ID: nht73-6.6

DATE: 04/13/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. Thomas B. Mitchell

TITLE: FMVSS INTERPRETATION

TEXT: (Illegible Text)

DIRECTOR DIVISION OF MOTOR CARRIER SAFETY DEPARTMENT OF TRANSPORTATION 400 SEVENTH STREET, S.W. WASHINGTON, D.C. 20590

2 (Illegible Text)

MRCH 27, 1973

The Officer in Charge, Federal Highway Administration,

Dear Sir,

I have been advised by the American Embassy in New Zealand to write to you so that(Illegible Word) may be furnished with certain information concerning the American Federal Motor Vehicle Safety Standards which I believe have been in force in your Country since 1968 to which Motor Vehicle Manufacturers must conform in respect to vehicles for sale or use in the United States.

Whilst I am very much interested in all the Safety Standards and Regulations which are in force in your Country the one which I am most interested in at the moment is the one which I believe specifies certain requirements for the safety of Fuel Tanks etc..

I particularly wish to know if the relevant Safety Standard in force in American requires the fuel tanks to be located outside the main body shell of the vehicles or if it is permissible under this Safety Standard for fuel tanks to be situated in the interior of the vehicles.

Trusting that the amount enclosed will be sufficient to cover the costs of postage etc and thanking you in anticipation.

Yours faithfully,

T. B. MITCHELL 707 EAST QUEEN ST. HASTINGS, NEW ZEALAND

ID: 10227

Mr. Richard J. Quigley
5886-b Fernflat Road
Aptos, CA 95003

Dear Mr. Quigley:

This responds to your request for reconsideration of our July 15, 1994 interpretation letter on Standard No. 218, Motorcycle helmets. In that letter, we stated that a drawing you provided would not meet the requirement in S5.6.1(e) of the standard that motorcycle helmets be labeled with the symbol DOT. You enclosed a new drawing and ask whether it meets S5.6.1(e). The answer is no.

The new version of the drawing consists of three figures that you believe constitute the symbol "DOT." Your new drawing continues to incorporate a corporate logo in lieu of the letter "O." As explained in our July 15, 1994 letter, because the symbol DOT constitutes the manufacturer's certification that the helmet conforms to Standard No. 218, there must be no ambiguity in the symbol. Using the corporate logo in lieu of the letter "O" introduces ambiguity as to whether the manufacturer has certified the helmet. Thus, the new version of the drawing you provided does not meet S5.6.1(e) of Standard No. 218.

I hope this answers your question.

Sincerely,

John Womack Acting Chief Counsel

ref:218 d:8/18/94

ID: nht68-3.21

DATE: 04/04/68

FROM: AUTHOR UNAVAILABLE; John R. Jamieson; NHTSA

TO: The Firestone Tire & Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: Your petition of March 7, 1968, requesting a reduction in the high speed performance test (Section S5.5) of the Federal Motor Vehicle Safety Standard No. 109 (23 CFR, Part 255) for special heavy gauge troad taxi tires is denied.

While we agree that some taxis are used for low speed intercity operation, many taxis now use high speed freeways for sustained periods of time. With the continuous expansion of freeways in metropolitan areas, the average service speed for taxi tires is certain to increase. In view of this, and because it is impossible to limit the use of taxi type tires to speeds lower than those presently permitted for other passenger vehicles, an amendment to Standard No. 109 exempting the heavy gauge tread tires from the high speed performance requirements, would not be in the interest of safety.

For your future reference enclosed is a copy of Rule Making Procedures: Motor Vehicle Safety Standards as published in the Federal Register (32 F.R. 15816 - 15820). Your attention is directed to S210.31 which sets forth the procedural regulations for petitions for rule making.

ID: nht73-4.31

DATE: 07/12/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Gaylord Products Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of June 26, 1973, to Mr. Vinson of this office, enclosing the proposed Panther certification label, and asking whether it conforms to our requirements. The label is arranged as a narrow horizontal strip with two lines of type.

The label contains the required statements in the required order, and thus fulfills the requirements.

ID: nht69-2.47

DATE: 12/23/69

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

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 8, 1969, concerning alternate flashing of side marker lamps with turn a signal lamps.

Alternate flashing sidemarker lamps are permitted in paragraph S3.5 of Motor Vehicle Safety Standard No. 108 for signaling purposed; however, they must not impair the effectiveness of the turn signal lamps as required in paragraph S3.1.2.

ID: 23918.ztv

Mr. Bing Kam
6902 Midhurst
Memphis, TN 38119





Dear Mr. Kam:

This is in reply to your letter of November 14, 2001. Because of the precautions being taken with mail addressed to Federal agencies, we did not receive it until January 16, 2002.

You have asked for an interpretation of the phrase "flashes in use" as used on the advisory sheet regarding lighting inventions which we provided you earlier. This phrase appears in the list of factors which we believe may impair the effectiveness of lighting equipment required by Federal Motor Vehicle Safety Standard No. 108 if present in supplemental lighting equipment not required by the standard. You have raised the possibility that a supplemental lamp whose cycle of flashes is more than 5 seconds might not be considered one that "flashes in use."

Standard No. 108 defines "flash" as "a cycle of activation and deactivation of a lamp by automatic means continuing until stopped either automatically or manually." The definition does not specify a time rate for a cycle. This means that any cycle of activation and deactivation is a flash, regardless of its duration.

Additionally, in our view, impairment may occur when any supplemental lamp gives the appearance of flashing, e.g., modulating in intensity or varying the illuminated area of the lens.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:108
d.4/8/02

ID: nht72-6.55

DATE: 03/09/72

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

TO: Mid-North American Import Export Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of February 26, 1972, regarding importation of truck tires that were manufactured in Spain.

At the present time, the proposed Federal Motor Vehicle Safety Standard No. 119 that will apply to truck tires is in preparation. We expect that it will be issued in the very near future and that it will become effective on or about September 1, 1972.

Until then, truck tires are subject only to Regulation Part 574-Tire Identification and Recordkeeping, which became effective May 22, 1971. Importation of truck tires for use on the public roads and highways requires compliance with Regulation Part 574. We are enclosing a copy of the regulation so that you may be informed of your obligations as an importer. You may use the listed tires or sell them to distributors and dealers if regulation requirements are satisfied.

We are also enclosing a pamphlet that contains additional guidelines concerning importation of motor vehicles and equipment.

Apparently the tires described in your letter are manufactured in the Torrelavego, Santander, Spain plant of General Fabrica Espanola del Caucho, S.A. (General Tire International) and if manufactured since May 22, 1971, would be identified by the code marking AE

Please let us know if we can be of further assistance in this matter.

ID: nht92-2.34

DATE: November 12, 1992

FROM: P.R. Smorra -- Group Vice President, Chrysler Corporation

TO: Administrator -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2/9/93 from John Womack to Patrick R. Smorra (A40; Part 555)

TEXT:

Chrysler Corporation is considering a program in which a foreign national could purchase a Chrysler vehicle through a dealer in their country but take delivery of it in the United States so they could use it while on vacation in the States. At the conclusion of their vacation the vehicle would be shipped to them in their home country.

In order to implement this program and export a Chrysler product which is certified in our customer's home market the vehicle would not comply with all U.S. regulations (including EPA and FMVSS). Chrysler International is requesting a variance to these vehicle requirements for the purpose of temporary use by our vacationing customers.

Chrysler has been very aggressive in relaunching our international efforts over the past five years. In 1993 we expect to sell over 100,000 vehicles overseas. We are confident that this program will further contribute to our international growth.

Please advise me if you require additional information in order to grant this variance. Relative to this variance, please clarity two issues: If, upon the expiration of the variance, the vehicle has not left the U.S., who is responsible for the delinquency? In the unlikely event that this vehicle has an accident in which it is deemed undriveable, who is responsible for its disposition?

Thank you for your consideration. I look forward to your reply.

ID: nht88-4.45

TYPE: INTERPRETATION-NHTSA

DATE: 12/19/88

FROM: ROBBIE FOLINO-NAZDA -- ATTORNEY-IN-FACT FRITZ COMPANIES, INC.

TO: FRANK E. YOUNG, -- COMMISSIONER FOOD AND DRUG ADMINISTRATION

TITLE: ANIMAL WARNING DEVICE

ATTACHMT: ATTACHED TO LETTER DATED 3/13/89 FROM ERIKA Z. JONES -- NHTSA TO ROBBIE FOLINO NAZDA, REDBOOK A33, STANDARD 102

TEXT: PRODUCT: Animal Warning Device FUNCTION: Whistle sound warns animals of oncoming car MANUFACTURE NAME: Kiang Niao Traffic Material Co., LTD No. 23, Lane 87, Yung Kang Hsiang, Tainan Hsien, Taiwan, R.O.C. EPA ESTABLISHMENT NO: 60144-TW-1 IMPORTER NAME AND ADDRESS: Menard Inc., 4777 Menard Drive, Eau Claire, WI 54703

Enclosed please find samples of animal warning devices. Menard Inc. is proposing to import this product in the future and we are requesting on their behalf, whether there are any restrictions in your agency which would prevent lawful importation of the devices.

Please advise in writing any restrictions or requirements which need to be complied with in order to legally import this product.

If you have any questions or need additional information please contact me.

Sincerely,

ENCLOSURE

ID: nht78-3.44

DATE: 06/28/78

FROM: John Womack; NHTSA

TO: McMullen & Porter

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of June 6, 1978, requesting an interpretation of the Feeral odometer disclosure requirements. The question you raised was whether the owner of a truck with a gross vehicle weight rating of 64,000 pounds is required under Federal regulations to issue an odometer disclosure statement to the purchaser of the truck. 49 CFR @580.4, Disclosure of odometer information, requires each transferor of a motor vehicle to furnish to the transferee a written disclosure statement. 49 CFR@580.5 (a) (1), however, exempts a transferor of a vehicle having a gross vehicle weight rating of more than 16,000 pounds from having to fulfill the requirements of @580.4

The National Highway Traffic Safety Administration (NHTSA) in promulgating these regulations added this exemption section because buses and large trucks are routinely driven hundreds of thousands of miles, and their maintenance records, not their odometers, have traditionally been relied on by buyers as the principal guide to their condition. It is, therefore, the interpretation of the NHTSA that in the situation you describe in your letter, no disclosure statement was required to be issued under the Federal regulations.