ID: nht75-6.40

DATE: APRIL 16, 1975

FROM: MR. SICKS; MR. PETZOLDT -- FACHNORMENAUSSCHUSS

TO: NHTSA, DOCKET SECTION

TITLE: BURNING BEHAVIOUR OF INTERIOR MATERIALS FOR MOTOR VEHICLES

ATTACHMT: ATTACHED TO LETTER DATED 5-9-75 TO MR. SICKS FROM RICHARD B. DYSON

TEXT: In March 1975 the ISO Central Secretariat has published DRAFT INTERNATIONAL STANDARD

ISO/DIS 3795 - Road vehicles - Determination of burning behaviour of interior materials for motor vehicles

Please find enclosed the English version of this Draft International Standard. As mentioned in our letter of September 3, 1974 Sub-Committee 16 decided to require in this Draft International Standard the presence of supporting wires in all cases in order to avoid subjective interpretations of sample behaviour by the test personnel. As it is essential that laboratories charged with flammability tests conduct these tests according to the same procedure, we ask you to take into consideration the specifications of ISO/DIS 3795. We would appreciate it very much, if you could modify MVSS 302 so that also this standard requires the presence of supporting wires in all tests. We look forward to receiving your reply.

(Attachment Omitted)

ID: nht71-3.48

DATE: 07/22/71

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

TO: S. Jackson-Smith

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your recent letter inquiring about the mounting of a spare tire between headlights of a Volkswagen Camper.

There is no Federal regulation that prohibits the mounting of the spare tire on the front of a vehicle. Federal motor vehicle safety standards apply to new vehicles and regulate manufacturers so as to assure compliance with applicable requirements. The standards do not regulate the vehicle purchaser and owner.

However, in the importation of vehicles into the United States, certain requirements must be met. These requirements are described in the enclosed pamphlet dated October 1969. If your vehicle has been manufactured more recently, up-to-date requirements may be obtained from your Volkswagen dealer.

It is recommended that inquiry be made of the State in which the vehicle will be licensed or driven for applicable laws and regulations in this area.

We appreciate your concern for motor vehicle safety.

ENC.

ID: nht69-1.44

DATE: 08/13/69

FROM: AUTHOR UNAVAILABLE; Dowell H. Anders; NHTSA

TO: Great Dame Trailers Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 4, 1969, in which you asked whether the name of your company may be placed on the certification label affixed to vehicles manufactured by another company.

The question of "private brand" manufacturing was raised at various stages of rulemaking in respect to the certification regulations. It was decided that the certification label on a vehicle must show the name of the actual manufacturer. This information is important in the enforcement of standards and regulations under the Act. The Vehicle Safety Act, moreover, places primary responsibility for conformity to the standards, and for certification of conformity, on the manufacturer, and the regulations are designed to implement that intent. You should note, however, that as a distributor of the vehicles in question you share the responsibility for compliance with the standards to the extent of your knowledge, and participate in the certification by passing it along to dealers or other distributors.

We are pleased to be of assistance.

ID: nht69-2.26

DATE: 09/24/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Arrow Trailers Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 15, 1969, to Dr. Brennar that has been referred to this office, in which you asked whether the name of another company may be placed on the certification label affixed to vehicles manufactured by your company.

The question of "private brand" manufacturing was raised at various stages of rulemaking in respect to the certification regulations. It was decided that the certification label on a vehicle must show the name of the actual manufacturer. This information is important in the enforcement of standards and regulations under the Act. The Vehicle Safety Act, moreover, places primary responsibility for conformity to the standards and for certification of conformity, on the manufacturer, and the regulations are designed to implement that intent. You should note, however, that distributors of the vehicles in question share the responsibility for compliance with the standards to the extent of their knowledge, and participate in the certification by passing it along to dealers or other distributors.

We trust this will clarify the situation for you.

ID: nht72-5.29

DATE: 08/21/72

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of July 5, 1972, requesting an opinion as to how manufacturers may take into account a vehicle's speed capability in establishing GAWR.

The Certification regulations do not specify particular speed criteria for establishing weight ratings. As a minimum, however, we believe the speed chosen should reflect the maximum speed at which it is reasonable to expect the vehicle to be driven. In the case where a vehicle is subject to some low-speed uses, such as seasonal use as a snow plow, we believe the figure on the certification label should be based on that use of the vehicle in which its expected speed is greatest. The regulations do not provide for variable ratings based on speed.

Finally, you ask whether cautionary labels dealing with GAWR and GVWR figures may be installed in the cab. The NHTSA does not object to the use of such labels. They may be used, as appropriate, to indicate permissable use of higher loads in low-speed applications.

ID: nht70-1.34

DATE: 01/21/70

FROM: AUTHOR UNAVAILABLE; Z. Taylor Vinson; NHTSA

TO: American Motors Corporation

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of January 14 you discuss providing a right hand drive automobile to an "individual wish 'Diplomatic Status'". Since the car does not comply with Federal motor vehicle safety standards you ask if American Motors could "Sell such a vehicle for operation in the United States and could we deliver the vehicle and omit the safety plate."

Because section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act of 1966 prohibits the sale of vehicles which do not comply(Illegible Line) delivery of this right hand drive automobile could not take place in the United States. If the sales contract is executed in England and the vehicle delivered in Canada, to name one possibility, there would be no objection to importation of the vehicle pursuant to the term of 10 C.F.R. @ 12.80(b)(2)(vi), assuming diplomatic eligibility of the importer. I enclose a copy of the importation regulation for your information. There is no requirement for affixation of the certification label under these circumstances. I am not aware of any law which would prohibit operation of a right hand drive vehicle in this country.

ID: 15082.wkm

Mr. Claude R. Beverly
390 Rhea Lee Drive
Paducah, KY 42001

Dear Mr. Beverly:

Please pardon the delay in responding to your letter to this agency in which you expressed concerns about the small space-saver spare tires with which new passenger motor vehicles are commonly equipped.

We have addressed this issue in the past (see enclosed letters to Representative Paul E. Kanjorski, dated May 13, 1996; and to Senator Bob Graham dated January 11, 1993). We explained in those letters that although the space-saver spare tires are smaller than regular tires, they are nevertheless required to meet the Federal motor vehicle safety standards applicable to tires. Thus, although they are designed to be used only in emergencies and their service life is normally less than regular tires, they are as safe as regular tires if properly maintained and inflated and the vehicle manufacturer's recommendations are followed.

Should you have any further questions, feel free to provide them to this office at this address or by fax at (202) 366-3820.

Sincerely,
John Womack
Acting Chief Counsel
Enclosures
ref:109
d.10/1/97

ID: 86-3.49

TYPE: INTERPRETATION-NHTSA

DATE: 06/18/86

FROM: M. ARISAKA -- MANAGER, AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPT. STANLEY ELECTRIC

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/28/86 TO M ARISAKA, FROM ERIKA Z JONES, REDBOOK A29, (3) STANDARD 108;

TEXT: Dear Ms. Jones,

We are thinking to sell an optional rear spoiler, in which a high-mounted stop lamp (HMSL) is built, because the optional spoiler prevents the signal of originally equipped HMSL from being seen.

Since an electrical connector is removed from the original HMSL and connected with another HMSL in the optional spoiler (See the following drawing), the original HMSL never lights up. In a word, the original HMSL has no function in a car. Therefore, we think it is allowed to leave the original HMSL equipped in a car.

(DRAWINGS OMITTED)

Please let us know your opinion towords this matter.

We are looking forward to your reply.

Very truly yours,

ID: nht76-5.31

DATE: 11/01/76

FROM: CHARLES E. DUKE FOR JOHN W. SNOW -- NHTSA

TO: House of Representatives

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your September 20, 1976, letter concerning record keeping with respect to new passenger cars that are damaged prior to retail sale.

I would like to clarify the discussion of record requirements in my September 14, 1976, letter to you. While the National Highway Traffic Safety Administration (NHTSA) does not require vehicle manufacturers to create records of safety-related repairs that are made to new motor vehicles prior to sale, we do require the retention of all such records that are in fact created by the manufacturer. Through such records, the NHTSA can in many cases trace the history of vehicles suspected of containing safety-related defects. We have not to date found a safety need sufficient to justify further requirements specifically regarding identification of the vehicles in question.

A copy of the record retention regulation, 49 CFR Part 576, is enclosed for your convenience.

ID: nht91-5.29

DATE: August 20, 1991 EST

FROM: Jt Covelli -- President, Jt Covelli Marketing & Media

TO: Taylor Vinson -- Legal Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-6-91 from Paul Jackson Rice to Jt Covelli (A38; Std. 108)

TEXT:

Recently a woman in the creative department of my advertising agency saw a decal placed on the third brake light of a car in Illinois. The decal's backround was clear and in black bold letters was the name of the auto dealer. The letters appear only when the brake light is on and are only visible from a short distance.

I have been advised by the Wisconsin D.O.T. that Wisconsin has no law governing the use of a decal on the third brake light. Is there a federal law allowing the use of a clear decal in this manner?

My agency has a client we would like to present the idea to. We respectfully request your legal opinion in this matter. Thank you in advance for your consideration. Please feel free to call me with questions at 608 274-9906. I look forward to hearing from you.