ID: nht68-4.21

DATE: 11/18/68

FROM: AUTHOR UNAVAILABLE; R. Brenner for William Haddon, Jr., M.D.; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 25, 1968, regarding Federal Motor Vehicle Safety Standard No. 211 and the use of hexagonal wheel nuts.

The requirement of this standard that wheel nuts, hub caps and wheel dirce "shall not incorporate vinged projections" apparently applied to all wheel nuts, whether hexagonal or otherwise.

I agree that clarification of the standard is needed, but the method of accomplishing this is yet to be resolved. I have asked the Motor Vehicle Safety Performance Service to look into this problem immediately and to take the neccessary steps to relieve any undue burdens.

ID: nht68-4.22

DATE: March 1, 1968

FROM: George C. Nield -- Acting Deputy Director, Motor Vehicle Safety Performance Service

TO: Earl Allgaier -- Manager, Driver Education Division, Traffic Engineering and Safety Department, American Automobile Association

TITLE: None

ATTACHMT: Attached to letter from Joseph R. O'Gorman to A. Nathan Darby (Std. 101); Also attached to letter dated 3-14-91 from Paul Jackson Rice to George Smyth (A37; Std. 101); Also attached to letter dated 7-30-75 from Richard B. Dyson (signed by Z. Taylor Vinson) to Bryon A. Crampton; Also attached to letter dated 8-27-68 from Eugene B. Laskin to Barry G. Seitz (Std. 203; Std. 204)

TEXT:

Thank you for your letter of February 16 concerning the installation of dual controls and handicapped controls on passenger cars.

In general, your evaluation of the effect of installing dual controls for driver training or controls for handicapped persons by dealers is correct. The present Federal motor vehicle safety standards do not prohibit the installation of these controls provided none of the requirements specified by the standards are eliminated or adversely affected by such installation. I am enclosing a complete set of standards now in effect for your information.

In the event that dual steering controls and other controls are provided on driver training vehicles, the applicability of the appropriate standards is confined to the primary controls. For example, under Standard No. 101 the person seated behind the secondary steering control need not be able to reach all controls.

Should you have any further questions on this matter, I would be most happy to have you again contact me.

ID: nht68-4.23

DATE: 01/01/68 EST

FROM: Joseph R. O'Gorman -- Acting Director, Office of Performance Analysis, Motor Vehicle Safety Performance Services

TO: A. Nathan Darby

TITLE: None

ATTACHMT: Attached to letter dated 3-14-91 from Paul Jackson Rice to George Smyth (A37; Std. 101); Also attached to letter dated 7-30-75 from Richard B. Dyson (signed by Z. Taylor Vinson) to Byron A. Crampton; Also attached to letter dated 8-27-68 from Eugene B. Laskin to Barry G. Seitz (Std. 203; Std. 204); Also attached to letter dated 3-1-68 from George C. Nield to Earl Allgaier

TEXT:

Thank you for your letter of December 17, 1967, to the National Highway Safety Bureau, concerning the installation of dual controls on passenger cars.

The present Federal Motor Vehicle Safety Standards do not prohibit the installation of dual controls provided none of the requirements specified by the standards are eliminated or adversely affected by such installation. In other words, if a dealer or manufacturer modifies a conforming vehicle, then he assumes the responsibility for the vehicle's certification. We enclose a complete set of standards now in effect for your information.

In the event that dual steering controls and other controls are provided on driver training vehicles, the applicability of the appropriate standards is confined to the primary controls, For example, under Standard No. 101, the person seated behind the secondary steering control need not be able to reach all controls.

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

ID: nht68-4.3

DATE: 08/20/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Calumet Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 22, 1968, to Mr. George C. Nield, concerning the applicability and effective date of Motor Vehicle Safety Standard No. 108.

Standard No. 108 is applicable to new vehicles manufactured on or after the effective date of the standard. Initial Standard No. 108 was published on February 3, 1967, and became effective January 1, 1968. The initial standard is applicable only to vehicle that are 80 inches or more in overall width. Revised Standard No. 108 was published on December 16, 1967, and becomes effective January 1, 1969. The revised standard is applicable to passenger cars, multipurpose passenger vehicles, trucks, buses, trailers and motorcycles, regardless of overall width; however, the special requirements for vehicles that are 80 inches or more in overall width have been identified in the standard. Copies of the initial and revised standard are enclosed for your information.

In reply to your specific questions, information is provided as follows:

1. With respect to your first question, Standard No. 108 is applicable to trailers manufactured for personal use by an individual and for commercial use.

2. With respect to your second question, Revised Standard No. 108, effective January 1, 1969, specifies the lighting requirements for trailers that are less than 80 inches in overall width.

3. With respect to your third question, the regulations of individual States and of the Bureau of Motor Carrier Safety (for vehicles engaged in interstate commerce) presently govern the lighting required on trailers that are less than 80 inches in overall width. Effective January 1, 1969, these trailers will be subject to the requirements of Revised Standard No. 108. Installation and location requirements for the individual lamps are contained in the referenced SAE standards (see Table III of Standard No. 108) and in Table IV of Standard No. 108.

Also enclosed is a copy of the notice on "Certification Requirement," which provides information on the manufacturer's certification of vehicles that are subject to the Federal motor vehicle safety standards.

ID: nht68-4.4

DATE: 08/20/68

FROM: AUTHOR UNAVAILABLE; John A. McLaine; NHTSA

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 9, 1968, containing literature on "Super-Lite" which will be an optional lighting device on the 1969 Dodge Polara and Monaco Models.

According to the literature, "Super-Lite" is an auxillary or supplemental light to be used in conjunction with the low beams of the regular headlamps.

For many years, all lighting devices used on motor vehicles registered in New Jersey have been required to be approved by the New Jersey Division of Motor Vehicles. Lighting devices are added to our approved list after a sample has been submitted along with a report from an independent testing laboratory showing that the device meets the standards of the Society of Automotive Engineers. We will also add a motor vehicle lighting device to our approved list after we receive an Approval Certificate from the American Association of Motor Vehicle Administrators showing that the device meets the SAE Standards.

Electric Supplementary Lamps, such as the "Super-Lite" are covered by SAE Standard No. J582. Perhaps you have submitted a sample light and the necessary test report to the AAMVA, but as yet, we have not received a copy of the Approval Certificate.

In case you desire to have us approve the "Super-Lite" on the basis of New Jersey alone. Please send us a sample and test report, as mentioned above.

Unless the "Super-Lite" is on our approved list at the time motor vehicles equipped with the lighting device are going through our inspection stations, the vehicles will have to be rejected.

New Jersey R S. 39:3-51 concerns the mounting and aiming of auxiliary driving lights. A copy of this section is enclosed for your information.

ID: nht68-4.5

DATE: 08/23/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: The Coleman Company, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 12, 1968, to Mr. Ed Laysath concerning lighting requirements on camper trailers.

The lamps and reflectors shown on your sketch appear to meet the requirements of Standard No. 108 with the exception that a license plate lamp is not indicated. Since no dimensions are specified on your sketch, we can only assume that the locations are as specified in the standard.

With respect to the requirements of Standard No. 103, 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 Standard No. 108.

ID: nht68-4.6

DATE: 08/27/68

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

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of July 31, 1968, to Mr. George C. Neild, Motor Vehicle Safety Performance Service, requesting the addition of a 5-K rim for use with a 5.60 x 15 tire to Table II of Federal Motor Vehicle Safety Standard No. 110.

On the basic of the data submitted showing satisfactory completion of the test requirements specified in the Federal Motor Vehicle Safety Standards No. 109 and No. 110, your request for the approved equivalent rim is granted.

The 5-K rim will be listed in Table II of Standard No, 110 and published in the Federal Register.

ID: nht68-4.7

DATE: 09/02/68

FROM: AUTHOR UNAVAILABLE; C. D. Ferguson; NHTSA

TO: General Supply and Equipment Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 7, 1969, to the Federal Highway Administration, concerning head restraints on your 1969 Lincoln Continental Sedan.

Federal Motor Vehicle Safety Standard No. 202: Head Restraints Passenger Cars, specifies that a head restraint must be provided at each outboard front seating position on cars manufactured on or after January 1, 1969. This standard does not prohibit an individual from modifying or removing the head restraints once he purchases the car. However, a particular state may have inspection laws which prohibit such actions. I suggest you check the matter with your state inspection authorities.

Our Highway Safety Program Standards, copy enclosed, set minimum performance requirements for state inspection programs. Each state is free to establish its own program which meets or exceeds the Federal guidelines. The fact that our Federal Motor Vehicle Safety Standard requires head restraints to be installed on all new passenger cars is evidence of our belief in the level of safety provided by these devices in rear collisions. We would strongly endorse a state inspection program which supported this and our other standards. I am enclosing a booklet which describes all of our motor vehicle standards.

Regarding your particular case, we agree that good visibility is necessary for the safe operation of an automobile. However, properly designed head restraints should not significantly restrict visibility. The injury-reducing benefit far outweights the slight loss of visibility which may occur in certain passenger cars. See(Illegible Word) to the head restraint standard enclosed.

As a practical matter, I would not recommend removal of your head restricts. Aside from the level of rear collision protestion which they provide, their removal may mean that their support structure within the seat back is exposed and this may present a hazard to any rear seat occupants who may hit their heads on the front seat back in a forward collision.

I would suggests the alternative of an additional rear view mirror on the right side of your vehicle to provide increased rear visibility.

Your interest in our progress is appreciated.

ID: nht68-4.8

DATE: 09/03/68

FROM: JOHN A. MCLAINE -- DEPT. OF LAW AND PUBLIC SAFETY, DIV. OF MOTOR VEHICLES, NEW JERSEY

TO: National Highway Safety Bureau

TITLE: FMVSS INTERPRETATION

TEXT: As requested, we are enclosing a copy of the letter we wrote to Mr. Paul L. Nine of the Chrysler Corporation after he sent us literature describing the Dodge "Super-Lite".

Since receiving our letter, Mr. Nine has told us that the "Super-Lite" does not conform to the SAE Standards.

SAE J582 states that the color of the light from a supplementary passing lamp must be white. The light from the "Super-Lite" is blue when the person looking at the light is in certain positions in front of the light. When a driver looks into his rear-view mirror and the vehicle behind is equipped with a "Super-Lite" the driver sees a blue light in his rear-view mirror.

New Jersey and many other States have regulations restricting the use of a blue light on the front of a motor vehicle to a motor vehicle operated by a volunteer fireman on his way to a fire, and for other emergency purposes.

SAE J582 also states that for greatest visibility, with reasonable limitations of glare to approaching drivers, the left edge of the stray light immediately to the left of the high intensity zone should be aimed at the vertical line through the lamp center, at 25 feet.

The "Super-Lite" does not meet this requirement because the left edge of the high intensity zone of the "Super-Lite" is aimed 5 1/4" to the left of the vertical line through the lamp center at 25 feet.

I suggested to Mr. Nine that if the color of the "Super-Lite" could be made to conform to the SAE Standard, perhaps we could aim the "Super-Lite" in New Jersey to conform to the SAE requirement. Mr. Nine said that this would not be satisfactory because it would destroy the purpose of "Super-Lite".

The Chrysler engineers also told me that they do not recommend that the "Super-Lite" be used on two-lane highways. I do not know how such a restriction could be enforced to insure maximum safety.

According to the literature, the "Super-Lite" was designed to bridge the gap between high and low beam lights. Our experience has shown that where traffic density permits the use of high beam lights there is no need for additional lighting and when traffic density requires the use of low beam lights there is no need for additional lighting because the tail lights and head lights of the vehicles ahead provide ample guidance.

In spite of the fact that "Super-Lite" does not meet the SAE Standards, Mr. Nine does not believe we can prohibit the use of this light in New Jersey because of Federal Law 89-563 which requires that no State shall have any safety standard applicable to the same item of equipment which is not identical to the Federal Standard.

As you know, Federal Standard 108 requires headlamps, tail lamps, stop lamps, license plate lamps, parking lamps, back-up lamps, turn signal lamps, side marker lamps, and reflectors in accordance with SAE Standards and recommended practices.

Section S 3.1.2 of Standard 108 states that no additional lamp, reflective device and associated equipment shall be installed if it impairs the effectiveness of the required equipment. Mr. Nine believes the Federal Government allows the "Super-Lite under the above section.

We do not believe the Federal Government should permit the use of a driving light which does not meet the SAE Standards, especially since all other motor vehicle lighting equipment is required to meet the SAE Standards. We also believe that the NHSB should have tests made to make certain that the use of auxiliary lights does not impair the effectiveness of the required equipment, and does not increase the danger caused by glare and confusion with various types of emergency lighting equipment.

Your comments will be appreciated.

ID: nht68-4.9

DATE: 09/03/68

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

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 19, 1968.

You state that you do not find any provision which would permit temporary mounting of lighting devices on mobile homes and ask that we inform you what provision in Public Law 89-563 or the Federal motor vehicle safety standards permits installation of temporary devices. There is no provision in P.L. 89-563 or the standards which either permits or prohibits the temporary mounting of devices. The National Highway Safety Bureau has taken the position that, insofar as mobile homes are concerned, temporary lighting devices may be used if they meet the requirements of Standard No. 108.

With respect to your request for a copy of Docket No. 26, I enclosed a copy of the notice of request for comments recently issued and published in the Federal Register. This docket was opened several months ago and contains several hundred pages of documents. The docket is scheduled to remain open, for the receipt of additional comments, until September 10, 1968. Our rules require us to charge 50 cents per page, payable in advance for copies of docket material. should you want a copy of the complete docket, please let us know and we will advise you, after September 10, of the fee for this service.

Thank you for your continuing interest in motor vehicle safety.