ID: nht79-3.16

DATE: 11/14/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Performance Plus Products, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to the questions that you raised on October 23, 1979, with Ms. Debra Weiner of my office concerning the legal and technical issues arising from the manufacture of auxiliary fuel tanks for use in pickup trucks. You noted that you are going into the business of manufacturing auxiliary fuel tanks, that you will not be involved in the installation of such tanks, and that you would like any advice that we might be able to provide as to the construction standards that should be followed in manufacturing such tanks.

I have enclosed a copy of a letter which was sent to a company that planned to manufacture auxiliary fuel tanks for passenger cars and to do some installation. The legal principles enunciated in that letter are applicable to auxiliary fuel tanks intended for use in all types of motor vehicles except motor carriers in interstate commerce. Although your company is not planning to install auxiliary tanks, I think that you might find that the discussion of the legal issues that arise with respect to installation may be helpful in determining what safety margins should be built into these types of tanks.

As Ms. Weiner noted on the phone, this agency has not issued any standards applicable to the construction of auxiliary fuel tanks. However, the Federal Highway Administration, Bureau of Motor Carrier Safety has issued standards relevant to the construction of auxiliary fuel tanks for use in motor vehicles which are engaged in interstate commerce. I have enclosed a copy of these standards in hope that they will provide you with some suggestions as to what would constitute safe construction of an auxiliary fuel tank. In addition, the Society of Automotive Engineers has published standards pertinent to some aspects of the construction of fuel tanks. I have also enclosed copies of these.

I hope that you will find the enclosed material helpful. If you have any further questions, please feel free to contact Ms. Weiner for further information.

ID: nht79-4.13

DATE: 07/17/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Department of Education; Ohio

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your June 15, 1979, letter asking about the use of standard production vans for the transportation of school children to or from school or related events. In particular, you ask whether a 15-passenger Dodge Maxi-Van can be used for school transportation.

Whether a new vehicle sold for use as a school vehicle must comply with the Federal school bus safety standards depends on whether the vehicle meets our definition of a bus. Our definition provides that a bus is "a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons." (Title 49 of the Code of Federal Regulations, Part 571.3). Thus, a vehicle that transport 10 or fewer persons may be sold as a school vehicle and need not comply with the Federal school bus safety standards. However, a Dodge Maxi-Van capable of carrying 15 persons is a bus. If such a vehicle is sold new for use as a school vehicle, it must comply with those standards.

ID: nht91-5.38

DATE: September 6, 1991

FROM: None

TO: Taylor Vinson -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10-23-91 from Paul Jackson Rice (A38; Part 571.3)

TEXT:

This is to request confirmation of our interpretation that specific future vehicle models may be properly classified as multipurpose passenger vehicles (MPVs) for purposes of the Federal Motor Vehicle Safety Standards. Attachment I contains a description of these future vehicle models.

As described in Attachment I, the new models will be constructed on a truck chassis. The chassis-frame is separate from the vehicle body (a design usually associated only with trucks) and the chassis was originally designed to provide cargo-carrying capability as well as to permit rough road and off the road vehicle operation.

The vehicles also have special features for occasional off-road operation.

- Attachment I describes some of the special features for off-road operation.

- Attachment II shows a comparison of vehicle specifications for the new models (preliminary estimates) with characteristics listed in NHTSA's CAFE regulations which are used to identify vehicles capable of off-highway operation (minimum approach angle, departure angle, breakover angle, running clearance, and front and rear axle clearances). The new models are expected to meet the criteria for three out of the five off-highway vehicle characteristics listed.

- Attachment III shows a comparison of vehicle specifications for approach angle, departure angle, breakover angle, running clearance, and axle clearances for a variety of current model passenger cars and MPVs with estimated specifications for the new models. In general, the new models have specifications outside the range of most passenger cars and within or close to the range of most MPVs.

Because the future vehicle models described above are constructed on a truck chassis and have special features for occasional off-road operation, we believe that they would be properly classified as MPVs for purposes of the Federal Motor Vehicle Safety Standards. Please confirm that our interpretation is correct.

ATTACHMENT I

Description of Future Vehicle Models ATTACHMENT II

CAFE Regulation Minimum Preliminary Vehicle for Automobiles Capable Estimate for Characteristic of Off-Road Operation New Models

Approach angle 28 degrees Departure angle 20 degrees Breakover angle 14 degrees Running clearance 203 mm Axle clearance Front 178 mm Rear 178 mm

ATTACHMENT III

Charts and graphs showing vehicle specifications. (Graphics omitted)

ID: nht75-2.31

DATE: 05/20/75

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

TO: Toyo Kogyo co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: In reply to your letter of April 22, 1975, the "wheel nuts" covered by Motor Vehicle Safety Standard No. 211 are large, center-mounted hub nuts, one to a wheel, that lock the tire to the axle.

They are not the individual nuts, often six to a wheel, that perform the same function, and which are generally covered by a wheel disc or hub cap.

Your hub nuts and hub bolts therefore need not be marked with a manufacturer's identification code.

YOURS TRULY,

April 22, 1975

James C. Schultz Chief Counsel National Highway Traffic Safety Administration

In the Docket No. 73-14; Notice 3 issued in the Federal Register dated on March 19, 1975, S 571.211 S 3.2. says,

"Each wheel nut, wheel disc, and hubcap shall be permanently and legibly marked or labeled with the manufacturer's identification code---"

As shown in the sketch below, we use two ways to put the wheels on the vehicle, that is either (a) by screwing hub bolts only, or by screwing hub nuts into hub bolts inserted in the dram or disc with the pressure.

We are now wondering if these hub nut and hub bolt will be included in above requirement. We would appreciate your view on this issue. Thank you.

H. (SPEEDY) Hirai Technical Representative Toyo Kogyo Co., Ltd. (MAZDA) Representative Office

(Graphics omitted)

ID: nht90-2.3

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 8, 1990

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TO: HERBERT E. STOEL

TITLE: NONE

ATTACHMT: LETTER DATED 2-1-90 TO JOHN WOMACK FROM HERBERT E. STOEL ATTACHED; (OCC-4406). ALSO ATTACHED LETTER DATED 12-30-87 TO KEN SIKKEMA FROM HERBERT E. STOEL. TEXT:

This is in reply to your letter to John Womack of this office, suggesting that the color of taillamps on motor vehicles be green.

The agency is concerned about methods to effectively improve rear lighting and signaling. The issues involved include lamp size, location, operation, combinations and separation, and color. We are learning that changes in lamp function, operation, and c olor should be approached in a conservative fashion, so as not to confuse the operators of other vehicles.

With specific respect to use of the color green on rear lighting equipment, we are aware that some research suggests a green/red color scheme may enhance driver performance. In such systems, a green lamp indicates that the accelerator pedal is applied, amber that the foot has been lifted from the accelerator pedal, and red, that the brake is being applied. Some years ago, an experiment was conducted with such a system using transit buses in the D.C. area. The results were inconclusive. Although some research suggests a possible improvement in driver performance with green/red lamps, there are no data addressing the possible driver confusion that might arise from multiple color lighting arrays.

Thank you for your suggestion to enhance motor vehicle safety.

ID: nht92-1.47

DATE: 12/01/92

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: CHESTER I. NIELSEN, III -- VICE PRESIDENT SALES, WESBAR CORPORATION

ATTACHMT: ATTACHED TO LETTER DATED 10-21-92 FROM CHESTER I. NIELSEN, III TO WALTER B. MCCORMICK, JR. (OCC 7912)

TEXT: This responds to your letter of October 21, 1992, to Walter B. McCormick, Jr. (the General Counsel of this Department). You have written for "further explanation of S5.3.1.1.1 in FMVSS 108."

You have heard that there is an additional interpretation with respect to the location of clearance lamps on boat trailers whose overall width is 80 inches or more, which would allow mounting of these lamps in accordance with a sketch that you enclosed, and you ask for confirmation of this interpretation.

We are unaware of any interpretation of this nature. The requirements for the provision and location of clearance lamps on wide boat trailers remain those set forth in Tables I and II of Standard No. 108, with the exceptions set forth in paragraphs S5.1.1.9, S5.3.1.1.1, and S5.3.1.4.

ID: 7892

Mr. Chester I. Nielsen, III
Vice President Sales
Wesbar Corporation
P.O. Box 577
West Bend, WI 53095

Dear Mr. Nielsen:

This responds to your letter of October 21, 1992, to Walter B. McCormick, Jr. (the General Counsel of this Department). You have written for "further explanation of S5.3.1.1.1 in FMVSS 108."

You have heard that there is an additional interpretation with respect to the location of clearance lamps on boat trailers whose overall width is 80 inches or more, which would allow mounting of these lamps in accordance with a sketch that you enclosed, and you ask for confirmation of this interpretation.

We are unaware of any interpretation of this nature. The requirements for the provision and location of clearance lamps on wide boat trailers remain those set forth in Tables I and II of Standard No. 108, with the exceptions set forth in paragraphs S5.1.1.9, S5.3.1.1.1, and S5.3.1.4.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:108 d:12/1/92

ID: 7912

Mr. Chester I. Nielsen, III
Vice President Sales
Wesbar Corporation
P.O. Box 577
West Bend, WI 53095

Dear Mr. Nielsen:

This responds to your letter of October 21, 1992, to Walter B. McCormick, Jr. (the General Counsel of this Department). You have written for "further explanation of S5.3.1.1.1 in FMVSS 108."

You have heard that there is an additional interpretation with respect to the location of clearance lamps on boat trailers whose overall width is 80 inches or more, which would allow mounting of these lamps in accordance with a sketch that you enclosed, and you ask for confirmation of this interpretation.

We are unaware of any interpretation of this nature. The requirements for the provision and location of clearance lamps on wide boat trailers remain those set forth in Tables I and II of Standard No. 108, with the exceptions set forth in paragraphs S5.1.1.9, S5.3.1.1.1, and S5.3.1.4.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:108 d:12/1/92

ID: nht92-8.46

DATE: February 24, 1992

FROM: Neil Friedkin -- Attorney at Law

TO: Erica Z. Jones -- Chief Counsel, NHTSA

TITLE: Re: Fred Levinson Productions v. Sports Imports Inc. and Coachbuilders Ltd.

ATTACHMT: Attached to letter dated 4/13/92 from Paul J. Rice to Neil Friedkin (A39; S 108 (a)(1)(A); S 108 (a)(2)(A); S 108 (b)(1); Part 567)

TEXT:

I am the attorney for Fred Levinson Productions Inc. ("FLP"). In August of 1986, FLP leased a 1986 Mercedes 560 LEC from Sports Leasing. As part of the lease, Coachbuilders Ltd converted the vehicle from hardtop to convertible. The vehicle identification Number is WDBCA45D3GA270730.

Mr. Levinson is in litigation concerning the vehicle. In part, he alleges Coachbuilders did not RECERTIFY the vehicle after conversion and that the conversion did not conform with the standards of the Safety Act.

In the past, I have written to your office concerning what rules would be applicable to the conversion and whether Coachbuilders would have been required to recertify the vehicle. I also asked if any complaints had been made against Coachbuilders.

In response, you were kind enough to provide me with certain rules and regulations and with opinion letters you had issued in the past (copies of which are enclosed) on similar inquiries.

I am writing to you now to see if you can provide a similar opinion letter addressed to my client and the conversion of this Mercedes hardtop to convertible. If this is possible, or if you require further information, please contact me.

ID: nht90-1.50

TYPE: Interpretation-NHTSA

DATE: February 20, 1990

FROM: David G. Dick -- Technician, Toy Laboratory, ACTS Testing Labs, Inc.

TO: NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-10-90 from P.J. Rice to D.G. Dick (A36; Std. 213)

TEXT:

This letter is to request an interpretation of the National Highway Traffic Safety Administration, Department of Transportation, Code of Federal Regulations, Title 49, Transportation, Part 571.213, S5.2.3 Head Impact Protection requirements.

Section 5.2.3.2(a) of the Standard requires a 25% compression-deflection resistance of not less than 0.5 and not more than 10 pounds per square inch (psi) when tested in accordance with Section 6.3 for the energy absorbing material.

The requirements of not less than 0.5 and no greater than 10 psi are listed in the standard to one significant figure, however, when specimens are tested in accordance with the specified methodology, the results are calculated to more than one significan t figure. Is it acceptable to round off the result to one significant figure as stated in the standard as seen in the below example?

i.e.: 0.47 would be rounded up to O.5 and reported as a Pass.

Additionally, how was the lower limit of 0.5 psi decided upon?

Is there any situation in which an energy absorbing material with a 25% compressiondeflection resistance of less than 0.5 psi acceptable?

Your quick response to these questions would be greatly appreciated.