ID: nht68-3.21

DATE: 04/04/68

FROM: AUTHOR UNAVAILABLE; John R. Jamieson; NHTSA

TO: The Firestone Tire & Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: Your petition of March 7, 1968, requesting a reduction in the high speed performance test (Section S5.5) of the Federal Motor Vehicle Safety Standard No. 109 (23 CFR, Part 255) for special heavy gauge troad taxi tires is denied.

While we agree that some taxis are used for low speed intercity operation, many taxis now use high speed freeways for sustained periods of time. With the continuous expansion of freeways in metropolitan areas, the average service speed for taxi tires is certain to increase. In view of this, and because it is impossible to limit the use of taxi type tires to speeds lower than those presently permitted for other passenger vehicles, an amendment to Standard No. 109 exempting the heavy gauge tread tires from the high speed performance requirements, would not be in the interest of safety.

For your future reference enclosed is a copy of Rule Making Procedures: Motor Vehicle Safety Standards as published in the Federal Register (32 F.R. 15816 - 15820). Your attention is directed to S210.31 which sets forth the procedural regulations for petitions for rule making.

ID: nht68-3.22

DATE: 04/06/68

FROM: ROGER H. COMPTON -- NHTSA; SIGNATURE BY DAVID A. FAY

TO: Green and Green Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 19, 1968, to Secretary Boyd, concerning the location of rear identification lamps on best trailers.

Standard No. 108 permits rear identification lasts to be mounted at optional heights. Therefore, lamps mounted on extension brackets or add-on(Illegible Words) would be permissible. We would also point out that rear identification lamps are required only on those trailers that are 80 or more inches in overall width.

Thank you for writing.

ID: nht68-3.23

DATE: 04/16/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Bayerische Motoren Werke

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 21, 1968, to Mr. J. E. Leysath of this Bureau, concerning the use of tubular type bulbs in license plate lamps.

Motor Vehicle Safety Standard No. 108 requires that license plate lamps conform to Society of Automotive Engineers (SAE) Standard J587b. SAE J587b in turn requires that bulbs and bulb sockets conform to SAE Standards J573b and J567b, respectively. Since tubular type bulbs and sockets for these bulbs do not conform to these SAE Standards, their use in license plate lamps would not be permitted under the requirements of Standard No. 108.

Thank you for writing.

ID: nht68-3.24

DATE: 04/16/68

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

TO: R.J. Townsly

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of February 23, 1968, to the Department of Transportation, in regard to information pertaining to importation into the United States of a right hand drive Canadian manufactured vehicle.

If your vehicle was manufactured prior to January 1, 1968, the Federal Motor Vehicle Safety Standards would not apply, however, if built after January 1, 1968, full compliance to Federal Safety Standards is necessary.

While it is not clear from your letter, the status of your visa, or how long you wish to have the car in the United States a solution to your problem may be provided by the regulations governing the importation of motor vehicles subject to the Federal Standards which became effective January 10, 1968. You will see from 19 CFR Section 12.80 (b) (v) of the regulations enclosed that a non-resident of the United States may import a non-confirming motor vehicle for personal use for a period of not more than one year, and that it may not be resold in the United States.

The National Highway Safety Bureau has not been informed of the manner in which vehicles of Canadian manufacture, including those with right hand drive, do not comply with the Federal Standards. It would be best to communicate directly with the Canadian manufacturer as to the extent of modification necessary should you not come with the 12.80 (b) (v) exception.

If we can be of further assistance, please let us hear from you.

ID: nht68-3.25

DATE: 04/22/68

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

TO: Badger Auto Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your cooperation and response to the Federal Highway Administration request regarding the "Certification Requirements."

The information you have provided will be very useful to us; however, in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with information as to where your tag will be located on your vehicles and also the serial identification system as requested in order that vehicles manufactured (complete) after January 1, 1968, can be identified.

In regard to your question as to whether there is an exception to the law regarding the placement of the three light markers at the rear of your vehicle because of the limited space on your rear frame, the answer is there is no exception and adherence is required. One possible solution to your problem might be to mount an additional bracket to mount the cluster of lights. This is only a suggestion and you may be able to arrive at a more practical arrangement.

Trusting this information answers your questions.

ID: nht68-3.26

DATE: 04/24/68

FROM: AUTHOR UNAVAILABLE; G. C. Nield; NHTSA

TO: The Standard-Triumph Motor Company, Limited

TITLE: FMVSS INTERPRETATION

TEXT: This letter is in response to your February 29, 1968, request for approval of equivalent rims for use in the following tire and rim combinations:

A. Bias Ply Tires

1. 5.20-13 on 4 1/2J rim.

2. 5.60-13 on 3 1/2J rim.

B. Radial Ply Tires

1. 145-13 on 3 1/2J rim.

2. 145-13 on 4 1/2J rim.

3. 185-15 on 4 1/2J rim.

On the basis of the supporting information submitted, your request for approval of the equivalent rims and proposed tire combinations listed above is granted.

ID: nht68-3.27

DATE: 04/24/68

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

TO: Fiat Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reference to your letter of March 21, 1968, concerning Federal Motor Vehicle Safety Standard No. 202.

The standard does not preclude the use of a head restraint which, when not in use, can be fully retracted into the seat back.

MOTOR COMPANY, INC.

March 21, 1968

March 21, 1968

Robert O'Mahoney Federal Highway Administration

With reference to Federal Safety standard 202 issued on Federal Register Vol.33 of February 14, 1968, we would appreciate your confirming to us whether a head restraint which, when not in use, can be fully retracted into the seat back is acceptable.

Would you please clarify this to us.

Thanking you for your cooperation in this matter, we remain,

G. Gabrielli Technical Manager

ID: nht68-3.28

DATE: 04/24/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Schein Body and Equipment Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of February 29, 1968, to Dr. William Haddon, Jr. concerning the location of lamps and reflectors on your dump semi-trailers and equipment loaders.

Initial Motor Vehicle Safety Standard No. 108 requires that the side reflex reflectors be mounted not less than 15 inches nor more than 60 inches above the road surface. To meet this requirement, the front side reflex reflectors on your dump semi-trailers may be mounted below the side rail of the body. If necessary, a protective shield or housing could be provided to prevent the reflector from being damaged by rocks and mud.

With respect to the location of rear clearance lamps on your dump semi-trailers, Standard No. 108 requires that these lamps be located as near as practicable to the upper left and right extreme edges of the vehicle, except that optional heights are permitted when the rear identification lamps are mounted at the extreme height of the vehicle. Your photograph does not show identification lamps on the rear of your trailer; however, it does not appear that these lamps could be mounted at the extreme height of the vehicle, since the tail gate is often removed. In this case, the rear clearance lamps must be located as near as practicable to the upper left and right extreme edges of the vehicle. It appears that clearance lamps located immediately forward of the rear post of a point not obscured by the covering tarpaulin would meet this requirement of the standard. A combination clearance and rear side marker lamp at that location would also be permitted by the standard.

On your tilt type and roll-back equipment loaders, location of tail, stop, turn signal, and identification lamps 30 inches from the extreme rear of the platform, and location of the rear clearance lamps and rear reflectors 44 inches from the extreme rear of the platform, appear to be in accordance with the location requirements of Standard No. 108.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or 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 meets the requirements of the standard.

ID: nht68-3.29

DATE: 04/24/68

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

TO: Finderne Engine Co., No. 1, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 8, 1968, to the National Highway Safety Bureau, concerning the applicability of lighting requirements to fire trucks.

We agree that the front identification lamps might be slightly obscured while the stationary and rotating red and amber lights are flashing. However, when these lights are not flashing, the identification lights would clearly identify a vehicle that is more than 80 inches in overall width. Therefore, identification lights will be required on your fire truck. The same reasoning can be applied to clearance lights and compliance is also required.

The enclosed literature may be of additional assistance to you in response to your inquiry.

We trust this information will be of assistance to you in your desire to comply with existing safety standards.

ID: nht68-3.3

DATE: 12/30/68

FROM: AUTHOR UNAVAILABLE; H. M. Jackson, Jr.; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of October 23, 1968, requesting the addition of the 5-inch alternative rim size for use with the 155-13/6.15-13 tire size designation.

In your request you cited a letter from the German Rubber Industry stating that "for passenger car tires in addition to the rims specified in the German Industrial Standards (DIN) also the use of the next large size rims is permissible." The subject of the foot note in the German standard was discussed by my staff in conversations with Mr. Von Polhemus. When the Federal Motor Vehicle Safety Standards were written, it was the intent to accept the German Industrial Standards (DIN) of 1967 for all tire and rim combinations listed based on established usage. We did not intend to apply foot notes from any 1967 reference materials to the present or future tire and rim combinations.

However, on the basis of the data submitted indicating compliance with the requirements of Federal Motor Vehicle Safety Standards No. 109 and No. 110 and other information submitted in accordance with the procedural guidelines set forth in the Federal Register, Volume 33, No. 195, page 14969, dated October 5, 1968, the 5J alternative rim size for the 155-13/6.15-13 tire size designation will be listed within Table I of Appendix A to Standard No. 110. This change will be published in the Federal Register in the near future.

The addition of this new alternative rim size to the table is accomplished through an abbreviated procedure consisting of the publication in the Federal Register of the petitioned alternative rim size. If no comments are received, the amendment became effective after 30 days from the date of publication. If comments objecting to amendments are received, additional rule making pursuant to Part 216 of the Procedural Rules for Motor Vehicle Safety Standards will be considered.