ID: nht95-2.42

TYPE: INTERPRETATION-NHTSA

DATE: April 20, 1995

FROM: Valter Sforca

TO: Philipe Recht -- Chief Counselor, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 5/4/95 LETTER FROM JOHN WOMACK TO VALTER SFORCA (A43; PART 591)

TEXT: I have speak with Mr. Taylor Vincent about get a letter in writing from you, explaining if there is any regulation to bring from a foreign Country, a assembled unit called, Air Equalizer for Tire Pressure, wich comply with Safety Standarts. In a emergen cy the system have a safety valve for the air brakes the truck, for a properly stop.

Since now, I'wating for your response, please mail or fax to me a "Letter of Approval for Safety Standard", I'apreciatte at this matter thank you.

ID: nht95-1.2

TYPE: INTERPRETATION-NHTSA

DATE: January 2, 1995

FROM: Jim Cawse -- Principal Scientist; George Diehl -- Standards Engineer, General Electric

TO: Philip Recht -- Chief Counsel - NHTSA

TITLE: NONE

ATTACHMT: Attached to 2/6/95 letter from Philip R. Recht to Jim Cawse and Fred (George) Diehl (A43; Std. 108)

TEXT: Dear Mr. Recht:

As GE Plastics continues to develop and introduce new products for the Automotive Lighting marketplace, it is extremely important that we continue to adhere to the SAE testing protocol as delineated in SAE J576C, to ensure that our products meet the pass /fail three year natural weathering criteria in South Florida and Arizona. The Design of Experiment (DOE) approach we discussed with you in August and September, 1994, will enable us to generate a much wider spread of data utilizing dependent and indepe ndent variables including haze. Yellowness Index (YI), color shift, thicknesses, formulations, colors, color concentrations, and coatings. This will supply very meaningful results for us and our customers in that we will be able to extract more results from less testing.

As a result of our discussions with NHTSA, AAMVA (now AMECA), and the major automotive and automotive lighting players, we have modified our initial approach to incorporate the important concerns of all parties. These include:

* The thicknesses used in the study will be at least the three minimum as called out by SAE J576C (0.062, 0.125, and 0.250 inches). We have added the 0.040" thickness as well.

* The formulations (base material recipes) used in the study will be commercial formulations and the results of the study will be usable for only those formulations (i.e., no blends of two formulations).

* Each coating will be tested at least once on each formulation.

* Each color candidate will be tested in a low and high color concentration so that interpolations can be made from the test results for color concentrations that fall in between.

* The final list of coatings is being firmed up as of this writing, and actually is being expanded beyond the list presented in previous meetings.

We would appreciate your written affirmation of our approach so that we have a mutual understanding of our new testing directions, and so that our customers are assured of your concurrence.

Sincerely.

ID: nht89-1.13

TYPE: INTERPRETATION-NHTSA

DATE: 02/03/89

FROM: ROBERT C. CRAIG -- QUALITY CONTROL MANAGER COSCO INC

TO: GEORGE L. PARKER -- DIRECTOR OFFICE OF DEFECTS INVESTIGATION - ENFORCEMENT U.S. DEPARTMENT OF TRANSPORTATION N.H.T.S.A.

TITLE: 49 CFR 571.213; STANDARD NO. 213 CHILD RESTRAINT SYSTEMS. @ 5.5.1. LABELING; RULING: INCORPORATE THE METRIC SYSTEM OF MEASUREMENTS INTO THE STANDARD.

ATTACHMT: ATTACHED TO LETTER DATED 04/17/89 FROM ERIKA Z. JONES -- NHTSA TO ROBERT C. CRAIG, REDBOOK A33(2), STANDARD 213

TEXT: Dear Mr. Parker:

Cosco, Inc. has been purchased by Dorel Industries, Inc. of Montreal, Quebec. With the purchase, Cosco is making child restraints for the United States and Canada. Canada requires the metric system of measurements on all child restraint labels and instr uctions. To meet the Canadian requirement, Cosco wishes to incorporate the metric system of measurements on their present labels and instructions.

Example: "This child restraint is designed for use only by children who weigh 40 pounds (18 kg) or less and are 40 inches (1 M) or less in height."

Cosco requests permission to include metric equivalents on all Cosco child restraints and confirmation that use of metric equivalents as described above is in conformance with the requirements of FMVSS 213.

Thanking you in advance for your consideration of the above. If there are any questions or information needed, please contact me directly.

Sincerely,

ID: nht70-2.23

DATE: 08/27/70

FROM: AUTHOR UNAVAILABLE; R.A. Diaz; NHTSA

TO: Lanes Auto Sales

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter in which you asked about the requirements of the Federal motor vehicle safety standards in regard to combination of new and used components.

In your first group of questions, you asked whether you could put a used fifth wheel or a used dump body on a new truck. The answer is yes, but the finished vehicle must conforms to all the motor vehicle safety standards applicable to that type of vehicle at the time it is completed. At this time, probably the only standard that would require action on your part would be Standard 108 on lighting systems, Other Standards applicable to trucks have been proposed, however, which will require you to take further action or observe certain limits in the future, and you should take stops to keep informed of the applicable requirements. I an enclosing a copy of current standards and regulations, and if you will fill out the enclosed form you will be put on a smailing list for notices that apply to your operations.

Also in reference to this group of questions, the requirements on persons who complete vehicles are the same whether they own the trucks or do the work for a dealer or for the ultimate user.

You also asked about building "a trailer out of new frames using old axles, brakes, and wheels, with parts made before 1966". In such a case, the vehicle that you build must conform to current applicable safety standards, unless it is a repair job done on a presently registered used vehicle that will continue to be registered as a used vehicle. Whether you call the trailer a used or new one depends on the State requirements - you may do whatever is permitted by your State licensing authorities in this regard.

Finally, you asked whether, when you build a trailer with used wheels, axles, bearings, brake drums, and springs, you may put on used tires. At present you certainly may do so, since there is no Federal safety standard for truck tires. It is probable that one will be issued in the future, however, and if and when such a standard becomes effective, any tires you use must meet the requirements of that standard.

Please let us know if we can be of further assistance.

Enclosures

ID: 86-4.16

TYPE: INTERPRETATION-NHTSA

DATE: 07/18/86

FROM: Z. TAYLOR VINSON -- SENIOR STAFF ATTORNEY NHTSA

TO: INTERPS. - STD. NO. 108 REDBOOK (3)

TITLE: CHMSL INTERPRETATION

TEXT: On July 16, 1986, a mechanic phoned with the following question: if a customer wishes to have a deck lid luggage rack installed, and that rack incorporates a center high-mounted stop lamp that is mounted between the rack and the deck lid, and the original interior mounted center stop lamp remains in place, would Standard No. 108 prohibit such an arrangement?

I replied that it wouldn't, assuming that the rack itself in an unloaded condition prevented the lamp from full compliance with photometric and/or visibility requirements; paragraph S4.3.1.1. requires a supplementary or auxiliary lamp meeting Standard No. 108's requirements whenever motor vehicle equipment prevents compliance by a required item of lighting equipment.

ID: nht71-5.32

DATE: 12/28/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: U.S. Suzuki Motor Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 17, 1971, enclosing copies of consumer information documents you plan to use to comply with the Consumer Information requirements applicable to motorcycles. You state that you plan to place the information for particular models back to back on the same sheet of paper in order that they may correspond to your specification sheets.

The documents you have submitted, when they contain the appropriate values, will comply with the Consumer Information regulations. There is no prohibition against placing the information for two models back to back on the same sheet as you plan to do.

We are pleased to be of assistance.

ID: nht91-1.4

DATE: 01/01/91

FROM: UNDER SECRETARY -- MINISTRY OF COMMERCE & INDUSTRY, KUWAIT

COPYEE: THE MINISTER'S OFFICE; THE UNDER SECRETARY; INDUSTRIAL AFFAIRS; STANDARDS & METROLOGY DEPT.

ATTACHMT: ATTACHED TO LETTER DATED 11-13-92 FROM PAUL J. RICE TO UNDER SECRETARY, KUWAIT MINISTRY OF COMMERCE AND INDUSTRY (PART 574; STD. 109; STD. 119; A40; PART 571)

TEXT: We have studied your above mentioned standards with interst and we would appreciate if you please reply to following questions:

1) Do all tyres manufactured and sold in the US must bear the (DOT) mark?

2) What are the basises for granting the right to use the (DOT) mark by the manufacturer on their tyres?

3) Is the (DOT) mark required for local consumed and exported tyres also?

4) Is there a validity time for the use of the (DOT) mark?

5) What is the relation ship between your administnation and the Department Of Transportation concerning the implementation of the use of the (DOT) mark?

6) What are the legal responsibility of the manufacturer by using the mark.

7) What are the responsibility of the manufacturer in case of violation of mark's roles.

We would appreciate if you please kindly furnish us with all information and document concerning the above mentioned subject.

Thank you in advance for your cooperation.

ID: nht90-3.43

TYPE: Interpretation-NHTSA

DATE: August 2, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Tony Llama -- President, Davenport Enterprises

TITLE: None

ATTACHMT: Letter dated 6-11-90 to S. P. Wood from T. Llama; (OCC 4894) and letter dated 6-12-90 to T. Llama from D. Sander

TEXT:

This is in reply to your letter of June 11, 1990, with respect to the allowability of a temporary importation of a vehicle from Panama that does not comply with Federal motor vehicle safety standards.

Specifically, the vehicle is a "van" manufactured in the Soviet Union. Its Panamanian owner has requested that your company design and install a dual air conditioning unit for the vehicle. Once you have built and installed the unit, the van will be ret urned to Panama for evaluation and testing. You anticipate that the van will be in the United States for at least 90 days.

After our review of this matter, we have determined that it would be appropriate for you to enter the van pursuant to the provisions of 49 CFR 591.5(j), under the declaration that the vehicle is being imported solely for the purpose of research, investig ations, studies, or demonstrations. This declaration appears as Box 7 on the HS-7 importation form under which the vehicle will enter the United States.

If you have any further questions, we shall be happy to answer them.

ID: nht72-5.50

DATE: 03/30/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Champion Carriers Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 25, 1972, wherein you state that you manufacture "off-highway vehicles for cranes, drill rigs and truck terminals" and request that we advise you of the requirements regarding manufacturer registration which became effective February 1, 1972. In a telephone conversation with Mr. David Fay of NHTSA on March 23, 1972, you indicated further that the type of vehicle you manufacture is represented by the picture at the bottom of your January 25 letter to us.

We would not consider these vehicles to be "off-highway vehicles." In our view they appear to be similar to truck tractors, and have a primary purpose of transporting other vehicles (which may be off-highway vehicles) over the public roads. Consequently, we would consider them to be trucks under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1331 et seq.) and the motor vehicle safety standards and regulations issued pursuant to the Act.

As a manufacturer of such vehicles you must comply with the Manufacturer Identification regulations (49 CFR Part 566) and a copy of them is enclosed as you requested. Also enclosed is a copy of the National Traffic and Motor Vehicle Safety Act, and information on how to obtain copies of the Motor Vehicle Safety Standards and regulations.

IF YOU HAVE FURTHER QUESTIONS, PLEASE WRITE.

ID: nht90-2.25

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 25, 1990

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

TO: MARGARET SCHMOCK -- ROBERT BOSCH GMBH

TITLE: NONE

ATTACHMT: TELEFAX DATED 6-3-90 TO STEPHEN P. WOOD FROM MARGRET SCHMOCK ATTACHED; (OCC 4508) TEXT:

This is in reply to your FAX of March 6, 1990, with respect to the relationship between Federal Motor Vehicle Safety Standard No. 108, and "CAC Title 13, Article 9".

You have indicated that CAC requires a headlamp adjustment range in the horizontal of at least +/- 4 degrees, whereas Standard No. 108 requires a horizontal adjustment range of not less than 2.5 degrees. You have asked whether Bosch headlamps still must have an adjustment range of +/-4 degrees in the horizontal although Standard No. 108 has been changed.

We understand that "CAC" refers to "California Administrative Code". The effect of the preemption provisions of the National Traffic and Motor Vehicle Safety Act is to prohibit California from adopting and enforcing a minimum horizontal headlamp adjustm ent range greater or less than 2.5 degrees. Thus, a State requirement that a headlamp have a horizontal range of +/- 4 degrees is invalid because it differs from a corresponding Federal requirement.

We are unable to answer your further questions with respect to the California code, and suggest that, for further information you write Department of Motor Vehicles, State of California, 2415 First Avenue, Sacramento, California 95818, ATTN: Mr. A. A. Pi erce, Director (FAX 916-732-7854).