ID: 2776y

AIR MAIL

Mr. M. Iwase General Manager Technical Administration Department Koito Mfg. Co. Ltd. Shizuoka Works 500, Kitawaki Shimizu-Shi, Shizuoka-Ken Japan

Dear Mr. Iwase:

This is in response to your letter of November 20, l990 with respect to "interpretation and/or petition" concerning combination headlighting systems.

Koito has asked about the permissibility of two or four lamp headlighting systems in which the upper beam would be provided by integral beam headlamps, and the lower beam by replaceable bulb headlamps.

The systems you describe would not be permissible under Standard No. l08, which allows only the three types of headlighting systems that you mention. Integral beam headlighting systems must be comprised of integral beam headlamps which, by definition, are headlamps other than sealed beam or replaceable bulb headlamps. Replaceable bulb headlighting systems are those that incorporate the standardized replaceable light sources listed in Standard No. l08.

We are transmitting your request to the Office of Rulemaking, for consideration as a petition for rulemaking.

Sincerely,

Paul Jackson Rice Chief Counsel ref:108 d:l2/l3/90

ID: nht94-8.14

DATE: February 14, 1994

FROM: Daniel T. Mason -- Product Development Engineer, Automotive Division, Avery Dennison

TO: Barbara Gray -- Office of Market Incentives, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/8/94 from John Womack to Daniel T. Mason (A42; Part 541)

TEXT:

The purpose of this letter is to ask for a ruling of the footprint requirements of the parts marking legislation, 541-Federal Motor Vehicle Theft Prevention Standard.

I am a Product Development Engineer working under Cliff Nastas for Avery Dennison. My question refers to the footprint feature of the label that appears under a UV light in the substrate after the label (illegible words).

Both Avery Dennison and (illegible word) supply parts marking labels to the automotive industry. Both have a florescent agent that migrates into the substrate once applied. Would a label that substitutes a florescent copy of the VIN instead of the whole footprint of the label be in compliance to the federal legislation?

Please inquire for a ruling on this. I will follow up this letter with a phone call to discuss any questions you may have in the next couple weeks.

ID: nht92-7.18

DATE: May 5, 1992

FROM: Stephen Newmark

TO: Jerry Curry -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/27/92 from Frederick H. Grubbe to Phil Gramm (A39; Part 555)

TEXT:

I have been in contact with Congressman Geron's office concerning the formation of a Texas based company (Lonestar Classics Inc.) which will manufacture kit or reproduction automobile packages. We have been advised that an exemption is available to companies whose production does not exceed 10,000 units during a four year period in so far as Department of transportation safety standards are concerned. Our initial projections are that we would produce approximately 600 such units per year and are hereby requesting said exemption. It is our intent to use this exemption to obtain certificate of origin forms from the State of Texas which would otherwise require proof of our having met the aforementioned standards. We will in any case, make certain that our advertising clearly indicates that such standards have not been met. If you require any additional information, please feel free to contact me at 817-267-6241 or at the address listed below.

ID: nht89-2.34

TYPE: Interpretation-NHTSA

DATE: July 14, 1989

FROM: J. Michael Mundy -- Lease Sales Representative, Penske Truck Leasing Co., L.P.

TO: Emory Lariscy

TITLE: None

ATTACHMT: Attached to letter dated 9-4-90 from P.J. Rice to E.J. Lariscy (A36; Std. 108; Std. 124; Std. 301); Also attached to letter dated 8-28-89 from E.L. Lariscy to G. Shifflett (OCC 3910) with Patent Application for Vehicle Safety Light Assembly (gr aphics omitted); Also attached to letter dated 7-14-89 from J.M. Staples to E.L. Lariscy; Also attached to letter dated 8-8-89 from L. Baer to E.L. Lariscy; Also attached to letter dated 7-28-89 from A.M. Kennedy to E.L. Lariscy

TEXT:

I recently had the opportunity to witness your speed-caution light in operation. It is a truly effective piece of safety equipment.

Rear end collisions are especially prevalent in the transportation industry because of lower speeds required due to weight and product requirements.

This light would not only save money in reduced repair cost and lower insurance premiums. More importantly, it may save someone's life.

Please forward me any information possible on your product as it becomes available.

ID: nht81-1.33

DATE: 03/10/81

FROM: FRANK BERNDT -- NHTSA CHIEF COUNSEL

TO: DONALD W. VIERIMAA -- DIRECTOR OF ENGINEERING TRUCK TRAILER MANUFACTURERS ASSOCIATION

TITLE: NOA-30

ATTACHMT: LETTER DATED 02/09/81 FROM DONALD W. VIERIMAA TO FRANK BERNDT -- NHTSA, EXCLUSION OF THE TOWBAR OF A PERMANENT TRAILER DOLLY FROM THE FMVSS 108 LENGTH CRITERIA; LETTER DATED 04/04/73 FROM RICHARD B. DYSON -- NHTSA TO PAUL K. WILSON

TEXT: Dear Mr. Vierimaa:

This is to reply to your letter of February 9, 1981 asking for "exclusion of the towbar of a permanent trailer dolly from the FMVSS 108 length criteria."

As you indicated, an opinion by this office in 1973 excluded converter dollies and their integral towbar from inclusion in computation of the overall length of trailers (i.e. S4.1.1.3 which excludes intermediate side marker lamps on vehicles less than 30 feet in overall length). Even though a trailer might be manufactured with a permanent dolly, its function is identical to that of a converter dolly and there is no reason to distinguish one from the other for purpose of computation of overall length. Therefore, overall length may be computed exclusive of either the dolly or the tongue.

Sincerely,

ID: nht95-2.3

TYPE: INTERPRETATION-NHTSA

DATE: March 14, 1995

FROM: Takashi Adachi -- Manager, Ichikoh Industries, Ltd.

TO: Richard L Van Iderstin -- Visibility and Controls Group, Office of Vehicle Safety Standards, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 5/9/95 LETTER FROM JOHN WOMACK TO TAKASHI ADACHI (A43; STD. 108)

TEXT: Dear Mr. Van Iderstein,

I am writing this letter to ask you a view with regard to conformity of the reflex reflector included in rear lamp that our company are consider to design. Structure of design are described on the attachment.

My questions are related to conformity to FMVSS 108, as follows.

1. Does this structure of the reflex reflector conform to FMVSS 108? 2. Shall the reflex reflector meet the photometric performance requirement in the whole area of the reflex reflector? 3. Or shall each area (upper and lower) of the reflex reflector meet the photometric requirement individually?

Thank you in advance, I will call you later to listen your reply.

Enclosed: figure 1 (rear of lamp) shows clear and red outer lens, reflex reflector and opaque area. (Figure omitted.)

ID: 9161

Mr. Nicholas S. Copass
Sales Manager
Titeflex Industrial Americas
170 Tapley Street
Springfield, MA 01104-2893

Dear Mr. Copass:

This responds to your letter to Mr. David Elias, formerly of this office, concerning the manufacture of hydraulic brake hose assemblies by Titeflex and Russell Performance Products. I regret the delay in responding.

We recently responded to a letter from Mr. Jim Davis of Russell about the labeling of the hose assemblies. I have enclosed a copy of that letter for your information. In that letter, we explain that both Titeflex's and Russell's designations need not be marked on the assembly. Instead, since Russell is manufacturing the assemblies and will market the assemblies, Russell's designation must be marked. The designation will identify Russell as the manufacturer of the assembly in the event of a possible noncompliance or defect with the assembly.

I hope this information is helpful. If you have any questions, please do not hesitate to call Ms. Deirdre Fujita of my staff at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

Enclosure ref:106 d:5/12/94

ID: nht68-2.29

DATE: 11/14/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Timmons Metal Products Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 7, 1968, to Dr. William Haddon, Jr., Director, National Highway Safety Bureau, concerning additional side marker lights on tilt cab chassis.

In order to meet the requirements of Federal Motor Vehicle Safety Standard No. 108, an amber side marker lamp should be counted on each side of the chasis cab as far forward as practicable. Additional amber side market lamps are not required on the truck body, providing the overall length of the vehicle is less than 30 feet. This is a general clarification only, since we are not sure of the exact configuration of the vehicles in question. A picture or drawing with the necessary overall dimensions would be needed for specific comments.

This Burenu does not issue approval on items of lighting equipment of on vehicle designs incorporating this equipment, therefore, the above comments are for your information only, and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle lacks the requirements of standard No. 108.

ID: nht89-1.49

TYPE: Interpretation-NHTSA

DATE: March 22, 1989

FROM: Heracilio R. Prieto -- President, Easton, Inc.

TO: Erika Jones -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-27-90 from P.J. Rice to H.R. Prieto (A36; Std. 116)

TEXT:

Our company has blended and packaged brake fluids in Puerto Rico for over 10 years. We have always interpreted that the lot number/packaging date must be printed directly on the brake fluid container for us to be in strict compliance under FMVSS 116.

Given the aggressiveness of brake fluids on any ink, we have always wished we were allowed to use a label notch coding system which we have used successfully for years in our detergent packaging operation. The relative simplicity of the mechanical devic e, vis-a-vis the jet-ink coder, also makes thc notch system operationally more reliable.

The recent revisions in S5.2.2.2 of standard 116 seem oriented to demand indelibility and permanence in the information required on the brake fluid label or container. No ink system could possibly match the notched label on either count. In the spirit of this new approach, I urge you to consider the notch system as an acceptable method of batch/date coding brake fluid bottles.

I am attaching copies of the literature from the exclusive supplier of this system for your perusal.

I hope you concur with our assessment and look forward to your comments. Please let me know if you need any additional informational from us.

Attached is literature entitled Codedge Label Dating Machine (text omitted).

ID: nht92-9.21

DATE: February 6, 1992

FROM: S. Watanabe -- Manager, Automotive Equipment Legal & Homologation Sect., Stanley Electric Co., Ltd.

TO: Administrator, NHTSA

TITLE: Re: Marking requirements of FMVSS No. 108 S7.2.(b)

ATTACHMT: Attached to letter dated March, 1992 (est.) from Paul Jackson Rice to S. Watanabe (A39; Std. 108)

TEXT:

As the overseas company of our firm-Stanley Electric Co., Ltd. in Japan, there are Thai Stanley Electric Co., Ltd. in Thailand and Taiwan Stanley Electric Co., Ltd. in Taiwan. We would like to have your advice about the Manufacturer Identification Mark required by FMVSS No. 108 S7.2.(b) on Thai or Taiwan made headlamps for U.S.

As the Manufacturer Identification Mark, Thai Stanley Electric Co., Ltd. has "TH STANLEY", "TH STANLEY" (in capital letters) and "STANLEY. TH" (in capital letters), as well as Taiwan Stanley Electric Co., Ltd. has "TW STANLEY", "TW STANLEY" (in capital letters) and "STANLEY. TW" (in capital letters). Can Thai Stanley Electric Co., Ltd. and Taiwan Stanley Electric Co., Ltd. use one of the marks to identify the manufacturer in order to conform the requirements of FMVSS NO. 108 S7.2.(b)?

In connection with this matter, we inform you that "TH STANLEY" and "TW STANLEY" have been made an application to the U.S. Patent and Trade Marks Office as a trade mark. However, "TH STANLEY" (in capital letters), "STANLEY. TH" (in capital letters), "TW STANLEY" (in capital letters) and "STANLEY. TW" (in capital letters) are not registered as a trade mark, because we think that they are not a trade mark, but a manufacturer's name.