ID: 3133o

Mr. Richard W. Ward
Vice President
K-D Lamp Company
1910 Elm Street
Cincinnati, OH 45210

Dear Mr. Ward:

This is in reply to your letter of September 14, l988, asking for a clarification of Federal requirements for the minimum lens area for turn signal lamps and stop lamps.

The understanding expressed in your letter is correct. The SAE materials for turn signal lamps and stop lamps for wide vehicles incorporated by reference in Table I apply to original equipment on vehicles currently being manufactured, and to equipment intended to replace such original equipment. These standards were expressly incorporated to supersede earlier versions of SAE standards for turn signal lamps and stop lamps. However, in recognition that original equipment lamps made to earlier SAE specifications might not be compatible with the electrical systems of vehicles designed to conform to later SAE specifications, the agency adopted paragraphs S4.l.l.6 and 4.l.l.7, allowing the continued manufacture for replacement purposes only, of turn signal lamps and stop lamps designed to conform to earlier specifications. Both sections incorporate in their text portions of the earlier SAE standards. Because the earlier specification for turn signal lamps, J588d, required an effective projected luminous area not less than 12 square inches for turn signal lamps on wide vehicles, this requirement is also specified in S4.1.1.7 for replacement lamps manufactured in conformance with J588d.

In short, your interpretation is correct with respect to turn signal lamps manufactured for installation on vehicles whose overall width is 80 inches or more. Single compartment turn signal lamps designed to conform to SAE J588e need meet only a minimum luminous lens area of 8 square inches. But if a turn signal lamp is manufactured to replace a turn signal lamp that was designed to conform to SAE J588d, its minimum luminous lens area is 12 square inches.

I hope this clarifies the matter for your customer.

Sincerely,

Erika Z. Jones Chief Counsel

/ref: 108 d:ll/3/88

ID: nht81-2.10

DATE: 03/25/81

FROM: FRANK BERNDT -- NHTSA CHIEF COUNSEL

TO: STEPHEN W. MATSON -- TRIAD SERVICES INC.

TITLE: NOA - 30

ATTACHMT: LETTER DATED 03/10/81 FROM STEPHEN W. MATSON TO NHTSA STD. 108

TEXT: Dear Mr. Matson:

This is in reply to your letter of March 10, 1981, asking whether the placement of a clear lens cover in front of a motorcycle headlamp would be permissible under Federal Motor Vehicle Safety Standard No. 108.

SAE Standard J580 (both a and b versions) Sealed Beam Headlamp Assembly is incorporated by reference in Tables I and III of the standard as one of the standards pertaining to headlamps lamps for use on passenger cars, trucks, buses, and multipurpose passenger vehicles. Paragraph 5.2 of J580 states that, "When in use, a headlamp shall not have any styling ornament or other feature, such as a glass cover or grill, in front of the lens."

The principal referenced SAE material for motorcycle headlamps is J584a Motorcycle Headlamps. As options, both J584 and S4.1.1.34 of Standard No. 108 allow, in effect, a motorcycle to be equipped with one half of any sealed beam system permissible on four-wheeled motor vehicles. We therefore view the prohibition of J580 as applicable to use of any sealed beam headlamp, regardless of the type of vehicle on which it is installed.

Paragraph S4.1.3 of Standard No. 108 forbids the installation of additional equipment "that impairs the effectiveness of lighting equipment required" by Standard No. 108. Because of moisture accumulation, discoloration, cracks, etc., a glass or plastic cover might tend over a period of time to diminish or distort the headlamp beam. This is of particular concern with reference to the unsealed headlamps implicitly permitted by SAE J584 because of the tendency of the reflector to deteriorate with age.

2

The agency therefore has concluded that no motorcycle headlamp may have a glass shield in front of it when in use.

Sincerely,

ID: nht68-2.4

DATE: 05/16/68

FROM: ROGER H. COMPTON -- NHTSA; SIGNATURE BY DAVID A. FAY

TO: White Trucks, Division of White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 20, 1968, to Mr. Lowell Z. Bridwell, requesting clarification of paragraph S3.4.3 of Federal Motor Vehicle Safety Standard No. 109.

In your referenced letter you have asked two questions as follows:

"1. While we provide as standard on all tractor models built on or after January 1, 1968, a 7-wire trailer connection and cable, is it satisfactory to furnish the 3-wire cable and connector being requested by many customer? Would we still be considered as conforming to Standard No. 103 with such a cable and contector?

2. Upon customer request, will we still be considered as conforming to the requirements of Standard No. 103 if, in addition to providing the standard double pole double throw switch which would actuate the brown circuit for the tail, clearance and certain marker lights on the trailer, we also furnish a separate switch for the black circuit on the trailer which would illeminate the remainder of the running lights, provided the trailer was wired in accordance with SAE Recommended Practice J560A."

In answer to question No. 1, either the 7-wire or 6-wire trailer connection and cable may be used on truck-tractors, provided the wiring is such that trailer tail lamps will be illuminated when the truck-tractor headlamps are illuminated. It is also to be noted that Standard No. 105 does not specify the number of wires to be used in the trailer connector and cable.

In answer to question No. 2, on trailers wired in accordance with SAE Recommended Practice J560a, a seperate switch for the black circuit on the trailer is permitted under the provisions of Standard No. 103. Again, the wiring and switching for the brown circuit must provide illumination of the tail lamps when the headlamps are illuminated.

The above answer also appear to be responsive to the questions raised in your letter of March 14, 1963.

Thank you for writing.

ID: 16452.wkm

Mr. Barry Livett
Assistant Director
Corporate Finance Department
Bank of China International (UK) Limited
One Canada Square
London E14 5AA

Dear Mr. Livett:

Please excuse the delay in responding to your letter to Mr. Arthur H. Neill, Jr. formerly of this Department, requesting a list of Chinese tire companies that have been granted certification by the U.S. Department of Transportation. Please be advised that Mr. Neill has retired.

You state that you work for the merchant banking arm of the Bank of China and are preparing information on the Chinese tire industry. In connection with this, you request from us a list of Chinese tire companies and/or names of Chinese tire brands that have been granted any form of U.S. certification.

The law of this country establishes a self-certification system in which manufacturers of motor vehicles and motor vehicle equipment, which includes tires, themselves certify that their products meet all applicable Federal motor vehicle safety standards. Thus, this agency does not certify, approve, disapprove, endorse, or assure compliance of any motor vehicle or item of motor vehicle equipment prior to its being introduced for sale in the retail market. Rather, this agency enforces compliance with the standards after the fact; that is, we purchase vehicles and equipment that are available to consumers in the retail market and test them for compliance. If they are found to comply, nothing further is done. If they are found not to comply, the manufacturer is responsible for correcting the problem(s), by repair or otherwise, at no expense to the customers.

We do, however, issue identification codes to each plant of each manufacturer that produces tires for sale in the United States. The purpose of such codes is that in the event of a tire recall, the codes will enable this agency to readily identify the plant in which the affected tires were produced. Therefore, enclosed in accordance with your request is a list of tire companies in China to which we have issued tire codes as of January 22, 1998.

I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at 011-202-366-2992, or by fax at 011-202-366-3820.

Sincerely,
John Womack
Acting Chief Counsel
Enclosure
ref:574
d.2/12/98

ID: nht70-2.29

DATE: 10/07/70

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

TO: Automobili Lamborghini

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 23 informing us of Lamborghini's continued progress towards compliance with Federal motor vehicle safety standards.

I want to remind you that Standard No. 211 precludes the use of wheel nuts, wheel discs, and hub caps that incorporate winged projections, such as the one shown in the(Illegible Word) photograph which I enclose. We have seen several(Illegible Word) manufactured in 1969 with wheels identical to this one, and were informed in one instance that the winged projections had been shipped from Italy with the car. Such a shipment violates the spirit, if not the letter, of Standard No. 211.

There is no charge for the "Program Plan for Motor Vehicle Safety Standards", enclosed at your request.

ID: nht92-8.4

DATE: April 3, 1992

FROM: Frank J. Sonzala -- Senior Vice President, International Transquip Industries, Inc.

TO: Phil Gramm -- United States Senate

COPYEE: J.F. Haasbeek -- President; Gerald Flowers -- Past President

TITLE: None

ATTACHMT: Attached to letter dated 5/20/92 from Frederick H. Grubbe to Phil Gramm (A39; Std. 121); Also attached to letter dated 6/1/92 from Paul J. Rice to Frank J. Sonzala (A39; Std. 121); Also attached to letter dated 4/3/92 from Frank J. Sonzala to Paul J. Rice (OCC 7172)

TEXT:

In May of 1990 our company's former President, Gerald Flowers, asked you to intercede with NHTSA's rule-making powers as it related to our product, and our Texas-based company's future existence. Your help in this matter, I am sure, certainly influenced NHTSA to rule favorably concerning our product and its advanced technology for the transportation industry.

Once again we appeal for your assistance with the NHTSA. The attached letter was sent to Paul Jackson Rice requesting an interpretation of a test procedure mandated by FMVSS 121 regulation. Because of the ambiguity of the test procedure parmeters, our company's growth has been stifled. Our request of your office is to call upon the Chief Counsel for NHTSA and express your concern that this matter be tended to promptly and positively.

I have enclosed a copy of our company's video for your review. I realize you are very busy with government affairs, but you may be interested in knowing how a Texas-based company is leading the transportation industry in air brake technology. A positive response from NHTSA will go a long way in aiding our company to grow, add more jobs and ultimately improve the safety of the air brake equipped heavy truck, trailer and bus industry in the United States.

We thank you for your effective pursuit of this matter on our behalf.

ID: nht73-3.24

DATE: 02/14/73

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

TO: Orin D. Miner

TITLE: FMVSS INTERPRETATION

TEXT: Contact 6 of Milwaukee, Wisconsin has sent us a copy of your letter asking that we respond to your questions.

In your letter you inquire as to the distribution of fines collected from tire manufacturers as a result of their manufacturing tires that do not comply with the requirements of the Federal standard for passenger car tires (Standard No. 109).

Monies collected as settlement offers are transmitted to the general funds of the United States Treasury.

The Federal Motor Vehicle Safety Standards, including the passenger car tire standard, are minimum standards vehicle manufacturers and equipment manufacturers are required to meet. They are issued to give assurance that if the product in question meets the standards the public will have some protection against unreasonable risk of death or injury.

In addition to the question of civil penalties, manufacturers of non-conforming vehicles or tires are usually required to issue a defect notification and are urged to replace the defective equipment. Your complaint does not appear to be concerned with a safety related problem but rather with tires that you believe have not given you adequate treadwear. This is not an area covered by existing standards, however, this agency has under consideration a quality grading regulation which would include grading requirements for the treadwear life of each tire manufactured after a given date.

Concerning your recommendation that Federal inspectors be placed in tire manufacturers' plants, this has been considered at various times and the agency's present thinking is that the cost and manpower involved would not warrant this course of action.

Thank you for your interest in auto safety and your views in this area.

ID: nht92-9.10

DATE: February 11, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: H. Ino -- Manager, Quality Assurance, Diamond Star Motors

TITLE: None

ATTACHMT: Attached to letter dated 11/26/91 from H. Ino to Paul Jackson Rice (OCC 6723)

TEXT:

I am writing in response to your letter requesting confirmation that Federal Motor Vehicle Safety Standard No. 115 Vehicle Identification Number - Basic Requirements (49 CFR S571.115) applies only to vehicles manufactured for sale in the United States. This letter confirms that Standard No. 115 and all the rest of our safety standards apply only to vehicles manufactured for sale in the United States.

Please note that in general section 108 (a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397 (a)(1)(A); the Safety Act) prohibits any person from manufacturing, offering for sale, or importing into the United States any motor vehicle manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect, unless the vehicle conforms with the standard. One such standard that is presently in effect is Standard No. 115. However, section 108(b) (3) of the Safety Act (15 U.S.C. 1397(b)(3)) provides that this prohibition of the manufacture and sale of vehicles in the United States that do not conform with all applicable safety standards does not apply to a vehicle that:

1) is intended solely for export; 2) is labeled or tagged to show that it is solely for export; and 3) is actually exported out of the United States.

Any vehicle that meets all three of these conditions need not comply with Standard No. 115 or any other of our safety standards.

I hope this information is helpful to you. If you have any further questions or need additional information, please feel free to contact Dorothy Nakama of my staff at (202) 366-2992.

ID: nht94-1.5

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/94 EST

FROM: Denise Davis

TO: Whom It May Concern

TITLE: NONE

ATTACHMT: Attached to letter dated 8/9/94 from John Womack to Denise Davis (Std. 205)

TEXT: To Whom it May Concern:

I was pulled over recently for the tinting in my car windows. I was told to have it checked and I would be issued a sticker for my window if the windows complied with the law.

I've been to the Window Tinting Store and was told they would not issue me a sticker because my windows were only allowing 20% sunlight through and the NEW law wants 35% sunlight through.

I'm therefore under the impression that I should have my tinting removed, which would be no problem if it were to be replaced by the proper tint at the same time as the removal took place. I was informed that I would have to cover this expense.

I paid approximately $ 450.00 to have my windows tinted seven years ago when I purchased my car. I don't have a problem with the Georgia Law. I am, however, unemployed and do not feel I should have to cover an expense for a law that came into being aft er my car was tinted unless the State of Georgia has funds set aside to replace the tinting in my car with the proper shade of tint.

If I had recently had my windows tinted in the wrong strength, I would gladly remove it because I would have been in error in the first place for having it done incorrectly and unlawfully. At the time my windows were tinted I was not breaking any law an d I don't feel I should be put to an additional expense to conform to a law put into effect at a later date.

Your help in this matter would be greatly appreciated.

ID: nht90-4.76

TYPE: Interpretation-NHTSA

DATE: December 6, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA; Signature by S.P.W.

TO: Erika Z. Jones -- Mayer, Brown, & Platt

TITLE: None

ATTACHMT: Attached to letter dated 9-18-90 to S.P. Wood from E.Z. Jones (OCC 5222)

TEXT:

This responds to your letter requesting a confirmation of your telephone conversation with Mr. Stephen Wood of my staff. In that conversation, he informally stated that the attached letter dated January 5, 1990 from Fidelity Tire Manufacturing company c ontained the information necessary to comply with the notification requirements in S5.1 of Federal Motor Vehicle Safety Standard 119 (49 CFR 571.119) for tires and rims not listed in the publication of a specified tire and rim association. This letter c onfirms that Fidelity's letter would satisfy the requirements of section S5.1.

Section S5.1 requires that a listing of the rims which may be used with each tire produced by a manufacturer be provided to the public. The purpose of this requirement is to ensure that the tire will be mounted only on appropriate rims and that the tire will be mounted on vehicles where its load-carrying capacity will be adequate. That section gives manufacturers the option of using the data provided for the tire size and corresponding rims published in certain standardization organization yearbooks o r listing the appropriate information "in a document furnished to dealers of the manufacturer's tires, to any person upon request, and in duplicate to (NHTSA)." Fidelity's letter which includes the appropriate dimensional and load-carrying data for the tire and rim appears to satisfy this requirement.

I hope this explanation is helpful. Please contact Mr. Marvin Shaw of my staff at (202) 366-2992 if you have any further questions.