ID: nht68-3.30

DATE: 05/01/68

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

TO: Truck Equipment, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 6, 1968, to Mr. Lowell K. Bridwell, Federal Highway Administrator, in which you inquired about certification responsibility for lighting on your truck bodies.

Federal Motor Vehicle Safety Standard No. 108 on lighting applies to motor vehicles, not to motor vehicle equipment such as truck bodies.

When the body is mounted on the chassis cab, the lighting requirements of Federal Standard No. 108, not certified by the manufacturer, must be fulfilled.

Certification must be provided to the dealer when the chassis cab is completed for the dealer. A dealer selling to the final purchaser need not certify, but is responsible for lighting to be in compliance with Federal Standard No. 108, for that part of the lighting (or other standards) which have not been previously certified.

Trusting this information answers your questions.

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: nht68-3.32

DATE: 05/02/68

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

TO: Weslock Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of April 22, 1968, to Mr. Bridwell has been referred to me for reply.

You state that it is your understanding that the proposed rule making in Docket 2-16 will require door locks on trailers and mobile homes to be so constructed "as to be recessed flush on exterior doors." Federal motor vehicle safety standard No. 206, Door Latches, Hinges, and Locks - Passenger Cars, was originally issued on January 31, 1967 and became effective on January 1, 1968. An amendment to this standard was issued on April 24, 1968 with an effective date of January 1, 1969.

Neither the standard as presently written or the proposed amendment in Docket 2-16 is applicable to trailers and mobile homes. Moreover, there is no provision either in the standard or in the proposed amendment which requires that door locks must be so constructed "as to be recessed flush on exterior doors," even as to those motor vehicles to which the standard applies presently or to which it is proposed to apply in Docket 2-16. For your information, we are enclosing a copy of the recent amendment to Standard No. 206 as attachment No. 1, and a copy of the proposed amendment for Docket 2-16 as attachment No. 2.

In view of the foregoing, you may wish to reconsider your request that we forward to you the comments contained in Docket 2-16. The cost to you for forwarding those comments would be fifty cents a page and the number of pages contained in Docket 2-16 is considerable. Since your understanding of the thrust of Docket 2-16 is not correct, your request for an extension of time to May 25, 1968 is denied.

WESLOCK COMPANY

April 22, 1968

Federal Highway Administration Room 316, Donohoe Building 6th & D Street, S. W. Washington, D. C. 20591

Attention: Lowell K. Bridwell Federal Highway Administrator

Although we have not received Docket 2-16, an amendment to Standard 206, we are told that all interested persons have until April 25, 1968 to file comments.

As manufacturers of locks for trailers and mobile homes, we have reason to believe we are affected by Docket 2-16. By hearsay, we understand that this Docket will require that locks be so constructed as to be recessed flush on exterior doors.

If our understanding is correct, we fear that we, and many other lock manufacturers, may be seriously damaged by this requirement. We respectfully request an extension of time until May 25, 1968 to file comments and shall appreciate your sending us Docket 2-16 for study.

May we also suggest that serious consideration be given to the danger of entrapment in trailers arising from the use of locks which do not open automatically upon turning of the inside knob. To prevent loss of life, it may be wise to require panic-proof locks; that is, those which unlock and open merely by turning the inside knob and which do not depend upon the performance of some precedent operation.

Sincerely,

Ernest Cipriano President

ID: nht68-3.33

DATE: 05/06/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Utility Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 11, 1968, to Mr. George C. Nield requesting clarification of the positioning of lamps and reflectors as required by Motor Vehicle Safety Standard No. 108.

The lamps and reflectors that are shown on your Drawing No. X-78, dated January 17, 1968, appear to be in conformance with the requirements of Standard No. 109 with the following exceptions:

1. The front clearance lamps mounted on the chassis-cab of the top two vehicles on your drawing are not required by Standard No. 108, since those on the body and crew-carrying cab adequately define the extreme width and are as high as practicable.

2. The rear clearance lamps shown on the crew-carrying cab should be mounted on the rear of the bed similar to those on the bottom vehicle (P) to meet the requirement that they be mounted on the rear and indicate the extreme width.

3. The front clearance lamps on the third vehicle (S, SL, CO) should be mounted on the front of the tool panels at or near the same level as the rear clearance lamps to indicate the extreme width.

4. The front clearance lamps on the bottom vehicle (P) should be mounted on the front of the bed or platform if it projects beyond the sides of the chassis-cab.

Since no dimensions are specified on your drawing, we can only assure that the locations are as specified in the standard.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approval 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 Standard No. 108.

ID: nht68-3.34

DATE: 05/14/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 1, 1968, to Mr. Edwin L. Slagle, requesting a clarification of the location requirements for identification lamps on real trailers.

The brochures attached to your letter describe two types of reel trailers as manufactured by the Standard Trailer Company and designated as the "Reelmaster" and "Cable Winder/Stringer." These trailers are completely open in the rear with no permanently attached crossbar for mounting rear identification lamps. On these trailers, identification lamps mounted on permanently attached swinging arms which are located near the wheels of the trailers would appear to conform to the requirements of Motor Vehicle Safety 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.

Thank you for writing.

ID: nht68-3.35

DATE: 05/07/68

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

TO: Heiskell; Donelson; Adams; Williams & Wall

TITLE: FMVSR INTERPRETATION

TEXT: Mr. Bridwell has asked that I reply to your letter of April 9, 1968.

Enclosed for your information is a copy of the chassis-cab ruling and regulation issued December 29, 1967. Under the terms of the ruling and regulation and the National Traffic and Motor Vehicle Safety Act of 1966, when a truck body manufacturer assembles the truck body to a chassis-cab he is responsible for certification only if the completed vehicle is delivered to a dealer or distributor. The body manufacturer assembling the body to the chassis-cab would, however, be responsible for the vehicle's compliance with the lighting standard if not previously met by the chassis-cab manufacturer. Moreover if the addition of the body affects the chassis-cabs previous compliance with standards the body manufacturer would be responsible for compliance.

With regard to bodies mounted on chassis-cabs manufactured prior to January 1, 1968 compliance and certification is not required. However, the body, if manufactured on or after January 1, 1968, would have to contain glazing that complies with Standard No. 205 because the body is manufactured for use on motor vehicles and as such must meet any applicable equipment standards.

ID: nht68-3.36

DATE: 05/10/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Kaiser Jeep Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 17, 1968, to Mr. George C. Nield, requesting a confirmation of your interpretation of the visibility requirements for back-up lamps as specified in Motor Vehicle Safety Standard No. 108.

You are correct in your interpretation that the visibility requirements for back-up lamps on multipurpose passenger vehicles and trucks will be predicated on the normal driving, or closed tail gate, position.

Thank you for your interest in meeting the intent of the requirements of Standard No. 108.

ID: nht68-3.37

DATE: 05/13/68

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

TO: Utility Body Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of March 7, 1968 in which you asked if your company, a manufacturer of truck bodies and truck equipment that installs its product on a chassis furnished by a dealer or the ultimate user, is required to certify that "the completed package, including the chassis, meets Standard 108?"

Under the National Traffic and Motor Vehicle Safety Act of 1966, you are responsible for completing the vehicle so that it meets applicable standards. This means the vehicle should be assembled in a way that will not disturb existing compliance, and that portion of the vehicle you add must comply with any applicable standard.

This is a duty separate from certification. You are required to certify compliance under section 114 of the Act only if you deliver a completed vehicle to a distributor or dealer, and the certification would be as to all standards applicable to the vehicle, including Standard 108.

ID: nht68-3.38

DATE: 07/08/68

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

TO: Gypsy Campers

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of May 29, 1968, in which you state that your camper conversion is not subject to the requirements of the Federal Motor Vehicle Safety Standards.

Please note the requirements for glazing in Federal Motor Vehicle Safety Standard No. 205, contained in our letter to you dated May 24, 1968. Should your modification involve installation of glazing, then these requirements would apply.

Note also Standards No. 103, 106, 107, 111, and 211, which are applicable to a multi-purpose passenger vehicle. Your conversion of a van to a camper is conversion of a truck to a multi-purpose passenger vehicle, and therefore, requires compliance with applicable standards.

ID: nht68-3.39

DATE: 07/09/68

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

TO: Mr. Philips B. Boyer

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 24 to the Department of Transportation asking if manufacturers of motor homes are "required to equip the seats in such units with seat belts."

The self-propelled motor home is classified as a "multipurpose passenger vehicle" for purpose of the Federal motor vehicle safety standards. Currently seat belt installations and seat belt assembly anchorages are not required for multipurpose passenger vehicles, but if a seat belt assembly is(Illegible Word) by the vehicle manufacturer it must meet the requirement of Federal standard No. 209.

On October 14, 1967 the Federal Highway Administrator established dockets to receive comments on possible requirements for seat belt installations and seat belt assembly anchorages in multipurpose passenger vehicles. These comments are now under evaluation.