ID: nht72-6.56

DATE: 02/09/72

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

TO: Scott's Trailer Market

TITLE: FMVSR INTERPRETATION

TEXT: In reply to your letter of January 28, 1972, we are enclosing a copy of Regulation Part 574 - Tire Identification and Record-keeping.

To answer your specific question whether the manufacturer is responsible for furnishing the tire serial numbers, as a matter of record, on the invoice of the vehicle, the regulation does not specify this requirement.

The Manufacturer is not required to retain a record of tire identification numbers for each vehicle prior to shipment of the vehicle. Normally, the dealer records these numbers at the time of sale along with the purchaser's name and address. The manufacturer provides the means to record this information and the dealer remits the information to him.

If the manufacturer chooses to retain a record of tire identification numbers for each vehicle prior to shipment, although he is not required to do so, he may request the dealer to send him only replacement numbers involved in a change, plus name and address of purchaser.

Please let us know if you need further clarification of the subject.

ID: nht72-6.57

DATE: 08/07/72

FROM: RICHARD B. BYSON -- NHTSA ASSISTANT CHIEF COUNSEL

TO: LOUIS C. LUNDSTROM -- DIRECTOR GM ASE

TITLE: NONE

TEXT: Dear Mr. Lundstrom:

This is in reply to your letter of July 17, 1972, concerning the application of Motor Vehicle Safety Standard No. 302. Flammability of Interior Materials, n1 to radio speaker cones. You request clarification of an interpretation we sent to American Motors dated June 9, 1972, wherein we stated that "stereo speaker . . . cones incorporated into a door or rear shelf would be considered part of a 'trim panel' and 'compartment shelf,' respectively. You particularly request clarification of the phrase "incorporated into.

The NHTSA's position is that a speaker cone, while not generally subject to Standard No. 302 (we assume that it is not an "energy-absorbing" component), will be subject to the standard if it is "incorporated into" a component that is subject to the standard. We would consider a speaker cone to be "incorporated into" a trim panel or compartment shelf if the cone forms a portion of the surface of the panel or shelf. We would not consider a speaker cone merely attached to an enumerated component, but situated wholly underneath (shelf) or behind (trim panel) its surface to be subject to the standard.

I trust this clarifies our position.

Yours truly,

ID: nht72-6.58

DATE: 01/26/72

FROM: RICHARD B. DYSON -- ASSISTANT CHIEF COUNSEL NHTSA

TO: E. R. STERNBERG -- DIRECTOR ENGINEERING PLANNING - TRUCK GROUP WHITE MOTOR CORPORATION

COPYEE: DYSON; VINSON

TITLE: 40-30

ATTACHMT: LETTER DATED 1/3/72 FROM E. R. STERNBERG -- ENGINEERING PLANNING TRUCK GROUP WHITE MOTOR CORPORATION TO DOCKET ROOM NHTSA

TEXT: Dear Mr. Sternberg:

This is in reply to your letter of January 3, 1972, requesting an interpretation of S4.2.2 of Standard No. 101, as it applies to your proposed method of compliance for push-pull controls.

S4.2.2 requires, in pertinent part, that "Identification shall be provided for each function of any . . . heating and air conditioning system control, and for the extreme positions of any such control that regulates a function over a quantitative range." Identification such as that shown in your Example (2) would meet Standard No. 101, while the identification provided in Example (3) would not. Legends such as "Pull on" and "Push off" might more clearly indicate control positions than your suggested "Max (out)" and "Off (in)." The control which operates both the defroster and heater must identify both functions; "Defrost" as indicated is insufficient. Legends such as "Pull to defrost" and "Push for heat" would be acceptable for conformance.

Sincerely,

ID: nht72-6.59

DATE: 05/05/72 EST

FROM: RICHARD B. DYSON -- NHTSA ASSISTANT CHIEF COUNSEL

TO: W. G. MILBY -- PROJECT ENGINEER BLUE BIRD BODY COMPANY

TITLE: 40-30

TEXT: Dear Mr. Milby:

This is in reply to your letter of April 19 to Mr. Schneider asking for interpretations of the motor vehicle controls safety standard, Standard No. 101.

You have asked that we reconsider our earlier opinion that your heater gate valve is a "heating and air conditioning system control" for purposes of Standard No. 101. We see no reason to modify our earlier view. A control, as you have described it, that allows hot engine water to flow through the heater cores is clearly a heating system control, requiring identification as such. Table I of Standard No. 101 allows you the option of choosing your own form of identification. Perhaps a legend such as "Water Control" and a designation of "Winter" and "Summer" positions would clarify your intent that the valve not be used as a temperature control device. However, pursuant to paragraph S4.3 this control need not be illuminated, if, as appears likely, it does not direct air directly upon the windshield.

You have also asked if the cable-operated fresh air door whose function is to control the air that passes through the heater cores is also a "heating and air conditioning control." It appears that this control serves a function similar to that of the heater valve, and that identification is also required, with words or abbreviation at the manufacturer's option.

Finally, you ask if the defroster identification may be preceded by "RH" and "LH" to identify the right hand and left hand defroster systems respectively. The answer is yes; we have no objection to this form of identification.

Yours truly,

ID: nht72-6.6

DATE: 11/07/72

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Urban Economics Research Group

TITLE: FMVSR INTERPRETATION

TEXT: This is in further reply to your letter of August 31, 1972, to Mr. Bradford Crittenden, Regional Administrator, NHTSA, San Francisco, California, that has been referred to this office.

It appears from your letter that persons will not be able to ride in the device you plan to manufacture while the vehicle is in motion. If this is the case, the device would not be subject to the Federal Motor Vehicle Safety Standards at this time.

If this is not the case, however, we will need more information, including pictures or drawings, if possible, in order for us to accurately determine whether federal requirements are applicable.

A manufacturer of such a device would be considered a manufacturer of automotive equipment within the meaning of the National Traffic and Motor Vehicle Safety Act, copy enclosed. The device and mountings would be expected to be free of safety related defects.

If you have further questions, we will be pleased to answer them.

ID: nht72-6.60

DATE: 11/17/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Plaskolite, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 1, 1971, to Mr. Douglas W. Toms, Acting Administrator, National Highway Traffic Safety Administration, concerning an interpretation relative to the determination of(Illegible Word) of lamps.

Both of your interpretations are correct. The location of lamps and reflective devices is determined with the vehicle at its curb weight, which is the weight of a motor vehicle with standard equipment; maximum capacity of engine, fuel, oil, and coolant; and, if so equipped, air conditioning and additional weight optional engine.

The overall width is determined with "doors and windows closed" per the interpretation of 32 F.R. 8088, June 21, 1967.

The visibility requirements for lamps and reflective devices will therefore be determined with trunk lids, tail gates, hoods, and rear gates in the normal driving, or closed, position.

ID: nht72-6.61

DATE: DECEMBER 28, 1972

FROM: TATSUO KATO -- ENGINEERING REP, NISSAN MOTOR CO., LTD.

TO: LAWRENCE SCHNEIDER -- NHTSA

COPYEE: J. W. CARSON

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED FEBRUARY 16, 1973 FROM E.T. DRIVER, NHTSA, TO TATSUO KATO, NISSAN MOTOR CO.

TEXT: This is to request the answer to the following questions regarding MVSS 124 which we explained at a meeting held in the Office of NHTSA, on Friday, December 8, 1972.

1. We are using a two-barrel, down draft type carburetor with a linkage as shown in the attached schematic drawing (see Figure 1). We have designed the accelerator control system that has at least two sources of energy capable of returning the throttle to the idle position, that is, whenever the driver removes the opposing actuating force, the primary valve of the carburetor is closed by sources of energy of spring A and B and the secondary valve is done by spring A, B and C. Although in the event of failure of the spring C, the secondary valve is usually returned to the initial closed position by the lever L which is actuated by the torsion spring A and B as explained at the meeting, there is a possibility of slightly opening the secondary valve because of endplay by the tolerance of the production so that engine speed might slightly increase more than engine idle speed specified in our manuals.

Under the aforementioned situation, may be understand that the increase of engine idle speed resulting from the endplay caused by failure of the spring C will not be included in the scope of "Overspeed" which is stated in S2 of MVSS 124, that is, in the case of malfunctions, tolerance to the idle speed will be accepted by NHTSA.

If the tolerance is accepted, we would like to know the acceptable range (if possible, by rpm = revolution per minute of engine) of the increase of engine idle speed.

2. It is difficult to decide the components of accelerator control system which we have to consider a severence or disconnection which is specified in MVSS 124, S5.2, "The throttle shall return to the idle position from any accelerator position or any speed of which the engine is capable whenever any one component of the accelerator control system becomes disconnected or severed!'

Under the abovementioned situation, in case of our model PL610, we do not consider breakage of parts such as mounting brackets or mounting bolts as a portion of severence or disconnection, but we do only the portion with the mark X in the attached drawing. (see Figure 2). May we understand the definition of the portion of severence or disconnection as mentioned above?

Your prompt reply would be greatly appreciated.

Attachments

CONDITION OF FULL THROTTLE

In case of breakage of Spring "C" secondary valve is returned - by Linkage L.

Condition of Secondary Valve with possibility of opening.

(Graphics omitted)

FIGURE 2 SIDE VIEW

Graphics omitted)

FIGURE 2 FRONT VIEW

Graphics omitted)

ID: nht72-6.62

DATE: 01/26/72

FROM: RICHARD B. DYSON -- ASSISTANT CHIEF COUNSEL NHTSA

TO: K. NAKAJIMA -- TOYOTA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 05/31/90 FROM STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL TO VIRVE AIROLA; LETTER AND BROCHURE DATED 04/14/89 FROM VIRVE AIROLA OF OY TUPPI AB TO NHTSA CONCERNING ITS FINLAND COMPANY'S RANGE OF PLASTIC TUBES AND HOSES PARTICULAR ITS AIR BRAKE TUBING

TEXT: This letter is in response to your request for interpretations of Section 110(e) of the Act and 49 CFR Part 566, manufacturer Identification as they affect foreign manufacturers of motor vehicle equipment.

You state that it is your understanding that under these provisions:

If a foreign covered equipment manufacturer supplies his products, including original and (Illegible Word) equipment, to a vehicle manufacturer outside the United States, and if this equipment manufacturer is not engaged in business in the United States in this regard:

(1) he is not necessarily required to establish his agent under the job;

(2) he is required to furnish the manufacturer identification information to NHTSA separately from the vehicle manufacturer to which he supplies his products.

Your interpretations of both provisions are correct. Section 110(c) requires that all manufacturers of motor vehicles or motor vehicle equipment, whether "covered" or not, which is offered for importation into the United States, designate an agent in the United States. However, if an equipment manufacturer produces equipment which is supplied only to foreign vehicle manufacturers, he will not be offering that equipment for importation into the United States, and he therefore need not designate an agent under the Act.

Part 566 requires that a manufacturer of "covered equipment" must submit the required information to NHTSA separately from the manufacturer to whom he supplies his products. As you suggest, this is true regardless of whether the equipment manufacturer is engaged in business in the United States, as long as the foreign vehicle manufacturer to whom the equipment manufacturer supplies his products is selling those products in the United States.

Please write if we can be of further assistance.

ID: nht72-6.7

DATE: 09/19/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Gorou Utsunomiya

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 8, 1972, enclosing sketches of motor vehicles and asking into which vehicle category under the motor vehicle safety standards they fall. The numbered paragraphs below correspond to those in your letter.

1. Figures 1, 2, and 3 illustrate trailers under the standards. Trailers are presently subject only to Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices, and Associated Equipment." Trailers equipped with air brakes and manufactured after September 1, 1974, will be required to conform to Standard No. 121, "Air Brake Systems." It is unlikely that many camping or recreational trailers will be subject to these requirements.

2. Figure 4 illustrates two pickup trucks equipped with slide-in campers. Pickup trucks must conform to all standards applicable to trucks. The campers must conform, as you state, to Motor Vehicle Safety Standard No. 205, "Glazing Materials." Both pickup trucks and slide-in campers will be required to conform to a new Standard No. 126, "Truck-Camper Loading," when that standard becomes effective. A copy of the standard is enclosed.

3. In referring to the illustrations of the pickup trucks equipped with slide-in campers, you ask whether the requirements applicable to the trucks when combined with a camper are different from those applicable when the truck is not so equipped. The answer is no. The standards applicable to pickup trucks (those that are applicable to "trucks") are the same whether or not the pickup is equipped with a camper.

4. The requirements for pickup trucks and slide-in campers do not differ if both components are manufactured by the same company.

5. Wagon campers and motor homes are considered to be multipurpose passenger vehicles when constructed on truck chassis. The illustrations you enclose appear to us to represent vehicles manufactured on truck chassis.

ID: nht72-6.8

DATE: 02/08/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Lathrop; Koontz; Righter; Clagett; Parker & Norquist

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 25, 1972, concerning the confidentiality of information on manufacturers' quarterly production figures that is submitted pursuant to section 573.5(b) of the Defect Reports regulations (49 CFR Part 573).

Manufacturers' quarterly production figures submitted pursuant to section 573.5(b) will be kept confidential if the manufacturer so requests. This will be true except in those cases where the NHTSA determines that disclosure is necessary to carry out the purposes of the National Traffic and Motor Vehicle Safety Act.

In the event it is decided to make public such information the NHTSA will, before release of the information, notify the manufacturer in question.