ID: nht70-1.19

DATE: 07/01/70 EST

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSR INTERPRETATION

TEXT: In response to your letter of July 9 to Mr. Toms I would like to make clear that the creation of the subcategory "mobile structure trailer" does not remove mobile homes towed on their own wheels from their original categorization under the Federal motor vehicle safety standards as trailers. This means that rule making actions applicable to "trailers" are also applicable to mobile homes unless there is specific language indicating that a Federal standard or portion thereof does not apply to a mobile structure trailer.

Therefore, in answer to your specific questions:

(a) Proposed Standards Nos. 119 and 120 would apply to trailers and therefore to mobile structure trailers.

(b) No proposal has been issued which would extend the Federal hydraulic brake standard, No. 105, to cover trailers. Therefore a State may adopt hydraulic brake requirements for mobile homes. However, we have issued a proposal (Docket No. 70-16; 35 F.R. 10456, June 26, 1970) which would establish requirements for "trailers equipped with air brake systems". If adopted, this new standard would preclude a state from adopting other than identical air brake requirements for mobile homes and other trailers. The point may be academic as it is my understanding that mobile homes, as a rule, are equipped with electric brakes.

ID: nht70-1.2

DATE: 10/06/70

FROM: AUTHOR UNAVAILABLE; G. C. Nield; NHTSA

TO: European Tyre and Rim Technical Organization

TITLE: FMVSS INTERPRETATION

TEXT: (Illegible Text)

ID: nht70-1.20

DATE: 09/14/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Mobile Homes Manufacturers Association

TITLE: FMVSR INTERPRETATION

ID: nht70-1.21

DATE: 06/03/70

FROM: Rodolfo A. Diaz; signature by George Nield -- NHTSA

TO: Export Vehicle Engineering Dept.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 20 in which you ask "whether the Station Wagon should be construed as a Passenger Car or a Multipurpose Passenger Vehicle".

You are correct in your interpretation that a station wagon "does not normally fall under" the category of multipurpose passenger vehicle. However, if a station wagon "is constructed on a truck chassis" or "with special features for occasional off-road operation", such as four-wheel drive, it would be considered a multipurpose passenger vehicle. I hope this clarifies the matter for you.

ID: nht70-1.22

DATE: 10/27/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: General Motors Technical Center

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter to Mr. Toms of October 15, 1970, in which you asked whether General Motors could provide one consumer information document to fleet purchasers of motor vehicles, rather than putting a booklet in each car as is done in the usual case.

The answer is yes. 49 CFR 575.6(a) requires that the information be provided "to that purchaser", "at the time a motor vehicle is delivered" to him. It does not require that the information be in the vehicle, or that there be one booklet per vehicle.

We are pleased to be of assistance.

ID: nht70-1.23

DATE: 03/04/70

FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA

TO: Trelleborg Rubber Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of February 4, 1970, to the National Highway Safety Bureau concerning the labeling requirements for motor vehicle tires manufactured prior to August 1, 1968.

Federal Motor Vehicle Safety Standard No. 109 requires that all motor vehicle passenger car tires manufactured after January 1, 1968, conform to the requirements as cited. I have enclosed a copy of Standard No. 109 and No. 110 with amendments for your reference.

Section 54.3 specifies the labeling requirements. You will note 54.3.1 permits the sale of tires manufactured during the period January 1, 1968, to August 1, 1968, which have a label or tag affixed that incorporates the specified information. Inclusion of information on the invoice does not relieve the manufacturer from affiding the proper labeling on each tire.

ID: nht70-1.24

DATE: 04/17/70

FROM: Lawrence R. Schneider; NHTSA

TO: Hans J. Loeffler

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to our letter of April 5 and confirms your understanding that any Porsche automobile manufactured prior to January 1, 1968, need not confirm to Federal motor vehicle safety standards in order to be admitted into the United States.

If you wish to import a vehicle manufactured prior to that date, you may be asked to execute Form Ne-7 (Importation of Motor Vehicles and Motor Vehicle Equipment Subject to Federal Motor Vehicle Safety Standards) at the port of entry. You should supply the vehicle data requested and check box 1, the declaration that "The merchandise was manufactured on a date when there was no Federal motor vehicle safety standard in effect which was applicable to it". I enclose a copy of this Form for your information.

ID: nht70-1.25

DATE: 06/20/70

FROM: Lawrence R. Schneider; NHTSA

TO: Massachusetts Institute of Technology

TITLE: FMVSR INTERPRETATION

TEXT: I have read with great interest your letter of June 10 and its enclosures. You appear to be seeking an assurance that "we, the C&CR Organization Committee, are complying with all Federal rules and regulations in regard to highway safety", and information ensuring "that the race vehicles involved are satisfactory to [National Highway Safety Bureau] specifications and regulations".

The first part of your inquiry really requires a response from us to [Illegible Words] of your entry rules, which states that the entrant shall "Satisfy any additional requirements imposed by the U.S. Federal Government since cross-country travel will take place on interstate highways". There are no conditions which must be met prior to operation of experimental vehicles on the interstate system. Nor are there any Federal requirements applicable to the Committee as promoter or sponsor of a competition conducted in part on the interstate system. State and local laws, if any, would have to be followed of course.

In response to the second part of your inquiry the Federal "specifications and regulations" concerned are the Federal Motor Vehicle Safety Standards, issued under the authority of the National Traffic and Motor Vehicle Safety Act of 1966. The Committee has no responsibility under the Act for ensuring compliance with the Federal safety standards. This responsibility rests with the vehicle's original manufacturer, and with any person modifying a vehicle prior to its first sale in a manner affecting compliance with the safety standards. It is evident that standard production motor vehicles (such as the Chevelles presented to the Committee by General Motors) which originally

[Page 2 Is Missing.]

ID: nht70-1.26

DATE: 10/20/70

FROM: R. A. Diaz; NHTSA

TO: L. C. Lundstrom; GM

TITLE: FMVSS Interpretation

TEXT: The Director has asked me to reply to your letter of September 29, 1970, concerning the compliance of certain motor vehicles, which General Motors intends to import, with Federal Motor Vehicle Safety Standard No. 206 - Door Locks and Door Retention Components.

Each rear door of these vehicles has, in addition to a "conventional" locking mechanism, a special locking mechanism which is described in your letter as:

"an additional lever located on the rear edge of each door which, when placed in its 'lock position', will only allow the door to be opened from outside the vehicle even if the conventional locking knob on the upper portion of the door inside the vehicle is in the unlocked position. The additional lever is covered when the door is closed."

You ask whether the rear doors on these vehicles comply with @4.1.3 of Standard No. 206, which requires that each door "shall be equipped with a locking mechanism with an operating means in the interior of the vehicle."

A somewhat similar problem was discussed in the preamble to the April 27, 1968 amendment (33 F.R. 6465) to the Standard. As stated there, @4.1.3 does not preclude the installation of a special locking mechanism in addition to the required locking mechanism. However, the required locking mechanism must be able to be engaged or disengaged regardless of whether any additional locking mechanism is engaged or disengaged. If the special locking mechanism does not interfere with the operation of the required locking mechanism on the doors in question, therefore, it will not constitute a failure to comply with the standard.

Please write if I can be of any further assistance.

ID: nht70-1.27

DATE: 10/28/70

FROM: ROGER H. COMPTON -- NHTSA OFFICE OF OPERATING SYSTEMS MOTOR VEHICLE PROGRAMS

TO: E. W. BERNITT -- VICE PRESIDENT SAFETY AND QUALITY ASSURANCE AMERICAN MOTORS CORPORATION JEEP CORPORATION

TITLE: NONE

TEXT: Dear Mr. Bernitt:

This is in reply to your letter of October 12, 1970, to Mr. Charles A. Baker of this office in which you requested an interpretation of the phrase "effective projected illuminated area."

Class A turn signal lamps are required by Section S3.1 of Federal Motor Vehicle Safety Standard No. 108, which references SAE Standard J588d in Tables I and III for these lamps. The requirements for the illuminated area of a turn signal lamp are specified in J588d as follows:

"The effective projected illuminated area measured on a plane at right angles to the axis of the lamp must not be less than 12 sq. in. for Class A and 3 1/2 sq. in. for Class B."

In the 45 degree visibility requirements, this standard further states "To be considered visible, the lamp must provide an unobstructed projected illuminated area of outer lens surface, excluding reflex, . . .".

Our interpretation of effective projected illuminated area follows: The effective projected illuminated area is that area of the lens measured on a plane at right angles to the axis of the lamp, excluding reflex reflector, which is not obstructed by an opaque object such as a mounting screw, mounting ring or an ornamental bezel or trim.

The above interpretation allows the area of rings or other configurations (raised portions) molded in the lens to be considered part of the total effective area, even if this area does not contribute significantly to the total light output.

Sincerely,