ID: nht71-2.50

DATE: 05/13/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Harden Manufacturing Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 3, 1971, requesting an interpretation of the Tire Identification and Record Keeping Regulation. You indicated in your letter that you are a trailer manufacturer. As such, you are considered a motor vehicle manufacturer under both the regulation and section 102(3) and (5) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.) (copies enclosed).

As a manufacturer, you are required, by section 113(f) of the Act, to record the name and address of the first purchaser for purposes other than resale. Section 574.10 of the regulation requires that you maintain a record of the tires shipped on or in vehicles which you manufacture. In the event of a defect notification concerning either the vehicle or its tires, your responsibilities are enumerated in section 111 and 113 of the Act.

Enclosures

ID: nht71-2.6

DATE: 02/12/71

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: Koito Manufacturing Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 22, 1971, to Mr. Charles A. Baker of this Office concerning questions on paragraph S4.1.1.7 of Federal Motor Vehicle Safety Standard No. 108.

"Red" was inadvertently included in paragraph S4.1.1.7 of the amendment to Standard No. 108 published on October 31, 1970. It is anticipated that this paragraph will be further amended in the near future by changing" . . . requirements for Class A red turn signal lamps . . ." to ". . . requirements for Class A turn signal lamps. . ."

The answers to your questions are therefore as follows:

1. Amber turn signal lamps shall conform to the minimum candlepower requirements for Class A amber as specified in Table 2 of SAE J575d.

2. There is no maximum candlepower requirement for amber front turn signal lamps.

ID: nht71-2.7

DATE: 02/16/71

FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter dated January 22, 1971, to the National Highway Traffic Safety Administration, requesting the addition of the 5 1/2-J alternative rim size for the 175 SR 13 tire size designation to Table I - Appendix A of Federal Motor Vehicle Safety Standard No. 110.

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 14964, dated October 5, 1963, the 5 1/2-JJ alternative for the 175 a 13 tire size designation will be listed within Table I - Appendix A of Standard No. 110. Our substitution of rim size 5 1/2 J by 5 1/2 JJ follows our practice of not listing the "J" or "JK" rim contours since a footnote to Table I, Appendix "A" states "Where JJ rims are specified in the above table, J and JK rim contours are permissible."

The above change will be published in the Federal Register in the near future.

The addition of new alternative rims to the table is accomplished through an abbreviated procedure consisting of the publication in the Federal Register of the petitioned alternative rim. If no adverse comments are received, the amendment becomes effective after 30 days from date of publication. If comments objecting to amendments are received, additional rule making pursuant to Part 553 of the Procedural Rules for motor vehicle safety standards will be considered.

As we reviewed your attachments we note on attachment I - page 1 a statement that "in compliance with Legal Requirements 4.04 for the U. S. A., the tires were to be burst not only for one wheel position, but for all of the four wheel positions. Federal Motor Vehicle Safety Standard No. 110 - Section 4.4.1 requires that only one tire be tested for retention on the rim under conditions of rapid deflation. There is a possibility of some misunderstanding in these items which may be causing the overseas people doing more testing than necessary.

He also note in attachment III that the(Illegible Words) data is referenced to specific tires but the rim is not identified. This lack of rim identification precludes using the data for petition purposes even though the data level is of interest and shows that a(Illegible Word) seating problem is very unlikely. Fortunately for the purposes of this petition, Attachment II - page 2 contained adequate but less information(Illegible Word) Unseating data.

ID: nht71-2.8

DATE: 02/18/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Arctic Enterprises Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 7 setting forth certain facts about the manufacture and marketing of Arctic mini-bikes, and asking for assurance that Arctic is not a "manufacturer" of "motor vehicles" within the meaning of the National Traffic and Motor Vehicle Safety Act of 1966.

The criteria determinative of this question were published in the interpretation on mini-bikes (34 F.R. 15416). Persons who manufacture mini-bikes are not "manufacturers" if they

"(1) do not equip them with devices and accessories that render them lawful for use and registration for use on public highways under State and local laws; (2) do not otherwise participate or assist in making the vehicles lawful for operation on public roads (as by furnishing certificates of origin or other title documents, unless those documents contain a statement that the vehicles were not manufactured for use on public streets, roads, or highways); (3) do not advertise or promote them as vehicles suitable for use on public roads; (4) do not generally market them through retail dealers in motor vehicles; and (5) affix to the mini-bikes a notice stating in substance that the vehicles were not manufactured for use on public streets, roads, or highways and warning operators against such use.

The facts as you state them indicate that Arctic fulfills all but the first criterion. Your letter is not clear on this point,

but it implies that you furnish lighting equipment that is sufficient even without a manufacturer's title documents, to render your mini-bikes registerable in some States. Our position is that a manufacturer who equips his vehicle in such a manner that it is registerable for use on the public roads is a "manufacturer," not withstanding his fulfillment of the remaining criteria, and must comply with all applicable regulations including provision of lighting equipment meeting Federal Motor Vehicle Safety Standard No. 108, appropriate certification, and motorcycle consumer information.

ID: nht71-2.9

DATE: 02/18/71

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Bandag Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter to Mr. Hartman concerning the tire identification and record keeping regulation (49 CFR Part 574) requesting that you be allowed to code by pressure chamber rather than by matrix.

Since the pressure chamber is used by Bandag to serve a purpose similar to the purpose served by the matrix in hot processing of retreaded tires, you may assign(Illegible Word) numbers to your pressure chambers and use this code number in place of the matrix code number required by Part 574.

ID: nht71-3.1

DATE: 05/14/71

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: Mrs. Barbara G. Rothschild

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 28, 1971, in which you asked whether modifications to a "forced-action" belt could make it into a system that would satisfy the passive restraint requirements of Standard No. 208. Although we cannot at this time comment on the changes to which you refer, a passive belt system can be used to satisfy the requirement that protection be provided by means that require no action by vehicle occupants.

As you requested, we have enclosed copies of the Standard as published March 10, 1971.

ID: nht71-3.10

DATE: 05/27/71

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Ideal Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of May 4, 1971, to Francis Armstrong you request permission to conduct testing of turn signal and hazard warning signal flashers pursuant to SAE Standard J823b, "Flasher Test Equipment," April 1963.

Federal Motor Vehicle Safety Standard No. 108 incorporates by reference SAE Standard J590b, "Automotive Turn Signal Flashers," October 1965, and SAE Recommended Practice J945, "Vehicular Hazard Warning Signal Flasher," February 1966, both of which specify test circuitry and equipment according to "SAE J823." It is my understanding that the major difference between J823 and J823b, which becomes the appropriate sub-referenced standard on January 1, 1972, is the specification in the latter that "The required voltage tests [for variable-load flashers] with maximum bulb load shall be conducted without readjusting each corresponding power supply voltage, previously set with minimum bulb load." It appears that J823 was written before variable load flashers were in general use and that this is the reason for omission of this specification from J823. Since J823b includes all the requirements of the presently referenced SAE standard, you may proceed to implement it immediately.

ID: nht71-3.11

DATE: 06/01/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: The General Tire & Rubber Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of May 17, 1971, concerning the applicability of the Tire Identification and Record keeping Regulation (49 C.F.R. 574) to trailers as expressed in our letter of March 18, 1971, to Mr. Charles O. Verrill.

As you mentional in your letter, under the regulation, a vehicle dealer has the responsibilities of a tire dealer if he adds or changes the tires on a vehicle he sells. This was considered appropriate because the manufacturer has little, if any, control over which tires go on which vehicles if the tires are shipped separately. In such a case, the vehicle dealer will be mounting the tires and therefore it is logical that he record the name and address of the first purchaser along with the identification number of the tires mounted on the vehicle and forward this information to the tire manufacturer.

The Tire Identification and Record Keeping Regulation and the Certification Regulation for Vehicles Manufactured in Two or More Stages are two completely different regulatory matters. The factors which dictate the related responsibilities of the incomplete vehicle manufacturer and the final-stage manufacturer for purposes of certification are not necessarily relevant to the tire identification regulations.

ID: nht71-3.12

DATE: 06/02/71

FROM: L. R. SCHNEIDER -- NHTSA; SIGNATURE BY DAVID SCHMELTZER

TO: Truck Trailer Manufacturers Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 28, 1972, requesting clarification of whether a vehicle manufacturer, under 574.10 of the Tire Identification and Record Keeping regulation, may designate someone to maintain the records for his.

This letter is to confirm that motor vehicle manufacturers may assign a designee for the record keeping requirements of Part 574.

ID: nht71-3.13

DATE: 06/02/71

FROM: L. R. SCHNEIDER -- NHTSA; SIGNATURE BY DAVID SCHMELTZER

TO: Long Mile Rubber Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter to Mr. Van Orden dated May 20, 1971.

Tires retreaded prior to the effective date of the retread standard (January 1, 1972) are not permitted to contain the DOT symbol on the tire. If you have marked your matrices with the symbol, I suggest you buff the letters off the tire after it is retreaded, or remove the symbol from the matrix, or fill in that portion of the matrix.

The retreading of tires without the DOT markings before the effective date of the standard is permissible.