ID: nht90-2.31

TYPE: INTERPRETATION-NHTSA

DATE: 04/25/90

FROM: RAYMOND D. STRAKOSCH -- PRESIDENT SAFETY PREMIUMS

TO: JOHN MESSERA -- NHTSA

TITLE: AUTOMOBILE TRIANGLE DEVICE AUTOMOBILE TRIANGLE DEVICE

ATTACHMT: ATTACHED TO LETTER DATED 06/05/90 FROM STEPHEN WOOD -- NHTSA TO RAYMOND D. STRAKOSCH -- SAFETY PREMIUMS, ON A 35, STD 125

TEXT: One of your associates provided us with a copy of the Motor Vehicle Safety Standard #125 while you were away from the office.

The standard was called to our attention since we have marketed for years a Signal Glo Car Mirror warning device, as described in the enclosed literature. Included in those products were two different triangle shapes.

One of our customers, who is in the retail automotive trade, has asked us to develop a larger size warning triangle for mounting on a car mirror for possible retail sales.

As our triangle gets larger, we wish to make sure that it is not confused with the roadside truck version described in the Standard #125. In addition, we would like to make sure that our instructions for use are clear and in no way conflict with the sta ndard.

A sample of our earliest Signal Glo triangle, and our prototype new larger size "Light at Nite" Reflective Auto Triangle are enclosed for your information.

We would appreciate any comments or assistance you may be able to give us.

[BROCHURE OMITTED]

ID: nht71-3.32

DATE: 07/13/71

FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY DAVID SCHMELTZER

TO: FWD Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 1, 1971, concerning the Tire Identification and Record Keeping Regulation (49 CFR 574).

You are correct in your interpretation of the regulation, the vehicle manufacturer is not required to forward tire data to the tire manufacturer. The vehicle manufacturer's responsibilities are limited to maintaining a record of the tires on or in the vehicle when shipped along with a record of the names and addresses of first purchasers of the vehicles equipped with such tires. The method of complying with these requirements is left to the vehicle manufacturer. In the event of a defect notification, the tire manufacturer will be under an obligation to notify the vehicle manufacturer describing the suspect tires.

If we can be of further assistance, please feel free to write.

ID: nht69-2.20

DATE: 11/24/69

FROM: R. H. COMPTON -- DIR., OFC. OF STANDARDS ON ACCIDENT AVOIDANCE, MVS PS, NHTSA; SIGNATURE BY C. A. BAKER

TO: Gumifabriken Gislaved Aktiebolag

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of November 3, 1969, the Department of Transportation hereby assigns number 210 to the Gumifabriken Gislaved Aktiebolag, Gislaved, Sweden, as its approved code mark. The approved code mark is for use in identifying the tire manufacturer in accordance with S4.3 of Federal Motor Vehicle Safety Standard No. 109 and the National Traffic and Motor Vehicle Safety Act of 1966 (15 USC 1421 (1)).

Your attention is directed to the requirement for designation of an agent in accordance with the National Traffic and Motor Vehicle Safety Act of 1966, Subsection (110(e)). This requirement is implemented by our "General Procedural Rules, Subpart D - Service of Process; Agents.

As requested, I have enclosed a copy of the Federal Motor Vehicle Safety Standards No. 109 and No. 110 with amendments.

ID: nht75-3.40

DATE: 06/01/75 EST

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

TO: Floyd, Kramer & Lambrecht

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of April 25, 1975, concerning the applicability of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, to the Wabco Westinghouse Duo-Matic Coupler.

You have described the Coupler as a device which replaces the glad hand coupler now used by most manufacturers to connect truck tractor and trailer brake lines. Because the brake hose which attaches to the Coupler is equipped with its own end fittings, the Coupler itself is not an end fitting. Therefore, Standard No. 106-74 is inapplicable.

The Coupler is, however, subject to the requirements of 49 CFR Part 393.45 and 393.46, of which I have enclosed a copy. Please direct any questions you may have concerning interpretation of these requirements to the Office of the Chief Counsel, Federal Highway Administration, at 400 Seventh St., S.W., Washington, D.C. 20590.

YOURS TRULY,

DOUBLE QUICK-RELEASE COUPLING DUO-MATIC "SEMTRA" FOR SEMI-TRAILERS

DUO-MATIC "SEMTRA" is a compressed air brake coupling for fitting on semi-trailers.

* No possibility of confusing the lines when connecting up.

* Simple to fit with or without attaching plate.

* Cover closes automatically -- no lost covers.

* Valves placed in the hose part.

* Takes up little room.

Ordering example: 452 803 500 0 Trailer part and towing vehicle part.

452 805 000 0 Towing vehicle part

For other combinations, see table.

PATENTED TRAILER PART TOWING VEHICLE PART TRAILER PART ASSEMBLY NO. ASSEMBLY NO. TOWING VEHICLE PART ASSEMBLY NO. 452 803 000 0 452 805 000 0 452 803 500 0 [Graphics omitted]

TOWING VEHICLE PART 452 805 000 0 Item Qty Part No. Description 1 1 152 805 230 1 Hose connection 2 2 896 010 680 1 Valve spring 3 2 152 802 190 1 Valve cap 4 2 897 181 100 1 Cylinder seal 5 2 805 070 430 1 Dished washer 6 2 810 518 018 1 Locking ring 7 2 899 504 400 2 Valve assembly 8 1 452 801 650 1 Dust cover 9 1 896 200 710 1 Spring 10 1 892 222 200 1 Shaft

Part marked x are included in spare parts set. E Packenhen kompl. Best. no. 452 805 000 2

TRAILER PART 425 803 000 0 Item Qty Part No. Description 4 1 152 802 100 1 Bracket 5 2 152 803 230 4 Sleeve 6 2 891 500 451 1 Nut 7 2 895 110 750 4 Press ring 8 1 452 802 550 1 Bettom plate 9 1 452 802 610 1 Dog for cover 10 1 452 802 555 1 Upper cover 11 2 452 802 690 1 Shaft 12 4 895 222 330 1 Locking ring 13 4 152 802 710 1 Lever 14 1 152 802 553 1 Holding-down P.

15 1 800 200 700 1 [Illeg.] springs 16 1 896 010 690 1 Compr. spring

Part marked x are included in spare parts set. E Packehen kompl. Best. no. 152 803 000 2

FITTING OF DUO MATIC "SEMTRA" ON SEMI-TRAILER IN ACCORDANCE WITH AMERICAN METHODS

[Graphic omitted]

ID: nht71-3.43

DATE: 07/19/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: General Telephone Company of California

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of June 17, 1971, concerning General Telephone's obligations under the Tire Identification and Record Keeping Regulation (49 CFR 574).

You have asked if General Telephone is required to keep records under the regulation in connection with the sale of used vehicles, and if it is, whether a specific exemption is required.

If you are selling used vehicles to purchasers who are the ultimate users of these vehicles, and you are equipping those vehicles with new or newly retreaded tires, you are considered a tire dealer under section 574.9 of the regulation and you are required to maintain the records required by section 574.8 of the regulation.

If, however, you are selling used vehicles without equipping them with new or newly retreaded tires, to dealers rather than users, the regulation does not apply to General Telephones and no specific exemption is necessary.

Enclosed for your convenience is a copy of the regulation, if we can be of further assistance please feel free to write.

ENCLOSURE

ID: 1984-2.16

TYPE: INTERPRETATION-NHTSA

DATE: 07/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Automobile Importers of America

TITLE: FMVSS INTERPRETATION

TEXT:

Bruce Henderson Automobile Importer of America 1735 Jefferson Davis Highway Suite 1002 Arlington, VA 22202

Dear Mr. Henderson:

This is to follow-up on your phone conversation with Stephen Oesch of my staff concerning Safety Standard No. 201, Occupant protection in interior impact. Your specific question was whether a fuse box cover must comply with the requirements of section 3.3 of the standard. As explained below, a fuse box cover does not have to comply with section 3.3.

Section 3.3 of the standard provides that each "interior compartment door" in certain vehicle locations must remain closed when subjected to the specified performance tests. Section 571.3 defines an interior compartment door as "any door in the interior of the vehicle installed by the manufacturer as a cover for storage space normally used for personal effects." The definition is meant to include such storage areas as the "glovebox" which has a large door which could fly open in a crash, and not a portion of the vehicle's electrical system such as a fuse box, which is not used as storage space.

Although not covered by the standard, we would urge a manufacturer carefully to design the fuse box in such a way as to prevent injuries if it is located in an area which could be struck by an occupant in a crash.

If you have further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

ID: nht89-1.71

TYPE: INTERPRETATION-NHTSA

DATE: 04/14/89

FROM: EUGENIA M. PIERAKOS; JAMES L. PIERAKOS -- SNOWLIFTING EQUIPMENT AND

TO: CONSULTANTS OF BUFFALO INC HENRY J. NOWAK -- 33RD CONGRESSIONAL DISTRICT, NY

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/27/89 FROM STEPHEN P. WOOD -- NHTSA TO HENRY J. NOWAK -- CONGRESS; REDBOOK A33; PART 571; LETTER DATED 04/30/89 FROM HENRY J. NOWAK -- CONGRESS TO JOHN STONNER -- DOT;

TEXT: Dear Congressman:

This firm is the Western New York State dealer for Jaeger Industries, Inc., manufacturers of curbside recycling equipment, brochure and specifications for same enclosed.

For some time now, the manufacturer has attempted to obtain official information/data regarding their equipment, specifically the use of chain steering for dual steering applications; brakes, throttle, etc. They have spoken to various officials in NYSMV D with no success. They have been referred to NHTSA in Washington (202-366-2992), spoken with Asst. Chief Consul Steve Wood and Chief Consul Erika Jones, and no one has provide Jaeger with any definitive answers.

Since USDOT has no office in the Buffalo area, we are asking your help in obtaining the data/regulations that apply to this vehicle, especially the dual steering mechanism, brakes, throttle, etc.

We know you are vitally interested in the recyling programs in our area, and realize that its success is very dependent on good equipment. Several communities in the Buffalo area are planning to purchase these vehicles, but we must be sure that it meets all Federal and State standards. In view of the urgency of this matter, we would appreciate your office expediting same, so that we can have factual information as soon as possible. Your cooperation in this matter is greatly appreciated.

Respectfully,

enclosures omitted

ID: nht72-2.10

DATE: 03/14/72

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Hance; Caston; Hefner and Green

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 25, 1972, concerning the certification of new trailers which your client manufactures. You state that some of those trailers are shipped (to customers) equipped with used tires that are intended primarily to be used to ship the trailers to their destination, and ask whether these tires should be taken into account in the values for GVWR and GAWR on the certification label.

We do not consider that temporary tires attached to a vehicle for purposes of shipment should be refelcted in the GVWR and GAWR on the certification label, if these tires are not intended to be part of the completed vehicle. Consequently, we would expect trailers certification as vehicles for which no tires have been provided. In such a case, the complete vehicle manufacturer, as indicated in the preamble to the Certification regulations (April 14, 1971, 36 F.R. 2054) must still bear responsibility and certify the vehicle, even though he does not install the tires with which the vehicle will ultimately be equipped. We suggest that one manner in which this could be accomplished by the manufacturer is to list GAWR and GVWR for the optional tire sizes which he recommends in accordance with the amendment to the Certification regulations published December 10, 1971 (35 F.R. 23571). The manufacturer should make it clear to the purchaser of the vehicle that the temporary tires should be replaced when the vehicle is put into use.

We are pleased to be of assistance.

ID: nht93-3.8

DATE: April 20, 1993

FROM: Dennis Platt -- Sergeant, Program Supervisor, Vehicle Safety & Equipment Section, Department of Public Safety, Utah Highway Patrol

TO: Marvin Shaw -- U.S. Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6-17-93 from John Womack (Signature by Kenneth N. Weinstein) to Dennis Platt (A41; Std. 205)

TEXT: Recent school bus and truck inspections performed by inspectors from our agency have found some safety glass installations that may or may not be legal application.

Windshields (flat glass applications) in some Blue Bird School buses and other heavy trucks have been replaced locally with glass that is marked;

- Buchman AS1 Safety Laminated Float glass DOT #146M-592 16 CFR 1201 CAT II

Other manufacturers are etching similar markings on flat glass for replacement windshields, all of which are marked with the common AS1, 16 CFR 1201 CAT II marking.

In speaking with Mr. Messera of your office, he indicated he was not aware of any automobile AS1 glass that has been dual certified as being 16 CFR 1201 CAT II.

In reading 16 CFR 1201, our staff has been unable to find any provision in the regulation that allows dual certification.

If there is such a provision, and AS1 glass may also be 16 CFR 1201 CAT II, and 16 CFR 1201 CAT II may also be AS1 certified, please advise.

Our intent is to prevent glass which has been designed for shower stall doors and patio doors from being installed in school bus windshields and side windows and similar applications in heavy trucks.

Your attention and response in this matter is appreciated.

ID: nht93-5.45

TYPE: Interpretation-NHTSA

DATE: August 3, 1993

FROM: Maine E. Peace -- Supervising Revenue Officer, State of Washington, Dept. of Revenue

TO: Robert Hellmuth -- Director, Vehicle Safety Compliance, DOT

TITLE: None

ATTACHMT: Attached to letter dated 2/3/94 from John Womack to Maine E. Peace (A42; Part 591; VSA Sec. 108(a)(1)(A); VSA Sec. 108(a)(2)(A))

TEXT:

I AM A SUPERVISOR FOR THE WASHINGTON STATE DEPARTMENT OF REVENUE IN BELLINGHAM, WASHINGTON.

I HAVE WORKED CLOSELY WITH U.S. CUSTOMS, U.S. BORDER PATROL, AND THE CANADIAN R.C.M.P. ON CUSTOMS VIOLATIONS AND VIOLATIONS OF WASHINGTON STATE LAW REGARDING THE POSSESSION AND TRANSPORTATION OF ILLEGAL CIGARETTES THROUGH WASHINGTON STATE FOR EVENTUAL SALE IN CANADA ON THE BLACK MARKET.

MY PROBLEM BEGINS WHEN A SUSPECT IS APPREHENDED IN WASHINGTON STATE. THE INDIVIDUAL IS ARRESTED, THE CIGARETTES CONFISCATED AND THE VEHICLE SEIZED. SELLING SEIZED CANADIAN VEHICLES HAS BECOME A PROBLEM AS UNLESS I CAN GENERATE SOME INTEREST BY ADVERTISING IN CANADA, I AM STUCK WITH THE VEHICLE AND THE COST OF TOWING AND STORAGE WITH NO LOCAL MARKET AVAILABLE TO SELL THE SEIZED VEHICLES.

I AM REQUESTING YOUR AGENCY PROVIDE AUTHORITY FOR THE DEPARTMENT OF REVENUE TO SELL THE VEHICLES LOCALLY, EVEN THO THEY WERE MANUFACTURED IN CANADA, PROVIDING OF COURSE THE VEHICLES MEET MOST IF NOT ALL THE STANDARDS REGULATED BY YOUR AGENCY REGARDING VEHICLE SAFETY.

THE VEHICLES IN QUESTION WERE SEIZED AS THE METHOD OF TRANSPORTING ILLEGAL GOODS THROUGH WASHINGTON AND NOT IMPORTED FOR SALE OF PERSONAL USE BY AN INDIVIDUAL OR COMPANY DOING BUSINESS IN THE U.S.

ANY ASSISTANCE AND ADVISE YOU CAN PROVIDE WILL BE MOST APPRECIATED.