ID: nht78-3.3

DATE: 09/13/78

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

TO: Department of Transportation - Rhode Island

TITLE: FMVSS INTERPRETATION

TEXT: I regret the delay in answering your letter. This responds to your questions concerning the recent amendment of Safety Standard No. 205, Glazing Materials, that permits the use of rigid plastics in the side windows of buses. Specifically, you ask whether the amendment includes school buses and whether plastic glazing would be allowed in entrance doors and in rear emergency doors of school buses.

Safety Standard No. 205 was amended to permit the use of rigid plastic glazing in all doors and windows of buses, except windshields or in windows to the immediate right or left of the driver (42 FR 61465, December 5, 1977). This amendment is applicable to school buses, since they are a special sub-category of "bus." The plastic glazing would not be allowed in a bus entrance door since this would constitute a "window to the immediate right" of the driver. Plastic glazing would be allowed in the rear emergency door, however, since that location was not excepted in the amendment.

Please contact Hugh Oates of this office if you have any further questions (202-426-2992).

Sincerely,

ATTACH.

STATE OF RHODE ISLAND AND PROVIDENCE PLANTATIONS

Department of Transportation

July 12, 1976

Joseph J. Levine -- Chief Counsel, N.H.T.S.A.

RE: Docket No. 71-1; Notice 06 Final Rule, Glazing Materials. Amended Safety Standard No. 205

Dear Sir:

During a recent telephone conversation with Ms. Nancy Egar it was suggested that I submit my request for an interpretation of the above mentioned amendment relative to glazing material to be used with the use of school buses.

In preparing our school bus inspection for the start of the September 1978 school year, I am in need of guidelines in interpreting whether or not rigid plastic glazing material is allowed for use in the school buses in particular locations such as the rear emergency door which is a visible location via the rear view mirror and the entrance door which is a visible location for children prior to the door being opened. Further to this, the overall amendment includes buses but I was wondering if school buses per say may be exempt in the interpretation of the word bus.

I would appreciate your reviewing the above comments and notifying me in writing as to the N.H.T.S.A. interpretation relative to these questions as soon as possible so that I in turn may respond to the school bus owners before August 15, 1978.

Sincerely yours, Alfred Massarone, Chief -- MOTOR VEHICLE SAFETY AND EMISSION CONTROL DIVISION

ID: nht73-2.30

DATE: 12/26/73

FROM: DARROLL P. YOUNG -- PRESIDENT YOUNG'S MACHINE COMPANY

TO: OFFICE OF CHIEF COUNCIL NHTSA U.S. DEPT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 1/8/74 FROM RICHARD B. DVSON -- NHTSA TO DARRELL P. YOUNG -- PRESIDENT YOUNG'S MACHINE COMPANY

TEXT: We are manufacturers of Diesel powered underground mine trucks. These vehicles utilize truck differential having hydraulic brakes. Most of the vehicles have two wheel drive, and in such cases have brakes only on the driving axles.

The maximum speed attainable under full power is approximately 12 miles per hour. The vehicles are not designed to operate on highways or public roads.

Kindly supply us with regulations number 121 and 105A in order that we may determine our responsibility as regards compliance with the above regulations.

Thank you very much.

Very truly yours,

ID: nht75-4.20

DATE: 03/28/75

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

TO: The Glass Doctor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter dated January 29, 1975, asking whether a product which you use to repair damaged windshields is prohibited by Federal law or regulation. Your letter was forwarded to our office by the NHTSA Regional Administrator in Fort Worth. You describe the repair process which you use as one in which the air in a damage spot or crack in the windshield is displaced by the product in a liquid form. As this product hardens it bonds itself to the glass, making the damaged area stronger than the other areas of the glass.

There are no Federal laws or regulations which prohibit the use of such a material or process in the repair of windshields which have previously been installed in vehicles and damaged in use. Using such a material or process in a new (but damaged) windshield (such as in shipment) could cause the windshield to fail to meet the performance requirements of Motor Vehicle Safety Standard No. 205 (49 CFR @ 571.205) and we would therefore discourage its use in new windshields.

We are pleased to be of assistance.

Yours truly,

ATTACH.

The Glass Doctor

JANUARY 29, 1975

Dept. of Transportation-NHTS Legal Dept., Fort Worth, Texas 76102

Gentlemen:

The Glass Doctor has a patented compound and patented process for repairing damaged glass on vehicular windshields. The compound is a lucite or plexiglass base product which must be kept dark and refrigerated prior to use. Once exposed to sunlight (ultra-violet) and heat, the hardening process commences. This process is irreversible, similar to cement.

Repairs to windshield damages are accomplished through a process by which the air in a damage spot or crack on the windshield is displaced by the product while same is still a low viscosity fluid. As the compound hardens, it bonds itself to the glass, making the damaged area actually stronger than the other areas of the glass. A good analogy is that of welding two pieces of metal together. The same principle applies to our glass repair compound and process. We are able to confine existing damage, restore the strength of the glass, and improve the cosmetics of the damage anywhere from 75% to 99%.

In the course of offering our repair service to many of the Motor Freight Trucking firms in the Dallas area, the question has been raised as to whether use of our repair process would be in conflict with existing D.O.T. regulations.

Would appreciate greatly any correspondance from your department which would ascertain that use of our process would in no way conflict with existing D.O.T. regulations.

Sincerely,

E. J. Banks

ID: nht94-5.10

TYPE: INTERPRETATION-NHTSA

DATE: December 15, 1994

FROM: Tom Hindson

TO: Philip Recht -- Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 4/24/95 LETTER FROM PHILIP RECHT TO TOM HINDSON (A43; VSA 102(4))

TEXT: Dear Mr. Recht,

I have been told by other people within DOT that I should address my request to you. My company intends to develop and market a consumer device that fits on automobiles. It will be sold by dealers at time of new car purchase and will be installed by th e dealer. Basically it is comprised on a slim container holding a light weight car cover which will be bolted underneath the rear bumper and trunk of the automobile. By means of a handle(wand) and an electric motor which is supplied with power from the car's battery, the cover is propelled out of the container by means of motor driven rollers. The cover is then guided over the car and attached to the front bumper. When ready to leave, the handle switch is pressed and the whole operation reverses to that the cover is pulled off the car and back into the sealed container.

The system does NOT:

1. Invade any fuel storage. 2. Invade any EPA device 3. Hinder the driver in any way. 4. Pose any ground clearance problems 5. Pose any electrical problems. A simple battery lead and rugged conduit is used.

Please consider this system and give us a Letter of Interpretation concerning our compliance with any applicable safety standards. If more information is required please let me know.

Thanks very much for your help.

(PHOTOS OMITTED.)

ID: 17506-r.wkm

Mr. Chris Cardwell
Manufacturing Engineer
McKechnie Vehicle Components
Fluid Handling Division
Post Office Box 537
Newberry, SC 27108

Dear Mr. Cardwell:

Please pardon the delay in responding to your letter to this office in which you ask for an "official ruling" as to whether the plastic tubing you produce is subject to Federal Motor Vehicle Safety Standard (Standard) No. 106, Brake hoses, or any other Federal motor vehicle safety standard.

You state that your company intends to produce plastic tubing for use in the model year 2000 Ford Escort. The tubing will be utilized as low-pressure brake fluid return lines running from the clutch to the brake fluid reservoir and from the fluid reservoir to the brake master cylinder. The fluid in these lines will not be under pressure since the reservoir is open to the atmosphere. You feel that for that reason, these tubes are not subject to Standard No. 106.

Standard No. 106 applies to new motor vehicles and to "hydraulic, air, and vacuum brake hose, brake hose assemblies, and brake hose end fittings...." The term "brake hose" is defined in pertinent part in S4 of the standard as:

[A] flexible conduit, other than a vacuum tubing connector, manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.

Hoses are excepted from Standard 106 if they do not transmit or contain the brake fluid pressure or vacuum used to apply force to a vehicle's brakes. To determine whether the hoses you produce are excluded from the standard, you must determine whether a failure of your hose would result in a loss of pressure in the brake system. If this would be the case, the hoses transmit or contain the pressure used to apply force to the vehicle's brakes and therefore would have to comply with the standard. (See NHTSA's August 3, 1984 letter to Eaton Corporation, copy enclosed, concerning small diameter hoses used on air brake equipped trucks.) Failure of a conduit that transmits or contains the pressure used to apply force to a vehicle's brakes would either immediately or eventually affect the vehicle's braking performance. It is important, therefore, for such hoses to meet the performance requirements of Standard 106, to reduce the likelihood of failure in service. If you use a check valve or some other device to prevent loss of pressure, then the hose would not contain or transmit the pressure and would not be required to comply with Standard 106.

I hope this information is helpful to you.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:106
d.6/5/98

ID: nht95-2.1

TYPE: INTERPRETATION-NHTSA

DATE: March 14, 1995

FROM: Donnell W. Morrison

TO: Honorable Ricardo Martinez, Administrator, NHTSA

TITLE: RE.-49CFR571.108-S4, Table 1, 49CFR571.108-S4, Table 11

ATTACHMT: ATTACHED TO 4/10/95 LETTER FROM PHILIP RECHT TO DONNELL W. MORRISON (A43; STD. 108)

TEXT: Dear Administrator Martinez:

This in in further reference to my February 14, 1995 letter regarding the cited sections of the Code of Federal Regulations. As of this date I have not received a reply to my inquiry. A copy of the February 14 letter is enclosed.

As I indicated in my February 14 letter I am working on a project and need to know if the cited sections of the CFR have been amended to allow the rear identification lamps and the rear clearance lamps to be mounted at a location other than specified in the tables mentioned above. In other words can both the rear identification and the rear clearance lamps be mounted at bed level. The tables in Standard 108 indicate the rear lamps mentioned are to be mounted as high as practicable.

A timely response to my inquiry would be very much appreciated.

ENCLOSED LETTER:

D. W. Morrison Engr. Consultant

1005 Dr innon Drive

Morristown, Tenn. 37814

615-587 0534

February 14, 1995

Honorable Ricardo Martinez, Administrator

National Highway Traffic Safety Administration

Washington, D.C. 20590

Re:49CFR571.108-S4, Table 1 49CFR571.108-S4, Table 11

Dear Administrator Martinez:

I am doing some research on a project and need to know if your organization has amended the cited sections of the CFR.

The question has been raised since I notice many semi-trailers in operation on the highway with all of the rear lighting devices down at bed level. If I understand the wording of the cited sections correctly the identification lamps are to be mounted as close as practicable to the top of the vehicle and on the vertical center line.

If the standards have been amended I would appreciate your furnishing me with a copy of the rule making action. Notice of Proposed Rule Making and the Final Rule.

Sincerely,

DONNELL W. MORRISON

ID: 20174.ztv

Mr. Bart W. Hill
JMH Trailers
233 Far View Road
Hamburg, PA 19526

Dear Mr. Hill:

This is in reply to your letter of June 9, 1999, with respect to the operation of side turn signal lamps on dump bodies that your company manufactures. Thank you for including photos to help us advise you.

You install side turn signal lamps on your products. The wiring on trucks with dump bodies is such that "the side turn also lights when the brakes are applied" (we understand that the side turn signal is steady burning when activated by the brakes). A Pennsylvania state police officer has told your customer that this is illegal. However, the Pennsylvania Department of Transportation ("PennDot")has informed you that it is legal "if it does not violate the Federal standard." Therefore, you have asked whether this configuration does violate the Federal standard.

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, does not require a vehicle to have side turn signal lamps. S5.1.3 of Standard No. 108 prohibits the installation of supplemental lighting equipment if the lamps would impair the effectiveness of lighting equipment that the standard requires. As we see it, the question here is whether the operation of both amber-colored side turn signal lamps in a steady burning mode when the red stop lamps are activated in a steady burning mode can be said to impair the effectiveness of the stop lamps.

The activation of both side turn signal lamps in a steady burning mode is the functional equivalent of an amber supplementary stop lamp that is mounted on the vehicle's side. In our opinion, auxiliary lighting equipment must perform in the same manner, and perform the same function, as the original equipment it is intended to supplement. Standardization of signals is important so that following drivers will not hesitate to respond when the brakes of a vehicle are applied and its stop lamps are activated. The combination of amber side lamps and red rear ones have the potential to create confusion in adjacent and following drivers. I am sorry, therefore, to tell you that we have concluded that your system of amber stop lamps would impair the effectiveness of the stop lamps required by Standard No. 108, and, hence is impermissible under S5.1.3.

If you have any questions you may phone Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.8/27/99

ID: nht88-2.18

TYPE: INTERPRETATION-NHTSA

DATE: 05/06/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Z. Taylor Vinson

TITLE: FMVSS INTERPRETATION

TEXT:

Subject: Oral Interpretation of Standard No. 108: Optical Combination

From Z. Taylor Vinson Senior Staff Attorney

To: Interpretations Files

Recently a lamp manufacturer phoned to ask whether a replacement lighting device it had developed for installation on trucks and trailers in use would be allowable under Standard No. 108.

The lamp as described is an amber-lensed wrap-around lamp incorporating a clearance lamp to the front and a marker lamp to the side, with one bulb for each function. I replied that the prohibition in S4.4. applicable to clearance lamps forbade their comb ination only with identification lamps and stop lamps, and that if his combination lamp met photometric and mounting requirements applicable to each function, it appeared to be permissible under Standard No. 108.

ID: nht68-1.42

DATE: 05/28/68

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

TO: Minnesota Automotive, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 1, 1968, to the Motor Vehicle Safety Performance Service, concerning compliance with the Federal Motor Vehicle Safety Standard No. 105.

Basically, when a car dealer modifies a conforming vehicle, he then assumes responsibility for the vehicle's compliance to all applicable standards if that vehicle is distributed to a purchaser for purposes other than resale. Specifically, if a car dealer installs the Model 7900 Driver Training Brake on a conforming vehicle that he sells, than compliance to the Federal Motor Vehicle Safety Standard No. 105, as well as other applicable standards, is required. In the case where the dealer owns and loans the vehicle with the installed Model 7900, we would hope that he would again comply.

The enclosed literature may be of additional assistance to you in response to your inquiry.

ID: nht71-5.38

DATE: 09/29/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Chrysler Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of September 10, 1971, concerning the Defects Reports regulations, 49 CFR Part 573. You ask whether @ 573.6 (Owner Lists) requires that the list "show only the latest quarterly status of inspection and defect correction", or whether all prior quarterly lists must also be retained.

Section 573.6 of the regulation requires the owner list to be "updated as of the end of each quarterly reporting period," with the list being retained for five years after the date on which the defect information report is initially submitted.

We do not consider this section to require all prior quarterly lists to be retained. Therefore if you maintain a list that shows only the latest quarterly status of inspection and defect correction you will be in compliance with the requirements.

WE ARE PLEASED TO BE OF ASSISTANCE.