ID: nht87-1.27

TYPE: INTERPRETATION-NHTSA

DATE: 02/02/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Guy Vander Jagt

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Guy Vander Jagt U.S. House of Representatives Washington, DC 20515-2209

Dear Mr. Vander Jagt:

Thank you for your November 3, 1986, letter on behalf of your constituent, Miss Reva Darling of Ludington, Michigan, who asked about requirements for safety belts on buses used for school transportation and other purposes. Your letter has been referred t o my office for reply, since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety.

Miss Darling is interested in extending the applicability of Michigan's safety belt use law to belts on "public" buses. She believes that safety belts should be installed on school buses and buses used by transit and charter companies, and suggests that funding be made available to encourage the installation of belts on those vehicles.

I appreciate this opportunity to respond to your inquiry. By way of background information, under the National Traffic and Motor Vehicle Safety Act, NHTSA is authorized to develop motor vehicle safety standards applicable to all new motor vehicles, inclu ding school buses and charter and transit buses. Our belt installation requirements vary according to the type of vehicle; for example, different requirements apply to passenger cars than to buses. For buses generally, our requirements only specify that a safety belt must be installed for the bus driver. They do not require safety belts for passengers on large buses used for pupil transportation and other purposes.

We have not required large buses to have safety belts for passengers because we have not found sufficient justification for such a requirement, given that buses have excellent safety records. This safety record arises in part from the fact that, in crash es with other vehicles, buses tend to be substantially heavier than the other vehicle while cars tend to weigh approximately the same as the vehicle with which they crash. As a result, the crash forces experienced by bus occupants tend to be less than th ose experienced by car occupants. Also, because of the elevated stating positions in large buses, bus occupants sit above the area typically damaged in a collision with another vehicle. Further, we require large school buses to provide passenger crash pr otection with higher and stronger seats, additional seat padding, and better seat spacing and performance. That approach, together with the other attributes of large school buses, provides adequate levels of crash protection in school buses without safet y belts. I have enclosed a copy of a NHTSA publication, "Safety Belts in School Buses," which addresses in more detail the issue of whether safety belts should be required on school buses.

NHTSA does not prevent States and local jurisdictions that wish to order safety belts on their own large buses from doing so. Although large buses are not required by Federal law to have passenger safety belts, bus owners are free to purchase their buses with safety belts installed if they believe their particular circumstances warrant such installation. However, we have no reason at this time to believe that such an installation is necessary as a Federal requirement applicable to all transit buses.

Miss Darling asks whether there have been any proposals to apply Michigan's safety belt use law to public buses. Safety belt use requirements art a matter of State rather than Federal law. Therefore, Michigan state officials would be able to answer Miss Darling's particular question concerning the state law.

On a final matter, Miss Darling suggested that funding be made available to equip buses with safety belts. For your information, while the Administration has not proposed any legislation affecting school buses, H.R. 749 (introduced in the 99th Congress) proposed incentive grants to the States encouraging the adoption and enforcement of laws requiring the use of safety belts in school buses. H.R. 749, however, was not enacted.

I hope this information is helpful. Please contact my office if we can be of further assistance.

Sincerely,

Erika Z. Jones Chief Counsel

The Honorable Guy Vander Jagt House of Representatives Washington, D.C. 20515

Dear Vander Jagt:

Thank you for your letter forwarding correspondence from your constituent, Miss Reva Darling.

I have transmitted your inquiry to the appropriate Departmental officials who are familiar with this matter and they will respond to you directly.

I appreciate your contacting me and hope you will not hesitate to call if I can be of any further assistance.

Sincerely,

Edward J. Babbitt Director, Office of Congressional Affairs

Mr. Ed Babbitt Director of Congressional Affairs Department of Transportation 400 7th Street, S.W., Room 10406 Washington, D.C. 20590

Dear Mr. Babbitt:

I have enclosed a copy of correspondence I received from a constituent, Miss Reva Darling, relative to seat belts in public buses.

As you will note, Miss Darling is interested any information on this issue. I would appreciate any information or comments you may be able to provide in response to her query.

Thank you for your time and attention to this matter. I look forward to hearing from you in the near future.

With all good wishes,

Sincerely,

Guy Vander Jagt Member of Congress

Rep. Guy Vander Jagt 2334 Rayburn Bldg. Washington, D.C. 20515

Dear Rep. Vander Jagt,

Hello, my name is Reva Darling and I am a junior in high school. I am writing in regard to the recent seatbelt law established in Michigan last year.

My question is this: Has there been any proposals in conjunction with applying this law to public buses? By buses, I am referring to both charter and/or school related buses. I believe that funding to make seatbelts possible on these vehicles is highly worthwhile considering the number of passengers and lives involved. I would appreciate any information that you could send me about hi s.

Thank you for your time.

Sincerely,

Reva Darling

Reva Darling 2456 S. Meyers Rd. Ludington, MI 49431

ID: nht87-1.28

TYPE: INTERPRETATION-NHTSA

DATE: 02/05/87

FROM: G T DOE -- LOTUS ENGINEERING

TO: ERIKA Z JONES -- CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 10/15/87 FROM ERIKA Z JONES TO GT DOE; VSA 108, STANDARDS 208, 216 LETTER DATED 09/18/87 FROM ERIKA Z JONES TO J. DOUGLAS HAND

TEXT: Dear Madam

Lotus is proposing to introduce a convertible car into the United States. It is planned to develop and certify the car as a two seat convertible. It is recognised, however, that if no other provision is made, accessory manufacturers may offer 'hardtop' conversions to our customers. In anticipation of the latter possibility, a factory manufactured and approved quality hardtop optional conversion would be offered. The hardtop would consist of a composite roof structure, which would replace the convert ible canopy and support frame. The removal of the latter would reveal a trimmed luggage shelf behind the two designated seating positions. It is conceivable that, although the shelf would not be recognised as a seating area, small occupants could trave l in this area. The fitting of the hardtop would in no way degrade the quality, reliability, or safety of the vehicle. The application of the hardtop conversion is depicted in the accompanying illustration.

It is possible that, whilst vehicles would be imported as convertibles, individual dealers might elect to fit hardtops to new vehicles and display them in their showrooms in this condition.

Could you please give interpretations with respect to the following:-

1. Convertibles are not required to conform to the roof crush requirements of FMVSS 216. Would the designation of the vehicle as a convertible remain unaffected by the hardtop conversion?

2. Would the requirement for seating and restraint system provision remain unaffected by the hardtop conversion?

Please do not hesitate to contact the undersigned for any further information, or discussion regarding the above.

ID: nht87-1.29

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/87

FROM: HANNS-OTFRIED WESTERMANN--HELLA KG HUECK & CO.

TO: DR. BURGETT--NHTSA

TITLE: RE MULTI BULB DEVICES

ATTACHMT: ATTACHED TO LETTER DATED 8-22-90 TO H. WESTERMANN FROM P. J. RICE; (A36; STD. 108)

TEXT:

We intend to equip motor vehicles with signalling devices, which have - opposite to conventional lamps - a great number of replaceable miniature bulbs instead of e.g. one 32 cp bulb. The miniature bulbs are about 2 to 3 cp each, as is actually applied t o CHMSL.

This design shows a number of advantages:

1. The failure probability of the signal function of a device is very low, because the burn out of a single bulb does not drop the light-out-put of the lamp below the minimum value required.

2. The average life of the miniature-bulbs is greater than the one of current 32 cp bulbs: about 3 per cent mortality rate after 1500 burning hours.

3. The devices can be built smaller and particularly with less depth.

4. The openings in the vehicle's body work can be avoided in part or totally, because the devices can be surface mounted.

5. The absence of body work openings increases the vehicle's stability and avoids sealing problems.

Summary: "Multi-bulb-devices" increase the traffic safety and lower the system costs over the vehicle's life time.

FMVSS No. 108 opposes this idea, because it is required that lamps with 2, 3 or more lighted sections have to comply with higher intensity requirements than a lamp with only one compartment or bulb. The reason for this requirement is to assure a uniform ly conspicuous surface luminance. These higher intensity requirements because of the larger overall lens area are not applicable to our design with a great number of miniature bulbs.

In spite of the great number of bulbs (10 to 20, depending on function) the total area of the lamp is not larger than the one of current one-compartment-lamps. The luminous Intensity requirement for 3- or more compartment lamps for this lamp size would c ause undesirable high luminances.

For each of the many bulbs the lighted lens area is substantially smaller than the required minimum area (22 inches square) for each compartment of multi-compartment lamps, but the total area of all bulbs is in compliance with the requirement for one-com partment-lamps.

We kindly ask for your comment on the legal aspects of this deviating design with many miniature bulbs and in particular, whether the intensity requirements of single-compartment lamps are applicable. (For LED-lamps it is even discussed, that for their higher conspicuity the intensity requirements could be lowered below those of single-compartment lamps). In our opinion the minimum requirements should not depend on the type of design (number of bulbs or compartments) but on the overall visible lens ar ea.

We want to draw your attention to the changes of ECE Regulations R6 and R7:

"If with a single lamp containing more than one bulb one of this bulbs fails, the lamp with the remaining bulbs shall comply with the minimum value required ...

Any failure of a bulb in such a lamp shall be clearly visible, if the lamp is switched on."

ID: nht87-1.3

TYPE: INTERPRETATION-NHTSA

DATE: 01/06/87

FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA

TO: Russell Thatcher -- Director, Mobility Assistance Program, Exective Office of Transportation and Construction, Commonwealth of Massachusetts

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Russell Thatcher Director Mobility Assistance Program Executive Office of Transportation and Construction Commonwealth of Massachusetts 10 Park Plaza, Room 3510 Boston, MA 02116-3969

Thank you for your letter of October 3, 1986, to NHTSA Regional Administrator Jack Connors requesting an interpretation of Standard No. 210, Seat Belt Assembly Anchorages. Your letter was referred to my office for reply.

You explained that you are in the process of buying a number of vans which will be outfitted with Republic Seating Corporation's Model D117 seats. You stated that questions have been raised about whether the safety belt placement on those seats complies with our standard. You enclosed a quarter-scale diagram of the seat in question showing the location of the safety belts and asked our opinion about whether the safety belt placement complies with our standard.

Under the National Traffic and Motor Vehicle Safety Act, which this agency enforces, it is the responsibility of a vehicle manufacturer to certify that its products comply with the requirements of our standards. This agency does not have the authority to approve a manufacturer's design plans. We can offer our opinion, but it is the manufacturer's obligation to ensure that the finished vehicle complies with all of the applicable standards.

The standard which affects the mounting angle for safety belts is Standard No. 210, Seat Belt Assembly Anchorages. The drawing enclosed with your letters shows that the lap safety belt anchorage for this seat is installed on the frame of the seat. S4.3.1 .3 of the standard provides:

In an installation in which the seat belt anchorage is on the seat structure, the line from the seating reference point to the nearest contact point of the belt with the hardware attaching it to the anchorage shall extend forward from that contact point at an angle with the horizontal of not less than 20o and not more than 75o.

According to the drawing enclosed with your letter, the line from the seating reference point to the nearest contact point of the safety belt, on the outboard side of the seat, with the hardware attaching it to the anchorage is 75o. If the outboard porti on of the safety belt is installed in a completed vehicle in the location shown in the drawing would meet the requirement of S4.3.1.3, since its mounting angle is not more than 75o.

We cannot offer a opinion as to whether the inboard portion of the safety belt would comply with S4.3.1.3, since the mounting angle for that portion of the safety belt is not depicted in the drawing. I want to emphasize again, that this letter represents the opinion of the agency based on the facts you have presented. It is a manufacturer's responsibility under the Vehicle Safety Act to certify that its completed vehicle complies with our standard.

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

Sincerely,

Erika Z. Jones Chief Counsel

Mr. Jack Connors, Regional Administrator National Highway Traffic Safety Administration 55 Broadway / Kendall Square Cambridge, Massachusetts 02142

Re: Interpretation of, and Compliance with, Specification 49 CFR Section 571-210 Subsection 4.3.1.3

Dear Mr. Connors:

The State of Massachusetts, acting through the Executive Office of Transportation & Construction, administers the Federal 16(b)(21 and State Mobility Assistance Programs. These programs provide grant subsidies to private and public non profit agencies ac ross the state for the purchase of wheelchair lift equipped vans and minibuses used to transport elderly and disabled persons.

We are currently in the process of purchasing forty three (43) vans from Collins Bus Corporation which will be outfitted with Republic Seating Corporations Model D117 seats. Questions have been raised about the current seat belt placement being utilized by Republic Seating.

We would like to request an opinion from your office on whether or not the design complies with federal standards. Attached is a quarter-scale diagram of the seat showing the location of the seat belts.

Your expeditious handling of the matter would be greatly appreciated. During the last year approximately 100 vehicles across the State have been purchased and are being operated in transportation programs.

Should you require additional information, please contact my Assistant Director Royal Spurlark or myself at 973-?000. should you need to contact Republic Seating for information, you can call Mr. Peter Redding, President of that company at (312) 628-8500 .

Sincerely,

Russell Thatcher Director Mobility Assistance Program

SEE HARD COPY FOR GRAPHIC ILLUSTRATIONS

ID: nht87-1.30

TYPE: INTERPRETATION-NHTSA

DATE: 02/10/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: M.R. Dunn

TITLE: FMVSS INTERPRETATION

TEXT:

AIR MAIL

Mr. M. R. Dunn Engineering Director Rolls-Royce Motor Cars Limited Crew Cheshire CW1 3PL ENGLAND

Dear Mr. Dunn:

Thank you for your telefax of December 18, 1986, concerning Rolls-Royce's ability to meet the automatic restraint phase-in requirements of Standard No. 208, Occupant Crash Protection. You reported that Rolls-Royce has experienced setbacks in both its aut omatic belt and airbag programs and faces "a real possibility of being unable to comply during the 1987 model year to 31 August 1987." You asked "whether there would be any restriction imposed on our sales of non-complying 1987 model year cars and the ex tent of any financial penalty per car if any."

The National Traffic and Motor Vehicle Safety Act sets out a manufacturer's obligation to produce vehicles that comply with all applicable Federal motor vehicle safety standards. The Vehicle Safety Act provides for a number of remedies the agency would p ursue if a manufacturer has failed to comply with the requirements of the Act. Those remedies are discussed below.

Section 108(a)(1)(A) of the Vehicle Safety Act obligates a manufacturer to produce vehicles that conform to the Federal motor vehicle safety standards. That section prohibits a manufacturer from manufacturing, introducing into interstate commerce, sellin g, or importing a vehicle that does not conform with all applicable Federal motor vehicle safety standards. Section 114 of the Vehicle Safety Act also obligates a manufacturer to furnish, at the time of delivery of a vehicle to a distributor or dealer, a certificate that the vehicle conforms to all applicable Federal motor vehicle safety standards. It is a violation of section 108(a)(1)(C) of the Vehicle Safety Act for a manufacturers to issue such a certification if it "in the exercise of due care has reason to know that such certificate is false or misleading in a material respect."

The Vehicle Safety Act provides NHTSA with a wide range of remedies the agency can pursue if there is a violation of the Act. Section 109(a) provides for a civil penalty of $1,000 for each violation of a provision of section 108 or any regulation issued under the authority of that section. Section 109(a) further provides that each non-complying motor vehicle constitutes a separate violation and entitles the agency to collect a civil penalty of up to $800,000 for a series of violations.

Under section 110 of the Vehicle Safety Act, the agency has authority to seek injunctive relief to restrain "violations of this title (or rules, regulations or orders thereunder), or to restrain the sale, offer for sale, or the introduction or delivery f or introduction in interstate commerce, or the importation into the United States" of non-complying motor vehicles.

Section 111 of the Vehicle Safety Act imposes additional duties on a manufacturer of a non-complying vehicle that has been delivered to a distributor or dealer but nor yet sold to a retail customer. That section requires the manufacturer to repurchase th e non-complying vehicle from the distributor or dealer, and to reimburse the dealer or distributor for a portion of its expenses. As an alternative, the manufacturer can furnish she purchasing distributor or dealer with the necessary conforming parts and reimburse the distributor or dealer for a portion of its expenses. If a non-complying vehicle has been sold to a retail purchaser, sections 151-159 of the Vehicle Safety Act require the vehicle's manufacturer so conduct a non-compliance notification and remedy campaign.

Under the phase-in requirements of Standard No. 208, Rolls-Royce has the obligation to install automatic restraints in ten percent of its vehicles manufactured during the period September 1, 1986 - August 31, 1987 for sale in the United Stares. If the ag ency were to determine that passenger cars manufactured by Rolls-Royce for sale in the United States do not conform to the automatic restraint requirements of Standard No. 205, the agency could pursue any or all of the following remedies under the Vehicl e Safety Act. To determine the extent of Rolls-Royce's compliance, the agency could require Rolls-Royce to provide information on the number of vehicles produced and the number equipped with automatic restraints. The agency could seek to restrain the sal e of the non-complying Rolls-Royce cars that have been imported into the United States. In addition, the agency could seek to restrain the further importation of non-complying Rolls-Royce passenger cars into the United States. Further, the agency could s eek a civil penalty against Rolls-Royce for each violation of section 108(a)(1)(A) and (C). In addition to seeking those remedies, the agency has authority under section 152 of the Vehicle Safety Act to determine whether Rolls-Royce should be ordered to conduct a notification and remedy campaign for the non-complying vehicles. While your question and the above discussion are hypothetical, we strongly urge Rolls-Royce to take all necessary steps to assure compliance with the phase-in requirements of Stan dard No. 208.

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

Sincerely,

Erika Z. Jones Chief Counsel

TELEFAX No 010 1 202 366 5930

National Highway Traffic Safety Administration Washington USA

For the attention of:

Barry Felrice, Associate Administrator for Rulemaking Room 5401

Following our telephone conversation I acknowledge your advice that a petition for temporary exemption from FMVSS 208 passive restraints is unlikely to be successful for 1987 model year. As described in our original petition for an extension of the effec tive 1987 model year to 31 December 1987 extra time is required to improve our chances or offering airbags. I must report that with setbacks in both our passive belt and our airbag programs we face a real possibility of being unable to comply during 1987 model year to 31 August 1987.

Will you please advise me whether there would be any restriction imposed on our sales of non-complying 1987 model year cars and the extent or any financial penalty per car if any.

N R Dunn Engineering Director Rolls-Royce Motor Cars Ltd, Crewe

ID: nht88-2.31

TYPE: INTERPRETATION-NHTSA

DATE: 05/20/88

FROM: JERRY SWISHER -- COOPER TIRE AND RUBBER COMPANY

TO: OFFICE OF CHIEF COUNSEL -- NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION U.S. DEPARTMENT OF TRANSPORTATION

TITLE: REQUEST FOR OPINION

ATTACHMT: ATTACHED TO LETTER DATED 08/26/88 TO JERRY SWISHER FROM ERIKA Z JONES, REDBOOK A32, STANDARD 109

TEXT: Gentlemen:

Cooper Tire & Rubber Company (Cooper) is a manufacturer of passenger, light truck and truck tires, which are sold and distributed to independent tire dealers through Cooper's own sales and distribution system and also sold to private brand customers f or distribution and sales through their own systems.

One of our private brand customers has inquired as to whether Cooper can manufacture and sell to them tires which would have:

1. No identification on the sidewall as to the name of the manufacturer or brand name owner, other than Cooper's assigned DOT letters. This tire would meet all the requirements of 49 CFR 571.109 S4.3(a) through (g) and 49 CFR 574.5; however, it woul d not have permanently molded on the upper sidewall the name "Cooper", the private brand owner's name, nor any other general trade name, trademark or identifying name. Each tire would have in the lower sidewall near the bead area, and visible after the tire was mounted, three different names, approximately one-quarter inch (1/4") in height, with each name appearing, for example, at the 2 o'clock, 6 o'clock and 10 o'clock positions on the tire. These names would be placed in such a manner that they woul d not interfere with the labeling or markings required under 49 CFR 571.109.

2. In the alternative, our private-brand customer makes the request as in 1. above, except that some generic connotation, such as, for example, "All Season" or "Performance" would also be molded on the upper sidewall.

The reason for the request from our private brand customer is that, in addition to its direct marketing, the private brand customer has two subsidiaries, and each of the three markets tires under a different name. They are seeking a generic tire with out prominent identification, but one which would contain all three names, thus making it marketable by any one or all three of the entities.

We request your opinion in reference to 1. and 2. above as to whether either would be in violation of, or in non-compliance with, 49 CFR Parts 571 and 574.

If you have any questions pertaining to the above, please feel free to contact me.

Very truly yours,

ID: nht88-2.32

TYPE: INTERPRETATION-NHTSA

DATE: MAY 24, 1988

FROM: ROBERT G. YORKS -- VICE PRESIDENT AND GENERAL MANAGER, AUTOMOTIVE BUSINESS GROUP, TRUCK-LITE

TO: KATHLEEN DEMETER -- ASSISTANT CHIEF COUNSEL FOR GENERAL LAW, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO MEMO DATED 8-1-88, TO ROBERT G. YORKS, FROM ERIKA Z. JONES, STD 108, REDBOOK A32; ALSO ATTACHED MEMO UNDATED, TO ROBERT G. YORKS, FROM KATHLEEN DEMETER

TEXT: Pursuant to your letter of April 28, 1988 (copy attached), we are rescinding our request for confidential treatment of this interpretation.

Please proceed with your analysis, without restriction.

Attachment

ID: nht88-2.33

TYPE: INTERPRETATION-NHTSA

DATE: 05/26/88

FROM: A. J. ACKLEY -- MARTEK CORP.

TO: JOAN TILLGHMAN, LEGAL COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12/08/88 FROM ERIKA Z JONES TO A J ACKLEY; REDBOOK A33, STANDARD 125; LETTER DATED 06/10/88 FROM A J ACKLEY TO ERIKA Z JONES; OCC - 2151

TEXT: Dear Ms. Tillghman:

We are in the process of submitting a proposal to an account utilizing the red safety triangle. All of the elements of the device will follow the standards as set by the D.O.C. What we propose is using their logo in the center - see drawing. This woul d revolve (to eliminate a windshield) and add to the reflective quality of the device.

Do you see any legal problem with the concept?

Thank you.

ENCLOSURE

ID: nht88-2.34

TYPE: INTERPRETATION-NHTSA

DATE: 05/27/88

FROM: TEVES, ALFRED -- TEVES TECHNICAL SERVICE

TO: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TITLE: BRAKE FLUID RESERVOIR DESIGN ACCORDING TO FMVSS 105 REQUEST FOR INTERPRETATION

ATTACHMT: OCTOBER 9, 1981 LETTER FROM BERNDT TO KAWANO, OCTOBER 3, 1988 LETTER FROM JONES TO BURKARD, EBNER, AND TEVES, FEBRUARY 3, 1981 LETTER FROM KAWANO TO BERNDT, JULY 10, 1974 LETTER FROM DYSON TO NAKAJIMA, AND MAY 24, 1988 LETTER FROM TEVES TO GREG ORY

TEXT: during his visit at NHTSA on May 17th, 1988 Mr. Ebner presented our new brake system to your experts.

We request an interpretation of S 5.4.2 (reservoir capacity) and S 5.3.1/b (Fluid level indicator) of FMVSS 105, with respect to the proposed brake fluid reservoir shown in the attachment.

Essential is the existence of an ancillary brake unit in this new brake system. This ancillary brake unit serves the brake circuits 1 and 2 directly.

Compared with a conventional reservoir the proposed brake fluid reservoir's distinctive feature is the exit for the ancillary unit.

This ancillary unit serves the brake circuits 1 and 2. When the brake pedal is released, the used brake fluid will flow back to the reservoir. This unit does not cause any additional fluid volume.

Teves interprets standard 105 S 5.4.2 and S 5.3.1/b) as follows:

1. The total minimum capacity of a reservoir shall be equivalent to the fluid displacement resulting when all the wheel cylinder or caliper pistons serviced by the reservoir move from a new lining, fully retracted position to a fully worn, fully applied position.

2. Reservoir systems utilizing a portion of the reservoir for a common supply to two or more subsystems, individual partial compartments shall each have a minimum volume of fluid equal to at least the volume displaced by the master cylinder piston servi cing the subsystem, during a full stroke of the piston.

3. The total amount of the fluid shall be solely available for the brakes.

4. The ancillary unit shall not use brake fluid for other purposes than for the brake circuits.

5. A drop in the level of brake fluid in any master cylinder reservoir compartment to less then the recommended safe level specified by the manufacturer ot to one-fourth of the fluid capacity of that reservoir compartment, which ever is greater.

The ancillary unit does not diminish the built in safety features of the reservoir. In case of a circuit failure, volume 1 resp. volume 2 remains still available for the brakes and the fluid level indicator lamp gives a warning to the driver.

In case of a fluid leakage in the ancillary unit, the unit is switched off. The fluid level indicator lamp and additional a separate warning lamp gives a warning to the driver. The fluid volumes 1 and 2 remain in the reservoir and are fully usable fo r applying the brakes with the master cylinder.

Accordingly, we believe that the proposed brake fluid reservoir described in this letter and presented to your experts fulfils the requirements S 5.4.2 and S 5.3.1 (b) of FMVSS 105.

We ask that you confirm our interpretation at your earliest convenience.

FMVSS 105, S 5.4.2: V = V[1] + V[2] + V[3] + V[4] V: GREATER OR EQUIVALENT TO FLUID DISPLACEMENT RESULTING WHEN ALL W/C MOVE FROM A NEW LINING POSITION TO A FULLY WORN LINING POSITION. MAX V[4] FLI V[3] V[1] V[2] BRAKE BRAKE ANCILLARY UNIT CIRCUIT 1 CIRCUIT 2 SERVICING BRAKE CIRCUIT 1+2

FMVSS 105, S 5.3.lb V[1] + V[3] >/- 0.25 (V[1] + V[3] + V[4]) V[2] + V[3] >/- 0.25 (V[2] + V[3] + V[4])

V[1] VOL. DISPLACEMENT EQUIVALENT TO A V[2] >/- FULL STROKE OF THE RELATED M/C-PISTON. TEVES MASTER CYLINDER RESERVOIR DESIGN ACCORDING TO FMVSS 105 3-34513-07

ID: nht88-2.35

TYPE: INTERPRETATION-NHTSA

DATE: MAY 31, 1988

FROM: M. ARISAKA -- MANAGER, AUTOMOTIVE LIGHTING, STANLEY ELECTRIC CO., LTD.

TO: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: MEMO DATED 8-10-88, TO M. ARISAKA, FROM ERIKA Z. JONES-NHTSA, STD 108

TEXT: We would like to know about the installation of an additional Rear Reflex Reflector (RR).

We are planning to install the additional Rear RR at the center portion of the rear face of cars in addition to present two Rear RRs required by FMVSS No. 108 Table III. (See attached drawing.)

The additional Rear RR will never impair the effectiveness of other lighting equipment required by FMVSS No. 108 Table III.

Kindly let us know your advice whether the above mentioned additional Rear RR is allowed or not.

We are looking forward to your reply.

Present two Rear RRs required by FMVSS No. 108 Table III

The Additional rear RR