ID: nht91-2.19

DATE: March 8, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: A. Kling -- Hamadbik, Ltd.

TITLE: None

ATTACHMT: Attached to letter dated 10-12-90 from A. Kling to U.S. Dept of Transport, NHTSA (OCC 5696)

TEXT:

This responds to your inquiry about the color coding requirements in section S5.1.14 of Federal motor vehicle safety standard No. 116, Motor vehicle brake fluids. (49 CFR 571.116). After noting that DOT 3 and DOT 4 brake fluid must be colorless to amber, you asked what is the color coding range for amber. As explained below, the agency has decided not to specify a numerical or chromatic "range" for the color coding requirements. Instead, the appropriate method for determining compliance to the color coding requirements is through visual inspection.

The purpose of the color coding requirements is to permit easy identification of fluids before they are placed in a vehicle, in order to prevent the mixing of an incompatible fluid in a braking system. At one time, the National Highway Traffic Safety Administration (NHTSA) had proposed color requirements defined in terms of millimicrons. (38 FR 32142, November 21, 1973). However, when the agency later determined that visual inspection for color compliance was adequate, the proposed wavelength bands were deleted. (39 FR 30353, August 22, 1974)

In a subsequent notice, the agency explained that

The specifications for fluid colors are intended to refer to color ranges as generally interpreted in daylight by persons of normal color vision. No color coordinates are proposed, since the fluids may change color in storage or in use (without detriment to the performance of the fluids). (40 FR 56928, December 5, 1975)

Thus, the generally interpreted meaning for "amber" (which is defined as "yellowish-brown" by the Random House Dictionary of the English Language) should be used to determine if a brake fluid complies with the color coding requirements for DOT 3 and DOT 4 brake fluid.

I hope this information is helpful. If you have any further questions, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: nht88-1.92

TYPE: INTERPRETATION-NHTSA

DATE: 04/11/88

FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA

TO: Gary Hackett -- State of Nevada Taxi Cab Authority

TITLE: FMVSS INTERPRETATION

ATTACHMT: 5/10/74 letter from Lawrence R. Schneider to City of Philadelphia (Std. 206)

TEXT:

Mr. Gary Hackett State of Nevada Taxi Cab Authority Suite 200 1785 E. Square Las Vegas, NV 89155

This is in further response to your March 28, 1988, telephone conversation with Mr. Steve Wood of my staff in which you asked for an Interpretation of Federal Motor Vehicle Safety Standard No. 206, Door Locks and Door Retention Components. Your specific question asked whether Standard No. 206 requires door handles on rear doors of motor vehicles. The answer to your question is no.

The agency addressed the question you raise in a May 10, 1974, letter to Mr. Charles Murphy who asked whether manufacturers selling vehicles to the City of Philadelphia can remove the door handles from the vehicles' rear doors. In response, the agency in terpreted Standard No. 206 as not requiring an inside rear door handle. The National Highway Traffic Safety Administration stated that the standard's requirements that each passenger car rear door must have a locking mechanism that is operable from withi n the vehicle and that, when engaged, renders the outside and inside door handles inoperative (@4.1.3) specify the performance required of door locking mechanisms only. The agency thus indicated that the standard sets no requirements for inside rear door handles.

I have enclosed a copy of the Murphy letter for your information. Please feel free to contact my office if you have further questions. Sincerely,

Erika Z. Jones Chief Counsel

Enclosure - See 5/10/74 letter

ID: GF0044754

Mr. Russ Hunt
C/O Snider Tire Inc.
PO Box 16046
Greensboro, NC 27416-6046

Dear Mr. Hunt:

This is in response to your e-mail of July 13, 2004, in which you seek clarification of certain regulations pertaining to retreaded tires. Specifically, you ask whether it is permissible to remove or obscure certain information originally located on the sidewall of a medium truck tire during the retreading process.

By way of background, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, manufacturers are required to certify that their vehicles and equipment meet applicable requirements. The issues raised by your letter are addressed below.

There is no FMVSS applicable to retreaded tires for vehicles other than passenger cars. However, 49 CFR 574.5 does require each tire sold in the United States, including retreaded medium truck tires, to be labeled with Tire Identification Number (TIN) in order to facilitate a recall in the event of a defect.

The DOT symbol located on the sidewall of a medium truck tire may either remain or be removed from that tire prior to retreading (see 574.5, enclosed).

With respect to other information located on the tire sidewall, including manufacturer name, ply rating, and maximum pressure, no regulation requires retreaded tires (for vehicles other than passenger cars) to show this information, and no regulation prohibits a retreader from removing this information.

I hope you find this information helpful. If you have further questions, you may contact Mr. George Feygin of my staff at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosure
ref 574
d.9/7/04

ID: nht93-5.11

TYPE: Interpretation-NHTSA

DATE: July 7, 1993

FROM: Joel Trim -- Manager - Mechanical Service Dept., Neal and Massy Motors

TO: The Secretary -- U.S. Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9/27/93 from John Womack to Joel Trim (A41; Part 567)

TEXT:

Within recent times various owners of motorcars who have had their vehicle bodies modified (extended) in the main for Limousine Service have solicited my assistance in inspecting the modifications before inspection for licensing by our Road Transport Authorities. However, our country does not have any laws or regulations pertaining to the inspection and certification of these vehicles, nor for vehicles falling under the categories: Kit Cars or Homemade Vehicles.

As a result of this the owner of such vehicles are unable to obtain a license from the Transport Department to operate them legally on the roads. There are however a number of private modified (extended) vehicles on our roads.

I have discussed this matter with several persons some of whom are directly related to the Transport Department and it is in the general view that if proof is shown where these vehicles are modified, assembled, built and inspected according to certain National or International Standards, the Licensing Department of the Ministry of Transport may be willing to license these vehicles.

Could you be so kind to assist in obtaining copies of any existing regulations/standards which govern the certification and operation of such vehicles on highways.

Thanks very much for your assistance. I look forward in anticipation to your favorable response.

ID: nht88-3.21

TYPE: INTERPRETATION-NHTSA

DATE: 08/26/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: EARL DAHL -- THE GOODYEAR TIRE & RUBBER CO.

TITLE: NONE

ATTACHMT: LETTER DATED 06/01/88 TO ERIKA Z. JONES FROM EARL W. DAHL, OCC - 2106

TEXT: Dear Mr. Dahl:

This responds to your letter of June 1, 1988, seeking an interpretation of 49 CFR Part 574, Tire Identification and Recordkeeping. Specifically, you asked whether Goodyear could engrave its mold for the Tire Identification Number with a style of charact ers that was not specifically authorized in the Notes following Figure 1 of @ 574.5.

Note 1 to Figure 1 of Part 574 specifies only four different print types which may be used for the DOT symbol and tire identification number. The style of print that you wish to use is not one of these designated styles. Nevertheless, Note 4 to Figure 1 states that other print types will be permitted if approved by the National Highway Transportation Safety Administration (NHTSA). The agency has examined the print type shown in the diagram attached to your letter and has no objections to your company printing the required information in the print type you submitted.

You should be aware that in the final rule establishing Part 574 (35 FR 17257, November 10, 1970), NHTSA explained that the reason for specifying only four print types which would be acceptable without advance agency approval was to ensure that the infor mation would be easily readable by all persons. The print type that you submitted is easily readable and thus satisfies our concerns in that regard. Accordingly, NHTSA approves your print type.

Sincerely,

ID: nht75-1.3

DATE: 03/03/75

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

TO: Paul Utans

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 3, 1975 N40-30 (TWH)

Mr. Paul Utans 55 Concord Street Englewood, New Jersey 07621

Dear Mr. Utans:

This responds to your January 19, 1975, questions whether S5.4.3 of Standard No. 105-75, Hydraulic brake systems, permit a brake fluid warning statement on a filler cap to be partially obscured by a locking component placed over it, and whether the statement may include the name of an automobile manufacturer in association with the recommended type of brake fluid.

The answer to both of your questions is no. Section S5.4.3(b) requires that the statement be "located so as to be visible by direct view". This requirement prohibits an arrangement which would obscure any part of the statement, as would the design described in the drawings which accompany your letter. Section S5.4.3(b) permits a location within 4 inches of the brake fluid reservoir filler plug or cap to accommodate arrangements which do not permit use of the filler cap as a location.

The content of the brake fluid warning statement required by S5.4.3 is specified in every respect other than designation of the recommended type of brake fluid. However, S5.4.3 does limit the permissible designation to "the recommended type of brake fluid as specified in 49 CFR S?571.116" and sets out an example of "DOT 3". These criteria do not permit the addition of an automobile manufacturer's name. Such a recommendation could, of course, appear separately in the vehicle's owner's manual.

Yours truly,

Richard B. Dyson Assistant Chief Counsel

ID: Kim.1

Mr. Jongsoo Kim
Senior Researcher
Korea Automobile Testing & Research Institute (KATRI)
#625, SamJon-Ri, Sonmgsan-Myun
Hwasung-Si, Gyeonggi-Do, Korea (445-871)




Dear Mr. Kim:

This responds to your e-mail to Coleman Sachs of the Office of Vehicle Safety Compliance in which you seek clarification regarding the manner in which air bag cushion material is tested under Federal Motor Vehicle Safety Standard (FMVSS) No. 302, Flammability of Interior Materials. Specifically, you asked whether the air bag material is tested in an uninflated (pre-deployment) or inflated (post-deployment) state. As discussed below, the standards test requirements apply to air bag cushion materials in an uninflated state.

By way of background, the National Highway Traffic Safety Administration is authorized to issue FMVSSs that set performance requirements for new motor vehicles and items of motor vehicle equipment. Standard No. 302 sets forth burn resistance requirements for materials used in the occupant compartment of motor vehicles, in order to reduce deaths and injuries associated with vehicle fires caused by matches, cigarettes, or some other source. In general, the standards test procedures provide for a component specimen to be burned in a metal cabinet, and in order to meet the requirements of the standard, such materials may not exceed a specified burn rate within 60 seconds from the start of timing.

Paragraph S4.1 of the standard delineates the types of materials covered by the standard. That listing includes any other interior materials, including padding and crash-deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash. Paragraph S4.1 does not specifically address whether an air bag is tested in a pre-deployment or post-deployment state. Moreover, this issue has not been addressed in FMVSS No. 302 rulemakings. We do not read into the standard a test condition that the air bag be deployed prior to testing. Accordingly, when conducting testing under FMVSS No. 302, the agency will test the air bag cushion material in its uninflated (pre-deployment) state.

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

Sincerely,

Stephen P. Wood
Acting Chief Counsel

ref:302
d.5/17/06

ID: nht91-2.42

DATE: March 21, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Chris Lawrence -- Chang & Lawrence

TITLE: None

ATTACHMT: Attached to letter dated 8-17-89 from Stephen P. Wood to Alan S. Eldahr (VSA 108(a)(2)(A)); Also attached to letter dated 1-5-91 from Chris Lawrence to August L. Burgett (OCC 5764)

TEXT:

This is in reply to your letter to Dr. Burgett of this agency. Though dated January 5, 1991, we did not receive it until March 7.

With respect to your wish to produce an electronic sign board for installation in the rear window area, or on the rear, of a passenger car, I enclose a copy of an interpretation of this Office dated August 17, 1989, regarding such a device. Although the interpretation is restricted to an interior-mounted electronic sign board, our conclusion would not be changed were the device to be mounted on the outside of the rear of the vehicle. In that location, and as an item of original equipment, we believe that it would impair the effectiveness of the required rear lighting equipment by its potential to distract following drivers from the signals sent by the rear lamps when they and the sign board are operated simultaneously. Although the considerations for aftermarket devices are expressed differently, as explained in the August 1989 letter, the potential for distraction would appear to create a partial inoperability of the rear lamps within the meaning of the prohibition.

ID: nht87-2.16

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 18, 1987

FROM: MARY F. BARRAS -- SALES ASSISTANT, CONTRACT ADMINISTRATION, M.A.N. TRUCK & BUS

TO: MICHAEL W. VORIS -- BUS PROCUREMENT SUPERVISOR, METRO

TITLE: CONTRACT NO. T/F 19-84 REAR EMERGENCY WINDOW

ATTACHMT: MEMO DATED 2-23-88, TO JAY COSTA, FROM ERIKA Z. JONES, STD 271, REDBOOK A31; MEMO DATED 7-1-87, TO ERIKA Z. JONES, FROM JAY COSTA; MEMO DATED 6-25-87, CONTRACT NO. T/F 19-83 REAR EMERGENCY WINDOW

TEXT: In response to your letter of June 16, 1987 I am providing the following information in regard to converting the rear emergency window to a non-openable type window.

According to FMVSS 217, a total of 4,355 square inches is required for this bus. Please see the attached FMVSS information provided in regard to the computations used to arrive at this figure. Our bus has 19 windows, including the rear window, which totals 536 square inches per window. The bus also has 3 roof hatches which total 506.25 square inches per hatch. Therefore, the computations are listed below: 536 sq. ins. x 19 windows, including rear = 10,184 sq. ins. 506.25 sq. ins. x 3 roof hatches = 1,519 sq. ins. *11,703 sq. ins. * This total can be considered the accountable square inches on the bus in regard to safety requirements set forth by FMVSS 217. Also, 1,742 square inches (40%) of one side of the bus is unobstructed thereby, complying with this standard.

Therefore, the rear emergency window may be changed and the bus will remain within the FMVSS 217 boundries.

May we suggest that Metro directly contact the window manufacturer in regard to any modification to be made to this window so that warranty provisions do not become void. Please feel free to contact Mr. Mike Hurtekant at Excel Industries at (219) 264 -2131 in Elkhart, Indiana. ATTACHMENTS

ID: nht76-5.9

DATE: 05/28/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck Body and Equipment Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to the Truck Body Equipment Association's May 7, 1976, question whether S5.2.3.2 of Standard No. 217, Bus Window Retention and Release, requires that the engine starting system of a school bus not operate if an emergency exist other than an emergency door is locked. Section S5.2.3.2 applies to school buses manufactured on or after October 26, 1976.

Section S5.2.3.2 only specifies requirements for the relationship of the engine-starting system to the operation of emergency doors. Reference to "any emergency exit" in the first sentence of the section is in error, as the correct reference to "emergency door" in the second sentence of the section demonstrates. A correction of this error will be made in the text of the standard shortly.

SINCERELY,

TRUCK BODY AND EQUIPMENT ASSOCIATION, (Illegible Word)

May 7, 1976

Frank Berndt, Acting Chief Counsel NHTSA

A question concerning FMVSS 217 as it relates to "School Bus Emergency Exit Requirements" was discussed at our recent Engineering Meeting. Section S5.2.3.2 states:

"The engine starting system of a school bus shall not operate if any emergency exist is locked from either inside or outside the bus. For purposes of this requirement, 'locked' means that the release mechanism cannot be activated by a person at the door without a special device such as a key or special information such as a combination."

Our question concerns the use of the term "emergency exits" in this section with regards to the ignition interlock system.

Does this section require the installation of an ignition interlock system on push-out type emergency windows?

Thanking you in advance for your prompt reply.

Byron A. Crampton Manager of Engineering Services