ID: 77-1.39

TYPE: INTERPRETATION-NHTSA

DATE: 03/04/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Trailer Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 20, 1976 asking for a clarification of the statement in my letter to you dated December 3, 1976, that "the light emitted by one bulb must not be perceived as performing the function of the other in addition to its design function."

It is evident from your letter and others that our previous interpretations of the term "optical combination" have been found to be ambiguous and lacking in the objective criteria that a Federal motor vehicle safety standard must provide. We have reviewed the matter, and now wish to modify our previous interpretation. In our view a lamp is "optically combined" when the same light source (i.e. bulb) and the same lens area fulfill two or more functions (e.g. taillamp and stop lamp, clearance lamp and turn signal lamp). A dual filament bulb would be regarded as the "same light source". In determining conformance, the photometric requirements for clearance and taillamp functions, where two bulbs are located in a single compartment, must be met with only the bulb energized that is designed to perform the specific function. But the 15 candlepower maximum under Standard No. 108, however, would be determined with both the taillamp and clearance lamp bulb energized. Further, the lamp must be located to meet requirements for both clearance and taillamps. Our re-interpretation means that the issue of light spill-over form one area of the lamp to another is irrelevant to conformance.

SINCERELY,

Trailer manufacturers association

December 20, 1976

Mr. Frank A. Berndt U.S. DEPARTMENT OF TRANSPORTATION

Further to my letter of October 29th, and yours of December 3, 1976 (N 40 - 30), the 47 Series Tite Lite contains a No. 57 2 CP bulb serving the clearance and sidemarker lamp functions and a No. 1157 3/32cp bulb serving the remaining functions.

Our question concerning this light was limited to whether the clearance lamp function is considered "optically combined."

Your December 3rd letter indicates that "the light emitted by one bulb must not be perceived as performing the function of the other in addition to its design function." We don't understand the meaning of this statement. In the 47 Series Tite-Lite, the No. 57 bulb provides the clearance lamp design function, yet the No. 1157 bulb which is always lit simultaneously certainly augments the light emitted by the clearance lamp, and will light the clearance lamp lens an appreciable amount if the design bulb was burned out. That would seem a safety feature.

An early response will be appreciated.

Director of Engineering

Donald I. Reed

ID: nht94-5.26

DATE: May 17, 1994

FROM: Dietmar K. Haenchen -- Manager Vehicle Regulations, Voirswagen of America, Inc.

TO: John Womack -- Acting Chief Counsel, NHTSA

COPYEE: Barbara Gray

TITLE: Request for Confirmation of Interpretation Relating to 49 CFR Parts 541 & 543, Theft Prevention Standard

ATTACHMT: Attached to letter dated 7/1/94 from John Womack to Dietmar R. Haeochen (A42; Part 543; Part 541

TEXT: This is to request an interpretation relative to the parts marking requirements for replacement parts on a vehicle which has been granted an exemption from parts marking pursuant to 49 CFR Part 543.

By letter dated May 7, 1993, NHTSA granted an exemption for the 1995 model year Volkswagen Corrado from the parts marking requirements based on a petition for exemption filed by Volkswagen on September 29, 1992. The Volkswagen Corrado was parts marked for the model years 1990 to 1994.

In an interpretation letter of October 12, 1989 to Saab-Scania of America, Inc., NHTSA stated that after a carline has been granted an exemption from the parts marking requirements, the replacement parts for that carline no longer need to be marked even if the replacement parts can also be used on prior model years during which the particular carline was parts marked and not exempt under Part 543.

Volkswagen has just determined that the Corrado will not be sold in the United States for the 1995 model year and as such, Volkswagen will not be selling vehicles covered under the exemption granted in the letter of May 7, 1993.

Our question is whether in line with the interpretation to Saab the marking of replacement parts for the Volkswagen Corrado carline can be terminated based on the exemption granted for the 1995 model year, even if the replacement parts can be used for earlier model years and even though the 1995 model year Corrado will not be sold in the United States (although it will be available in Europe).

4

Because we would like to take advantage of the cost savings from the termination of parts marking as soon as possible, your earliest possible response to the issue will be appreciated.

As an additional question with regard to replacement parts anti-theft marking, Volkswagen would like to know whether replacement parts marking can ever be terminated on carlines that were parts marked while they were in production, but which have been out of production for more than five years and which are therefore statistically low theft. The particular example Volkswagen has in mind is the Audi 5000 carline which was produced through the 1988 model year as a parts marked vehicle.

Thank you for your consideration of the issues in this letter.

ID: 24207.jeg

Jim Smith, Managing Engineer
Exponent
Failure Analysis Associates
1850 West Pinnacle Peak Road
Phoenix, AZ 85027

Dear Mr. Smith:

This responds to your letter concerning the calculation of chest g's for purposes of Standard No. 208, Occupant Crash Protection.

S6.3 of Standard No. 208 provides that, in specified tests, chest acceleration "shall not exceed 60 g's, except for intervals whose cumulative duration is not more than 3 milliseconds." You stated that your company's procedure totals up the maximum peaks and checks that the resultant acceleration does not exceed 60 g's, except for intervals whose cumulative duration is not more than 3 milliseconds. However, you have learned that NHTSA's Signal Analysis Software, consistent with SAE J1727, calculates chest g's with the 3 millisecond clip limit determined on a continuous basis. The practical effect of this latter approach is that chest g's will sometimes be lower (but never higher) than the former approach. You also noted that the "cumulative duration" language also appears in Standards No. 203 and No. 213.

Thank you for bringing this matter to our attention. We plan to initiate rulemaking shortly to address this issue.

Sincerely,
Jacqueline Glassman
Chief Counsel
ref:208
d.7/2/02

ID: nht88-3.15

TYPE: INTERPRETATION-NHTSA

DATE: 08/25/88

FROM: BEVERLY B. BYRON -- MEMBER OF CONGRESS

TO: NANCY MILLER, -- OFFICE OF CONGRESSIONAL AFFAIRS UNITED STATES DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 10/27/88 FROM ERIKA Z JONES TO BEVERLY B BYRON; REDBOOK A32, STANDARD 205 MEMORANDUM DATED 08/14/85 FROM C. RICHARD FRAVEL TO WHOM IT MAY CONCERN RE JOSEPH CIAMPA JR.; MEMORANDUM DATED 08/04/88 FROM ARTHUR J LOMART TO W HOM IT MAY CONCERN; LETTER DATED 08/01/88 FROM C. E. SHUE TO JOSEPH CIAMPA JR RE 0590630; LETTER DATED 09/12/88 FROM NANCY F MILLER TO BEVERLY B BYRON; LETTER DATED 08/24/88 FROM JOSEPH L. CIAMPA TO BEVERLY B. BYRON

TEXT: Dear Ms. Miller:

I have enclosed correspondence received from Mr. Joseph L. Ciampa, Jr. of 4855 Cherry Tree Lane, Sykesville, Maryland 21784 concerning a number of questions he has with regard to tinted automobile windows.

I would very much appreciate your assistance in reviewing those concerns which Mr. Ciampa has raised and providing me with appropriate information in order that I may properly respond.

ENCLOSURE

ID: nht70-1.3

DATE: 09/17/70

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Univeral Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: The Office of Trade Regulation Rules of the Federal Trade Commission has forwarded your letter of July 30, 1970, concerning tires marked "Radial" that have casing cord angles that vary as much as 15 degrees from 90 degrees.

Paragraph 33 of Federal Motor Vehicle Safety Standard No. 109 -- New Pneumatic Tires, Passenger Cars -- defines a radial ply tire as a "pneumatic tire in which the ply cords which extend to the bends are laid at substantially 90 degrees to the centerline of the trend".

The Bureau does not consider cords laid at 75 degrees to the centerline of the trend as "Radial" tires and tires marked as much would not be in compliance with the tire standard.

Persons importing tires that do not comply with the standard would be violating section 108(a) (1) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1397).

For your information enclosed is a copy of the Passenger Car Tire Standard and the National Traffic and Motor Vehicle Safety Act.

ID: nht70-1.8

DATE: 05/13/70

FROM: AUTHOR UNAVAILABLE; G. C. Nield for Rodolfo A. Diaz; NHTSA

TO: K. L. Rosenberger

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 18, 1970, concerning the use of tires designed for racing purposes for street use.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) prohibits the sale of motor vehicle equipment that does not comply with applicable Federal Motor Vehicle Safety Standards. Therefore, it would be a violation of the Act if someone manufactured or sold a passenger tire that did not meet Standard No. 109. However, the Act does not apply to the use of non-conforming tires so that it would be the sale of such tires for street purposes, not the use, that would be a violation of the Act.

With regard to your comments that the California Highway Patrol considers these tires "OK" for street use, we understand that the restriction in the California regulations is presently limited to the prohibition of the sale of racing tires for street use but that legislation has been introduced which would prohibit the use of such tires for street purposes.

ID: nht72-1.36

DATE: 09/05/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Toyo Kogyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 8, 1972, on the subject of the location of the anchorages for passive belt systems. We understand from your letter that you are considering using a door-mounted anchorage for your system, but we are uncertain as to the nature of your difficulties with Standard No. 210.

The standard does not prohibit door-mounted anchorages. If an anchorage can be placed on the door so that it directs the belt across the occupant at the angle specified in the standard, and if it also meets the strength requirements, then it would be considered to conform to the standard. It may be that the anchorage you are considering fails to provide the correct belt angle.

At this time there is no exemption provided for passive belts from the belt angle requirements of Standard No. 210. If you wish to petition for rulemaking to amend the requirements for passive belts, you should accompany your petition with full information concerning the system and the advantages of the proposed anchorage locations

ID: nht94-8.38

DATE: January 28, 1994

FROM: Steve Williams -- Director, Public Transportation, Mississippi Department of Education

TO: Terry L. Voy -- Consultant, Bureau of School Administration and Accreditation, Iowa Department of Education

TITLE: None

ATTACHMT: Attached to letter dated 5/31/94 from John Womack to Mike Parker (A42; Std. 222; Part 571.3), letter dated 4/18/94 from Mike Parker to Christopher Hart, and letter dated 1/31/94 from Steve Williams to William Moss

TEXT:

A school district in our state has expressed interest in installing four VCR's and TV monitors on a school bus. The equipment would be used to show films relating to drug education and would target long school bus routes. A school district in Arizona has implemented such a program on one bus and serves as a model for the interest expressed by the district in Mississippi.

The school district proposes to mount the equipment in a school bus equipped with luggage racks. Two units would be mounted in the front of the luggage racks on each side and two in the middle on each side. This provides for maximum visibility of the TV monitor.

We all applaud these efforts to provide an educational opportunity for students that must ride lengthy and time consuming bus routes. However, to my knowledge, there has been no official test conducted to certify the wiring, mounting, and installation of such equipment. This certainly raises various safety and liability concerns. However, it does not appear to be in conflict with the Federal Motor Vehicle Safety Standard 222, head impact zone.

The 1990 National Standards for School Buses and Operations (NSSBO) appear to most appropriately address this matter. Bus Body Standards - Interior (1), page 16, states in part:

Interior of bus shall be free of all unnecessary projections, which include luggage racks and attendant hand rails, likely to cause injury.

Based on the concerns expressed above, I am requesting an interpretation and/or opinion from the Interpretation Committee on the following questions:

1. Would the installation of VCR's and TV monitors in luggage racks on a school bus be prohibited based on the language of the 1990 NSSBO - Bus Body Standards - Interior (1), page 16.

2. Would the installation of VCR's and TV monitors in luggage racks on a school bus be prohibited based on any other standard included in the 1990 NSSBO.

3. In the committee's opinion, does installation of VCR's and TV

monitors on school buses as described above, violate any Federal Motor Vehicle Safety Standard. Although Federal Motor Vehicle Safety Standards regulate the manufacture and sale of school buses, it is the intent of national and state specifications that users (school districts) not modify or install any component contrary to Federal Motor Vehicle Safety Standards.

I appreciate your assistance and timely consideration of this matter. If you have any question, let me know.

ID: nht88-2.69

TYPE: INTERPRETATION-NHTSA

DATE: 07/13/88

FROM: KATHLEEN DEMETER -- NHTSA ASSISTANT CHIEF COUNSEL FOR GENERAL LAW

TO: LARRY P. EGLEY

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/09/89 FROM STEPHEN P. WOOD -- NHTSA TO LARRY P. EGLEY; REDBOOK A33 [2]; STANDARD 108; LETTER DATED 01/17/89 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 3028; LETTER DATED 05/23/89 FROM LARRY P. EGLEY TO KAT HLEEN DEMETER -- NHTSA; LETTER DATED 09/10/88 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 2530; REPORT DATED 09/10/88 FROM LARRY P. EGLEY, REQUEST FOR EVALUATION / INTERPRETATION OF PROPOSED INVENTION SUDDEN STOP FLASHER [SSF]; REPORT DATED 09/ 07/88 FROM LARRY P. EGLEY, AN APPEAL FOR VARIANT INTERPRETATION OF NHTSA STANDARDS AS THEY RELATE TO BRAKE LIGHTS AND THE SUDDEN STOP FLASHER [SSF]; LETTER DATED 06/23/88 FROM LARRY P. EGLEY TO RALPH HITCHCOCK -- NHTSA; OCC 2256; LETTER DATED 06/20/88 FR OM LEWIS S. BUCHANAN -- EPA TO LARRY P. EGLEY; OCC 2199; LETTER DATED 06/09/88 FROM LARRY P. EGLEY TO LEWIS BUCHANAN

TEXT: Dear Mr. Egley:

In a letter dated June 9, 1988, you requested our interpretation as to whether a new motor vehicle device would comply with applicable Federal Standards. You also asked that details of the device be afforded confidential treatment.

Please be informed that this agency requires all of its interpretations to be made publicly available. Hence, you must decide if you still desire an interpretation to be issued in this matter, with the result that the confidential status of the informat ion will be compromised. I am prepared to delete any information specifically identifying you or your address from our analysis if you so request, but the substantive information describing the item of motor vehicle equipment will be made part of the pu blicly available analysis.

No further action will be taken in this matter until we have received a response from you.

Sincerely,

ID: clarke.ztv

Mr. Robert M. Clarke
President
Truck Manufacturers Association
1225 New York Avenue, N.W.
Suite 300
Washington, DC 20005-6156

Dear Mr. Clarke:

This is in reply to your letter of July 11, 2003, regarding early warning reporting (EWR) requirements for manufacturers of incomplete vehicles, Subpart C of 49 CFR Part 579.

You referenced my letter of April 11, 2003, to Spartan Motors, Inc., in which I advised that manufacturers of incomplete medium-heavy vehicles and buses are subject to the limited reporting requirements of 49 CFR 579.27, rather than the comprehensive reporting requirements of Section 579.22. In my letter, I observed that EWR information is more likely to be received by the manufacturer completing the vehicle rather than by the manufacturer of the incomplete vehicle. However, you believe that "in the case of chassis-cab manufacturers, warranty claims, field reports, consumer complaints, etc. are usually filed with the chassis-cab manufacturers and their dealers, not the final stage manufacturers." Accordingly, you have asked whether your member companies that manufacture "chassis-cab incomplete vehicles" should report under Section 579.22 or Section 579.27.

It is possible that some relevant EWR information with respect to multi-stage vehicles may not be received by the final stage manufacturer. However, for many years, NHTSA has considered incomplete chassis to be items of original equipment. (Nonetheless, incomplete vehicle manufacturers are subject to NHTSAs defect and noncompliance responsibility and reporting regulation, 49 CFR Part 573.) Therefore, under the EWR regulation, "chassis-cab incomplete vehicles" are subject only to the limited reporting requirements of Section 579.27. Please note that the agency may consider this issue as part of its review of the EWR regulation conducted pursuant to 49 U.S.C. 30166(m)(5).

If you have any questions, you may call Taylor Vinson or Andrew DiMarsico of this Office (202-366-5263).

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:579
d.8/22/03