ID: nht69-2.29

DATE: 12/05/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: La France Precision Casting Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 11, 1969, to Mr. Lowell K. Bridwell. Your letter was misplaced and did not reach me until now. I apoligise for the delay.

You submitted a label, asking whether it would comply with the Certification Regulations for motor vehicles, with particular reference to campers, trailers and motor homes. The current Certification Regulation for motor vehicles, published July 9, 1969 (34 F.R. 11560, copy enclosed), require that the vehicle label contain, in the order listed:

1. name of manufacturer;

2. month and year during which manufacture of the vehicle is completed;

3. the following statement --

"THIS VEHICLE CONFORMS TO ALL APPLICABLE FEDERAL MOTOR VEHICLE SAFETY STANDARDS IN EFFECT ON THE DATE OF MANUFACTURE SHOWN ABOVE:"

4. vehicle identification number;

5. (for multipurpose passenger vehicles only, as defined in 49 CFR @ 371.3) the words. "TYPE MULTIPURPOSE PASSENGER VEHICLE."

You should note that the above requirements only apply to complete vehicles, which include motor homes and trailers, and not to items of equipment, such as campers, which will be only part of a vehicle. No regulations have been issued as yet for the certification of equipment. Under the National Traffic and Motor Vehicle Safety Act, equipment that either is covered by a standard or, as in the case of most campers, contains other equipment such as glazing that is covered by a standard, must carry a label or tag certifying that the equipment conforms to applicable Federal motor vehicle safety standards.

The label that you submitted differs from the above requirements in several respects. If you or your customers have further questions concerning the certification requirements, we will be pleased to answer them.

ENCLOSURE NATIONAL HIGHWAY SAFETY BUREAU -- MVSFS

ID: nht76-4.14

DATE: 07/23/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to White Motor Corporation's April 26, 1976, question whether S5.3.3 and S5.3.4 of Standard No. 121, Air Brake Systems, require minimum brake chamber air pressures of 60 psi and 95 psi, respectively, or whether these air pressures are included in the sections only as "bench marks" on which to base specifications for minimum actuation and release timing in brake systems. Section S5.3.3 specifies in part:

. . . With an initial service reservoir system air pressure of 100 psi, the air pressure in each brake chamber shall, when measured from the first movement of the service brake control, reach 60 psi in not more than 0.45 seconds. . . .

Your understanding that S5.3.3 and S5.3.4 only specify the air pressures of 60 psi and 95 psi as the basis for timing requirements is correct. Neither value is intended as a requirement that the vehicle be designed to provide a certain level of brake chamber air pressure. The values were based on an understanding of the typical configuration of existing air brake systems at the time the final rule was issued.

In response to your request for interpretation of these sections in view of White's intent to use a lower air pressure than was commonly used in the past, the agency will utilize the stated 60-psi value or a value that is 70 percent of the maximum air pressure (measured by the NHTSA at the brake chamber), whichever is lower. In the case of release, the stated 95-psi value or the value that represents maximum air pressure (measured by the NHTSA at the brake chamber), whichever is lower, will be used. For purposes of this determination, the maximum air pressure in the brake chamber is that obtainable with full brake application when the pressure in the service reservoir is at 100 psi. Use of the maximum air pressure application timing would be unreasonable because of the decreased rate of air pressure build-up that occurs as the brake chambers reach maximum pressure.

The agency will issue an interpretive amendment to S5.3.3 and S5.3.4 to reflect this interpretation.

ID: nht75-2.3

DATE: 10/28/75

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

TO: Swan and Woodford

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 27, 1975, request for standards applicable to glass-belted tires with the size designation H78-15 which were standard equipment on a 1973 Ford automobile. Such tires are subject to Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires -- Passenger Cars, a copy of which is enclosed.

YOURS TRULY,

SWAN & WOODFORD

August 27, 1975

National Highway Traffic Safety Administration

Re: Standards for Firestone Brand Tires

This letter is to inquire of any available information regarding standards for the below listed equipment.

Size H-78-15 glass-belted Firestone brand tires; standard equipment on 1973 Ford automobile.

I am particularly interested in a standard as it applies to "blow outs" at 65 miles per hour on an improved road with tires having been driven 14,000 miles. ("Blow-out" occurred in inner sidewall

Thanking you in advance for your cooperation.

C. BRAD WOODFORD

ID: nht68-4.1

DATE: 08/15/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Toyota Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 23, 1968, to Mr. George C. Nield, Acting Director, Motor Vehicle Safety Performance Service, concerning the requirements for turn signal and hazard warning signal flashers as specified by Motor Vehicle Safety Standard No. 108.

With certain exceptions, paragraph S3.3 of Standard No. 108 permits the use of combination lamps, reflective devices and items of associated equipment, provided the requirements for each lamp, reflective device and item of associated equipment are met. Therefore, a combination turn signal and hazard warning signal flasher may be used, provided the requirements for each signal (turn and hazard warning) are met.

You are correct in your understanding that Standard No. 108 and basically referenced SAE Standards J590 and J945 do not require operation of the flasher unit with only one signal bulb in the test circuit. The standard test circuit shown in Figure I of SAE Standard J823 indicates a minimum of two signal lamps and one pilot indicator lamp as the lamp load.

Thank you for writing.

ID: nht78-2.31

DATE: 02/27/78

FROM: AUTHOR UNAVAILABLE; Joseph J. Levin Jr.; NHTSA

TO: Mercedes-Benz of N.A.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 1, 1978, letter asking whether your certification label complies with the requirements of Part 567, Certification.

Your certification would state the gross vehicle and axle weight ratings in both pounds and kilograms. In the past, the agency has permitted this approach for the purpose of international harmonization of measurements. Therefore, your proposed label appears to comply with the requirements.

ID: nht72-2.17

DATE: 11/21/72

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

TO: American Plywood Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 25, 1972, in which you ask whether there are any NHTSA requirements applicable to "do-it-yourself" plans for camper trailers.

Certain Federal requirements are applicable to the camper trailers which will be built based on your plans. These are Federal Motor Vehicle Safety Standard No. 108. "Lamps, Reflective Devices, and Associated Equipment" (49 CFR 571.108). Requirements which we expect to issue in the near future will apply to the tires with which such trailers are equipped (proposed Standards Nos. 119 and 120). Moreover, manufacturers of these trailers are required by NHTSA "certification" regulations (49 CFR Part 567) to certify the trailer's confermity with the motor vehicle safety standards. These requirements apply to the finished trailer itself, and not to the plans for it, but the plans should include stops that will cause the finished trailer to conferm to all applicable requirements.

I have enclosed directions on how you may obtain copies of NHTSA requirements.

ID: nht73-2.39

DATE: 03/26/73

FROM: E. T. DRIVER -- DIR., OFFICE OF OPERATING SYSTEMS, MVP; SIGNATURE BY CHARLES A. BAKER

TO: Monsanto Textiles Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 12, 1973, requesting assignment of a tire manufacturer's identification code number to Monsanto Company.

In a telephone conversation March 12, 1973, your Mr. E. Schary explained to our Mr. F. Koch that you are building experimental and development tires for test on vehicles that remain under your control. It is understood that the tires are not sold or leased to the general public. Under these conditions you are required to have a tire identification code number. These tires must, however, conform to Standard No. 109, and be certified as such by applying the DOT symbol to the sidewall. We understand you are acquainted with these requirements.

To bring you up to date with recent progress in development of new and amended regulations we are enclosing several of the latest(Illegible Word) pertaining to rule making. Please let us know if you have any other questions regarding the applicability of the tire identification code and whether we can be of further assistance.

ID: nht95-1.95

TYPE: INTERPRETATION-NHTSA

DATE: March 8, 1995

FROM: Barbara Bailey -- Administrative Assistant to Steve Altick, Director/CEO, CAMP Berachah Christian Retreat Center

TO: Walter Myers -- Attorney-Advisor Office of Chief Counsel, NHTSA

TITLE: Transportation of school students

ATTACHMT: ATTACHED TO 5/30/95 LETTER FROM JOHN WOMACK TO BARBARA BAILEY (A43; PART 571.3)

TEXT: In our phone conversation today, I addressed issues of specific concern to us in relation to the use of our vans by a school. You had asked that these questions be put in written form so that your agency could respond. PLEASE EXPEDITE via fax as soon a s possible. Material being presented on Friday morning here.

1. Camp Berachah has leased two vans. Those vans are borrowed for occasional use by a school for athletic activities, etc. Is it necessary for these vans to comply with Federal safety standards relating to school buses? Please discuss.

2. Must these vans comply with Federal safety regulations for school buses if Camp Berachah were to lend, rent or sublease them to a school? Please discuss.

Thank you for your swift response to this. And thank you again for your help over the phone.

ID: nht70-2.5

DATE: 04/29/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: David Hemenway

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of March 9, 1970, addressed to the National Highway Safety Bureau, concerning data provided pursuant to the Consumer Information regulations, 49 CFR @ 575.101, Vehicle Stopping Distance. A copy of the consumer information date for 1970 vehicles is enclosed.

You asked whether stopping distances greater than 194 feet for vehicles traveling 60 mph indicate the likelihood that such vehicles are(Illegible Word) to meet Federal Motor Vehicle Safety Standard No. 105. As you have noted, the stopping distance for a constant(Illegible Words) deceleration from 60 mph would be 194 feet. However, Standard No. 109 does not require an average deceleration rate. ((Illegible Words) up" time) of 24(Illegible Word) during the entire period of deceleration. The Standard requires only that a vehicle attain a deceleration rate of 20(Illegible Word) with a pedal force of between 15 and(Illegible Word) lbs., in a(Illegible Word) 60 mph. Consequently, the standard does not require that the stopping distance not exceed 194 feet, and consumer information data showing a stopping distance in excess of 194 feet for the 60 mph test does not indicate non-compliance with Standard No. 105.

The attached Discussion Paper indicates none of the revisions in Standard No. 105 that are under consideration. Should amendments be found desirable, a notice of proposed rule making containing the proposed revisions will be issued.

Thank you for your interest in motor vehicle safety.

ID: nht88-2.79

TYPE: INTERPRETATION-NHTSA

DATE: 07/24/88

FROM: STEPHEN BORKOWSKI

TO: ERICA JONES -- NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATOR

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/10/88 TO STEPHEN BORKOWSKI FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 108

TEXT: This letter is request for the legality of my Bimmer Dimmer Safety Stop Light Concept. It utilizes various devices to govern the intensity of brake light brightness to indicate the degree of braking being applied to a vehicle. The goal of my concept is to lessen the chance of rear end collisions.

My concept was borne by a personal experience of mine in which I was able to avoid crashing into a car in front of me but four cars behind me were not able to escape damage as a result of multiple rear end collisions.

As a driver with 40 years of experience with a good driving record, I pondered over why or what I did wrong that put me into such a situation. My conclusion is that through the years I was lulled into a false sense of security. I realized there were co untless number of times when I was in a line of cars that were slowing down and the brake lights of the car or cars in front of me were lit even though we all were in the process of moving. Also, there are many times when drivers "ride" the brakes in hi gh density traffic. The activated stop light, therefore, does not indicate a drivers intent to actually come to a stop or the degree of his slowing down.

In the military as well as in other organizations, people are trained for emergency situations so that they will react in the correct manner, subconsciously. If drivers can learn to apply their brakes quickly and fully when they see a very bright red br ake light, I believe a false sense of security will not be developed and thus, hopefully, rear end collision can be reduced. I would like to pursue to research and develop my concept to test its validity and effectiveness.

I would appreciate any advice and suggestions that I should have in seeing how I could make it legal.

Sincerely,