ID: nht73-4.47

DATE: 08/13/73

FROM: AUTHOR UNAVILABLE; Richard B. Dyson; NHTSA

TO: SCARTI

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 19, 1973, to the Administrator.

The exemption provided vehicles with a curb weight of 1,000 pounds or less will cease to exist as of January 1, 1974, and lightweight vehicles manufactured on or after that date will be required to meet all Federal motor vehicle safety standards applicable to their vehicle category, e.g. passenger cars.

Under the circumstances you indicate, you would be the final-stage manufacturer of a vehicle manufactured in two or more stages, under 49 CFR Parts 567 and 568 of our regulations. We refer you specifically to sections 567.5 and 568.6 of those regulations.

ID: nht70-2.18

DATE: 08/11/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: University of Michigan Law School

TITLE: FMVSR INTERPRETATION

TEXT: Your letter of June 22, 1970, concerning the Cyromatic Safety Control, together with a copy of the July 1, 1970, reply sent by Mr.(Illegible Word) Weinberger, Chairman of the Federal Trade Commission, has been referred to my office for reply.

The National Highway Safety Bureau does not have the facilities for testing or investigating specific devices or designs. However, the(Illegible Word) on Winter(Illegible Words) of the National Safety Council has completed an(Illegible Words) of the type mentioned in your letter. I am enclosing for your information a copy of the National Safety Council report on this evaluation.

In brief, the conclusion of the Committee were that there were no significant differences in the performance of the test vehicles whether the device was stated and operable, rendered inoperable, or removed from the vehicles. The only test results considered significant involved a high(Illegible Words) on dry pavement where the device increased(Illegible Words) of the test vehicles by a substantial amount, thus effecting their handling performance adversely.

It is felt that sufficient date is available in the National Safety Council Committee on(Illegible Words) evaluation to warrant investigation on the(Illegible Words) on the Federal Trade Commission, concerning possible misleading advertising on the part of manufacturers of this type of device. Consequently, we have contacted, Mr. Weinberger directly concerning the(Illegible Words).

ID: nht94-4.66

TYPE: INTERPRETATION-NHTSA

DATE: October 27, 1994

FROM: Lois Castillo -- President, Travel Tray, Inc.

TO: Joan Womack -- NHTSA; John Womack

TITLE: NONE

ATTACHMT: Attached to 1/9/95 letter from Philip Recht to Lois Castillo (A43; Std. 213)

TEXT: Dear Joan Womack:

My name is Lois Castillo. I represent a new company called Travel Tray, Inc. based in Utah. Our tray fits across children's carseats and is easily attached and removed. I have enclosed one of our brochures that describes our tray.

I need your help in obtaining any information you might have regarding safety regulations pertaining to a tray such as this.

We are in preparation to start manufacturing and have been advised to seek information from your department first. I have spoken with Craig Allred, Director of the State of Utah Division of Highway Safety and showed him my tray. He felt the tray was okay, but suggested that I should apply a disclaimer clause and warning that the tray should not be used as part of the safety apparatus. That it is only to be used as a convenience item - like a toy - for the child. My patent attorney also suggested thi s.

Please let me know what you think and any information you might have regarding this.

Thank you in advance for your time.

Enclosure

(Brochure omitted.)

ID: nht69-1.12

DATE: 03/16/69

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

TO: Corporation Commission of Oaklahoma

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 15, 1969, in which you inquire about Federal regulation of brake fluid.

Brake fluid performance is regulated under the National Traffic and Motor Vehicle Safety Act by Federal Motor Vehicle Safety Standard No. 116. Copies of the Act and the current standards are enclosed.

Under the Vehicle Safety/Act, manufacturers of motor vehicles and equipment (including brake fluid) that are covered by standards are fully responsible for ensuring that all of their products conform to the standards. The National Highway Safety Bureau conducts conformity tests of vehicles and equipment, either through its own personnel and facilities or under contract with other public or private testing organizations, but these are for enforcement purposes only.

The Bureau is conducting a continuing series of tests on brake fluid, that has included samples from a majority of the major manufacturers, and will include the remainder is the near future. If you need more detailed information concerning this testing program, I suggest that you contact Mr. Francis Armstrong, Director, Office of Performance Analysis, National Highway Safety Bureau, Federal Highway Administration, Washington, D.C. 20591.

In answer to your Final question, Standard No. 116 applies to all brake fluid manufactured or sold in the United States, and is not Limited to that sold by automobile manufacturers or distributors.

ID: nht73-5.12

DATE: 09/25/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Crown Coach Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 28, 1973, concerning the effective date of Motor Vehicle Safety Standard No. 121. Your direct question is whether the effective date is the starting or completion date for the vehicle's components or the starting date for the vehicle.

Standard No. 121 applies to the vehicle and its effective date therefore relates to the vehicle, rather than to any of its components. A vehicle completed after the effective date will have to meet the standard, even though it is equipped with a foundation brake system that was manufactured before the effective date.

The vehicle's completion date, rather than its starting date, is the date that determines whether it must conform to the standard. If your company manufactures its vehicles from the ground up, rather than installing a body on a vehicle built by another manufacturer, the relevant completion date is the date you complete your manufacturing operation. However, if you buy an incomplete vehicle, as defined in our regulation on vehicles manufactured in two or more stages (49 CFR Part 568), and complete that vehicle, you may choose as the completion date for purposes of Standard No. 121 the date on which the manufacturer of the incomplete vehicle finished his work, the date on which you completed the vehicle or any date in between.

ENC.

ID: nht93-7.32

DATE: October 21, 1993

FROM: James "Bubba" Schaub -- Midas Muffler and Brake

TO: John Womack -- Acting Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/8/94 from John Womack to James Schaub (A42; Std. 105; Part 570)

TEXT:

First allow me to introduce myself. My name is James "Bubba" Schaub. I manage a Midas Muffler and Brake Shop in Slidell, Louisiana, located at 180 Gause Blvd., and have for 9 years now. My concern is in the area of ethical and sound business practice. I'm taught by Midas to replace brake rotors and/or brake drums when they exceed the minimum thickness (on disc rotors) or maximum diameter (on drums), published by Original Equipment Manufacturers. My questions are as follows:

1. Please interpret F.M.V.S.S. 105 HYDRAULIC BRAKE SYSTEMS.

2. Is there any basis for fraud in following this policy? (Of disc rotor and/or drum replacement when out of manf. safety tolerances).

Please understand that my concern lies only with doing the right thing - the safe way, for our costumers. Let it be known that the local auto dealership service dept.'s are not following their own recommendations, for safety in this matter, which causes my costumers to believe that we (Midas) are fraudulently selling and installing parts on their vehicles when they're not needed. But, if I can present an established standard to our (Midas) costumers, I can prevent them from feeling they've been taken advantage of.

ID: nht68-3.31

DATE: 04/30/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: R.M. Falconer

TITLE: FMVSR INTERPRETATION

TEXT: In reply to your second inquiry concerning importation of foreign manufactured vehicles, the recent amendment to the Customs regulations answers your question on alien residents importing vehicles not meeting safety regulations.

Quote Section b, Part 12.80 of Chapter 1, Title 19:

5. The importer or consigner is a non-resident of the United States, importing such vehicle or equipment item for personal use or for the purpose of making repairs or alterations to the vehicle or equipment item, for a period not exceeding one year from the date of entry, and that he will not resell it in the United States during that time.

If the importer or consignee files with the entry, in duplicate, a verified declaration to the above, a vehicle may be imported.

A copy of form, HS-7, entitled, "Importation of Motor Vehicles and Motor Vehicle Equipment Subject to Federal Motor Vehicle Standards" is enclosed.

As stated in my original letter, vehicles manufactured prior to January 1, 1968, need only a statement to that effect for importation into the United States.

For custom duties on such a transaction of importing a car, I refer you either to the foreign car manufacturing representative or the Office of the Commissioner of Customs, Treasury Department, Washington, D. C.

This office will be glad to provide further assistance if required.

ID: nht89-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 02/14/89

FROM: KAREN E. FINKEL -- EXECUTIVE DIRECTOR NATIONAL SCHOOL TRANSPORTATION ASSOCIATION

TO: JOAN TILGHMAN -- NCC-20 NATIONAL HIGHWAY TRAFFIC SAFETY ADMIN. U.S. DEPT. OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 04/27/89 FROM ERIKA Z. JONES -- NHTSA TO KAREN E. FINKEL, REDBOOK A33(2), STANDARD 217

TEXT: Dear Joan:

As we discussed on the phone earlier this week, NSTA members (who are school bus contractors) have a question regarding push-out windows on school buses.

The Federal Motor Carrier Safety Standards, Sec. 393.61, states that push-out windows are required and that they must conform to Federal Motor Vehicle Safety Standard No. 217. However, in reading FMVSS 217, there are different requirements for buses and school buses. School buses are not required to have push-out windows. Therefore, the question arises whether school buses being used by school bus contractors in interstate commerce, for other than to and from school work, must have push-out windows.

Because many contractors are purchasing buses now in order to have delivery for the coming school year, and they do not know whether to purchase them with push-out windows or not, I would appreciate a very response to this question.

Thank you for your assistance in clearing up this confusion. If you have any questions, please let me know.

Sincerely,

ID: nht76-5.60

DATE: 02/04/76

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: King Company Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of November 19, 1975, concerning tire registration numbers, and in confirmation of your telephone conversation with Mr. Schwartz of this office.

Thank you for your suggestion that the tire identification number appear on both sidewalls of tires which are delivered already mounted on a vehicle. It is being reviewed by our technical staff, and we will advise you by letter of our decision in this matter.

In answer to your question concerning the types of vehicles covered by the term "motor vehicle," "motor vehicle" is defined in the National Traffic and Motor Vehicle Safety Act of 1966 as "any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails."

YOURS TRULY,

KING COMPANY INC.

DATE 11-19-75

TO R. B. Dyson US Dept of Transportation National Highway Safety

Thank you for your letter N40-30. We are primarily in the travel trades retail business and have been send in the tire numbers on tires registration forms that the respective manufacture send to us. Some of there tire mumbers are hard to locate as they are stamped on the inside section of the trailer tire, I would like to see the numbers printed on both side of the tire and in a (Illegible Word) that would be more ledgible to use.

Also, do the numbers actually (Illegible Word) to be recorded, as I see the regulation state "tires for use on motor vehicles", and I wonder if travel trailers, compare, (Illegible Word) trailers etc apply. Would you please help answer these questions.

Thank you!

Roger R. King

ID: 8692

Ms. Laura J. Platter
6662 Mohawk Court
Columbia, MD 21046

Dear Ms. Platter:

This responds to your letter to Senator Barbara Mikulski about the Federal government's classification of minivans for safety purposes. You were concerned that classifying minivans as trucks rather than passenger vehicles would permit these vehicles to be equipped with fewer safety features.

Congress has authorized this agency, the National Highway Traffic Safety Administration (NHTSA), to issue Federal motor vehicle safety standards that are applicable to new motor vehicles and items of motor vehicle equipment. In the last few years, NHTSA has extended nearly all the passenger car safety standards to cover light trucks and multipurpose passenger vehicles (MPVs). (Minivans are typically considered to be MPVs under our safety standards.)

The only significant safety requirement for passenger cars that the agency has not extended to light trucks and MPVs is dynamic side impact protection. This is a new requirement that is being phased in for passenger cars beginning this September. NHTSA is currently in rulemaking to consider whether the dynamic side impact protection requirements should be extended to light trucks and MPV's, and published an advance notice of proposed rulemaking on this subject in June 1992.

I hope this information is helpful to you.

Sincerely,

Howard M. Smolkin Acting Administrator

cc: The Honorable Barbara A. Mikulski

ref:571 d:6/11/93