ID: nht93-4.31

DATE: June 11, 1993

FROM: Howard M. Smolkin -- Acting Administrator, U.S. Department of Transportation, NHTSA

TO: Laura J. Platter

COPYEE: Barbara A. Mikulski -- United States Senate

TITLE: None

ATTACHMT: Attached to letter dated 5-21-93 from Carl W. Vogt to Howard Smolkin (OCC 8692)

TEXT: 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.

ID: nht69-2.11

DATE: 02/07/69

FROM: AUTHOR UNAVAILABLE; William Haddon Jr. M.D.; NHTSA

TO: Messrs. Tanaka and Walders

TITLE: FMVSR INTERPRETATION

TEXT: In response to your letter of September 19, I attach an interpretation of the applicability of the National Traffic and Motor Vehicle Safety Act of 1966 to the Heads Mini-Trail and other similar vehicles ("mini-bikes"), which has been prepared for publication in the Federal Register.

This interpretation reiterates the opinion rendered American Honda Motor Co. Inc. on August 8 that mini-bikes are motor vehicles subject to the Act, must comply with applicable Federal Motor Vehicle Safety Standards, and must bear an appropriate certification of compliance.

Publication of this interpretations will insure that the Federal requirements will be understood equally by all manufacturers of mini-bikes, domestic and foreign.

ID: nht91-5.9

DATE: July 30, 1991

FROM: Martin L. Marinoff

TO: NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10-23-91 from Paul Jackson Rice to Martin L. Marinoff (A38; Std. 105)

TEXT:

Thank you so very much for sending me the information I requested. If and when your office is restocked with (1989 Safety Related Recall #12) I would deeply appreciate you sending me a copy.

My second request is a clarification as stated in your booklet (Federal Motor Vehicle Safety Standards and Regulations). Page #2 states under Standards #105 there must be a warning light system to indicate loss of pressure or low fluid level in the braking system. Please advise, have I interpreted this passage correctly?

Your forwarding of the above information will be deeply appreciated.

ID: nht69-1.47

DATE: 09/04/69

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

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of August 12, 1969, to Dr. Robert Brenner, Acting Director, National Highway Safety Bureau, concerning visibility angles for turn-signal, stop and tall lamps on all vehicles requiring such lamps, and stop lamp operation on motorcycles.

Federal Motor Vehicle Safety Standard No. 108 requires that turn signal, stop and tail lamps, upon installation on vehicles subject to the Standard, meet the 45 degree, vicibility requirements specified in SAE Standards J538d, J586c and J585c.

The dual switching of stop lamps, with activation both by foot brake and hand brake on motorcycles, is required by Standard No. 108 in paragraph S3.4.4

ID: nht94-2.80

TYPE: Interpretation-NHTSA

DATE: May 12, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Nicholas S. Copass -- Sales Manager, Titeflex Industrial Americas

TITLE: None

ATTACHMT: Attached to letter dated 9/29/93 from Nicholas S. Copass to David Elias (OCC-9161), letter dated 3/6/91 from Anthony J. Laliko to Vernon G. Bloom, and letter dated 3/18/91 from Arthur H. Neill, Jr. to Anthony J. Lalikos

TEXT:

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 b e 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 n oncompliance 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.

ID: nht73-6.14

DATE: 04/10/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Robins Davis & Lyons

TITLE: FMVSS INTERPRETATION

TEXT: (Ilegible Text)

ROBINS. DAVIS & LYONS

March 16, 1973

United States Department of Transportation Federal Highway Administration National Highway Safety Bureau Washington, D. C.

Attn: Office of Performance Analysis

Re: Roste v Ford Our File: S72-0534

Gentlemen:

Our office represents a woman who was badly burned in an automobile accident when the Ford Cortina, in which she was a passenger, exploded upon rear-end impact with another automobile. I am interested in knowing whether or not there have been promulgated any Federal standards or regulations pertaining to the safety of gasoline tanks, appurtenances thereto, fuel tank filler hoses and connections, or the need for a protective fire wall between the fuel tank compartment and the rear of the automobile.

If you can refer me to any information pertaining to these questions or send to me copies of the appropriate data, I would be most appreciative. We will, of course, reimburse you for any costs incurred.

Thank you.

Very truly yours,

John F. Eisberg

ID: nht94-5.37

DATE: May 12, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Nicholas S. Copass -- Sales Manager, Titeflex Industrial Americas

TITLE: None

ATTACHMT: Attached to letter dated 9/29/93 from Nicholas S. Copass to David Elias (OCC-9161), letter dated 3/6/91 from Anthony J. Laliko to Vernon G. Bloom, and letter dated 3/18/91 from Arthur H. Neill, Jr. to Anthony J. Lalikos

TEXT:

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.

ID: nht73-3.42

DATE: 03/08/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Wiggins & Christian

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of February 27, 1973, concerning the application of the new Federal Odometer Disclosure Requirements to transfers between dealers.

The Federal requirements apply, with certain exceptions, to each transfer of ownership of a motor vehicle. Some types of vehicles, such as heavy trucks and antique vehicles, are exempt. Passenger cars and lighter vehicles, however, are exempted only in the case of transfers of new vehicles from a manufacturer or a distributor to a dealer or from one dealer to another. The transfer of a used car or light truck, whether from dealer to dealer, dealer to wholesaler, or dealer to customer, must be accompanied by a disclosure statement.

ENC.

ID: nht75-3.22

DATE: 07/03/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: Steer Safe Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of May 22, 1975, in which you request a ruling that a person who installs a "Steer Safe" steering stabilizer is not required to recertify the vehicle in which it is installed. You refer to a letter to Safety Products, Inc., dated August 24, 1972, in which it was stated that we would accept a determination that the installation of a steering stabilizer manufactured by Safety Products did not constitute remanufacturing, and that a person who installed such a device need not recertify the vehicle on which it is installed.

Since that letter, the National Highway Traffic Safety Administration has issued regulations covering the alteration of completed, certified motor vehicles before their sale to a purchaser for purposes other than resale. These regulations (49 CFR @@ 567.7 and 567.8; copy enclosed) supersede opinions such as the one we provided Safety Products, which was based solely on the more general provisions of the National Traffic and Motor Vehicle Safety Act and the certification regulations in effect at that time. Under the new regulations, which were effective February 1, 1974, an alteration which either (1) invalidates a vehicle's existing weight ratings or (2) involves installation of other than "readily attachable" components gives rise to a responsibility for affixing an alterer label, which identifies the alterer and contains some additional information.

From the description of your device, with the enclosed (Illegible words) to require no special expertise or special (Illegible words). It would also seemingly not affect a vehicle's weight ratings. If this assessment is correct, we would accept as reasonable a manufacturer's determination that it is "readily attachable", and that an alterer label is not required when a "Steer Safe" steering stabilizer is installed.

ID: nht88-4.24

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/88

FROM: THOMAS E. GUNTON -- CORPORATE COUNSEL MCCULLAGH LEASING, INC.

TO: JUDITH KALETA -- OFFICE OF THE CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: ODOMETER DISCLOSURE REQUIREMENTS

ATTACHMT: ATTACHED TO LETTER DATED 03/20/89 FROM ERIKA Z. JONES -- NHTSA TO THOMAS E. GUNTON, REDBOOK A33, PART 580

TEXT: Dear Ms. Kaleta:

This is to request your guidance with respect to whether the odometer disclosure requirements of the Truth and Mileage Act of 1986, 15 USC Section 1981 et seq and the regulations promulgated thereunder, apply to large scale sales of motor vehicles and be tween leasing companies.

In particular, where a motor vehicle leasing company, in a single transaction, sells several hundred of its vehicles (and the related commercial leases) to another leasing company while such vehicles are on lease to numerous lessees whose drivers are loc ated throughout the country, must the transferring leasing company provide odometer mileage disclosures for each of the vehicles transferred, or does the Act exempt such transactions?

If you have any questions or need further information in order to respond, please contact me at your earliest convenience. Thank you for your assistance.

Very truly yours,