ID: nht73-1.43

DATE: 09/26/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Sekurit-Glas Union GmbH

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 19, 1973, requesting information regarding the marking requirements in FMVSS No. 205 for automobile safety glass.

With respect to your request for a copy of the marking requirements, they may be found in paragraph S6. of the enclosed copy of the standard, and in section 6 of American National Standard Z26.1 - 1966. The latter standard can be obtained by writing to the American National Standards Institute, 1430 Broadway, New York, New York 10018.

Information on various State requirements should be obtained from Mr. Armond Cardarelli, American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, D.C. 20036.

You ask whether marking requirements can be met using a specific format you include in your letter, and refer to "Approval" and "Supplemental" markings. It is not clear to us to what you refer, as we prescribe neither "approval" nor "supplemental" markings in the standard, and perhaps we will be better able to answer any questions you may have after you have had an opportunity to review the requirements.

Yours truly,

Enclosure

July 19, 1973

Administrator -- National Highway Traffic Safety Administration

Ref.: Markings of Safety Glass

Dear Sirs,

According to the FMVSS 205 all the safety glasses built in cars have to be marked. Beside the prescriptions of the Department of Transportation there are other special prescriptions for each state (for instance California). Please could you send us an exact list of all these special specifications.

Could you send us as well the concerned regulation or a list from which we can take the form and the contains of the markings.

Is it sufficient to write as Approval Markings

DOT . . . /M . . . /AS

and all other denominations, as for instance laminated, Kinonglas-Kristall-HI-BFG, plate in the Supplemental Markings?

We would be very grateful if you could answer our letter as soon as possible.

Yours sincerely,

SEKURIT-Glas Union GmbH

i.V. i.A.

ID: nht68-1.47

DATE: 01/12/68

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

TO: Headquarters 26th Tactical Reconnaissance Wing (USAFE)

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 21, 1967, to Mr. Lowell K. Bridwell, requesting information on the enforcement of the National Traffic and Motor Vehicle Safety Act of 1966 with reference to vehicles imported by servicemen.

Specifically you have asked:

"a. If (1) A foreign made vehicle, or (2) An American made vehicle, which was purchased prior to 1 January 1968, is imported into the Continental United States subsequent to 1 January 1968, must the vehicle conform to the standards presently established?"

The Federal motor vehicle safety standards affect only vehicles manufactured on or after January 1, 1968. Vehicles manufactured prior to January 1, 1968, need not conform.

"b. Is there any exception for vehicles purchased after 1 January 1968 and imported after that date from the safety standards?"

I enclose a copy of the regulations promulgated jointly by the Department of Transportation and the Department of the Treasury which appeared in the Federal Register on January 10 which govern importation of vehicles. Section 12.80 (b)(1), (b)(2), (b)(3), and (b)(7) set out exemptions which are applicable, generally, to American citizens including servicemen (for whom no special exemption is provided).

Currently we have no information as to which foreign made vehicles will conform to the standards. I agree that information concerning which cars would be helpful to overseas military personnel and I am hopeful that eventually we may be able to implement your suggestion.

For your information, we plan, in the near future, to inaugurate an information program for United States military and civilian personnel overseas. Among those who will be contacted in this regard are the legal assistance officers of each of the Staff Judge Advocates of the Military Services.

ID: nht72-2.11

DATE: 11/21/72

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

TO: Mobile Aerial Towers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to the questions you asked in your letter of October 24, 1972, to Mr. Wells of the Federal Highway Administration concerning compliance with Standard No. 108 of trucks to which mobile aerial towers are mounted.

"1. The aerial tower is considered a load rather than part of the vehicle to be included in determining the overall length. Correct?"

Correct.

"2. Are amber intermediate side marker lights and/or reflectors required on the body?"

If the overall length of the vehicle is 30 feet or more, intermediate side marker lamps and reflectors are required, and they must be located at or near the midpoint between the front and rear side marker lamps and reflectors.

"3. Are amber side marker lights and/or reflectors required on the body?"

Front amber side marker lamps and reflectors are required to be mounted as far to the front as practicable on a vehicle. Generally, this is somewhere on the front fender, though in some configurations a manufacturer might determine that a location on the truck body is as far to the front as practicable.

"4. Are amber clearance lights and/or reflectors required on the front of the body?"

Yes. Front clearance lamps are required to indicate the overall width of the vehicle and to be mounted "as close to the top [of the vehicle, exclusive of load] as practicable."

"5. If a unit is over 30 ft. long, will amber side marker lights and reflectors suffice also as amber intermediate side marker lights and reflectors?"

No, they will not. As the above answers indicate, the location requirements are different for front and intermediate side markers.

ID: nht74-3.22

DATE: 10/07/74

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

TO: Diamond Reo Trucks, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 13, 1974, question whether building a motor vehicle from a used power train (rear axle, suspension, drive line, and engine) and a new "glider kit" constitutes the manufacture of a new motor vehicle, subject to Federal motor vehicle safety standards, including Standard No. 121 after March 1, 1975. Typically, a "glider kit" is a truck chassis on which a cab and front axle system are mounted, which is purchased to permit the re-utilization of a power train from another vehicle.

Re-use of components from an existing vehicle in the construction of another vehicle may or may not result in the manufacture of a new vehicle. The NHTSA has established that the addition of new components (such as a truck body) to the chassis of a used vehicle does not constitute the manufacture of a new vehicle. Conversely, the addition of used components to a new chassis which has never been certified in a vehicle constitutes the manufacture of a new vehicle, subject to the safety standards in effect for that vehicle class on the date of manufacture. This criterion has been relied on in the area of chassis-cab multistage manufacture.

Since a glider kit typically incorporates a new chassis (as well as a new cab and front suspension), the NHTSA finds that the use of such a glider kit in the construction of a motor vehicle constitutes the manufacture of a new motor vehicle. To conclude otherwise would mean that a vehicle composed entirely of brand new components except the rear axle and perhaps the engine and transmission, would qualify as a used vehicle.

You noted that our decision could eliminate the use of glider kits because Standard No. 121 certification would prevent re-use of rear axles which do not meet 121-level performance requirements. We believe that our determination will contribute to motor vehicle safety by introducing more 121-type vehicles on the highway and will not interfere with the use of glider kits in the long term. Glider kits can be made to meet Standard No. 121 as soon as 121-type rear axles become available on the used market. Until that time, the rear axles of present vehicles may be utilized as replacement parts in used vehicles which are not required to meet Standard No. 121.

ID: 11654DRN

Mr. John A. Silva
Partner
EMECO
P. O. Box 766
Grover Beach, CA 93483

Dear Mr. Silva:

This responds to your letter advising us that your company is developing a product in the "automotive safety field," and asking for guidance about how this agency=s requirements may affect your product.

The National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards that set performance requirements for new motor vehicles and items of equipment. Enclosed is an information sheet, "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment,@ describing NHTSA=s regulations for motor vehicle and motor vehicle equipment manufacturers. Under the agency=s governing statute, NHTSA does not certify or approve products. Instead, each manufacturer is responsible for "self-certifying" its products to all applicable safety standards.

You did not specify in your letter what type of automotive product you plan to manufacture, and thus our guidance on our standards is limited. Please write to us again when you can provide more details about your product. If you are concerned about maintaining confidentiality about business information concerning your product, this agency has procedures at 49 CFR Part 512, Confidential Business Information, under which NHTSA will consider claims that information you submit to us is confidential business information as described in the Freedom of Information Act.

You also state that your product may require patent protection. For guidance on patent matters, I would suggest that you consult

an attorney with expertise in patent law, who can provide specific guidance about your product.

If you have questions about NHTSA=s requirements or any other matter, please feel free to contact Dorothy Nakama of my staff at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure ref:571 d:4/3/96

ID: nht93-5.31

TYPE: Interpretation-NHTSA

DATE: July 21, 1993

FROM: Reuven Koter -- Director, Baran Advanced Technologies, Ltd.

TO: Rich Van Iderstine -- Office of Crash Avoidance Research, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7/7/93 from John Womack to Reuven Koter (A41; Std. 108)

TEXT:

Thank you very much for the pages from the CFR 49 mailed to me.

Page 233 paragraph S.5.1.1.19 mentions a specific requirement for the flashing rate of the Hazard Light, as per SAE standard J590b. Can you please fax or mail to us the details of this SAE standard or inform us how it can be obtained.

For the purpose of initial fact finding survey, we kindly ask your opinion on the following issues:

1. What exactly are the U.S. regulations, recommendations, driving codes, common practice or otherwise in regard to use, operation, installation or requirements of the Turn Lights and Hazard (Flasher) Lights including their respective driver console's pilot (operation tell-tale) lamp?

2. Is NHTSA processing in present, or contemplating or is NHTSA aware of future planning of changes, petitions, determinations or any rulemaking action in connection to 1 above?

All the above needed as soon as possible at your earlier convenience since we are now involved with a new safety program/product for the automotive industry based on the very same ABWS concept but activating on the Turn/Hazard Lights instead of the Stop Lamps.

By the way, I am aware of the next ECE Meeting of Experts on Lighting, 15-18 November 1993, in Geneva and their agenda. First item on the agenda is the "Regulation No. 48". Are there anymore details or subject/issues to be discussed under this title?

As always we are very appreciative for your help, asistance and cooperation.

Awaiting for your kind reply.

ID: nht95-2.74

TYPE: INTERPRETATION-NHTSA

DATE: May 9, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

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

TITLE: NONE

ATTACHMT: ATTACHED TO 3/14/95 LETTER FROM TAKASHI ADACHI TO RICHARD L. VAN IDERSTIN (OCC 10857)

TEXT: Dear Mr. Adachi:

This is in reply to your letter of March 14, 1995, to Richard Van Iderstine of this agency, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to a reflex reflector design that you attached. This design shows a single re flector 2 inches in height mounted behind a clear outer lens which is bisected horizontally by an opaque strip 6mm (.25 in.) wide, giving the impression from the exterior of two reflectors, one .75 in. high above the divider, and one that is 1.00 in. in height, below the divider.

You have asked whether the "structure of the reflex reflector conforms to FMVSS 108," and whether photometric conformance is judged with respect to the single reflector crossed by the opaque strip, or whether both the upper and lower portions of the bise cted reflector must meet the photometric specification.

Standard No. 108 is a performance standard, not a design standard. The standard does not specify any requirements concerning the structure of reflectors. The applicable requirements for reflex reflectors are those of SAE Standard J594f. Reflex Reflecto rs January 1977, which Standard No. 108 incorporates by reference. Your reflector should be tested as a single reflector according to the procedures set forth in J594f. If the reflector does not meet the photometric performance requirements of that sta ndard, you may add sufficient reflective elements to the reflector design until conformance is achieved. There is no need to test the upper and lower portions as separate reflectors.

If you have any further questions, you may refer them to Taylor Vinson (202) 366-5263 of this Office.

ID: 0857

Mr. Takashi Adachi
Manager
Ichikoh Industries, Ltd.
North American Liaison Office
555 Briarwood Circle, Suite 190
Ann Arbor, MI 48108

Dear Mr. Adachi:

This is in reply to your letter of March 14, 1995, to Richard Van Iderstine of this agency, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to a reflex reflector design that you attached. This design shows a single reflector 2 inches in height mounted behind a clear outer lens which is bisected horizontally by an opaque strip 6mm (.25 in.) wide, giving the impression from the exterior of two reflectors, one .75 in. high above the divider, and one that is 1.00 in. in height, below the divider.

You have asked whether the "structure of the reflex reflector conforms to FMVSS 108," and whether photometric conformance is judged with respect to the single reflector crossed by the opaque strip, or whether both the upper and lower portions of the bisected reflector must meet the photometric specification.

Standard No. 108 is a performance standard, not a design standard. The standard does not specify any requirements concerning the structure of reflectors. The applicable requirements for reflex reflectors are those of SAE Standard J594f Reflex Reflectors January 1977, which Standard No. 108 incorporates by reference. Your reflector should be tested as a single reflector according to the procedures set forth in J594f. If the reflector does not meet the photometric performance requirements of that standard, you may add sufficient reflective elements to the reflector design until conformance is achieved. There is no need to test the upper and lower portions as separate reflectors.

If you have any further questions, you may refer them to Taylor Vinson (202) 366-5263 of this Office.

Sincerely,

John Womack Acting Chief Counsel ref:108 d:5/9/95

ID: 1983-2.28

TYPE: INTERPRETATION-NHTSA

DATE: 07/12/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Ezon Products Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Louis Gaia V.P. Purchasing Ezon Products, Inc. P.O. Box 18134 Memphis, Tennessee 38118

Dear Mr. Gaia:

In your letter of June 2, 1983, to the Office of Chief Counsel, you asked if there were "any D.O.T. requirements on miniature bulbs?"

We understand your question to refer to bulbs used in lighting devices other than headlamps. Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, imposes no performance requirements on individual bulbs used in lighting devices other than those used in replaceable bulb headlamps (an option permissible as of July 1, 1983). Other lighting devices must meet the photometric requirements of the standard with the bulb, chosen by the lighting device manufacturer, installed.

I hope that this answers your question.

Sincerely,

Frank Berndt Chief Counsel

June 2, 1983

National Hwy. Traffic Agency Office of Chief Councel 400 7th St. S.W. Washington, D.C. 20590

Dear Sir:

We were advised by Mr. Al Kazmierzak from the D.O.T. to write you concerning the following.

Are there any D.O.T. requirements on automotive miniature bulbs?

Please advise.

Awaiting your reply,

EZON PRODUCTS, INC.

Louis Gaia V.P. Purchasing

LG/dd

ID: nht90-4.97

TYPE: Interpretation-NHTSA

DATE: December 26, 1990

FROM: Walter E. Gundaker -- Acting Director, Center for Devices and Radiological Health, Department of Health & Human Services

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2-19-91 from Paul Jackson Rice to Walter E. Gundaker (A37; VSA 102(4); VSA 108(a)(2))

TEXT:

On November 23, 1983 the Food and Drug Administration published in the Federal Register a Final Rule classifying the mechanical automobile hand and foot driving control as a class II medical device. The product is intended to enable persons who have lim ited use of their arms or legs to drive an automobile. The device allows hand operation of the gas, brake, and clutch pedals or foot operation of the steering and gear shift.

Recently we have found that more sophisticated versions of the controls are being developed. These products, which incorporate a joy stick, a microprocessor and servo controls, permit individuals with very limited body control to drive a motor vehicle. Applications to FDA for approval to market these controls have raised questions about vehicle safety which we feel are more appropriately addressed by the National Highway Traffic Safety Administration (NHTSA).

In view of the nature of these products, we would like to revoke the classification of the mechanical hand and foot driving control, and not actively regulate the device. Before we do this, however, we need assurances that these driving controls for han dicapped persons do fall in the jurisdiction of NHTSA and that significant complaints of malfunction would be investigated by NHTSA. Could you give us such assurances?

Thank you for your consideration of this subject. If you or your staff need additional background or information, please contact Mr. Leighton Hansel in our Office of Compliance & Surveillance at (301) 427-1144.