ID: nht88-3.81

TYPE: INTERPRETATION-NHTSA

DATE: 11/01/88 EST

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

TO: DAVE ANDERSON -- SALES MANAGER, GIST ORNAMENTAL IRON WORKS

ATTACHMT: NOT INCLUDED

TEXT: This responds to your letter about Federal requirements for trailers. According to your letter, you are in the planning stages of becoming a manufacturer of, and dealer for, automobile trailers. The trailers would hitch to the back of automobiles and b e designed to carry cargo. You noted that in response to an earlier inquiry, you received a copy of the handout entitled "Information For New Manufacturers of Motor Vehicles and Motor Vehicle Equipment." You stated that you are unclear just how this app lies to automobile trailers. You asked what you need to do to comply with any applicable Federal regulations, and what regulations apply to trailers of the kind you plan to build.

Trailers are considered motor vehicles under federal law. As a manufacturer of motor vehicles, you would be required to submit identification information to the National Highway Traffic Safety Administration (NHTSA) under 49 CFR Part 566, Manufacturer I dentification. You would also be required to certify that each trailer complies with all applicable Federal safety standards. The procedure is specified in 49 CFR Part 567.

The following safety standards apply to trailers: Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, Safety Standard No. 115, Vehicle Identification Number -- Basis Requirements, Safety Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. The content requirements for the vehicle identification number are found at 49 CFR Part 565. In addition, trailers with certain braking systems must meet Safety Standard No. 106

Brake Hoses, Safety Standard No. 116, Motor Vehicle Brake Fluids, and Safety Standard No. 121, Air Brake Systems. All of these safety standards are found in 49 CFR Part 571.

I hope this information is helpful.

ENCLOSURE

ID: nht93-7.15

DATE: October 7, 1993

FROM: Milford R. Bennett -- Head, Safety Affairs and Operations, NAO Engineering Safety Center, GM

TO: H. M. Smolkin -- Acting Administrator, NHTSA

COPYEE: John Womack -- Acting Chief Counsel; Barry Felrice -- Associate Administrator for Rulemaking; Taylor Vinson -- Office of Chief Counsel

TITLE: USG 3024, Part IV; Re: Part 555 Temporary Exemption from Motor Vehicle Safety Standards - Docket No. 93-39; Notice 2

ATTACHMT: Attached to letter dated 10/22/93 from John Womack to Milford R. Bennett (A41; Part 555)

TEXT:

The above referenced docket, as published in the Federal Register, Volume 58, Number 177, page 48421 on September 15, 1993, granted the petition of General Motors Corporation (GM) to allow a temporary exemption from several Federal Motor Vehicle Safety Standards (FMVSS) for a fleet of 50 GM Electric Vehicles (GMEV).

In accordance with Part 555.9(a), and as requested by Mr. John Womack, Acting Chief Counsel of the NHTSA, in his letter dated September 9, 1993, GM is submitting a sample of the certification label that will be affixed to the left front door of each GMEV. This label conforms with the requirements found in Part 567 and Part 555.9(c)(1), including revisions to Part 555.9(c)(1) proposed by the NHTSA (Docket 93-40, Notice 1).

Part 555.9(b) requires that a windshield or side window label containing the statement required by Part 555.9(c)(1) or (2) be affixed securely to each exempted vehicle. After a study of this label requirement, including discussion with Mr. T. Vinson, NHTSA Office of Chief Counsel, GM has concluded that this label is intended to notify prospective buyers that the vehicle has been exempted from certain FMVSS. GM therefore believes that the requirement of Part 555.9(b) to affix a window label to each GMEV is not applicable because GM does not intend to sell the exempted GMEVs. However, if the agency believes that this interpretation is incorrect, please notify us.

If you have any questions regarding these labels, please contact either Mr. R. F. Humphrey of our Washington, D.C. office at (202) 775-5071 or Mr. G. A. Zuchniewicz in Warren, MI at (313) 947-1726.

Attachment (sample of certification label) omitted.

ID: nht90-2.65

TYPE: INTERPRETATION-NHTSA

DATE: 05/31/90

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

TO: SUICHI WATANABE -- GENERAL MANAGER AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPARTMENT STANLEY ELECTRIC CO., LTD.

TITLE: NONE

ATTACHMT: LETTER DATED 03/19/90 FROM SHUICHI WATANABE TO ERIKA Z. JONES -- NHTSA; OCC 4549

TEXT: This is in reply to your letter of March 19, 1990, asking whether a new combination rear lamp is permitted under Motor Vehicle Safety Standard No. 108.

The lamp consists of three compartments. In its normal operating mode, when the taillamp and/or stop lamp are activated, all three compartments show a red light. Your question arises with respect to three different operating modes. The first occurs whe n the turn signal is activated; the red light in one of the compartments is replaced by an amber flashing one. The second occurs when the backup lamp is activated; the red light in another of the compartments is replaced by a white steady-burning one. The third occurs when both the backup lamp and turn signal are activated; in this event, the combination lamp would present an amber flashing light, a red steady-burning one, and a white steady-burning one. You have informed us that "the requirement of photometric and lighted area for each lamp function comply to FMVSS No. 108 and related comply with requirements for one and three compartment lamps when operating with one or three compartments (we assume that they would also meet the requirements for t wo compartment lamps).

The lamp appears to be intended to fulfill the requirements of Standard No. 108 for turn signal, stop, tail, and backup lamps. Thus, your question appears to be whether Standard No. 108 requires separate lamps or compartments dedicated to a specific pur pose, or whether your multiple purpose lamp is acceptable.

Standard No. 108 does not prohibit a combination of the functions that any chamber of your lamp provides. When a specific function is activated, the lamp will perform that particular function in a manner that appears to meet the minimum standard establi shed by Standard No. 108. Assuming that the CIE color definitions for white, amber, and red are met by the backup, turn, and stop/tail functions, the lamp appears to be permissible under Standard No. 108.

Sincerely,

ID: 21249.rbm

Mr. Thomas W. Blasingame
T.W. Blasingame Company, Inc.
P.O. Box 1532
Boise, ID 83701






Dear Mr. Blasingame:

This letter responds to your request that the National Highway Traffic Safety Administration (NHTSA) authorize you to certify a vehicle as a "modular truck/tractor chassis". I apologize for the delay in NHTSA's response.

Your letter requesting a legal interpretation included a service manual for which you subsequently requested confidential treatment. Your request for confidential treatment was granted on August 29, 2000.

You indicate in your letter that your company wants to market a new vehicle that can operate either as a truck or as a truck tractor. NHTSA does not have a vehicle classification for this type of hybrid vehicle. Rather, our regulations provide for a "truck", which is defined as a motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special purpose equipment, and "truck tractor", which is a truck designed primarily for drawing other motor vehicles and not so constructed as to carry a load other than a part of the weight of the vehicle and the load so drawn (49 CFR 571.3).

While we do not specifically address hybrid vehicles such as yours in our regulations, nothing in the regulations would prohibit a manufacturer from certifying a particular vehicle as complying with all applicable safety standards for separate vehicle types. Thus, we would not object to your classifying your vehicles as "truck/truck tractors". Please note, however, that such a characterization would require your company to certify compliance with all Federal motor vehicle safety standards (FMVSS) that are applicable to both vehicle types. As a practical matter, only FMVSS No. 108 and FMVSS No. 121 currently have requirements for truck tractors that are in addition to or different from the requirements for trucks.

I hope this information is helpful. If you have any further questions, please contact Rebecca MacPherson of my staff at (202) 366-2992.





Sincerely,
Frank Seales, Jr.
Chief Counsel

ref:567
d.11/6/00

ID: 3146o

Mr. Dave Anderson
Sales Manager
Gist Ornamental Iron Works, Inc.
l2l27 Woodside Avenue
Lakeside, CA 92040

Dear Mr. Anderson:

This responds to your letter about Federal requirements for trailers. According to your letter, you are in the planning stages of becoming a manufacturer of, and dealer for, automobile trailers. The trailers would hitch to the back of automobiles and be designed to carry cargo. You noted that in response to an earlier inquiry, you received a copy of the handout entitled "Information For New Manufacturers of Motor Vehicles and Motor Vehicle Equipment." You stated that you are unclear just how this applies to automobile trailers. You asked what you need to do to comply with any applicable Federal regulations, and what regulations apply to trailers of the kind you plan to build.

Trailers are considered motor vehicles under Federal law. As a manufacturer of motor vehicles, you would be required to submit identification information to the National Highway Traffic Safety Administration (NHTSA) under 49 CFR Part 566, Manufacturer Identification. You would also be required to certify that each trailer complies with all applicable Federal safety standards. The procedure is specified in 49 CFR Part 567.

The following safety standards apply to trailers: Safety Standard No. l08, Lamps, Reflective Devices, and Associated Equipment, Safety Standard No. ll5, Vehicle Identification Number--Basic Requirements, Safety Standard No. ll9, New Pneumatic Tires for Vehicles Other Than Passenger Cars, Safety Standard No. l20, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. The content requirements for the vehicle identification number are found at 49 CFR Part 565. In addition, trailers with certain braking systems must meet Safety Standard No. l06, Brake Hoses, Safety Standard No. ll6, Motor Vehicle Brake Fluids, and Safety Standard No. l2l, Air Brake Systems. All of these safety standards are found in 49 CFR Part 57l.

I hope this information is helpful.

Sincerely,

Erika Z. Jones Chief Counsel

ref: 571 d:ll/l/88

ID: 2505y

Mr. Suichi Watanabe
General Manager
Automotive Lighting
Engineering Control Department
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153, Japan

Dear Mr. Watanabe:

This is in reply to your letter of March 19, 1990, asking whether a new combination rear lamp is permitted under Motor Vehicle Safety Standard No. l08.

The lamp consists of three compartments. In its normal operating mode, when the taillamp and/or stop lamp are activated, all three compartments show a red light. Your question arises with respect to three different operating modes. The first occurs when the turn signal is activated; the red light in one of the compartments is replaced by an amber flashing one. The second occurs when the backup lamp is activated; the red light in another of the compartments is replaced by a white steady-burning one. The third occurs when both the backup lamp and turn signal are activated; in this event, the combination lamp would present an amber flashing light, a red steady-burning one, and a white steady-burning one. You have informed us that "the requirement of photometric and lighted area for each lamp function comply to FMVSS No. l08 and related SAE Standards." Further, as for the stop and taillamp functions, they comply with requirements for one and three compartment lamps when operating with one or three compartments (we assume that they would also meet the requirements for two compartment lamps).

The lamp appears to be intended to fulfill the requirements of Standard No. l08 for turn signal, stop, tail, and backup lamps. Thus, your question appears to be whether Standard No. l08 requires separate lamps or compartments dedicated to a specific purpose, or whether your multiple purpose lamp is acceptable.

Standard No. l08 does not prohibit a combination of the functions that any chamber of your lamp provides. When a specific function is activated, the lamp will perform that particular function in a manner that appears to meet the minimum standard established by Standard No. l08. Assuming that the CIE color definitions for white, amber, and red are met by the backup, turn, and stop/tail functions, the lamp appears to be permissible under Standard No. l08.

Sincerely,

Stephen P. Wood Acting Chief Counsel

ref:l08 d: 5/3l/90

ID: 2506y

Mr. Suichi Watanabe
General Manager
Automotive Lighting
Engineering Control Department
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153, Japan

Dear Mr. Watanabe:

This is in reply to your letter of March 19, 1990, asking whether a new combination rear lamp is permitted under Motor Vehicle Safety Standard No. l08.

The lamp consists of three compartments. In its normal operating mode, when the taillamp and/or stop lamp are activated, all three compartments show a red light. Your question arises with respect to three different operating modes. The first occurs when the turn signal is activated; the red light in one of the compartments is replaced by an amber flashing one. The second occurs when the backup lamp is activated; the red light in another of the compartments is replaced by a white steady-burning one. The third occurs when both the backup lamp and turn signal are activated; in this event, the combination lamp would present an amber flashing light, a red steady-burning one, and a white steady-burning one. You have informed us that "the requirement of photometric and lighted area for each lamp function comply to FMVSS No. l08 and related SAE Standards." Further, as for the stop and taillamp functions, they comply with requirements for one and three compartment lamps when operating with one or three compartments (we assume that they would also meet the requirements for two compartment lamps).

The lamp appears to be intended to fulfill the requirements of Standard No. l08 for turn signal, stop, tail, and backup lamps. Thus, your question appears to be whether Standard No. l08 requires separate lamps or compartments dedicated to a specific purpose, or whether your multiple purpose lamp is acceptable.

Standard No. l08 does not prohibit a combination of the functions that any chamber of your lamp provides. When a specific function is activated, the lamp will perform that particular function in a manner that appears to meet the minimum standard established by Standard No. l08. Assuming that the CIE color definitions for white, amber, and red are met by the backup, turn, and stop/tail functions, the lamp appears to be permissible under Standard No. l08.

Sincerely,

Stephen P. Wood Acting Chief Counsel

ref:l08 d: 5/3l/90

ID: nht88-1.6

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/88 EST

FROM: JOSEPH P. FAIA

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/19/88 TO JOSEPH P. FAIA FROM ERIKA Z. JONES

TEXT: This letter is in reference to a vehicle lighting accessory for trucks. But its use is not limited to trucks.

On June 3, 1988 I met with Susan Schruth and Richard Van Iderstine, they advised me on questions of legality and design.

The description below is from my patent application.

ABSTRACT

A system for illuminating two-dimensional displays on the sides of vehicle trailers includes a plurality of reflector light assemblies disposed about the perimeter of a side of a trailer. Each light assembly includes a base which is affixed to the si de of the trailer and carries a light source. A housing formed of both a transparent section and semi-translucent sections is joined to the base and encloses the light source. The transparent housing section faces generally tward the center of the trai ler side surface. A concave reflector in the housing together with lens portions in the transparent housing section act to focus light across the trailer side surface to illuminate the two-dimensional display thereon. A lesser quantity of light passes through the semi-translucent section which are tinted and arranged to function as the running lights commonly seen on trailers.

I have also sent the drawings attached to further help explain.

My questions about the use of this light are:

-- Can this light be used as described, as a combonation side illumination and marker light.

-- As a back-up light and parking light, to be used only in these situations.

-- As a stop light, To come on only when brake is applied.

-- As a light to illuminate the side of trailer only. not in combibnation with marker light.

[DRAWING IMITTED])

(DRAWING OMITTED)

ID: nht94-3.7

TYPE: INTERPRETATION-NHTSA

DATE: May 25, 1994

FROM: George W. Sudenga, Johnson, Sudenga, Latham & Peglow

TO: Marvin Shaw -- Attorney at Law, NHTSA

TITLE: Neil Rowe

ATTACHMT: Attached to letter dated 7/1/94 from John Womack to George W. Sudenga (A42; STD. 106) and letter dated 5/18/94 from John Womack to Neil Rowe.

TEXT: I represent Neil Rowe who has corresponded with you historically concerning his "Glad Grip". I visited with you via telephone communication on May 12, 1994 and am happy to report that a response has come from the NHTSA, Mr. John Womack.

By way of reference I am enclosing a reproduced copy of the letter to Neil dated May 18, 1994.

The contents of the letter, unfortunately, are vague to both myself and Mr. Rowe. We would like to market the Glad Grip, both as an improvement to the present system of hooking up airlines, and ultimately for use in new equipment. We would like appro val of NHTSA in advance of major marketing efforts. If possible, I would like to impose on you and the engineering offices and receive suggestions as to additional testing that might be provided with positive results that when forwarded to NHTSA would r esult in advance approval. Please help.

Enclosure

ID: 7018

Herrn. Westermann u. Schmidt
Hella KG Hueck & Co.
Rixbecker Strae 75
Postfach 2840
4780 Lippstadt
Germany

Gentlemen:

This responds to your FAX of December 9, 1991, to Richard Van Iderstine of this agency. You ask for a definition of two and four headlamp systems, stating that formerly "this definition was done under para. S4.1.1.36, but today there only remains figure 26, which explains the application of photometric requirements with respect to the bulb or bulb combination used." You have enclosed sketches of three replaceable bulb headlighting systems and ask for confirmation that each is a two or four headlamp system under Standard No. 108.

Standard No. 108 has never contained a specific definition of two or four lamp headlamp systems. Paragraph S4.1.1.36 impliedly defined these systems for headlamps incorporating replaceable bulbs by specifying requirements for the upper and lower beams of headlamp systems consisting of two or four lamps, each containing one or two standardized replaceable light sources. When Standard No. 108 was amended to delete S4.1.1.36, these provisions became part of new paragraph S7.5 Replaceable Bulb Headlamp System. Figure 26 Table of Photometric Requirements was added to illustrate photometric requirements for headlighting systems that use combinations of replaceable bulbs listed in S7.6 Standardized Replaceable Light Sources, and as the systems are described in S7.5.

The understanding expressed in your drawings of replaceable bulb headlamp systems is correct. A 4-lamp system is one in which each lamp contains one light source, usually HB3 or HB4 light source for a total of two HB3 and HB4 light sources per system. A 2-lamp system is one in which each lamp typically contains a single dual filament light source such as HB1 or HB5, and achieves both a lower beam and an upper beam; alternatively, each lamp may contain two light sources, typically one HB3 and one HB4 light source, each with individual reflectors, but together with a common housing and lens. This lamp achieves both a lower and an upper beam.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:108 d:3/5/92