL D. KEGG -- TIRE WHEEL CONSULTANTS

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 01/1/8/89 FROM ERIKA Z. JONES -- NHTSA TO WENDELL D. KEGG, REDBOOK A33, STANDARD 109

TEXT: Dear Ms. Jones:

I am confused by the FMVSS 110 Standard. As I read Paragraph S4.3.1 covering inflation pressure on the vehicle placard, the tire cannot by inflated beyond that maximum pressure embossed on the tire. Subparagraph S4.3.1(c) is not clear.

Can a vehicle manufacturer specify a higher inflation pressure in a spare tire application than that which is embossed on the sidewall of the tire?

Thank you.

Very truly yours,

ID: nht88-3.53

TYPE: INTERPRETATION-NHTSA

DATE: 09/15/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: M. IWASE -- MANAGER TECHNICAL ADMINISTRATIVE DEPARTMENT KOITO MFG. CO., LTD.

TITLE: NONE

ATTACHMT: LETTER DATED 07/30/80 TO DIETMAR M HAENCHEN FROM FRANK BERNDT; LETTER DATED 02/22/88 TO ERIKA Z JONES FROM M IWASE RE INSTALLATION OF TAIL AND STOP LAMP ONTO MOVING VEHICLE PART

TEXT: Dear Mr. Iwase:

This is in reply to your letter of February 22, 1988, asking whether location of a stop and taillamp on a deck lid would comply with Federal Motor Vehicle Safety Standard No. 108. In your opinion this is acceptable because the vehicle complies with the trunk lid closed. You have also asked, alternatively, whether the deck lid is an acceptable location for turn signal lamps.

Section S4.3.1 of Standard No. 108 requires lighting devices to be mounted on "a rigid part of the vehicle...that is not designed to be removed except for repair". In past interpretations the agency has stated that a deck lid is "a rigid part of the veh icle", and that compliance with the standard will be determined with the deck lid closed. Thus, it may be used for mounting lamps and reflectors required by Standard No. 108. However, Table IV specifies the location for rear lamps. Stoplamps, taillamp s, rear turn signal lamps, and rear reflex reflectors must be mounted "as far apart as practicable". Although the determination of practicability is initially made by the vehicle manufacturer, the agency in its enforcement efforts would consider whether lighting equipment mounted on the deck lid meets the requirements of Table IV. On the other hand, the separation requirement is not specified for backup lamps and license plate lamps.

I have enclosed for your information a copy of a 1980 interpretation that addressed a similar question. As you will note, the agency raised some safety concerns in that letter which could also pertain to your design.

Operation of a motor vehicle in the United States is subject to the laws of the individual States, some of which may prohibit operation of a vehicle when its turn signals and stop lamps are not visible.

In summary, we urge you to consider the issues described above, including those raised in the 1980 letter, in deciding whether to proceed with this design.

ENCLOSURE

Sincerely,

ID: nht88-3.54

TYPE: INTERPRETATION-NHTSA

DATE: SEPT. 17, 1988

FROM: MARK JANSEN -- CHEVY DUTY PICKUP PARTS

TO: TAYLOR VINSON -- LEGAL COUNSEL, NHTSA

ATTACHMT: UNDATED LETTER TO MARK JENSEN, CHEVY DUTY PICKUP PARTS, FROM ERIKA Z. JONES, NHTSA

TEXT: I own and operate a small parts store specializing in parts for 1947-1966 Chevrolet and GMC pickup trucks. I have many requests for parklamp and taillamp lenses for these pickups that are not currently available. I would like to have these lenses reman ufactured and am requesting information concerning requirements and restrictions before proceeding.

These will be reproduced exactly like the original lenses, which I assume would have been approved by the D.O.T. Must the reproduction lenses also be supplied to the D.O.T. for approval? If so, how is this accomplished? Is there a charge for this serv ice? Will be anxiously awaiting your reply.

ID: nht88-3.55

TYPE: INTERPRETATION-NHTSA

DATE: 09/21/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: HIROSHI KATO -- MMC SERVICES INC.

TITLE: NONE

ATTACHMT: LETTER DATED 05/18/88 TO ERIKA Z. JONES FROM HEROSHI KATO, OCC-2048

TEXT: Dear Mr. Kato:

This responds to your letter asking for an interpretation of Safety Standard No. 201, Occupant Protection in Interior Impact, as it applies to so-called "one-piece" instrument panels and console assemblies. Your request for confidential treatment of the photographs and diagrams you enclosed with your letter of vehicle models "A" and "B" was granted by the agency on June 21.

The areas of the vehicle interior to which your question relates are the instrument panel, which generally speaking, is subject to the standard, and the console assembly, which is not. Most of our letters relating to these areas dealt with vehicles whos e console assemblies were separate structures distinguished by "gaps," or indentations. However, you ask about a vehicle interior that has no obvious gaps or separation between the dashboard and the console assembly (hence its "one-piece" appellation). Instead, the longitudinal floor-mounted structure that lies between the front seats of the vehicle rises gradually at an upward slant towards the vehicle's dashboard, and joins with the vehicle's dashboard without any obvious gaps or spaces, as though t he dashboard and center console were of one piece. At the top of the instrument panel is an overhanging surface above a setback area. This overhanging surface protrudes rearward in such a way that a vertical line tangent to the surface strikes the bott om of the one-piece structure at a point near the floor of the vehicle, between the front seats.

Paragraph S3.1 of Standard No. 201 sets the head impact protection requirements for instrument panels. These requirements apply primarily to the upper portions of the instrument panel. Paragraph S3.1 states, "Except as provided in S3.1.1, when that are a of the instrument panel that is within the head impact area is impacted" by a head form, the deceleration of the head form shall be within specified limits. S3.1.1 sets out five exceptions to the instrument panel performance requirements, two of which (S3.1.1(a) and S3.1.1(e)) are relevant to your design. The first of these, S3.1.1(a), provides that the requirements of S3.1 do not apply to console assemblies.

We believe your letter raises two primary issues. The first is whether a console assembly in effect ceases to be a console assembly for the purposes of the head impact protection requirements of Standard No. 201, and as a consequence becomes subject to those requirements, when it is part of a one-piece design and adjoined with the dashboard. While we concur with your assessment that the answer to this question is no, we note that determining the dividing line between a dashboard and an adjoining conso le is difficult where there is no intervening gap or indentation.

That brings us to the second issue, which is how to determine the rearmost surface of the instrument panel in a vehicle using a one-piece design such as yours. S3.1.1(e) of the standard provides that "(a)reas below any point at which a vertical line is tangent to the rearmost surface of the panel" are not subject to the head impact protection requirements of the standard. You suggest that the rearmost surface is the overhanging surface at the top of the instrument panels on your two vehicles and that the console is the area below that overhanging surface. While we are not prepared to pick the dividing line between the instrument panel and the console, we agree that those overhanging surfaces are the rearmost points of the instrument panel. A vertic al line tangent to those overhanging surfaces strikes the one-piece structure at a point that is clearly part of the longitudinal structure running between the seats, i.e., that is clearly part of the console, and therefore excluded by S3.1.1(a) from the head impact protection performance requirements of Standard No. 201.

Notwithstanding the direct reference in S3.1.1(a) to console assemblies, the agency has not defined the term either in Standard No. 201 or elsewhere. In the October 27, 1986 letter to which you refer in your letter, we told your associate, Mr. Shimizu, that we regarded a "low-lying structure mounted on the floor and [lying] primarily between the vehicle seats" to be a console assembly. However, no attempt was made to define what was meant by "low-lying" or "console assembly" or to apply the latter term to structures such as yours that join with the vehicle's dashboard without any obvious gaps or spaces.

Given that console assemblies are excluded from the requirement in S3.1 for instrument panels, it is important to determine the boundaries of the instrument panel. S3.1.1(e) is helpful in this regard. S3.1.1(e) has the effect of limiting the head impac t protection requirements of the standard to the upper portions of the instrument panel.

With respect to the instrument panel for model A, we conclude that the rearmost surface of the instrument panel is the overhanging surface that is above the setback area. Any area that is rearward of a vertical line tangent to the overhanging surface on the one-piece instrument panel and console assembly is located on a "low-lying structure mounted on the floor and lying primarily between the vehicle seats"--i.e., it is located

on a console assembly. Since, for the purposes of S3.1.1(e), the relevant area is the rearmost surface of the instrument panel, areas of the instrument panel on model A that are below this rearmost surface are excluded from the head impact protectio n requirements of the standard.

Similarly, with respect to model B, the rearmost surface of the instrument panel is the overhang at the top of the panel. Any area rearward of this surface would be part of the "console assembly," as we have used that term in our letter to Mr. Shimizu. Accordingly, areas of the panel lying below the point at which a vertical line is tangent to this surface are excluded from S3.1. Generally speaking, the upper portions of the instrument panel of both models A and B are subject to S3.1 and would theref ore have to meet the head impact protection requirements of the standard.

In conclusion, we concur with your belief that there should be a reasonable way to distinguish a console assembly from an instrument panel. Your letter has highlighted a possible need to clearly define either "instrument panel" or "console assembly" in Standard No. 201, and also an issue as to whether there is a continued need for the exemption for console assemblies found in S3.1.1(a) of the standard. We will further consider these issues and may initiate rulemaking to possibly define console assembl y or to remove the current exemption in S3.1.1(a) of the standard.

I hope this information is helpful. Please contact my office if you have further questions.

Sincerely,

ID: nht88-3.56

TYPE: INTERPRETATION-NHTSA

DATE: 09/23/88

FROM: DANIEL F. WIECHMANN

TO: RUTH SKLUZACEEK -- IOWA DIRECTOR OF VEHICLE REGISTRATION OFFICE

TITLE: THE STATE OF IOWA VS. BARRY LYNN SPEICH, FRANKLIN COUNTY CRIMINAL NO. WD488435; NO. 24.432.0788 (@ 321.424) OF THE CODE OF IOWA

ATTACHMT: ATTACHED TO LETTER DATED 07/05/89 FROM JEFFREY R. MILLER -- NHTSA TO FRED GRANDY, REDBOOK A33 (3); STANDARD 108; LETTER DATED 05/09/89 FROM FRED GRANDY -- CONGRESS TO JERRY CURRY -- NHTSA; LETTER DATED 05/05/89 FROM DANIEL F. WIECHMANN TO ROBER T A. DETERMAN, RE THE STATE OF IOWA VS. BARRY LYNN SPEICH; LETTER DATED 10/10/88 FROM JODY JOHNSON -- IOWA DOT TO DANIEL F. WIECHMANN, REF NO 911.2; LETTER DATED 10/14/88 FROM DANIEL F. WIECHMANN TO RALPH HITCHCOCK -- NHTSA, RE THE STATE OF IOWA VS. BARR Y LYNN SPEICH FRANKLIN COUNTY CRIMINAL NO WD488435; NO. 24.432.0788 [321.424] OF THE CODE OF IOWA

TEXT: Dear Ms. Skluzaceek:

Please be advised I represent the above named Defendant, who was charged with the violation of Section 321.424 of the Code of Iowa, which is Sale of Lights-Approval, which basically states that no person shall have for sale, sell or offer sale for use upon or as a part of the equipment of a motor vehicle, trailer, or semitrailer, or use upon any such vehicle any headlight, auxiliary or fog lamp, rear lamp, signal lamp, or reflector, which reflector is required hereunder, or parts of any of the forego ing which tend to change the original design or performance, unless of a type which has been submitted to the director and approved by the director.

I also refer to you Section 329.428 of The Code of Iowa which authorizes the director to approve or disapprove lighting devices and to issue and enforce rules establishing standards and specifications for the approval of such lighting devices, etc.

The bottom line herein is the above named Defendant had headlight covers such as described in the information I have enclosed, which is pages 210 and 211 from an auto parts catalog.

I am wondering as to whether or not these headlights or covers are approved by the State of Iowa, and if so, would you please be so kind as to set forth the fact these headlight covers are an approved device. If they are not approved, please kindly s o state.

If you are looking for further information concerning this matter, please do not hesitate to contact me. As I have stated, for your assistance, I am enclosing pages 210 and 211 from an auto parts catalog, as well as a copy of the ticket issued to the young man.

For your information, the Hearing is set on this ticket for the 29th day of September, 1988, at 1:00 P.M.

I look forward to your response.

Thank you very much.

Yours very truly,

ENCLOSURES

ID: nht88-3.57

TYPE: INTERPRETATION-NHTSA

DATE: 09/23/88

FROM: HARRY B. SKINNER -- FEDERAL HIGHWAY ADMINISTRATION

TO: RUSSELL A. STORMS

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/17/89 FROM STEPHEN P. WOOD -- NHTSA TO RUSSELL STORMS; REDBOOK A34; STANDARD 125; VSA 108[B]; LETTER DATED 09/12/88 FROM RUSSELL A STORMS TO FEDERAL HIGHWAY ADMINISTRATION

TEXT: Dear Mr. Storms:

The Office of Traffic Operations received your September 12 letter requesting approval of a vehicular device you designed to be used by motorists prior to the use of flares or other similar emergency devices.

Our office is responsible for establishing national standards for the design, placement, and application of traffic control devices used on roadways open to public travel. These standards apply to highway signs, signals, and pavement markings, not to ve hicular devices. We are forwarding a copy of your letter to the National Highway Traffic Safety Administration (NHTSA). Since vehicle safety is one of its program areas, we feel NHTSA is in a better position to advise you concerning your device.

Thank you for your interest in motorist safety and much success in your endeavor.

Sincerely yours,

Please reply further to Mr. Storms advising him of his device. Also, please[Illegible Word] a copy of your response to HTO-22. Thank you.

ID: nht88-3.58

TYPE: INTERPRETATION-NHTSA

DATE: 09/26/88

TO: BARRY FELRICE -- ASSOCIATE ADMINISTRATOR FOR RULEMAKING, NHTSA U.S. DEPT. OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/09/89 FROM STEPHEN P. WOOD -- NHTSA TO BLANCHE KOZAK; REDBOOK A33 [2]; VSA 108 [A] [1] [A]; LETTER DATED 04/04/89 FROM NANCY L. BRUCE -- DOT TO CHESTER ATKINS -- HOUSE; LETTER DATED 03/29/89 FROM CHESTER G. ATKINS -- HOUSE TO NANCY BRUCE -- DOT, RE MRS. BLANCHE KOZAK; LETTER DATED 10/16/79 FROM EDWIN P. RIEDEL; REPORT UNDATED; LETTER DATED 08/09/88 FROM BLANCHE G. KOZAK TO DEPARTMENT OF TRANSPORTATION

TEXT: Dear Mr. Felrice;

On Dec. 9, 1980 my husband was involved in a fatal accident while driving a 3-wheel Cushman Vehicle, as a security guard, at the Lawrence General Hospital.

I have been informed by Ma. Secr. of Public Safety, Charles V. Barry that there are two basic designs for the Cushman Vehicle, one specifically for on-road use, categorized as a Police Vehicle and under the jurisdiction of the NHTSA as a motorcycle. The other an off-road unit which is not under the jurisdiction of the Registry of Motor Vehicles since the Registry is authorized to regulate only on-road Vehicles. According to Secr. Barry, the unit my husband was killed on is an off-road vehicle, ther efore, it does not come under the jurisdiction of the Registry of Motor Vehicles.

Enclosed you will please find an Oct. 16, 1979 copy of the Common-weath of Massachusetts, Registry of Motor Vehicles classification and Registration of the vehicle on which my husband was killed. As you can see it contradicts Secr. Barry's informatio n to me since it had been registered and passed inspection for on-road use as a Police Vehicle, on the Public Roadways.

On July 22, 1988 you sent Congressman Florio the following statement in regards to the Cushman Vehicle; "This vehicle is classified as a motorcycle under current definitions found in Code of Federal Regulations Vol. 49, Part 571.3." You further stated "Ma. is currently one of the States that has a motorcycle helmet use law for all riders."

After a Congressional Inquiry, Mr. Edward Harril, Director of Congressional Relations, sent Congressman the following information; "Our inquiry of the Vehicle's manufacturer indicates that the particular vehicle involved in this accident was indeed ce rtified for road use and would thus be considered a "motor vehicle" subject to the jurisdiction of NHTSA, and not the Commission, under 15 U.S.C. 2052 (A) (1) (C)."

Please be informed that none of the above regulations were made known to my husband, he was issued the vehicle by the Lawrence General Hospital as a motor vehicle requiring only his car license to operate and was not warned of the potential hazards in herent in the unit. I feel a determination should be made as to what agency should regulate the use of this vehicle on Public Highways and the person required to operate it should be warned of the hazards inherent in the unit.

ID: nht88-3.59

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 27, 1988

FROM: CLARK, TRACY L. JR. -- COTTLE INDUSTRIES VICE PRESIDENT

TO: ERICA JONES -- CHIEF COUNSEL-NHTSA

TITLE: NONE

ATTACHMT: DECEMBER 19, 1988 LETTER FROM JONES TO CLARK

TEXT: We are finalizing arrangements to produce a three-wheeled gasoline-powered vehicle. The vehicle will be classified as either a moped or a motorcycle depending on choice of engine size.

In reviewing sections 566-568 of the Federal Motor Vehicle Safety Standards and Regulations, it appeared that we should be classified as an alterer. I wanted to confirm this, so I contacted your organization directly. I discussed our classification by phone with Ms. Dorothy Nakoma of your offices. She believes that we should indeed be registered as an 'alterer of a certified vehicle'. She also suggested that we write to you and get a written opinion confirming the correct classification.

I have enclosed a brochure which highlights the basic description of the vehicle. The production process goes as follows:

1) We purchase a completed, certified Honda moped.

2) We then remove the plastic body shell and seating components.

3) Next, the frame is cut behind the steering column, separating the Honda vehicle into two sections.

4) The front section is welded to the tubular steel frame.

5) The rear section is welded to the tubular steel frame.

6) A third wheel assembly added to the frame.

7) Wiring is completed and the fiberglass body shell is installed.

The Honda front end and drive train components continue to retain their integrity.

We intend to issue a new Certificate of origin for each vehicle, but would continue to use Honda's VIN number as identification. Please confirm this procedure.

Several states make no provision for classifying alterers. Their categories are limited to manufacturers and franchised dealers or distributors. We will register as a manufacturer in these states.

If you have any questions, or require further information, please do not hesitate to contact me. Thank you for your time and consideration on this issue. We look forward to your response.

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* Total weight: 270 pounds

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* Electric ignition

* Automatic transmission

* Steel wheels

* 2.75 x 10-inch tires

* Independent suspension with hydraulic damper

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Cottle Industries recommends wearing a safety helmet when operating the CHARIOT.

ID: nht88-3.6

TYPE: INTERPRETATION-NHTSA

DATE: 08/15/88

FROM: LEBOEUF LAMB LEIBY AND MACRAE

TO: KATHLEEN DEMETER -- ASSISTANT CHIEF COUNSEL FOR GENERAL LAW NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: PORSCHE'S JUNE 28 REQUEST FOR REGULATORY INTERPRETATION FMVSS 101 AND 102

ATTACHMT: ATTACHED TO LETTER DATED 04/03/89 FROM ERIKA Z. JONES -- NHTSA TO KARL H. MAYER, REDBOOK A33 (4), STANDARD 101, STANDARD 102; CONFIDENTIAL LETTER DATED 06/28/88 FROM KARL H. MAYER TO ERIKA Z. JONES, REQUEST FOR INTERPRETATION -- CLARIFICATION F MVSS 101 AND FMVSS 102; LETTER DATED 06/28/88 FROM KARL H. MAYER TO ERIKA Z. JONES -- NHTSA, REQUEST FOR CONFIDENTIAL TREATMENT

TEXT: Dear Ms. DeMeter:

I write to confirm our conversation of August 15 concerning Porsche's June 28, 1988 request for a regulatory interpretation of FMVSS 101 and 102. We ask that the June 28 request and the attachments to that request remain confidential until September 30, 1988, at which time this information may be made public.

I understand from our conversation with NHTSA will honor our request to keep the information confidential until September 30. If my understanding is not accurate, please let me know.

Thank you for your cooperation.

Yours truly,