ID: nht75-2.2

DATE: 12/16/75

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

TO: Engineering Services

COPYEE: M. I. SCHWIMMER

TITLE: FMVSS INTERPRETATION

TEXT: In response to your November 24, letter concerning the relationship between Federal Motor Vehicle Safety Standards Nos. 109 and 119, I am enclosing a copy of a prior interpretation letter on the same subject, which was sent to Mr. C. D. McCarty of the B. F. Goodrich Company on October 15, 1975.

ID: nht75-2.20

DATE: 08/25/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Firestone Tire & Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: I am writing to confirm the interpretation of Federal Motor Vehicle Safety Standard No. 119, New pneumatic tires for vehicles other than passenger cars, which was given to you by Mark Schwimmer on April 16, 1975.

Your letter of February 26, 1975, explained that:

(i) Firestone would produce 100 tires in size D50C-16.5 for use on one of the prototype vehicles in the Urban Mass Transit Administration's Trans-Bus program;

(ii) these tires would be certified as being in compliance with Standard No. 119; and

(iii) D50C-16.5 is a new size, not appearing in any existing tire and rim organization publications.

In such cases, S5.1(a) of the standard requires tire and rim matching information to be furnished to dealers of the manufacturer's tires. Your letter suggested that, because Firestone does not expect the tire to be sold through any dealers, this requirement would be inapplicable. As Mr. Schwimmer explained, that interpretation is incorrect. S5.1 of Standard No. 119 applies to all new bus tires, including prototypes manufactured for prototype vehicles. Therefore, you must furnish the matching information to all dealers of Firestone non-passenger-car tires.

Sincerely,

ATTACH.

February 26, 1975

Mark Schwimmer, Attorney -- Office of Chief Counsel, National Highway Traffic Safety Adm.

RE: TIRES FOR UMTA TRANS BUS PROGRAM

Dear Mr. Schwimmer:

As I advised you in our telephone conversation, Firestone has the contract to produce tires for the prototype vehicles being tested by UMTA currently. We have received an order for an additional 100 tires in size D50C-16.5 for use on the prototype manufactured by The Rohr Industries. Since these tires will be produced after March 3rd, they will be certified by Firestone as being in compliance with FMVSS 119.

Size D50C-16.5 is a new size and is not included in any list showing tire and rim matching information. FMVSS 119 specifies in Section S5.1(a) that where such information is not published in the documents listed it is to be supplied to dealers and to NHTSA.

By copy of the attached letter to the Tire Division, NHTSA, we are supplying the necessary information to NHTSA. However, since we have orders for only 100 tires to be used only on the prototype vehicle and since it is our understanding from the prime contractor that the test will be terminated at the end of this year, thereby precluding any possibility of this size being sold for this purpose through any dealers, we are not planning to send copies of the tire and rim matching information to our dealers.

May I have your confirmation that we will be acting within your interpretation of FMVSS 119 in this matter?

As you know, the testing of the three prototype buses is under the control of UMTA. It is not anticipated that any additional tires will be needed for the other two prototypes, however, if the prime contractors should order additional tires it would most likely be under the same conditions as the order received from Rohr Industrial and we would follow the same procedure as it is agreed will be acceptable with the D5OC-16.5 tires.

In view of the fact that an order has been placed with us, it would appear that the prime contractor anticipates a need in the near future. Therefore, we would appreciate your prompt attention to this matter.

Sincerely, A. J. DiMaggio -- QUALITY ASSURANCE, FIRESTONE

February 26, 1975

The Tire Division National Highway Traffic Safety Adm.

Gentlemen:

Pursuant to Section S5.1(a) Motor Vehicle Safety Standard 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, this is to advise that tire size D50C-16.5 is to be used with a 6.0 x 16.5 rim.

This size tire is not listed in any of the publications of the organizations listed in FMVSS 119.

Very truly yours, A. J. DiMaggio -- QUALITY ASSURANCE, FIRESTONE

ID: nht75-2.21

DATE: 10/03/75

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

TO: High & Walters

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your August 11, 1975, request for information on regulations concerning the matching of innertube sizes with motorcycle tire sizes. Federal Motor Vehicle Safety Standard No. 119 (copy enclosed) specifies performance and labeling requirements for motorcycle tires manufactured after March 1, 1975. There are no Federal regulations, however, containing requirements for proper matching of tubes with tires.

Yours truly,

Enclosure

HIGH & WALTERS -- ATTORNEYS AT LAW

August 11, 1975

Department of Transportation 400 - 7th Street SW Washington, D.C. 20590

TIPE SAFETY REGULATIONS

Madam or Sir, would you please inform this office how we might obtain any regulations of the Department of Transportation relating to proper tube sizes for particular tire sizes.

We are interested specifically in motorcycle tire regulations with regard to the size of the innertube for a given tire size.

Thank you in advance for your assistance with regard to this matter.

JAMES P. WALTERS

ID: nht75-2.22

DATE: 09/18/75

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

TO: Michelin Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 9, 1975, inquiring as to the proper designation of plies on a truck tire constructed with two polyamide plies in the casing and two steel plies in the belt.

The designation that you suggested ("Tread: 2 Steel Plies; Sidewall: 2 Polyamide Plies") is incorrect. The designation on such a tire should indicate the presence of four plies in the tread area and two in the sidewall area (with compositions in each case).

Yours truly,

ATTACH.

JULY 9, 1975

Administrator -- National Highway Traffic Safety Administration, Department of Transportation

Dear Sir:

The Michelin Tire Corporation will be offering for sale in the U.S.A. truck tires which contain casing plies made of polyamide and belts made of steel.

A typical tire would be constructed with two polyamide plies in the casing and two steel plies in the belt.

Pursuant to paragraph S6.5(f) of Federal Motor Vehicle Safety Standard 119, we will mark such a tire as follows: Tread: 2 Steel Plies Sidewall: 2 Polyamide Plies

Please advise us if this does not comply with the requirements of the regulation.

Thank you.

Yours truly,

MICHELIN TIRE CORPORATION Technical Group;

John B. White -- Engineering Manager, Technical Information Dept.

ID: nht75-2.23

DATE: 12/23/75

FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA

TO: FILE

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: VEHICLE REQUIREMENTS AND STANDARD NO. 119

On December 10, 1975, I received a telephone call from Mr. Dan Warner of Transportation Manufacturing Corporation in New Mexico (505 347-2011), concerning the scope of Standard No. 119.

Mr. Warner asked whether the standard required vehicles to be equipped with tires conforming to it. I explained that Standard 119 applies only to tires, while vehicles would be the subject of Standard No. 120. I declined to predict the issue date or effective dates of Standard 120, but assured him that the scheme of effective dates would take into account the realities of production and inventories.

Meaning of effective date of Standard No. 119

Attorney Advisor

Interps. file

On December 1, 1975, I received a telephone call from Mr. Nakajima of Bridgestone Tire Co. (213-320-6030) concerning the meaning of the March 1, 1975, effective date of Standard No. 119. He wanted confirmation that tires, for vehicles other than passenger cars, that were manufactured before that date are not subject to the standard's labeling requirements. I explained that his understanding was correct, citing 49 CFR @ 571.7.

Mark Schwimmer

ID: nht75-2.24

DATE: 08/18/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: County of Los Angeles Road Department

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of April 28, 1975, concerning tires used on pull brooms.

Federal Motor Vehicle Safety Standard No. 119, New pneumatic tires for vehicles other than passenger cars, (copy enclosed), specifies labeling and performance requirements for all tires designed for use on pull brooms. This standard applies to all such tires manufactured on or after March 1, 1975. There is presently no requirement, however, that vehicles be equipped with tires conforming to the standard. The National Highway Traffic Safety Administration has proposed and is considering the issuance of a new Standard No. 120, Tire selection and rims for motor vehicles other than passenger cars, which would require all new pull brooms manufactured after its effective date to be equipped with tires conforming to Standard No. 119.

YOURS TRULY,

TO: Dear Sir

FROM: (Illegible Word)

Date 3-6-75

Please send me all the necessary information you have about implement (Illegible Words) (Illegible Line)

Thank you

76L265 Cdb 274 LOS ANGELES COUNTY LETTERGRAM

TO: E.T. Driver

FROM: Carl Morton

Subject: Implement tires.

Date: 4-28-75

Reply no N41-33

Our fleet of Pull Brooms are equipped with implement rib type tires. They are used 100% of the time on Highways.

Please advise

Thank you Carl Morton

ID: nht75-2.25

DATE: 08/18/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Holiday Rambler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: I am writing in response to your letter of June 23, 1975, which inquired about the status of proposed Federal Motor Vehicle Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other than Passenger Cars.

The NHTSA expects to issue Standard No. 120 in the near future. It will not become effective September 1, 1975. An effective date which allows adequate lead time for manufacturers to prepare for compliance will be specified in a Federal Register notice when the rule is issued. Your second question, concerning the responsibility for providing GAWR and GVWR information for motor homes manufactured by you with chassis supplied by other manufacturers, will also be answered in that notice.

SINCERELY,

June 23, 1975

Administrator National Highway Traffic Safety Administration

This letter is in reference to proposed F.M.V.S.S. 120. Holiday Rambler Corporation is a large manufacturer of recreational vehicles and Multipurpose Passenger Vehicles. As regards to the proposed Standard 120, we request your answer to the following questions.

1. What is the present status of this proposed standard; Does the effective date remain September 1, 1975?

2. HRC purchases from various manufacturers large numbers of chassis-cab type truck chassis for use in class "C" motor homes and commercial vehicles and will purchase a number of regular truck chassis for use in Class "A" Motor Homes. These manufacturers certify these "incomplete vehicles" at a specified G.V.W.R. and G.A.W.R. which our completed vehicle may not exceed. As regards proposed Standard 120 then, would the incomplete vehicle manufacturer be responsible for furnishing the required information label, or would HRC be responsible using such information as supplied by the incomplete vehicle manufacturer?

Thank you for your time and consideration. If this letter requires further explanation, please feel free to call me at 219 862-4551. Otherwise you may address your reply to the address below. Your prompt reply would be greatly appreciated.

Terrell T. Coleman Codes and Standards Co-Ordinator

CC: S. MOSS; T. COLEMAN

ID: nht75-2.26

DATE: 11/10/75

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

TO: DPD Mfg. Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of September 22, 1975, requesting information concerning the applicability of Federal motor vehicle safety standards to automatic cruise control devices.

As you were advised by telephone, Motor Vehicle Safety Standard No. 124, Accelerator Control Systems, does not preclude the use of cruise control units. While Standard No. 124 requires that the accelerator control device return to "idle" when the operator removes his foot from the accelerator or when the system itself fails, the term "idle position" is defined in S4.1 of the standard to include the position set by a throttle setting device. The rationale for not regulating automatic speed control devices is found in the preamble to the standard, issued on April 8, 1972 (37 FR 7097), which states:

The rule does not contain requirements for automatic speed control devices. It was found that although nine recall campaigns involving 61,176 vehicles have concerned these devices, no relationship to accelerator overspeed accidents could be established from automatic speed controls. Of the 540 multi-disciplinary accident reports that were studied in formulating the final rule, none mentioned the automatic system.

There are no other Federal motor vehicle safety standards which are concerned with the use of automatic cruise control devices.

I trust this information will be useful to you. I have enclosed a copy of Standard No. 124 for your future reference.

YOURS TRULY,

September 22, 1975

U.S. Department of Transportation Federal Highway Administration National Highway Safety Bureau

Enclosed is a copy of our request to you for automatic cruise control safety standards.

Your telcon to us revealed that there were no safety standards applicable to cruise control. However, we need this information, in writing, to provide to our customers s required.

Thank you for an early reply.

DPD MFG. CO., INC.

O. D. Hunter Director of Training and Publications

May 21, 1975

U.S. Department of Transporation Federal Highway Administration National Highway Safety Bureau

We are embarked on a project to manufacture automobile, automatic cruise control devices. Accordingly, please forward appropriate safety standards for our guidance.

Thank you for an early reply.

DPD MFG. CO., INC.

O. D. Hunter Director of Training and Publications

ID: nht75-2.27

DATE: 03/11/75

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

TO: Joseph Lucas North America Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 7, 1975, in which you ask whether the control lever/throttle arm of diesel fuel injection equipment is considered part of the pump mechanism or part of the "linkage," i.e. the accelerator control system, within the meaning of Standard No. 124.

The control lever/throttle is similar to the throttle lever referred to in Docket 69-20, Notice 5 (copy attached). In that notice, we established that the throttle lever is not part of the "driver-operated accelerator control system", but rather part of the fuel metering device and therefore does not fall within the ambit of Standard No. 124.

Yours truly,

ATTACH.

February 7, 1975

Fred Schwartz -- Attorney Advisor, Office of the Chief Counsel, National Highway Traffic Safety Admin.

Dear Mr. Schwartz:

FMVSS 124 - Accelerator Control Systems

Joseph Lucas North America Inc. is a subsidiary of Joseph Lucas (Industries) Ltd. of England. Two other subsidiaries, CAV Limited and Simms Motor Units Limited manufacture diesel fuel injection equipment, some of which is exported to the United States fitted to engines, or as sold by Joseph Lucas North America Inc.

A question has arisen concerning the control lever/throttle arm on these pumps. Is this lever/arm part of the pump or it is part of the linkage?

Enclosed are two publications:

1. Publication No. 2067/4 - CAV DPA Distributor Type Fuel Injection Pump with Mechanical or Hydraulic Governor. The Green arrows on pages 2, 66, 67, 68, and 69 point out the item in question.

2. Publication P29E - Simms Mechanical Fuel Injection Pump. The green arrows on pages 2 and 3 point out the item in question.

We feel that this lever/arm is part of the injection pump, and not the linkage. Would you please confirm that our interpretation is correct?

Any help which you could give us in correctly interpreting the definition of such a pump mounted lever/arm would be appreciated, so that we may correctly appraise the arrangements on other such pumps.

Yours truly, JOSEPH LUCAS NORTH AMERICA INC. -- A. J. Burgess, Vice President (Technical)

Enclosures

ID: nht75-2.28

DATE: 07/18/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 19, 1975, seeking an interpretation of Standard No. 124, Accelerator Control Systems, with regard to an accelerator control system which contains either elements in parallel or a complete parallel system.

The requirements of S5.2 of Standard No. 124 are met if, after a severance or disconnection of any component of the accelerator control system, the throttle returns to the idle position within the time specified in S5.3, measured from the first removal of the opposing actuating force by the driver, or from the disconnection or severance. You are correct in your interpretation that Standard No. 124 is intended to protect against a single severance, and that there are no requirements in Standard No. 124 concerning the severance or disconnection of the remaining one(s) of two or more parallel elements in an accelerator control system.

SINCERELY,

June 19, 1975

James Schultz, Chief Counsel National Highway Traffic Safety Administration

Re: Request for Interpretation of FMVSS No. 124

Section S5.2 of FMVSS No. 124 - Accelerator Control Systems specifies requirements for return of the throttle to the idle position ". . . whenever any one component of the accelerator control system is disconnected or severed at a single point." The operation of this section of the standard is clear when the accelerator control system consists of a single series of links and/or cables and/or other connecting devices. Severance or disconnection at any one point will result in a loss of control by the operator and the return of the throttle to its idle position.

The situation is not as clear when the accelerator control system contains either elements in parallel or a complete parallel system. In this case if one of two or more parallel links, cables or other connecting devices is severed or disconnected, the operator still maintains control of the accelerator control system. Since the throttle does not return to the idle position at the time of severance or disconnection, the requirements of S5.2 will be met if the system returns to idle within the time limit specified by S5.3, measured from the first removal of the opposing actuating force by the driver.

With regard to the above situation it is our understanding there are no requirements in FMVSS No. 124 concerning the severance or disconnection of the remaining of two or more parallel elements in an accelerator control system since S5.2 refers to the severance or disconnection of only one component.

Thus the requirements of S5.2 would be met if such a system returns to the idle position within the specified time after the removal of the opposing actuating force.

Your verification of our understanding of the standard's applicability to parallel links or systems would be appreciated. Thank you for your prompt consideration of this request.

VOLVO OF AMERICA CORPORATION Product Engineering and Development

Donald J. Gobeille, Jr. Product Safety Engineer

CC: E. SKARIN/AB VOLVO