ID: nht72-2.23

DATE: 09/13/72

FROM: AUTHOR UNAVAILABLE; E. T. Driver for R. L. Carter; NHTSA

TO: Hon. P. H. D. Fratinghuysen - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 31, 1972, to Secretary of Transportation John A. Volpe, concerning Mr. Richard J. Orgass' comments on headlighting for motor vehicles.

The National Traffic and Motor Vehicle Safety Act of 1966 required that the initial Federal motor vehicle safety standards be based on existing standards. In this respect, Federal Motor Vehicle Safety Standard No. 108, the initial Federal standard on lighting requirements, specifies that headlamps conform to existing standards, these of the Society of Automotive Engineers (SAE Standards J579a and J5SCa) for sealed beam headlamps. The SAE standards were developed by authorities in the field of vehicular lighting and were adopted by a number of State and Federal regulatory agencies prior to the existance of Standard No. 108. Specifying the use of these standard headlamp assemblies enhances traffic safety, since replacement assemblies are readily available when needed by the vehicle operator.

It is recognized that a number of currently available headlamps produce higher lighting intensities than those permitted by Standard No. 108. Such headlamps, while providing a more effectively illuminated roadway for the driver behind the lamps, could under certain traffic environments produce an annoying or even blinding effect on approaching drivers. Therefore, all aspects of highway safety must be considered during the development of new or revised requirements which will eventually be included in Standard No. 108.

As an indication of the National Highway Traffic Safety Administration's plans for improving headlighting, I am enclosing a copy of an Advance Notice of Proposed Rule making relating to Standard No. 108. Included In the Notice are several proposals which affect the present requirements for headlamps. Also, a recently completed research program on improved forward lighting included studies and evaluations on the performance and other technical aspects of several types of headlamps, including the quartz-halogen type. Results of this research will assist in the development of requirements for more effective headlighting systems. It is anticipated that a second notice including new and revised requirements for headlighting will be Issued late in 1972.

Thank you for bringing Mr. Orgass' comments to my attention.

ID: nht72-2.24

DATE: 05/09/72

FROM: AUTHOR UNAVAILABLE; D. W. Toms; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 18, 1972, requesting an interpretation of the requirements of Federal Motor Vehicle Safety Standard No. 108 which relates to the use of mechanical aimers on headlamps.

Standard No. 108 references, in Tables I and III, SAE Standard J580a. As stated in your letter, SAE J580a specifies in part that "Headlamps shall be designed so that they may be checked by mechanical aimers without the removal of any ornamental trim rings or other parts." The language in this requirement, and that contained in other referenced and subreferenced SAE standards, does not specifically identify the design or complete dimensional details of "mechanical aimers." Therefore, the use of any mechanical aimer, including those fitted with special adapters for specific vehicles, would be permitted under the above stated requirement.

Specifically, you asked, "If a vehicle is so designed that the headlamps cannot be checked with mechanical aimers of the type now commonly available without the removal of ornamental trim rings or other parts, does it meet the requirements of Federal Standard 108?" A "commonly available" aimer is defined as one that is manufactured and offered for sale, including an aimer with adapters for special applications. A vehicle which is so designed that the headlamps cannot be checked with mechanical aimers as thus defined, without the removal of ornamental trim rings or other parts, would not meet the requirements of Standard No. 108.

ID: nht72-2.25

DATE: 03/03/72

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

TO: Koito Manufacturing Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This replies to your letters of January 27, February 8 and February 9, 1972, to the National Highway Traffic Safety Administration, regarding questions on headlamp mounting requirements of Federal Motor Vehicle Safety Standard No. 108.

The following comments relate to the specific questions in the letters of each date.

Question 1 - January 27, 1972

The Federal Motor Vehicle Safety Standard No. 108 and referenced SAE standards do not preclude the headlamp aiming adjustment by direct sliding contact of the headlamp back (Illegible Word) to the housing.

We're concerned however that headlamps of different manufacturers may not always (Illegible Words) properly in such an arrangement because of non-specific dimensional requirements of SAE J571 for the headlamp back envelope. Also in this arrangement pressure is applied to areas of the headlamp not designed for such mechanical pressures. This may result in a high incidence of lamp breakage particularly with some of the "thin walled" lamps.

Question 2 - January 27, 1972

The arrangement of the headlamp mounting ring as shown on Figure 3. conforms to the requirements of Federal Motor Vehicle Safety Standard No. 108.

Question 3 - January 27, 1972

The arrangement of the headlamp mounting ring as shown on Figure 4 conforms to the requirements of Federal Motor Vehicle Safety Standard No. 108.

Question 4 - January 27, 1972

The arrangement of the headlamp mounting ring as shown on Figure 5 conforms to the requirements of Federal Motor Vehicle Safety Standard No. 108.

Your letter of February 8, 1972, relates to the request of January 27 1972, and is therefore answered by the above comments.

The question in your letter of February 9, 1972, relates to a modification of the headlamp (Illegible Words) as described under question 1 in your letter of January 27, 1972, whereby you propose a single locating lug match in the headlamp retaining ring. The requirements of Federal Motor Vehicle Safety Standard No. 108 are for three-lug indexing. The retaining ring-housing as shown on Appendix - I of your letter of February 9, 1972, does not, therefore, conform to Federal Motor Vehicle Safety Standard No. 108.

This Administration has been concerned about problems of accurate headlamp aim and aim retention capabilities, and currently has a research contract titled "Stability of Headlamp Aim" contract DOT-HS-024-1-202 scheduled for completion in July 1972. In general one of the problem areas seems to relate to insufficient strength and life of headlamp aim and retention mechanisms, along with (Illegible Word) that cause field service problems by shifting or actually falling out when replacement of the headlamp is attempted. If you desire, you may contact Mr. Roger Benion of the Southeast Research Institute, (Illegible Words) Road, San Antonio, Texas, 73284, who manages our stability of headlamp Aid contract, for additional technical contracts on your proposed headlamp aiming mechanism.

We have enclosed a copy of report DOT-HS-(Illegible Words) on "Vehicle Forward Lighting Performance and Inspection Requirements" which includes preliminary research information on headlamp aim.

ID: nht72-2.26

DATE: 01/11/72

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

TO: Westinghouse Electric Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 22, 1971 to Lawrence R. Schueider you ask for a clarification of the relationship between 49 CFR Part 566 "Manufacturer Identification, and 49 CFR @ 571.108, Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. Specifically you ask whether identifying information is required for miniature bulbs.

Standard No. 108 establishes performance requirements for items of motor vehicle lighting equipment, and incorporates by reference certain SAE standards that specify requirements lamps must meet in laboratory tests when assembled. The SAE standard that applies to bulbs: J573d, Lamp Bulbs and Sealed Units, is not incorporated by reference, and Standard No. 108 contains no requirements for the output of bulbs furnished with a lamp assembly. When a lamp is tested for conformity, the production bulb is removed and a calibrated bulb substituted, in accordance with Paragraph 0 of SAE Standard J575d, Tests for Motor Vehicle Lighting Devices and Components; the test bulb is to be "representative of Standard bulbs in regular production" and must be "selected for accuracy in accordance with specifications listed in . . . SAE J573." In summary, Standard No. 108 does not specify performance requirements for lamp bulbs, and production bulbs are not used in lamp testing. Therefore, Standard No. 108 does not apply to bulbs and bulb manufactures are not required to certify conformance to Federal standards, or to submit information pursuant to the Manufacturer Identification regulations.

ID: nht72-2.27

DATE: 06/05/72

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

TO: State of Louisiana

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 26 to Mr. Schneider, referencing your conversation with Mr. Vinson of this office on Federal motor vehicle safety standards appliable to mobile homes.

In answer to your questions:

(1) Mobile homes (house trailers) are required to comply with the same Federal Safety Standards applicable to other types of trailers.

(2) Lights are not required to be permanently installed. The use of a temporary lighting harness, removable when the home was completed its trip from factory to point of purchase, is acceptable.

(3) There are no Federal safety standards for hydraulic surge brakes on trailers.

ID: nht72-2.28

DATE: 09/08/72

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

TO: Zundapp-Werke GMBH Munchen

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of August 8 and your follow-up letter of August 22 to Mr. Francis Armstrong, Director, Office of Standards Enforcement, concerning the lighting requirements for motor-driven cycles, were forwarded to this Office for consideration and reply.

The lighting requirements specified in Federal Motor Vehicle Safety Standard No. 108 are identical for a motorcycle and a motor-driven cycle (except for headbumper see SAE J584 April 1964), because the letter is defined in Part 571 of the standard (Illegible Word) "a motorcycle with a motor that produces 5-brake horsepower or less."

In addition, the answers to your specific questions follow --

1. Must the stop-light of a motor-driven cycle be operated by hand and foot brake?

Answer -

Yes. Paragraph S4.5.4 of FMVSS No. 103 requires the stop lamps on each vehicle to be activated upon application of the service brakes, and since both the hand and foot brakes are service brakes, the application of either must activate the stop lamps.

2. Does there exist any regulations concerning the light intensity of the brake-light?

Answer -

Yes. Currently stop lamps must conform in the photometric requirements specified in SAE Standard J575d. Paragraph S4.1.1.6 of FMVSS No. 108 also requires that vehicles manufactured on or after January 1, 1973, be equipped with stop lamps meeting the candlepower requirements for Class A from signal lamps in SAE J575d.

3. Are turn signal prescribed?

Answer -

Yes. Class B turn signal lamps (see SAE J575d) are required as motorcycles manufactured on or after January 1, 1973, and should be mounted as specified in Table IV of FMVSS No. 108 (copy enclosed for your information).

NOT CONTROLLED

ID: nht72-2.29

DATE: 06/12/72

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Harker Enerprises, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of May 22, 1972, to the Director, National Highway Traffic Safety Administration, concerning your patented Anti-Clare lenses for automotive headlights.

Federal Motor Vehicle Safety Standard No. 108 does prohibit the installation of devices in front of the headlamp lens, and also allows only white light from the headlights (Illegible Word) you have correctly concluded. There is no expectation of any future significant change in this area of Standard No. 108 requirements.

These requirements of Standard No. 108 are applicable to original equipment furnished on new vehicles; therefore, the allowance of sale of your Anti-Glare lenses in the aftermarket is under the jurisdiction of the Individual States.

ID: nht72-2.3

DATE: 07/24/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Weirich Associates

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 11, 1972, inquiring about the use of plastic for an automatically closing fuel cap for automobiles.

The National Highway Traffic Safety Administration (NHTSA) has the responsibility for promulgating standards that improve the safety performance of new motor vehicles to minimize injuries and fatalities associated with the use of motor vehicles. Among the standards that have been issued is Federal Motor Vehicle Safety Standard (FMVSS) No. 301, which specifies performance requirements for the fuel tank, fuel tank filler pipe, and fuel tank connections. Like other Federal Standards issued by the NHTSA, this standard is performance oriented and does not specify design requirements. This standard will shortly be amended to specify additional performance requirements including rear-end collisions and rollover. In addition, other proposals will also be issued to considerably improve fuel containment to minimize the possibility of fuel spillage resulting from additional vehicle impacts. The essential requirements pertain to demonstrations of safe fuel containment as the result of standardized vehicle crash tests. How the results are to be achieved, what materials can or cannot be used, or other design features, are left to the discretion of the motor vehicle manufacturer in order that there should be the maximum freedom for innovation and inventiveness to meet the specified safety performance. We have no restrictions in the use of plastics or other materials that meet a specified safety performance requirement.

In view of present rulemaking action to amend FMVSS No. 301, there has been much information assembled, which is part of the public record, concerning comments from manufacturers, the interested public, and from suppliers of components. Your components, including a self-closing fuel cap and a seal within the filler pipe are interesting developments having possible contribution to improved safety. We would be pleased to have more information concerning these developments and with your permission, we would like to have copies of descriptive information to put into our public record, Docket No. 70-20, for the public and for the motor vehicle industry to see.

We should mention also that the Bureau of Motor Carrier Safety, which regulates interstate commercial transportation of passengers and cargo, has regulations which include fuel caps. You may want to contact this organization for their current requirements. Their location is at the same address of NHTSA.

Relative to pollution, the current requirements for fuel evaporative emission controls have resulted in motor vehicles being equipped with fuel caps that either have no vents or which vent only after certain stress develops from positive or negative internal tank pressure. You may want to contact the Environmental Protection Agency concerning their regulations. The address is 1626 K Street, N.W., Washington, D.C.

We are enclosing a copy of FMVSS No. 301, a copy of a notice proposing additional requirements, and a copy of Public Law 89-563.

We appreciate your interest in motor vehicle safety.

SINCERELY,

WEIRICH ASSOCIATES

July 11, 1972

Department of Transporation

Bureau of Motor Vehicles

Gentlemen:

We have developed a closure for the gasoline tanks for automobiles that automatically closes after filling thereby preventing spillage in the event the present day cap is not replaced properly, or in some instances not put back in place.

The piece can also be made to include a seal inside the fill pipe which effectively closes in case of collision damage.

Our question is to inquire regarding the use of plastics in the manufacture of this type of closure. Does the government have any regulations in this regard?

We do believe the new closure will contribute to some degree in the prevention of pollution, and to a greater measure as a safety device.

May we please have your early reply?

Paul Weirich General Manager

ID: nht72-2.30

DATE: 03/01/72

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

TO: Motor Coach Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 7, 1972, to Mr. Lewis Owen of this Office concerning clarification of the requirements of paragraph S4.7 of Standard No. 108.

A label similar to that shown on the enclosure to your letter would meet the certification requirements of paragraph S4.7.2 of Standard No. 108 as specified in the amendment published in the Federal Register on January 12, 1972, (copy enclosed).

"Associated equipment" covered by Standard No. 108 includes only that for which requirements are specified in the Standard. The only serviceable item, in addition to the completed assemblies, for which certification is required is a plastic part such as a (Illegible Word), which must meet the requirements of paragraph S4.1.2.

The requirement for replacement equipment to conform to Standard No. 108 was applicable to items manufactured on and after January 1, 1972. Certification of items received by your Service Parts Department after January 1, 1972, is therefore acceptable.

ID: nht72-2.31

DATE: 03/10/72

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Strick Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 21, 1972 asking for reconsideration of the opinion expressed in our letter of October 6, 1971, concerning the location of the rear identification lamp cluster on trailers of your manufacture.

You are correct in saying that the requirement that Identification lamps be located" 'as close as practicable to the top of the vehicle' is subject to interpretation and individual judgment." We have expressed our opinion previously, and if you choose to mount your lights below the rear crossmember you should be prepared to demonstrate that this location is "as close as practicable to the top of the vehicle."

I enclose a copy of a recent amendment to Standard No. 108 permitting off-center spacing of identification lamps. Perhaps this will alleviate your problem to come extent.