ID: nht74-5.54

DATE: 07/10/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Hellstar Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 17, 1974, requesting further information on the applicability of Federal safety standards to auxiliary fuel tanks.

Standard No. 301 does not apply directly to auxiliary or extra-capacity fuel tanks. However, it does apply to motor vehicle fuel systems. Therefore, if an auxiliary or extra-capacity tank is installed in the fuel system of a vehicle that is subject to the performance requirements of Standard No. 301, before its first purchase for purposes other than resale, causing that fuel system not to be in compliance with the standard, the person installing the tank or offering the vehicle for sale would be in violation of @108 (a)(1) of the National Traffic and Motor Vehicle Safety Act. Since Standard No. 301 becomes applicable to trucks with a GVWR of 6,000 pounds or less on September 1, 1976, the fuel systems of such trucks will have to meet the performance requirements of the standard as of that date.

The fact that a customer may have ordered the auxiliary or extra-capacity tank to be installed in the vehicle he is purchasing does not affect the installer's responsibilities under the Act. He would still be in violation of Standard No. 301 if the tank were installed prior to the first purchase causing the fuel system to be in noncompliance.

Auxiliary and extra-capacity fuel tanks are not subject to regulation under Standard No. 301 where they are installed after the first purchase of the vehicle for purposes other than resale. However, the auxiliary and extra-capacity tanks are subject to the

2 section of the National Traffic and Motor Vehicle Safety Act that authorizes the Secretary of Transportation to make a determination as to whether or not an item of motor vehicle equipment contains a safety-related defect. In the event that such a determination is made, the manufacturer may be compelled to notify purchasers of the hazard.

If the installation of the fuel tank occurs before the first purchase of the vehicle for purposes other than resale, the installer must affix to the vehicle an additional certification label stating the alterer's name, the date of the alteration completion, and that the vehicle conforms to all applicable safety standards in effect on a date no earlier than the manufacturing date of the original vehicle, and no later than the date the alterations were completed.

We appreciate your interest.

YOURS TRULY,

CORPORATION June 17, 1974

Richard B. Dyson Assistant Chief Counsel -- NHTSA

Re: N40-30 KK

Your letter to Merle Robberts did not state clearly what effects standard No. 301, Part 571 would have to pick up truck auxiliary fuel tanks when this standard takes effect in 1976.

If I am reading your letter correctly auxiliary fuel tanks will not be effected, even after 1976, as long as they are not installed prior to first sale. Is this a correct assumption?

We also manufacture a line of extra capacity fuel tanks where the original tank is removed and our tank is installed in its place. Would the above be true in this situation?

If a new truck dealer installed an auxiliary or a replacement fuel tank on a vehicle that was ordered by the customer, would he be in violation of Standard 301?

Would a person that installs an auxiliary or replacement fuel tank on a vehicle have to recertify this vehicle under Part 567 certification rules?

A reply to the above at your earliest convenience will be greatly appreciated.

John J. Gostomski President

ID: 3148o

Mr. Max J. Mizejewski
Foreign Marketing Specialists, Inc.
14451 Chambers Rd., Suite 155
Tustin, CA 92680

Dear Mr. Mizejewski:

This is in response to your letter in which you asked whether a product your company plans to import would be subject to any Federal motor vehicle safety standard (FMVSS). According to your letter, this product, which you refer to as a "Roadreader," attaches to the front of a motor vehicle and has two sensors which give a visual and audible alarm when the vehicle drifts off a road. You indicated that this product would be connected to the wiring related to the turn signals. You noted that this device does not affect vehicle functions such as acceleration, braking, lighting, or visibility. You further stated that if required, you would provide the device to NHTSA or another government agency for inspection.

Section 103 of the National Traffic and Motor Vehicle Safety Act ("Safety Act") directs the National Highway Traffic Safety Administration (NHTSA) to establish safety standards for motor vehicles and motor vehicle equipment. Title 49 CFR Part 571 contains the safety standards promulgated by the agency. Although you stated that this device does not affect the electrical wiring related to the turn lights, I suggest you closely review Standard No. 108, Lamps, Reflective Devices, and Associated Equipment (Copy enclosed). This safety standard applies to both motor vehicle equipment installed in new motor vehicles and replacement equipment sold in the aftermarket.

While I cannot conclusively say that this standard is or is not applicable to your product based on the limited facts in your letter, this standard may apply to your product because the wiring for your device is connected to components (i.e., turn lights) subject to the standard. For instance, S4.5.11 requires that components including the turn signal lamps must be wired to flash. More generally, S4.1.3 forbids the installation of an additional piece of motor vehicle equipment that impairs the lighting equipment required by Standard No. 108. Therefore, a device such as yours is permissible as original vehicle equipment provided that it does not impair the effectiveness of the lighting equipment required by the standard.

As for the sale of your product in the aftermarket for vehicles in use, Section 108 of the Safety Act prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with a FMVSS. Since an importer is defined by the Safety Act as a manufacturer, you should assure that installation of your device does not render inoperative, in whole or in part, the turn signal lamp or any other item of motor vehicle equipment subject to Standard No. 108.

As for your second question concerning inspection and approval of your product, you should be aware that NHTSA does not provide approvals of motor vehicles and motor vehicle equipment. Under Section 114 of the Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with all applicable safety standards. Further, as you noted, you would be responsible for recalling any safety-related defects which you or this agency finds in your product.

You also should be aware that laws from particular States may apply to your device. Therefore, you may wish to contact the State and local transportation authorities in the areas where you intend to market your product. The American Association of Motor Vehicle Administrators (4600 Wilson Boulevard, Arlington, Va. 22203) may also be able to provide information about State laws concerning devices similar to your product.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure /ref:VSA#108#108 d:ll/3/88

ID: 21770.rbm

Ms. Melba J. Collins
15614 Oakcrest Ln.
Little Rock, AR 72206





Dear Ms. Collins:

This responds to your letter to Rodney Slater, the Secretary of Transportation, asking whether it is legal to install "used" air bags in a vehicle. You wrote that after the air bag in your vehicle deployed, it was replaced with a used air bag. It is not clear from your letter what the condition of the air bag was when it was salvaged from another vehicle. Secretary Slater has asked this office to address your concerns.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized under Title 49, Chapter 301 of the U.S. Code (Motor Vehicle Safety) (Safety Act) to issue Federal motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. One of the standards established by NHTSA, Standard No. 208, Occupant Crash Protection (49 CFR 571.208), requires air bags be installed in cars and light trucks.

Your letter asks whether, when a deployed air bag is replaced, Federal law prohibits the use of a salvaged air bag as the replacement air bag. The answer to your question is no. The Safety Act does not require a manufacturer, distributor, dealer, or repair business to return a vehicle to compliance with a standard if a device or element of design has been "rendered inoperative" by another agent, such as a crash. Thus, Federal law does not require that deployed air bags be replaced or regulate the manner in which such air bags are replaced. However, some States may have requirements applicable to such replacements.

In order for a replacement air bag to provide protection to vehicle occupants, it is essential that the replacement be properly completed. The repair should be performed according to the procedures specified by the vehicle manufacturer. This may require replacement of system components in addition to the air bag inflator module such as crash sensors, wiring and other electronic components as specified by the manufacturer. As stated above, the repair or replacement of an air bag system is not addressed by federal regulations; however, manufacturers and/or insurance carriers may have policies addressing the use of salvage parts in the repair of crash vehicles. Finally, after the air bags are replaced, it is important that the air bag readiness indicator be in good working order to alert the occupants of any future malfunction of the air bag system.

While great care must be taken in any air bag replacement, the use of a salvaged air bag raises additional safety issues. An air bag may be rendered inoperable, for example, by damage in a low-speed crash, even if it has not been deployed. Likewise, even if the vehicle from which the air bag was removed had not been in a crash, the way in which the salvaged air bag was removed from the vehicle could affect how the air bag will perform in a crash. We would urge you to contact the vehicle or air bag manufacturer to determine whether and how a salvaged air bag could be inspected or tested to ensure that it is fully operable.

Finally, you may wish to consult a private attorney concerning the state law implications of using salvaged air bags to repair automobiles, including possible tort liability.

I hope you find this information helpful. If you have any other questions, please contact Rebecca MacPherson of my staff at this address or by phone at (202) 366-2992.





Sincerely,

Frank Seales, Jr.
Chief Counsel

ref:208
d.01/11/01

ID: nht74-4.32

DATE: 07/03/74

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

TO: Alfred Teves GMBH

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 10, 1974, request for permission to stamp label information on hose assemblies in place of banding, and to reduce S9.2.5 burst pressure from 350 to 100 psi, and your further request for an interpretation of the status of an in-line check valve as part of a vacuum brake hose.

The in-line check valve is not subject to Standard No. 106, Brake hoses, as a brake hose and fitting. In this configuration, the couplers depicted in your drawing are the clamps, and the check valve is a separate component to which the hose assemblies are attached.

The issue of stamping instead of banding will be answered in our upcoming Notice 11 in response to petitions for reconsideration of the brake hose standard.

Your petition for a reduction in the burst strength requirement for vacuum hoses is denied. The minimum burst pressure of 350 psi was established by the Society of Automotive Engineers in 1942, taking into consideration the effects of backfire pressure and the severe underhood environment to which vacuum hose may be exposed. Hoses with this burst pressure have provided excellent reliability and durability. We have no data to justify a reduction in burst strength in view of the two hazards just cited.

MAY 10, 1974

National Highway Traffic Safety Administration US Department of Transportation

Subject: Motor Vehicle Safety Standard No. 106

(Docket no. 1-5, Notice 10

According to Notice 10 the designation of fittings was dropped due to objections raised by various manufactures because of insufficient clearness. For years we successfully used to emboss the date of manufacture on to the fittings (after the swaging process). We therefore ask you to extend item S 5.2.4 to the effect that in case of two-piece end fittings, which are attached by crimping or swaging, embossing of the designation on to the fittings will also be allowed instead of using a band.

The present standard according to which only a band will be allowed would be connected with a high degree of capital expenditure (reconstruction of entire assembly machinery) for the manufacturing department of Alfred Teves GmbH.

As far as vacuum brake hoses (see item S 9.2.5) are concerned, we think that a 350 psi burst strength is too high. The maximum operating pressure amounts to a vacuum of 0,80 bar, so that the required 350 psi would mean a 27-fold safety.

For this field of application a burst strength of 100 psi is sufficient. We therefore ask you to amend item S 9.2.5 to the effect that in the case of vacuum brake tubes the burst strength will be reduced to 100 psi.

Our production programm also comprises a vacuum check valve, which 1st mounted between two vacuum brake tubes, according to the attached sketch. We kindly ask you to inform us whether in the case of vacuum check valves the same requirements as are applicable for complete brake tubes regarding a burst strength of 350 psi (item S 9.2.5) and a minimum cross-section of 70% (item S 9.2.1) will be made.

Considering the near effective date of FMVSS, we would like to receive your answer concerning the three items mentioned above as soon as possible.

Yours sincerely

ALFRED TEVES GMBH

ppa.

i.V.

BELLER

Attachment

1 sketch

Ruckschiagventil

Schlauchhalter

Vakuumschiauch

(Graphics omitted)

ID: 19436.ztv

Mr. Derek Shepherd
North American Automotive Group
7770 St. Marlo Parkway
Duluth, GA 30097

Dear Mr. Shepherd:

This is in reply to your letter of January 4, 1999, to Paul Atelsek of this Office. We regret the delay in answering.

You seek our "approval" of your product, the Safety Pulse, a device that causes the center-highmounted stop lamp ("CHMSL") to flash when the brake pedal is applied. You state that this type of product has been sold on the market for a number of years, and, that to the best of your knowledge, "none of these companies have asked for a letter of approval from your office." Further, you believe that DOT "regulations are relatively vague in terms of pulsing the 3^rd brake light."

We have no authority to approve or disapprove any motor vehicle or item of motor vehicle equipment. We do provide opinions as to the relationship of a particular product or its use to the Federal laws and regulations that we administer. Over the years, we have, in fact, provided a number of opinions on flashing CHMSL's. In our opinion, the applicable DOT regulation is straight-forward and clear on the subject. That regulation is Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment. S5.5.10(a), (b), and (c) of Standard No. 108 list the lamps which are permitted to flash. Stop lamps are not among them. S5.5.10(d) requires all other motor vehicle lamps to be steady-burning in use. "All other motor vehicle lamps" includes all stop lamps, including the CHMSL. The lighting standard is premised upon consistency of performance. We believe that the presence of both flashing and steady-burning stop lamps could result in momentary confusion as to the intended "message" of the flashing lamp, causing a delay in applying the brake pedal. For this reason, we do not allow CHMSLs to flash.

We believe that your uncertainty as to legality may be caused by the products available in the aftermarket that can cause the CHMSL to flash. Manufacture and sale of this product is not illegal under Federal law because this product, an automotive accessory module that can flash lamps, is not specifically regulated by our safety standard.

However, Federal law provides that a "manufacturer, distributor, dealer, or motor vehicle repair business" may not modify a vehicle so that it no longer conforms to Standard No. 108.

Installation of a device by one of these four entities that causes a CHMSL to flash would create a noncompliance with Standard No. 108, and therefore be a violation of 49 U.S.C. 30122. A civil penalty of up to $1,100 per violation could be imposed, up to $880,000 for a related series of violations. Please note that a vehicle owner does not violate Federal law if (s)he installs the device, but the legality of its use remains subject to state and local laws. We are unable to advise you about them. In spite of the fact that the prohibition of Sec. 30122 does not cover modifications by owners, it is not in the interest of safety for an owner to disconnect or modify the performance of equipment originally installed in order to comply with a Federal safety requirement.

Even though your product is not regulated by Standard No. 108, as an accessory or an addition to a motor vehicle, it is "motor vehicle equipment" as we define it (49 U.S.C. 30102(a)(7)(B)). This means that, if either you or we determine that it contains a safety related defect, such as shorting out other lamps, you, as its manufacturer, must notify and remedy the defect as required by 49 U.S.C. 30118-30120.

If you have any questions, please call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.9/27/99

ID: 13494.ztv

Mr. Dion A. DeVan
13061 Lakeridge Dr.
Spanish Lake, MO 63138-3307

Dear Mr DeVan:

This is in reply to your e-mail of January 2, 1997, to this Office. You informed us that you are building a "one-of-a-kind" truck/van, and need information such as how you can get a copy of the National Highway Traffic Safety Administration's "codes," whether you need a manufacturer's license, and how you "go about getting certification for GVWR, Safety, and Emissions?"

Under our primary safety statute, 49 U.S.C. Chapter 301, Motor Vehicle Safety, "manufacturer" means any person manufacturing or assembling motor vehicles . Even if someone produces only a single motor vehicle, that vehicle must be certified to conform to all applicable Federal motor vehicle safety standards if its producer intends it to operate on the public roads. The Federal motor vehicle safety standards are found at Title 49 Code of Federal Regulations Part 571. As we are unsure of the final configuration of your "truck/van," you should review the definitions of "truck" and "multipurpose passenger vehicle" under Sec. 571.3(b) to see which is most appropriate to your vehicle. The application section near the beginning of each Federal safety standard will tell you whether that standard applies to multipurpose passenger vehicles and trucks.

I enclose an information sheet that will tell you how you may get a copy of Title 49. No Federal license is required to manufacture a vehicle or vehicles, though a manufacturer of vehicles must file a simple identification statement with the agency.

Manufacturers must certify compliance of their vehicles with the Federal safety standards on the basis of their own engineering judgment and test data. Certification is achieved through affixing a plaque permanently to the vehicle (49 C.F.R. Part 567), which contains the vehicle's GVWR.

The Environmental Protection Agency enforces Federal emissions regulations, and we are unable to advise you as to their applicability to your truck/van.

We appreciate your interest in the Federal motor vehicle programs. If you have any further questions, you may call Taylor Vinson of this Office at 202-366-5263. Because of the public interest in our interpretations and our desire to make them available to all interested persons, it is not our policy to reply by e-mail to requests for interpretations.

Sincerely,
John Womack
Acting Chief Counsel
Enclosure
ref:571
d.6/24/97

ID: nht73-4.21

DATE: 05/21/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Highway Aircraft Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of April 24, 1973, to Mr. Schneider asking for an interpretation that the Fascination vehicle your company proposes to manufacture is "an automobile." You state that you "are currently testing both a single wheel and a dual wheel arrangement on the front, and it is not clear yet which one will prevail."

If the final configuration of the Fascination were that of a four-wheeled vehicle it would be categorized as a "passenger car" under the Federal Motor Vehicle Safety Standards. Currently all three-wheeled vehicles are classified under our regulations as "motorcycles." Under a recent rule making proposal, a copy of which I enclose, the definition of a motorcycle with three wheels would be restricted to those lacking a full or partial enclosure for the driver, clearly excluding the Fascination. If the proposal is adopted, and you choose the three-wheel configuration for the Fascination, then the vehicle would probably be classified as a passenger car. It is possible that some adjustments would be made in the standards applied to three-wheeled or other lightweight vehicles, on petitions received from those interested.

ENC.

Highway Aircraft Corp.

April 24, 1973

Lawrence Schneider Office of Chief Counsel National Highway Traffic Safety Admin.

We are in final stages of development and testing on our new FASCINATION automobile. We have been in communication with Roger Compton and other members of the National Highway Traffic Safety Administration staff, and it has come to our attention that it is necessary for us to request a ruling as to the classification of our automobile. At least we feel it is an automobile; however, some of the regulations relating to three-wheel vehicles seem to confuse the issue.

We have no desire to side step any of the safety laws, which might be the case if our vehicle were called a motocycle. It has further come to our attention that several of the states have laws that classify a three-wheel vehicle as a motorcycle. It is therefore our desire to secure a ruling from your office that would clearly establish the FASCINATION as an automobile. This would make us subject to all the safety laws and would give us a sound basis upon which to approach the various states in which we will be licensing the car.

This is a four-passenger vehicle. The passenger compartment is 58" wide, the rear track width is 63", and the wheelbase is 130". The car will weigh something less than 2,000 pounds. We are currently testing both a single wheel and a dual wheel arrangement on the front, and it is not clear yet which one will prevail.

If any further details will be needed to clear up the situation, please contact us immediately. We will be waiting for your reply.

Doran Rhodes Assistant to the President

ID: Alliance.1

Robert Strassburger, Vice President
Vehicle Safety & Harmonization
Alliance of Automobile Manufacturers
1401 Eye Street, NW, Suite 900
Washington, DC20005-6562




Dear Mr. Strassburger:

This acknowledges receipt of your October 24, 2005, letter regarding our September 7, 2005, final rule responding to petitions for reconsideration under Federal Motor Vehicle Safety Standard (FMVSS) No. 138, Tire Pressure Monitoring Systems (TPMS)(70 FR 53079). Specifically, your letter raised an issue with paragraph S4.4(c)(2) of the standard, which sets requirements for flashing a combined low tire pressure/TPMS malfunction telltale for a period of 60-90 seconds to indicate to the driver when one or more malfunctions in the TPMS have occurred. The Alliance believes that this provision of the standard, as explained in the final rule, is design restrictive to the extent that the flashing sequence for a combined TPMS telltale is permitted only once per ignition cycle, regardless of the number of TPMS malfunctions encountered. Your letter also, argued that there is not a safety need to restrict the combined TPMS telltale to a single flashing sequence in the rare event of multiple TPMS malfunctions.

According to the Alliance, many current TPMSs have design architectures that automatically send a TPMS malfunction alert each time a new malfunction is detected, and you suggested that for manufacturers using such systems, a redesign would not be practicable before the September 1, 2007, compliance date for the TPMS malfunction indicator requirement. Consequently, your letter requested that the agency permit, but not require, vehicle manufacturers to install TPMSs with combined telltales that reinitiate the prescribed flashing sequence upon detection of subsequent TPMS malfunctions. Your letter sought this result either through a letter of interpretation of S4.4(c)(2), or alternatively, you asked that your letter be treated as a petition for reconsideration of the September 7, 2005, final rule.

Given the language of the standard and the preambles generally clear explanation of the agencys expectations regarding the requirements of S4.4(c)(2), we do not believe that the issue you have raised is amenable to a response via a letter of interpretation. Accordingly, we have decided to treat your letter as a petition for reconsideration of the final rule, and after careful consideration of the issue you have raised, we will respond accordingly.

If you have further questions, please feel free to contact Mr. Eric Stas of my staff at (202) 366-2992.

Sincerely,

Stephen P. Wood
Acting Chief Counsel

cc: Docket No. NHTSA-2005-22251
ref:138
d.12/21/05

ID: 77-3.40

TYPE: INTERPRETATION-NHTSA

DATE: 08/03/77

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

TO: Michelin Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your June 7, 1977, letter asking who must mark a rim in accordance with the requirements of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars, in those cases where the rim is manufactured by one manufacturer and then supplied to a wheel manufacturer who welds the rim to a disc making a completed wheel.

The National Highway Traffic Safety Administration has determined that the rim marking must be undertaken by the rim manufacturer. The rim manufacturer is best able to supply the required rim information and undertake the certification required by S5.2 of the standard. The subsequent addition of the disc to the rim should not alter the information marked on the rim.

SINCERELY,

JUNE 7, 1977

Office of the Chief Counsel National Highway Traffic Safety Administration Department of Transportation

Re: FMVSS 120, Tire Selection and Rims for Motor Vehicles other than Passenger Cars

We are writing to request an interpretation of the rim marking requirement of FMVSS 120 Tire Selection and Rims for Motor Vehicle other than Passenger Cars.

We are interested in the case where a rim manufacturer supplies rims to a wheel manufacturer who then welds these rims to discs thus producing wheels. In such a situation, is the rim manufacturer or the wheel manufacturer responsible for the markings required by FMVSS 120?

Your prompt reply to this inquiry would be appreciated.

MICHELIN TIRE CORPORATION Technical Group

John B. White Engineering Manager Technical Information Dept.

TELEGRAPHIC MESSAGE

NAME OF AGENCY:

Department of Transportation National Highway Traffic Safety Adm. PRECEDENCE Action P (Illegible Word) DATE PREPARED: 8/16/77

SECURITY CLASSIFICATION

TYPE OF (Illegible Word): [x] (Illegible Word) [] BOOK [] MULTIPLE-ADDRESS

NAME: Fred Koch PHONE NUMBER: 202-426-2800

THIS SPACE FOR USE OF COMMUNICATION UNIT: #26417

TO: ROBERT STEVENSON TECHNICAL SALES MANAGER, WHEEL DIVISION GKN SANKEY, LIMITED

PURSUANT TO YOUR TELEPHONE CALL OF AUGUST 15, 1977, TO FRED KOCH REGARDING FEDERAL MOTOR VEHICLE SAFETY STANDARD NO. 120, OUR ANSWERS TO YOUR TWO QUESTIONS FOLLOW.

1. REGARDING THE PRESENCE OF MOLDED LETTERING ON RIM SURFACES IDENTIFYING MILL SOURCE OF MATERIAL NOT SPECIFIED IN THE STANDARD, THERE IS NO OBJECTION TO SUCH MARKING APPEARING ON THE FINISHED RIM PROVIDED IT DOES NOT INTERFERE WITH UNDERSTANDING AND CLARITY OF SEPARATE MARKINGS REQUIRED BY THE STANDARD.

2. REGARDING THE SPACING OF NUMBERS ON THE RIM REPRESENTING DATE OF MANUFACTURER, THE INTENT IS TO MINIMIZE AREA OCCUPIED AND TO AVOID IRREGULAR OR INCONSISTENT SPACING AND OPENINGS IN WHICH INFORMATION MIGHT BE LOST OR UNDETECTED. HOWEVER, THE USE OF VERY SHORT SPACING BETWEEN MONTH, DAY, AND YEAR IS NOT PROHIBITED BY THE STANDARD.

E. T. DRIVER, DIRECTOR OFFICE OF CRASH AVOIDANCE MOTOR VEHICLE PROGRAMS NMV-30 PAGE NO.: 2 NO. OF PGS.: 2

ID: nht75-3.4

DATE: 11/05/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: General Electric Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 8, 1975, to Ed Leysath of this agency concerning wattage requirements for Type 1A and 2A headlamps.

Your specific question is whether the wattage specifications in Federal Motor Vehicle Safety Standard No. 108 for Type 1A and 2A headlamps are design wattages or maximum wattages.

Paragraph S4.1.1.21(b) of Standard No. 108 specifies that, "Each Type 1A headlamp shall be designed for a maximum of 50 watts. Each Type 2A headlamp shall be designed for a maximum of 60 watts for each filament." (Emphasis added.) It follows, therefore, that the 50 - and 60-watt values are design wattages. You are correct in your interpretation that a tolerance of approximately 7.5% applies to these values, and that an ampere value of 4.20 for a 50-watt filament and 5.02 for a 60-watt filament is permitted. The 7.5% tolerance as you know is the average actual maximum wattage (as opposed to design wattage) rating of headlamps listed in Table 2 of SAE Standard J573 as determined by multiplication of the maximum amperage times the design volts.

Sincerely,

ATTACH.

GENERAL ELECTRIC COMPANY

July 8, 1975

Ed Leyseth -- National Highway Traffic Safety Administration, Department of Transportation

Subject: FMVSS 108 - Section 4.1.1.2.1

Dear Mr. Leyseth,

On March 26, 1975 I wrote to Bill Eason and requested an interpretation of the wattage requirements of the rectangular headlamp system. (copy enclosed). To date we have heard nothing and we urgently need your reply.

I would appreciate your help in providing us with your interpretation as quickly as possible.

Very truly yours,

Frank W. Bowers -- Manager, Product Reliability

attach: copy of 3/26/75 letter March 26, 1975

William Eason -- National Highway Safety Administration, Department of Transportation

Subject: FMVSS 108 - Section 4.1.1.21

Dear Mr. Eason:

I have heard that the Department of Transportation has interpreted Section 4.1.1.21(6) of FMVSS as far as the wattage limitation on Type 1A and Type 2A rectangular headlamps is concerned.

It is my understanding that the 50 watt limit on the Type 1A and the 60 watt limit on the 2A apply as design maximums and that a tolerance of approximate 7.5% applies to these values. This, then, would permit a max. ampere value of 4.20 for a 50 watt filament and 5.02 for a 60 watt filament. If a 40 watt filament is used than its max. amperes would be 3.36.

I agree with this interpretation and understand that these are the figures that SAE is proposing.

I would appreciate it very much if you would confirm that this interpretation is correct since design and certification of the product depends upon an accurate interpretation of the standard.

Thanks very much for your help in this matter.

Very truly yours,

F. W. Bowers -- Manager, Product Reliability

bcc: R. G. Burnor #1200