ID: nht80-4.23

DATE: 12/04/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Toyo Kogyo USA Office

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 20, 1980, concerning Federal Motor Vehicle Safety Standard No. 115, Vehicle identification number (49 CFR 571.115).

Your question concerns the submission of horsepower data to the agency as required by the standard (S4.5.2). On February 25, 1980, the agency published an amendment to Standard No. 115 in the Federal Register (45 FR 12255) which authorized slight variations between the engine horsepower encoded in the vehicle identification number (VIN) and the actual engine horsepower. Except in the case of motorcycles, a variance in horsepower of plus or minus 10 percent was authorized. You wish to know whether the engine horsepower data you submit to the agency should be consistent with the VIN coding, or whether you should submit the precise horsepower.

The information which must be submitted pursuant to S6.3 is that necessary to decipher the characters contained in the VIN. Consequently, the engine horsepower submitted should represent the horsepower actually encoded in the VIN, whether or not this is the precise horsepower.

Sincerely,

ATTACH.

October 20, 1980

Frederic Schwartz -- Office of the Chief Counsel, National Highway Traffic Safety Administration

Dear Mr. Schwartz,

RE: Submission Data for VIN

As per our conversation concerning the above captioned matter, the following is (Illegible Word) question which we request to have your official written interpretation as soon as possible.

QUESTION

Is it necessary to submit the precise data concerning the engine net horse powers for each engine type which shows or certifies that our brake hose powers are within the same engine type differ or does not differ of more than 10 percent, in the case of the vehicles except motorcycles?

Sincerely yours, R. Kawaguchi -- Technical Representative, Toyo Kogyo USA Office

ID: nht75-4.2

DATE: 05/28/75

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

TO: Trailmaster Tanks, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Trailmaster Tank's May 14, 1975, request for a discussion of what constitutes the manufacture of a trailer in cases where used components from an existing vehicle are involved.

In response to a similar request from the Truck Trailer Manufacturers Association, the National Highway Traffic Safety Administration recently prepared a comprehensive discussion of this subject, a copy of which is enclosed for your information.

Yours Truly,

Trailmaster Tanks, Inc.

May 14, 1975

Mr. James C. Schultz Chief Counsel NH 13A - DOT

We manufacture transport trailers and with the new weight law, that has been passed, we need some information on the subject of stretching out a trailer. These trailers have already been manufactured and are in use at this time. We need to know, if the way that we plan to stretch out the trailers, if that is within the laws.

If you can send us some information on this subject, we will be most appreciative.

PHIL MARTINEZ, ENGINEER

ID: nht73-3.6

DATE: 01/03/73

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Office of Operating Systems

TITLE: FMVSS INTERPRETATION

TEXT: Your memorandum of November 27, 1972, concerning non-tabulated values for tire inflation pressures.

In response to the above-captioned memorandum, we, in coordination with the Chief Counsel's office, have concluded that Standard No. 110 does not preclude the use of odd-numbered tire inflation pressures on the placard required by S4.3 of Standard No. 110, and that the standard does not prohibit interpolation of the load values of the Standard No. 109 tables for purposes of compliance testing.

The relevant language of Standard No. 110 is in paragraphs S4.3 and S4.3.1:

S4.3 Placard. A placard, permanently affixed to the glove compartment door or an equally accessible location, shall display the --

(c) vehicle manufacturer's recommended cold tire inflation pressure for maximum loaded vehicle weight and, subject to the limitations of S4.3.1 for any other manufacturer-specified vehicle loading condition . . .

S4.3.1 No inflation pressure other than the maximum permissible inflation pressure may be specified unless --

(b) The vehicle loading condition for that pressure is specified; and

(c) The tire load rating from Table 1 of @ 571.109 for the tire at that pressure is not less than the vehicle load on the tire for that vehicle loading condition.

There is nothing in the standard which specifically requires the inflation pressure to be one actually listed (even-numbered) in the Tables of Standard No. 109. While paragraph S4.3.1(c) of Standard NO. 110, in referring to the load rating found in the table, arguably implies such a requirement, we cannot, without more specific language, read into the standard that recommended inflation pressures must be even-numbered. The mere fact that the specific tire load rating will not be printed in the table, however, does not preclude enforcement of the placard requirement. Because interpolation of values in a table is accepted engineering practice, we conclude that it is reasonable to interpolate such values in the Tables of Standard No. 109, for purposes of enforcing Standard No. 110, where manufacturers have specified odd-numbered inflation pressures.

ID: 2846o

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

Dear Mr. Hackett:

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 interpreted 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 within the vehicle and that, when engaged, renders the outside and inside door handles inoperative (S4.1.3) 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 ref:206 d:4/11/88

ID: 1985-04.20

TYPE: INTERPRETATION-NHTSA

DATE: 11/13/85

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Douglas I. Greenhaus

TITLE: FMVSS INTERPRETATION

TEXT:

November 13, 1985 Douglas I. Greenhaus, Esq. National Automobile Dealers Association 8400 Westpark Drive McLean, VA 22102 Dear Mr. Greenhaus: This is in response to your letter of September 30, 1985, to Taylor Vinson of this office. You present the situation of a dealer who "installs a rear mounted luggage rack, and moves the manufacturer installed stop lamp in compliance with the standard". You have asked "Does the franchised new car dealer incur a certification obligation under the above scenario?" This is an interesting question, and one which we have not been asked before. An additional certification is required by "a person who alters a vehicle that has previously been certified" if the alteration is "other components such as mirrors or tires and rim assemblies...." (49 CFR 567.7) In this instance, the center high- mounted stop lamp is not a "readily attachable component" within the meaning of the examples given by the regulation, and therefore the dealer as "alterer" must attach his certification that the vehicle as altered continues to conform. The component in question is one which was covered by the vehicle manufacturer's certification and its continued presence and complying location and visibility must be maintained after its removal and reinstallation so that the National Traffic and Motor Vehicle Safety Act is not violated when the car is sold to its first purchaser. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 19222.ztv

Mr. Edward L. Patterson, Sr.
Operations Manager
Gilbar Testing Laboratories, Inc.
6570 19 Mile Road
Sterling Heights, MI 48314

Dear Mr. Patterson:

We are replying to your letter of November 24, 1998, to Taylor Vinson of this Office, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment.

S7.8.2 of Standard No. 108 allows the installation of protective covers for headlamp aiming adjusters, "removable without the use of tools." You wish to manufacture a design to provide a locking feature. The design "would require only a slight rotating movement to lock." You "propose placing an indentation or hole in the cover, which would allow either a `key' or `coin' be used in order to accomplish this movement." You ask whether "the use of a coin or key, as proposed, be in violation."

The use of a key or coin to complete the locking movement would not result in a noncompliance with S7.8.2, but your letter implies that their use is also required for the cover to be removed. As we informed Ford Motor Company on February 12, 1998 (copy of letter enclosed), we consider an ignition key to be a "tool." If a tool is needed to remove a protective cover, then S7.8.2 has not been met. Similarly, we would consider a coin to be a "tool" when used for the purpose of removing the cover.

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

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:108
d.2/17/99

ID: 3063yy

Mr. Richard E. Wright
Richard E. Wright Associates
151 Fenwick Court
Delran, NJ 08075

Dear Mr. Wright:

This responds to your letter of May 3, 1991 concerning the possible applicability of the Federal Motor Vehicle Safety Standards to tempered glass products in travel trailers and motor homes. I am pleased to have this opportunity to explain the situation to you.

Some background information may be useful. The National Highway Traffic Safety Administration (NHTSA) has authority under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A), the Safety Act) to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Glazing, as an "addition to the motor vehicle," is considered to be an item of motor vehicle equipment (Section 102(4) of the Safety Act). New glazing material for use in motor vehicles is subject to the requirements of Standard No. 205, Glazing Materials (49 CFR 571.205). Standard No. 205 incorporates by reference "ANS Z26," the American National Standards Institute's Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways.

The agency has previously stated that Standard No. 205 does not apply to trailers, which our regulations define as "a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle." Thus, the standard would not apply to travel trailers.

NHTSA covers motor homes under Standard No. 205. Standard No. 205 specifies performance requirements for glazing material for use in specified locations in motor vehicles, including motor homes. The agency has previously stated that the standard establishes requirements for glazing used in windows and interior partitions in motor vehicles. Glazing used in locations other than windows and interior partitions would not be subject to the requirements of the standard.

I hope that this information is useful to you. If you have further questions, please contact John Rigby of this office at 202-366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Ref.# 205 D. 7/1/91

ID: nht91-4.33

DATE: July 1, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Richard E. Wright -- Richard E. Wright Associates

TITLE: None

ATTACHMT: Attached to letter dated 5-3-91 from Richard E. Wright to Chief Counsel, NHTSA (OCC 6005)

TEXT:

This responds to your letter of May 3, 1991 concerning the possible applicability of the Federal Motor Vehicle Safety Standards to tempered glass products in travel trailers and motor homes. I am pleased to have this opportunity to explain the situation to you.

Some background information may be useful. The National Highway Traffic Safety Administration (NHTSA) has authority under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A), the Safety Act) to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Glazing, as an "addition to the motor vehicle," is considered to be an item of motor vehicle equipment (Section 102(4) of the Safety Act). New glazing material for use in motor vehicles is subject to the requirements of Standard No. 205, Glazing Materials (49 CFR S571.205). Standard No. 205 incorporates by reference "ANS Z26," American National Standards Institute's Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways.

The agency has previously stated that Standard No. 205 does not apply to trailers, which our regulations define as "a motor vehicle with or without motive power, designed for carrying persons or property and for being drawn by another motor vehicle." Thus, the standard would not apply to travel trailers.

NHTSA covers motor homes under Standard No. 205. Standard No. 205 specifies performance requirements for glazing material for use in specified locations in motor vehicles, including motor homes. The agency has previously stated that the standard establishes requirements for glazing used in windows and interior partitions in motor vehicles. Glazing used in locations other than windows and interior partitions would not be subject to the requirements of the standard.

I hope that this information is useful to you. If you have further questions, please contact John Rigby of this office at 202-366-2992.

ID: nht93-6.34

DATE: September 8, 1993

FROM: Christopher S. Spencer -- Engineering

TO: R. C. Carter -- U.S. Department of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 4/25/94 from John Womack to Christopher S. Spencer (A42; Std. 121)

TEXT:

Allow me to introduce myself to you. I am an engineer at a manufacturer of air reservoirs for air braking systems. I am looking at modifying a present design. The new design is to improve the volume without increasing the need for more space. This design is to maintain a low cost as well. There is a problem with how to interpret the FMVSS-121 that I would like for you to help evaluate for me. According to FMVSS-121 Section S5.1.2.2 this reservoir should withstand a defined amount of pressure for 10 minutes. Generally speaking, this is 750 p.s.i. The safety standard does not clarify the test criteria specifically how the reservoir is to be sealed. We have tested two different ways. One shows acceptable results 100% of the time. The second way is not as impressive. Some people here say that both are valid test. My question to you is can we check reservoirs in either way. Why or why not. I look forward to hearing from you.

ID: nht69-1.29

DATE: 03/14/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: The Society of Motor Manufacturers and Traders Limited

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 9, 1969, to the Federal Highway Administrator concerning your 1963 Edition of the S.M.M.T. Tyre and Wheel Engineering Manual.

Federal Motor Vehicle Safety Standard No. 109, within Section S3, lists the "Tyre and Wheel Engineering Data Book dated 1965/1966 of the Society of Motor Manufacturers and Traders Limited (S.M.M.T.)" as one of the references containing acceptable test rims. When Standards No. 109 and No. 110 were developed, the National Highway Safety Bureau accepted the S.M.M.T. 1965/1966 Data Book tire and rim combinations based on established usage. We did not, nor do we at present intend to accept general updating of these referenced publications, either foreign or domestic, as valid reasons for answering Standard No. 109 and No. 110. Consequently, any new tire size designations or alternative rim sizes that you wish to list within Standards No. 109 or No. 110 will have to comply, on an individual basis, with the abbreviated guidelines as outlined in the October 5, 1968 Federal Register.