ID: nht92-6.24

DATE: May 29, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Herr Spingler -- Robert Bosch GmbH

TITLE: None

ATTACHMT: Attached to letter dated 4/3/92 from Herr Spingler to Richard van Iderstine (OCC 7289)

TEXT:

This responds to your letter of April 3, 1992, to Mr. Van Iderstine of this agency asking for a "quick answer" to your question regarding the acceptability of a new headlamp design. Please be advised that my Office is the one to which questions of interpretation of Motor Vehicle Safety Standard No. 108 should be addressed, and that correspondence addressed to the Chief Counsel allows us to respond more quickly to the concerns of the writer.

We understand that you discussed the headlamp with Mr. Van Iderstine on his recent trip to Europe, and that it will be used in a replaceable bulb headlighting system that is governed by S7.5 of Standard No. 108. Your proposed headlamp incorporates a lower beam provided by an ellipsoid and an upper beam provided by a parabola. The drawing you enclosed shows the lower beam source above the upper beam source. When the upper beam is on, both bulbs will be activated simultaneously.

Where, as in your design, each headlamp contains two light sources, S7.5(d)(2) (i)(A) and S7.5(e)(2)(i)(A) specify that the lower beam shall be provided by the outboard or uppermost light source. S7.5(d)(2)(ii)(A) and (B) and S7.5(e) (2)(ii)(A) and (B) specify that the upper beam shall be produced by the lowermost, or both, light sources. The beams in your headlamp are provided in this manner, and, therefore, are in accordance with the requirements of Standard No. 108.

ID: nht81-3.39

DATE: 11/12/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Letts Industries Inc.

TEXT: This is in response to your letter of October 15, 1981, requesting a "testing exemption" to import a 1976 BMW 3.0 CSi to study the wear characteristics of steering linkage components.

It is our understanding that the 1976 BMW 3.0 Si incorporates steering linkage components substantially similar to those used in the 3.0 CSi. As BMW sold the 1976 3.0 Si in the United States, examples should appear from time to time in the used car market. Accordingly, your request is denied.

You may, of course, import the 3.0 CSi, under bond, and bring it into conformity with all applicable Federal motor vehicle safety standards if you wish.

SINCERELY,

LETTS INDUSTRIES, INC.

October 15, 1981

DOT

ATTN: Chief Administrator, NHTSA

Gentlemen:

This letter is to request a one year testing exemption for one imported automobile with the following description: Manufacturer: BMW Year of Construction: 1976 Model: 3.0 csi Serial Number: 226 0602

Our company manufactures steering linkage components for automobiles and our objective would be to study the wear characteristics of similar components on the above described vehicle.

If there is any further information you need for the granting of this exemption, please advise. Thank you.

C. E. Letts, Jr. President

ID: nht71-4.19

DATE: 10/13/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of October 4, 1971, you asked whether under our Certification regulations (49 CFR Part 567) tandem axles should be considered as a unit in listing the gross axle weight rating, or should be listed separately with separate ratings.

He intend that each axle, including those part of a tandem arrangement, should be listed separately with a GAWR for each.

ID: nht70-1.11

DATE: 12/17/70

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Northeast Kentucky Area Development Council, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 28, 1970, to Mr. Lowell K. Bridwall, Administrator, Federal Highway Administration, asking for a definition of "blemished," "second," and "form use only," which has been referred to this office for reply.

Tire manufacturers are required to certify that their product complies with the Federal Motor Vehicle Safety Standard No. 109, and do so by labeling each tire they certify with the symbol "DOT." Tires that are certified by the manufacturer and marked "seconds" are not necessarily unsafe, as the "second" may be due to a cosmetic defect not affecting the tire's performance.

Sometime a tire manufacturer will make a tire that he believes is defective in a way that affects the safety of the tire. Often, that manufacturer will mark the tire "farm use only" or "non-highway use" and then sell it. In such instances, he is required to remove the DOT symbol.

We do not have a definition for "blemished."

We have enclosed a copy of an amendment to the passenger car tire standard (No. 109) that contains the definition for "non-highway use tires" which is applicable to "farm use only," and "tire identification and recordkeeping" which is applicable to "manufacturer's marks on tires."

Thank you for your interest in the Motor Vehicle Safety Program.

ID: nht71-5.59

DATE: 12/29/71

FROM: WALTER T. COX -- V. P., THEODORE BERGMAN COMPANY

TO: Recreational Vehicle Institute Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter to Frank Armstrong, Director of the Office of Standards Enforcement, National Highway Traffic Safety Administration, concerning the responsibilities of recreational vehicle manufacturers for whom the Bargman Lock Company is conducting a defect notification campaign.

The primary responsibility for conducting the defect notification campaign rests with the vehicle manufacturer. While, in this case, the campaigns are being conducted by the Bargman Lock Company on behalf of the various recreational vehicle manufacturers, it is the responsibility of the vehicle manufacturer to (1) assure that the Bargman Company is supplied a list of customers who purchased vehicles with non-complying door locks, and (2) make sure that the customer is, in fact, notified of the defect.

Since we have received samples of the defect letters the Theodore Bargman Company is sending the vehicle purchaser and the vehicle dealer, it is not necessary for the recreational vehicle manufacturers to send the National Highway Traffic Safety Administration copies of the defect notification letters as required under section 113(d).

Concerning the requirements of the Defects Reports Regulation (49 CFR 573), you are correct in your understanding that the regulation would not be applicable to the Bargman defect notification because the defect involved was determined to be safety-related prior to the effective date of the regulation.

ID: 1985-04.36

TYPE: INTERPRETATION-NHTSA

DATE: 11/25/85

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Richard Pertz

TITLE: FMVSS INTERPRETATION

TEXT:

November 25, 1985 Richard Pertz, Esq. Julian & Pertz, P.C. 1629 Oneida Street Utica, NY 13501 Dear Mr. Pertz: I regret the delay in replying to your letter of July 12, 1985, regarding interpretations of Standard No. 111, Rearview Mirrors. You asked whether the agency has issued any interpretations concerning S5.1.2 of the standard. In addition, you asked whether Ford Motor Company had submitted to the National Highway Traffic Safety Administration (NHTSA) any interpretations of paragraph S5.1.2 of Standard No. 111, regarding requirements for mounting inside rearview mirrors in passenger cars. This agency administers the National Traffic and Motor Vehicle Safety Act of 1966. As part of its responsibilities, this office issues interpretations of safety standards, upon written request. This agency has issued two interpretations of S5.1.2 of Standard No. 111. Copies of these interpretations are enclosed. In addition, NHTSA's Office of Vehicle Safety Compliance investigated the compliance of different makes of passenger cars with Standard No. 111 between 1977 and 1981. The Ford passenger car models tested were the Ford LTD, Econoline, and Fiesta and the Mercury Zephyr and Cougar. As a part of its submission to the agency in these investigations, Ford provided information on its compliance with S5.1.2. The files are available on microfiche from the Technical Reference Office, Room 5108 (202-426-2768) at the address shown above, and the file numbers are CIR Nos. 1708, 2062, 2063, 2064, and 2245. Your request in your letter of September 3, 1985, for comments by Ford on notices of proposed rulemaking on Standard No. 111 has been referred to the Docket Section. They will reply directly to you regarding this information. I hope this information is helpful to you. Sincerely, Original Signed By Erika Z. Jones Chief Counsel Enclosures

ID: nht73-2.46

DATE: 12/10/73

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

TO: Hyattsvile Auto Glass

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your November 29, 1973, request to know if urethane bonding material must be used in the installation of windshields in new motor vehicles not yet sold to a first purchaser for purposes other than resale.

Standard 212, Windshield mounting, is a performance standard for new motor vehicles. We do not require the use of specific bonding materials such as urethane, but only that the vehicle conform to Standard 212, whatever material is used. The New York suit you mentioned may involve a question of due care in the installation of the windshield, separate from the question of meeting a Federal minimum performance standard.

YOURS TRULY,

IHyattsville Auto Glass

NOVEMBER 29, 1973

ROBERT DYSON ASST. CHIEF COUNSEL NATIONAL HWY. SAFETY STANDARDS

DEAR MR. DYSON:

AFTER TALKING WITH YOU BY TELEPHONE ABOUT A STATEMENT MADE BY GENERAL MOTORS IN ONE OF THEIR BULLETINS ON THE USING OF URETHANE TO INSTALL WINDSHEILDS, I WAS TOLD OF A GLASS SHOP IN NEW YORK THAT IS BEING SUED BECAUSE THEY DIDN'T USE URETHANE IN THE INSTALLATION OF A WINDSHEILD OF A 1974 MODEL VEHICLE THAT WAS INVOLVED IN AN ACCIDENT.

I UNDERSTAND THAT SAFETY STANDARD 212 ONLY PERTAINS TO NEW VEHICLES NOT HAVING BEEN SOLD, AS WAS EXPLAINED IN YOUR LETTER OF JULY 20, 1972. IS THERE ANY REGULATION THAT SAYS THAT A WINDSHEILD BEING INSTALLED IN A NEW 1974 MODEL VEHICLE (ONE NOT SOLD TO A FIRST PURCHASER) HAS TO BE INSTALLED WITH URETHANE BONDING MATERIAL? OR ARE WE STILL ALLOWED TO USE THE BONDING MATERIAL OF OUR CHOICE AS LONG AS IT CONFORMS TO STANDARD 212?

I WOULD APPRECIATE ANY FURTHER ASSISTANCE YOU CAN GIVE US BECAUSE OF THE APPARENT HAZARDS AND LENGTH OF CURING TIME WE DON'T WANT TO USE URETHANE UNLESS WE ARE REQUIRED TO BY YOUR DEPARTMENT.

AGAIN I WOULD LIKE TO THANK YOU FOR THE ASSISTANCE YOU HAVE GIVEN US IN THIS AS IN PREVIOUS MATTERS.

SINCERLY YOURS

ROBERT WOOD PUBLIC RELATIONS

ID: nht92-3.15

DATE: 10/16/92

FROM: SHIRLEY A. STEWART -- PRESIDENT, SAS ELECTRICAL SERVICE, INC.

TO: CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-17-92 FROM PAUL J. RICE TO SHIRLEY A. STEWART (STD. 201; STD. 208; STD. 221; STD. 222; A40)

TEXT: In reference to an October 2nd meeting that I had with Messrs. Maurice Hicks and Rich Vaniderstine, Safety Standard Engineers, I presented a video tape on the installation of the silent monitor being installed on school buses. I also had a demo silent monitor box. We are requesting the federal motor vehicle safety standards interpretation on how those standards are applied for installation on school buses.

The silent monitor is a metal box designed to house a video camera to monitor the interior of school buses but can be used in hallways and classrooms. It is mounted by two angle brackets after cutting a 6 1/2" x 6 1/4" hole in the interior access door. The silent monitor box (6 x 6 x 6) is installed in the bus access door and will only protrude toward the interior of the bus 3 - 4 inches. The silent monitor is designed in a manner that keeps drivers and students from knowing if a video camera is in the locked box. The installer will use No. 10 x 1/2" self-drilling screws provided with the box and brackets to attach brackets to the access door and then install the camcorder into the box and focus the picture to the height of the words located in the rear of the bus that says, "emergency exit". The installer will then install the self-drilling screws in the silent monitor box and to the access door and the installation is complete.

The glass on our box is a reflective solar cool glass. This breaks the glare inside the box. The silent monitor box is 16 gauge, welded steel. Our box is designed to be tamper-proof and for safety. The lock is a 5-tumbler, brass lock for durability.

Enclosed are specifications and instructions for installation. Enclosed also is a picture that was taken on October 15th, on a Prince George's County school bus.

If there are any questions, please contact me at (703) 471-1450. (GRAPHICS OMITTED.)

ID: nht74-5.45

DATE: 08/01/74

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

TO: Bayerische Motoren Werke AG

TITLE: FMVSS INTERPRETATION

TEXT: This responds to BMW's June 20, 1974, question whether 7/16-inch vacuum tubing may be manufactured and sold although it does not appear in Table V of Standard No. 106-74, and if so, what Table V values would be used in testing it.

Table V establishes test values for vacuum hose but does not limit the vacuum hose sizes which may be manufactured and sold in conformity with the standard. You are free to utilize 7/16-inch vacuum hose, and the Table V test values for 15/32-inch hose should be used to test 7/16-inch hose.

We are considering the addition of an entry in Table V to cover 7/16-inch hose in the near future.

YOURS TRULY,

Bayerische Motoren Werke KTIENGESELLSCHAFT

AIR MAIL

Docket Section

National Highway Traffic Safety Administration

June 20, 1974

Betreff: Standard 109; Vacuum Brake Hose Tests

With reference to Table V (38 FR 31308) of the subject standard, BMW would like to forward the comments and requests contained below.

Table V lists various values relating to vacuum brake hoses of different inside diameters. We are presently contemplating the use of such a hose whose I.D. is 11.1 mm, or 7/16 of an inch, which is not included in the table.

There is concern here that it may have been omitted if, for some reason, this size is not approved.

If use of the 7/16 inch size is permitted, we would like to have written statement to that effect - since it is not part of the present table - and would further request that, in the interest of completeness, this size be included in future tables.

Accordingly, we await your reply.

ppa. i.v.

(Kraft) (Fellerer)

ID: nht72-5.19

DATE: 09/12/72

FROM: JOSEPH R. O'GORMAN FOR FRANCIS ARMSTRONG -- NHTSA

TO: Gardner-Denver Company

COPYEE: E. ROBERT ANDERSON -- REGIONAL ADMINISTRATOR, NHTSA REGION VI

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 4, 1972, to our Regional Office in Fort Worth, Texas, that has been referred to me, in which you request information concerning intermediate and final stage manufacturers.

I am enclosing, among other things, a copy of Part 568 of Title 49 of the Code of Federal Regulations that specifies the responsibilities of intermediate and final stage manufacturers. The final stage manufacturer applies the "Gross Axle Weight Rating" to the certification label in accordance with paragraph 567.5 of the Certification Regulation, a copy of Part 567 is also enclosed. The Preamble to Part 568 - Vehicles Manufactured in Two or More Stages, states ". . . By its definition a completed vehicle is one that requires no further manufacturing operations in order to perform its intended function, other than the attachment of readily attachable components and minor finishing operations . . ."

"In the event that a 'readily attachable component is a component regulated by the standard, such as a mirror or a tire, the final-stage manufacturer must assume responsibility and certify the vehicle even though he does not install the particular component. . . ." Persons who change tires, that are furnished by the final-stage manufacturer, prior to delivery to the user are not responsible for certification. However, he should assure himself that the tires he installs are compatible with the weight ratings on the certification label affixed by the final-stage manufacturer.

Final-stage manufacturers can rely on the documentation supplied by the incomplete and/or the intermediate vehicle manufacturer in establishing his weight ratings as long as he has no reason to believe it is false or does nothing in his operation that would change the ratings. Good business practices would dictate that a manufacturer would retain information supplied by other manufacturers that he uses as a basis for his certification.

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