ID: 3065yy

Mr. Cliff Chuang
Chief Design Engineer
Prospects Corporation
114 Crawford Street
Lowell, MA 01854

Dear Mr. Chuang:

This responds to your letter seeking clarification of recent amendments to Standard No. 118, Power-operated Window Systems (49 CFR 571.118), as published in the Federal Register on April 16, 1991. Specifically, you were interested in new requirements applicable to remote control operations of power windows. You first asked for confirmation of your interpretation of the new requirement in S5(a) that, while closing, remote control-operated power windows automatically reverse direction "when they meet a resistive force of 22 pounds or more." You also asked for an interpretation of the term "daylight opening" as it appears in S5(b) of Standard No. 118.

This agency has received several petitions for reconsideration of the recent amendments to Standard No. 118 with respect to the automatic reversal requirements. In response to the petitions, NHTSA is currently reexamining several aspects of this requirement, including those raised in your letter. The agency will publish its response to the petitions for reconsideration in the Federal Register after it has finished its reexamination of the automatic reversal requirement in the April 16 final rule. Please let us know if you have any questions about this new automatic reversal requirement after our response to the petitions for reconsideration has been published and you have had the opportunity to review it.

I hope this information is helpful to you. Please contact us if you have further questions.

Sincerely,

Paul Jackson Rice Chief Counsel

/ref: 118 D. 7/1/91

ID: nht91-4.35

DATE: July 1, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Cliff Chuang -- Chief Design Engineer, Prospects Corporation

TITLE: None

ATTACHMT: Attached to letter dated 5-1-91 from Cliff Chuang to Legal Counsel, NHTSA (OCC 6009)

TEXT:

This responds to your letter seeking clarification of recent amendments to Standard No. 118, Power-operated Window Systems (49 CFR S571.118), as published in the Federal Register on April 16, 1991. Specifically, you were interested in new requirements applicable to remote control operations of power windows. You first asked for confirmation of your interpretation of the new requirement in S5(a) that, while closing, remote control-operated power windows automatically reverse direction "when they meet a resistive force of 22 pounds or more." You also asked for an interpretation of the term "daylight opening" as it appears in S5(b) of Standard No. 118.

This agency has received several petitions for reconsideration of the recent amendments to Standard No. 118 with respect to the automatic reversal requirements. In response to the petitions, NHTSA is currently reexamining several aspects of this requirement, including those raised in your letter. The agency will publish its response to the petitions for reconsideration in the Federal Register after it has finished its reexamination of the automatic reversal requirement in the April 16 final rule. Please let us know if you have any questions about this new automatic reversal requirement after our response to the petitions for reconsideration has been published and you have had the opportunity to review it.

I hope this information is helpful to you. Please contact us if you have further questions.

ID: nht72-6.51

DATE: 11/20/72

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Edgewood Motorcycle Shop

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letters of October 10 and 29, 1972, asking whether motorcycle tires designed exclusively for hill climbing or other off-highway use are required to be registered in accordance with NHTSA Tire Identification and Recordkeeping regulations (49 CFR Part 574).

We do not consider the regulations to require such tires to be registered. The NHTSA has determined that motor vehicle tires designed and manufactured exclusively for off-road use are not subject to the Tire Identification-requirements.

ID: nht73-2.36

DATE: 08/31/73

FROM: R. B. DYSON -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY DAVID SCHMELTZER

TO: New York State Police

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter on August 20, 1973, asking that law enforcement vehicles be excluded from a Federal prohibition against headlight flashers.

There is no such prohibition. While paragraph S4.6(b) of Federal Motor Vehicle Safety Standard No. 108 requires headlamps to be steady-burning in use, it also specifically states that "means may be provided to flash [automatically] headlamps . . . for signalling purposes." Therefore, manufacturers are not prohibited from equipping vehicles with headlamp flasher units upon customer request.

ID: nht90-1.52

TYPE: Interpretation-NHTSA

DATE: February 21, 1990

FROM: Dipl.-Ing H. Westermann -- Hella KG Hueck & Co.

TO: Taylor Vinson -- Office of Chief Counsel., NHTSA

TITLE: Request for interpretation - CHMSL unity.

ATTACHMT: Attached to letter dated 4-25-90 To Dipl.-Ing H. Westermann and From Stephen P. Wood; (A35: Std.108); Also attached to letter dated 2-7-90 To Richard van Iderstine and From Dipl.-Ing. H. Westermann

TEXT:

Please receive enclosed our request for interpretation, which had accidentally been addressed to Mr. van Iderstine but we were informed that it is yours responsibility. A major uncertainty has arisen with respect to CHMSL unity, where the CHMSL is mounted on the trunk of a convertible (no rear window, appendix 2 of the letter). By ECE unity is defined but SAE and FMVSS 108 yield no such definition. In absence of a clear definition of unity for CHMSL, please let us know, whether the appropriate ECE definition can be applied and whether the designs as shown in the appendices form a CHMSL unity in the sense of FMVSS 108. A soon answer is very much appreciated.

ID: nht93-5.7

TYPE: Interpretation-NHTSA

DATE: July 2, 1993

FROM: Ron Marion -- Sales Engineer, Thomas Built Buses, Inc.

TO: Marvin Shaw -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/16/93 from John Womack to Ron Marion (A41; Std. 131)

TEXT:

We at Thomas Built Buses, Inc. have been asked to provide school buses for a customer in the U.S. Virgin Islands.

Since in this location they drive on the left side of the road, these buses will be built as right hand drive vehicles with the entrance door located on the left side.

The customer would like to have only one stop arm, to be located on the vehicles right side.

I would like to obtain an interpretation of FMVSS 131, School Bus Pedestrian Safety Devices. Would it be acceptable to place only one stop Arm on the school bus and locate it on the right side for this U.S. holding?

Thank you for your consideration in this matter.

ID: nht68-3.37

DATE: 05/13/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Utility Body Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of March 7, 1968 in which you asked if your company, a manufacturer of truck bodies and truck equipment that installs its product on a chassis furnished by a dealer or the ultimate user, is required to certify that "the completed package, including the chassis, meets Standard 108?"

Under the National Traffic and Motor Vehicle Safety Act of 1966, you are responsible for completing the vehicle so that it meets applicable standards. This means the vehicle should be assembled in a way that will not disturb existing compliance, and that portion of the vehicle you add must comply with any applicable standard.

This is a duty separate from certification. You are required to certify compliance under section 114 of the Act only if you deliver a completed vehicle to a distributor or dealer, and the certification would be as to all standards applicable to the vehicle, including Standard 108.

ID: nht73-4.1

DATE: 04/04/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Great Southern Equipment Company of Tampa

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 31, 1973, requesting "an application form and requirements for the mounting of hydraulic cranes behind the cab of . . . trucks".

Under NHTSA regulations, the operations you perform appear to make you a final-stage manufacturer who is responsible for the conformity of the completed vehicle to the Federal Motor Vehicle Safety Standards, and for certifying conformity in accordance with NHTSA Certification regulations (49 CFR Part 567), and regulations regarding Vehicles Manufactured in Two or More Stages (49 CFR Part 568). As a manufacturer you are also required to submit certain information required by Part 566, "Manufacturer Identification".

Copies of NHTSA regulations may be obtained as indicated on the enclosed, "Where to Obtain Motor Vehicle Safety Standards and Regulations". We have no requirements involving application to this agency. If after reviewing the regulations you have specific questions, we will be happy to answer them.

ENC.

ID: 1982-2.17

DATE: 06/30/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Jeff Wimer

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your phone request of June 11, 1982, concerning Federal motor vehicle safety standards that apply to motorcycle sidecars sold as aftermarket motor vehicle equipment.

While there are no "sidecar" standards, certain of the items of equipment that may be found in sidecars are covered by Federal equipment safety standards. Specifically, brake hoses, lighting equipment, tires, rims, and glazing materials (if provided) would have to comply with Standards Nos. 106, 108, 119, 120 and 205. I have enclosed an information sheet explaining how you can obtain copies of the agency's safety standards.

Because a sidecar itself is an item of motor vehicle equipment, the manufacturer of any sidecar sold in the aftermarket would be responsible for notification and remedy in the event the product was determined to contain a safety-related defect.

If you have any further questions, please let me know.

ENC.

ID: nht71-1.35

DATE: 12/02/71

FROM: RICHARD B. DYSON For Lawrence R. Schneider -- NHTSA

TO: G & D Communications Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 22, 1971, and your phone call to Michael Peskoe of November 15, 1971, requesting a copy of the Consumer Information regulations and asking what penalties may be imposed on manufacturers if their vehicles cannot perform as well as the figures they provide pursuant to the regulation. You stated in the above conversation that you have obtained the volume entitled "Performance Data for New 1971 Passenger Cars and Motorcycles" which contains a copy of the Consumer Information requirements. I have enclosed certain amendments to the Consumer Information regulations which will bring the regulations as they appear in this volume up to date.

With reference to your question regarding penalties for violations of the Consumer Information requirements, Section 108 and 109 of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C.@@ 1397, 1398) authorize the imposition of civil penalties of up to $ 1,000 per violation, and up to $ 400,000 for any related series of violations, against manufacturers whose vehicles cannot perform at least as well as the data they supply indicates. In addition, injunctive proceedings may be utilized pursuant to section 110 of the Act (15 U.S.C.@ 1399).

I trust this answers your question. We regret that it was over-looked in our first response to your letter.