ID: nht87-1.26

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/87

FROM: GLENN M. MAKI -- COUNTY OF BARAGA BOARD OF COUNTY ROAD COMMISSIONERS L'ANSE, MICHIGAN

TO: WHOM IT MAY CONCERN:

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER FROM STEPHEN P. WOOD -- NHTSA TO THOMAS C. GRAVENGOOD, DATED 5/16/89, REDBOOK A33; STANDARD 108; LETTER DATED 4/3/89 FROM THOMAS C. GRAVENGOOD OF AGAPE PLASTICS TO NHTSA CHIEF COUNSEL ON FEDERAL MOTOR VEHICLE STANDARD NO 108 -- HEATED SAFETY LIGHTS FOR VEHICLES DRIVEN IN WINTER WEATHER; LETTER FROM KENNETH R. HAMMERBERG, SUPERINTENDENT OF SCHOOLS TO TO WHOM IT MAY CONCERN, UNDATED; LETTER DATED 4/2/87 FROM PRINCIPAL ARVON TOWNSHIP SCHOOL TO TO WHOM IT MAY CONCERN; LETTER DAT ED 3/2/88 FROM RONALD R. MITCHELL SUPERINTENDANT, MORAN TOWNSHIP SCHOOLS TO VAN STRATEN HEATED TAIL LIGHT LENS CO; BROCHURE, UNDATED, OF VAN STRATEN COMPANY ON HEATED SAFETY LIGHT

TEXT: Throughout the years the road commissions have had a safety problem associated with their snow removal and ice control equipment. This same problem exists, to some degree, with all vehicles traveling the roads during the winter season. When the vehicles are plowing snow the problem is compounded due to the snow being caught-up in the wind turbulence caused by the vehicle and attached equipment.

The problem is -- snow and ice build-up on the warning, directional and flood lights at the rear of the vehicle. This obscures the lights, sometimes totally, making it difficult for any vehicles following behind to see the vehicle ahead or see the st op or turn signals when they are used.

This hazard could be reduced or eliminated if the lights could be kept free of snow and ice build-up. George VanStraten of Baraga, Michigan has developed a "Heated Lens" which has worked very well for us. We installed these "Heated Lenses" on two of our sander trucks and the lights have remained snow free and clear when the surrounding area was covered with a thick layer of snow. The tail-lights and directional lites remain clear and highly visible. We feel this improves safety significantly and should result in reducing rear-end collisions. We have also installed a "Heated Lens" on the rear flood-lite on our sander truck. This also stays snow-free and helps the operator see if the material is being discharged from the sander.

In my opinion the "Heated Lens" has a very broad potential application on all types of vehicles operating in the snow belt and in my opinion should be required by law on all trucks and other equipment traveling on the highways. Perhaps automobiles sho uld be included as well. The Baraga County Road Commission plans to install them first on all sander trucks and next on all snow plow trucks.

How many times have you heard the expression "I didn't see his signal". We feel in many cases the "Heated Lens" would prevent a serious accident. I would urge others to try these "Heated Lens" and let the results speak for themselves.

Sincerely yours,

ID: 18345pulse

Mr. John C. Stultz
Research Scientist
Transportation Research Center Inc.
East Liberty, OH 43319-0367

Dear Mr. Stultz:

This responds to your letter asking about the acceleration curve shown in Figure 2 of Federal Motor Vehicle Safety Standard No. 213, "Child Restraint Systems" (49 CFR 571.213). I apologize for the delay in responding. You explain that Transportation Research Center (TRC) is interested in conducting certification testing for manufacturers and possibly bidding on the National Highway Traffic Safety Administration (NHTSA) compliance programs for Standard 213. However, due to features of the TRC sled and others of its type generally, you see a problem with achieving the acceleration curve specified in the standard and suggest that the pulse can be slightly revised, by manipulating time zero, to accommodate your type of sled without having an appreciable affect on test results.

Paragraph S6.1.1(b)(1) of the standard specifies that when testing child restraints to the 48 kilometers per hour (30 miles per hour) dynamic test, the acceleration of the test platform shall be entirely within the curve shown in Figure 2 of the standard.⁽¹⁾ The curve shown in Figure 2 begins at zero g's and zero time.

You state that your type of acceleration sled is generally unable to produce the required acceleration curve. You state that your sled "fires" by cracking a seal between a high pressure chamber and a low pressure chamber, with the flow of gas (around a metering pin, which controls acceleration curve shapes) from high pressure to low pressure providing the acceleration force. You explain that initially, the area available for gas flow is small, and a short amount of time is required for pressure to build enough to cause significant acceleration. To illustrate, you enclose an acceleration curve obtained from your sled showing the time lag between initiation of the test and appreciable acceleration of the sled.

When the curve begins at zero g's and zero time, a significant portion of the curve is not within the tolerance band required by our test procedure. However, you state that when time zero has been manipulated so that the initial acceleration pulse falls within the zero to 10 millisecond envelope, and the acceleration at time zero is 1.25 g's, the required tolerance band is achieved.

You state that the velocity change during negative time is only 0.08 mph, which you believe is inconsequential to test results. You suggest that "TRC would like NHTSA to reconsider its pulse envelope requirements to allow a small deviance at time zero so that . . . sleds [similar to TRC's] may defendably participate in certification and compliance testing."

We have considered your request and agree that it is an issue which merits consideration. However, it is not possible to interpret Standard 213 to provide for a different means of defining time zero. Instead, your suggestion would have to be addressed through a rulemaking process to amend the standard.

In December 1998, NHTSA conducted a rulemaking to amend the sled test requirement in Standard 208, "Occupant Crash Protection," by, among other things, revising how time zero is defined (63 FR 71390, December 28, 1998). The sled test in that standard tests air bags. In that rulemaking, NHTSA determined that it is impractical for that test to have time zero at 0.0 g acceleration, because of the time lag between initial movement of the sled and significant acceleration. The agency decided that the start of the sled test will be determined by a specific acceleration level for the sled which corresponds to a time at which the most rapid acceleration begins, at about 0.5 g's (63 FR at 71393).

I have enclosed a copy of the December 1998 final rule for your review. We would be interested in your views on whether the issues discussed in that rule are similar to those you raise. To discuss possible rulemaking to follow up on your letter to us, please contact Michael Huntley of NHTSA's Office of Vehicle Crashworthiness Standards at (202) 366-0029.

If you have other questions, please contact Deirdre Fujita of my staff at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:213#208
d.5/4/99

1. Our laboratory test procedure (TP) for Standard 213 (TP-213-04, September 1, 1997), specifies a "tolerance band," or "acceleration function envelope," that incorporates the upper limit of Figure 2 and that also sets a lower limit (see section D.3.3, "Impact Severity" (page 53)).

ID: nht74-1.27

DATE: 03/14/74

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

TO: Ichikon Industries, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 25 to Mr. Charles A. Baker of this Office concerning the performance requirements of automotive lamp bulbs.

The answers to your specific questions follow.

"(1) At the present, have we need to comply the performance of bulbs with the requirements including the dimentional specification of SAE (Illegible Word) subreferenced in the current FMVSS 108 as well as lighting devices?"

The answer is no. The lamp bulbs installed in production lamps or lighting devices are not included in the requirements of FMVSS No. 108. The requirements apply only to the lamp assembly (the reflector, lens, and associated components other than the bulb) when tested with a selected lamp bulb that (Illegible Words) and the specifications of paragraphs S4.1.1.19 and S4.1.1.20 of Standard 108.

"(2) In the final rule, which of SAE J573d or J573e is applicable as the subreferenced standard of the bulbs?"

The proposal in Docket (Illegible Word) Notice 3 was in paragraph 57.6 which referenced the 1972 edition of the SAE Handbook. SAE (Illegible Word) was included in this Handbook, and is, therefore, the reference for test bulbs in the proposal.

"(3) Do you have a plan that such consideration will be taken into the rule making for proposed FMVSS 108A?"

No such consideration is necessary, because, as indicated above SAE J573d is only a specification for the test bulbs used for the photometric tests of the lamps.

We trust that these answers are satisfactory; however, please feel free to contact us in case of future questions.

Sincerely,

Not controlled

ICHIKOH INDUSTRIES, LTD.

February 25, 1974

Charles A. Baker -- Acting Chief Division of Lighting and Vision, National Highway Safety Bureau Department of Transportation

Dear Mr. Baker, Subject: Performance Requirements of Automotive Lamp Bulbs

As you awaire, SAE Standard J573, Lamp Bulbs and Sealed Units, was revised from J573d to J573e, and SAE Recommended Practice J1049, Service Performance Requirements and Test Procedure for Motor Vehicle Lamp Bulbs was newly issued on August, 1973 respectively.

These revision and new issue confuse us in respect the conformity to FMVSS 108 in production of the bulbs.

Then we would like to ask you the following questions regarding the interpretation of the current FMVSS 108 and the proposed FMVSS 108A.

(1) At the present, have we need to comply the performance of bulbs with the requirements including the dimentional specification of SAE J573d subreferenced in the current FMVSS 108 as well as lighting devices?

(2) On the otherhand, the final rule for proposed FMVSS 108A (Docket No. 69-19: Notice 3) is expected to issue in early 1974.

In the final rule, which of SAE J573d or J573e is applicable as the subreferenced standard of the bulbs?

(3) We think that SAE J573 was established in the nature of design standard and revised as the specification of bulbs for photometric test of lamps. We think further that SAE J1049 was issued as the survice use of bulbs.

Do you have a plan that such consideration will be taken into the rule making for proposed FMVSS 108A?

Your early reply would be highly appreciated.

Very truly yours,

Yoshio Horii, Manager -- Lighting Engineering Dept.

ID: nht68-1.44

DATE: 06/03/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Bert's Truck Equipment Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 18, 1968, in which you provided certification information, and presented extra axle modification problems.

Enclosed is a copy of the Federal Motor Vehicle Safety Standards with chassis-cab information from the Federal Register.

Your certification of compliance concerns compliance of the vehicle at the time of your installation or modification. It does not extend to subsequent additions or modifications by others.

With respect to an old truck body mounted on a chassis-cab which is manufactured on or after January 1, 1968, you are required to bring the lighting into compliance. (See Federal Standard 108 applicable for January 1, 1965.

With regard to lighting requirements for trucks, the corner lights, or side marker and clearance lamp requirements are also provided in the foregoing, enclosed standard.

Your letter is being referred to the engineers responsible for standards preparation, and the information is appreciated.

ID: nht78-2.24

DATE: 07/27/78

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: Niles Parts Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: We refer to your letter of March 15, 1978, concerning the testing of hazard warning and turn signal operating units (switches) in accordance with Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

The purpose of requiring 3-inch wire leads on any operating unit during testing is to permit the measurement of any voltage drop across a connector in the circuit. Since the connector is an integral part of your type of operating unit with its "terminal-direct" connection system, the wire leads are not necessary. We, therefore, interpret the society of Automotive Engineers Standards J589 and J910, covering Hazard Warning and Turn Signal Operating Units respectively, to require 3-inch wire test leads only on those units that are supplied with integral wire leads. During the prescribed tests, voltage measurements on units such as those that you provide shall be made at the electrical contacts on the units.

ID: nht75-6.11

DATE: 03/13/75

FROM: AUTHOR UNAVAILABLE; A.G. Detrick; NHTSA

TO: Norton Triumph Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in acknowledgment of your Defect Information Report, in accordance with the defect reporting regulations, Part 573.

The Defect Information Report involves: 1,471 Norton Commando 850cc motorcycles which may experience failure of a rear suspension unit.

The following National Highway Traffic Safety Administration identification number has been assigned to the campaign 75-0040. The first quarterly status report for this campaign is required to be submitted by May 5, 1975. Please refer to the above number in all future correspondence concerning this campaign.

The letter which you propose mailing to owners of the subject vehicles does not meet the requirements of the Motor Vehicle and Schoolbus Safety Amendments of 1974. The sections of this law dealing with defect notifications became effective December 26, 1974. Specifically, the statement made in the fourth paragraph, that at moderate speeds or in straight line operation "there is no safety problem", is a disclaimer and is prohibited by 49 CFR @ 577.6 (copy enclosed). The phrase "there is no safety problem" must therefore be deleted from the notification. A statement that the motorcycle continues to be rideable at moderate speeds or in straight line operation is permissible as long as this is accurate.

Since remedy without charge is contingent upon actual dates, your letter should further designate a specific date as the earliest date on which the defect will be remedied without charge, as required by section 153(a) (5). The letter must also include information responsive to section 153(a) (6). This can be done by informing owners that they may write to the Administrator, National Highway Traffic Safety Administration, Washington, D.C. 20590 if they are unable to obtain remedy without charge.

The notifications should be mailed by first class mail as specified by section 153(c) (1), and not by certified mail as you have indicated is your intention.

A copy of the 1974 amendment is enclosed. If you desire further information, please contact Messrs. W. J. Reinhart or James Murray of this office at (202) 426-2840.

ID: nht80-3.12

DATE: 06/25/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Kansas Department of Transportation

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your June 2, 1980, letter asking whether a school bus that is to be sold to a school district in your State will meet the Federal minimum requirements applicable to gross axle weight ratings (GAWR) and gross vehicle weight ratings (GVWR).

To the best of my knowledge, the Federal government has no minimum specifications for GAWR or GVWR. Certainly, this agency does not specify minimum weight ratings. Our only requirement is that the GAWR and GVWR be appropriate for the size and weight of a vehicle taking into consideration the type of equipment installed on it. From the information that you have provided us, we cannot say that the vehicle in question would or would not comply with that requirement. It is the responsibility of the vehicle manufacturer to certify that its vehicles comply with the Federal safety standards. No school bus manufacturer can sell you a school bus that they know will not comply with the requirements.

ID: nht94-3.41

TYPE: Interpretation-NHTSA

DATE: June 20, 1994

FROM: Irene M. Thomas (Aurora, CO)

TO: Dee Fujita, NHTSA

TITLE: CarMobile

ATTACHMT: Attached to letter dated 8/26/94 from John Womack to Irene M. Thomas (A42; Std. 213)

TEXT:

Thank you for your time and consideration during our phone call this morning about my "CarMobile". Enclosed please find a notarized sketch and description.

I would greatly appreciate an analysis in writing. Thank you!

The CarMobile is a device which is attached by velcro strips to the handrails located at the top of the interior rear car doors. It is made of grosgrain ribbon, with three round rings sewn on to it. Toys can be hung from the rings, so that babies and t oddlers can play with them as they dangle in front of their carseats. The children can reach the toys, but not the CarMobile itself.

The toys are not included with the CarMobile.

Inventor: Irene Thomas Dated: June 21, 1994Notarized

ID: 8085

Mr. Nilton Mello
Vitrotec - Vidros De Seguranca Ltda
Rua Jacofer, 350
CEP 02712
Sao Paulo, Brazil

Dear Mr. Mello:

This responds to your inquiry about the exportation of your laminated motor vehicle windshields into the United States. According to your letter, you have already designated an agent in this country and have received your DOT number. You asked whether you are required to perform tests at an American laboratory before you can export your product into the United States. I am pleased to have this opportunity to respond to your inquiry. I am also enclosing a copy of a fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."

By way of background information, section 103 of the National Traffic and Motor Vehicle Safety Act ("Safety Act," 15 U.S.C. 1392) authorizes NHTSA to issue safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA does not however approve or certify any vehicles or items of equipment. Instead, the Safety Act establishes a "self- certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

NHTSA tests vehicles and equipment sold to consumers for compliance with safety standards and investigates defects relating to motor vehicle safety. If a manufacturer or NHTSA determines that a noncompliance or safety-related defect exists, the manufacturer must notify purchasers of its product and remedy the problem free of charge. A manufacturer of noncomplying or defective products is also subject to civil penalties.

In response to your question about whether you are required to perform tests at an American laboratory, the answer is no. As indicated above, manufacturers of motor vehicles and motor vehicle equipment are required to certify that their products comply with all applicable safety standards. Manufacturers must have some basis for their certification. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations. You are not required to use the services of an American laboratory in conducting tests associated with certification.

I hope that you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

Enclosures

ref:205 d:2/17/93

ID: nht93-1.38

DATE: 02/17/93

FROM: JOHN WOMACK -- ACTING CHIEF COUNSEL, NHTSA

TO: NILTON MELLO -- VITROTEC - VIDROS DE SEGURANCA LTDA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11-26-92 FROM NILTON MELLO TO KATHLEEN DEMETER (OCC 8085)

TEXT: This responds to your inquiry about the exportation of your laminated motor vehicle windshields into the United States. According to your letter, you have already designated an agent in this country and have received your DOT number. You asked whether you are required to perform tests at an American laboratory before you can export your product into the United States. I am pleased to have this opportunity to respond to your inquiry. I am also enclosing a copy of a fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."

By way of background information, section 103 of the National Traffic and Motor Vehicle Safety Act ("Safety Act," 15 U.S.C. 1392) authorizes NHTSA to issue safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA does not however approve or certify any vehicles or items of equipment. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

NHTSA tests vehicles and equipment sold to consumers for compliance with safety standards and investigates defects relating to motor vehicle safety. If a manufacturer or NHTSA determines that a noncompliance or safety-related defect exists, the manufacturer must notify purchasers of its product and remedy the problem free of charge. A manufacturer of noncomplying or defective products is also subject to civil penalties.

In response to your question about whether you are required to perform tests at an American laboratory, the answer is no. As indicated above, manufacturers of motor vehicles and motor vehicle equipment are required to certify that their products comply with all applicable safety standard. Manufacturers must have some basis for their certification. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations. You are not required to use the services of an American laboratory in conducting tests associated with certification.

I hope that you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992.