ID: nht68-1.4

DATE: 01/25/68

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

TO: The Armstrong Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: In our telephone conversation of January 8, 1968, and your letter of January 9, 1968, you requested:

". . . . an early reply whether labels are required, when the information already appears on one sidewall, except the basic label. (Basic label Information - DOT-153) It is also our feeling that the labeling is not a serious requirement to meet minimum safety standards."

This letter confirms my statement in our telephone conversation that Motor Vehicle Safety Standard 109 may be met if the information required in S4.3 of this standard is molded on one or both sidewalls of the tire in lieu of a label until August 1, 1968, after which this information is required on each sidewall.

Sincerely,

THE ARMSTRONG RUBBER COMPANY

January 9, 1968

Roger H. Compton, Director Office of Standards on Accident Avoidance U.S. Department of Transportation Federal Highway Administration

Dear Mr. Compton:

Re: Replies to 1) Our December 5, 1967, Letter Addressed to Mr. L. K. Bridwell

2) Confirmation of Telephone Call (December 15, 1967) Placing Labeling on One Side of Tire by Stencils Molded into the Tire in Lieu of labels

My letter of December 5, 1967, last paragraph, stated as follows:

"We request an early reply whether labels are required, when the information already appears on one sidewall, except the basic label. (Basic Label Information - DOT-153) It is also our feeling that labeling is not a serious requirement to meet minimum safety standards."

On December 15, 1967, our Mr. John A. Diehl called Mr. Schwentker and received a verbal reply by telephone from you that The Armstrong Rubber, Company could proceed without labels if the required information of S4.3 MVSS Standard 109 was molded on one sidewall of the tire in lieu of labels.

We appreciate your position and understand that your staff is not complete. However, we would like to receive a reply in writing or by means of a notice in the Federal Register that the course which you approved and which we are following can be used by all tire manufacturers.

Sincerely,

R. L. Donnelly Secretary

ID: nht68-1.40

DATE: 02/21/68

FROM: EDWIN L. SLAGLE -- DOT NHSB DIRECTOR MOTOR VEHICLE SAFETY PERFORMANCE SERVICE

TO: H. S. BEAGLE -- PRESIDENT ELECTRICAL TESTING LABORATORIES, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 2/20/68 FROM H. S. BEAGLE OF ELECTRICAL TESTING LABORATORIES, INC. TO EDWIN L. SLAGLE OF D.O.T. NATIONAL HIGHWAY SAFETY BUREAU;

TEXT: Dear Mr. Beagle:

Thank you for your letter of February 20 in which you request clarification as to the proper test procedures to be employed in determining compliance of electrically heated automotive glazing with the requirements of Motor Vehicle Safety Standard No. 205 - Glazing Materials.

Since neither Standard No. 205 nor the USASI Standard Z26.1 - 1966, which is referenced in Standard No. 205, specifies special procedures with regard to electrically heated glass, the same procedures required for non-electrically heated glass are appropriate.

Although at present rear window defrosting and defogging are not required, I would be most pleased to review with you your experience as to the effectiveness of this type of glass in meeting requirements such as have been established under Motor Vehicle Safety Standard No. 103.

Sincerely,

ID: nht68-1.41

DATE: 06/10/68

FROM: WILLIAM HADDON -- FEDERAL HIGHWAY ADMINISTRATION

TO: HARRY F. BARR -- VICE PRESIDENT ENGINEERING STAFF GENERAL MOTORS TECHNICAL CENTER GENERAL MOTORS CORPORATION

TITLE: NONE

TEXT: Dear Mr. Barr:

The interpretations of Motor Vehicle Safety Standard No. 105 regarding cable type and bar type brake controls for driver training vehicles described in your letter of May 24 are quite correct. Motor Vehicle Safety Standard No. 105 does not apply to the installation of add-on driver training brake controls following retail sale of a new car. In the case of installation of add-on driver training brake controls in new cars prior to retail sale, the following apply:

a. Motor Vehicle Safety Standard No. 105 does not apply to the add-on brake control itself; however, the installation of such controls must not affect compliance of the regular hydraulic brake system to Motor Vehicle Safety Standard No. 105.

b. Following installation of a mechanical-type add-on brake control, the installing dealer is responsible for determining that compliance of the regular brake system is not impaired by verifying that the add-on control does not interfere with normal driver access to and application of the regular brake pedal.

Although endorsing your understanding of the requirement imposed by Motor Vehicle Safety Standard No. 105, I am not endorsing these brake devices or passing on their safety from a crash standpoint.

I appreciate your interest in driver education and training and your efforts to further traffic safety through this program.

Sincerely,

ID: nht69-1.21

DATE: 08/29/69

FROM: WARREN M. HEATH -- COMMANDER ENGINEERING SECTION CALIFORNIA HIGHWAY PATROL

TO: ROBERT BRENNER -- ACTING DIRECTOR NATIONAL HIGHWAY SAFETY BUREAU

COPYEE: GAIL STRADER -- SAFETY SERVICES DIV. DEPT. REV.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/29/69 FROM CHARLES A. BAKER -- NHTSA TO WARREN M. HEATH

TEXT: Dear Dr. Brenner:

A vehicle manufacturer has notified us that their 1970 model vehicles will be equipped so that the sidemarker lamps will flash when the turn signal switch is activated. The flashing will occur on the side contemplated for the turn.

An interpretation is requested as to whether or not Section S3.5 of Federal Motor Vehicle Safety Standard No. 108 would permit the flashing of sidemarker lamps simultaneous with the turn signal lamps on the side to which a turn is contemplated.

Very truly yours,

ID: nht69-1.22

DATE: 09/12/69

FROM: CHARLES A. BAKER -- NHTSA OFFICE OF STANDARDS ON ACCIDENT AVOIDANCE MOTOR VEHICLE SAFETY PERFORMANCE SERVICE

TO: WARREN M. HEATH -- COMMANDER, ENGINEERING SECTION DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

TITLE: NONE

ATTACHMT: LETTER DATED 08/29/69; FROM WARREN M. HEATH TO ROBERT BRENNER -- NHTSA

TEXT: Dear Mr. Heath:

Thank you for your letter of August 29, 1969, to Dr. Robert Brenner, Acting Director, National Highway Safety Bureau, concerning the flashing of sidemarker lamps when the turn signal switch is activated.

Paragraph S3.5 of Federal Motor Vehicle Safety Standard No. 108 permits the flashing of sidemarker lamps simultaneously with the turn signal lamps on the side to which a turn is contemplated.

Sincerely,

ID: nht69-1.23

DATE: 08/20/69

FROM: WARREN M. HEATH

COMMANDER ENGINEERING SECTION

TO: ROBERT BRENNER --

ACTING DIRECTOR NATIONAL HIGHWAY SAFETY BUREAU U.S. DEPARTMENT OF TRANSPORTATION

COPYEE: GEORGE GAUDAEN -- SAE

TITLE: REF: 81.A215.A1575

TEXT: Dear Mr. Brenner:

We have a copy of a letter to Mr. Charles W. Heyer of Electrical Testing Laboratories from Mr. Charles A. Baker regarding photometric test procedures. That letter quite clearly points out the method in which the National Highway Safety Bureau desires multicompartment turn signal lamps to be(Illegible Word). However, it raises additional questions concerning procedures to be used both by a laboratory in determining compliance of a device with the Federal standards and by a manufacturer in designing a lamp to meet these standards.

The photometric requirements in SAE(Illegible Word) were developed several years ago before multicompartment lamps were in common use. These standards reasonably well fulfilled the need in upgrading the performance of single-compartment lamps at that time. Later, experience with some of the original multicompartment lamps and complaints about excessive brightness of the taillamps and stoplamps on vehicles brought about a need for revising the standards.

At that time, each section of a multicompartment lamp was treated in the same manner as an individual lamp, since their performance was little different than that of individual lamps set side by side. Therefore, each compartment of a three-compartment lamp had to meet the(Illegible Words) for a taillamp and the 80 candlepower minimum for a turn signal lamp. In addition, each compartment was allowed to have a maximum intensity of 15 candlepower at or above horizontal for the taillamp and 300 candlepower in red for the turn signal lamp.

The above maximum values were reasonable when only one or two lamps were used on each side of the vehicle. Unfortunately, the first three-compartment lamps were built with such high light output that each compartment barely complied with the

maximum. This meant in some cases that the combined taillamp output on each side of the vehicle was over 45 candlepower and the combined turn signal output was barely below the total maximum of(Illegible Word) candlepower, thereby being annoyingly bright to following drivers.

The manufacturers and the(Illegible Word) Lighting Committee recognized this problem and alter a number of demonstrations of systems and rewriting of proposed crafts developed the multicompartment rear lamp specification in(Illegible Words). The original brightness problem appeares to be quote simple and could have been solved merely by reducing the maximum intensities allowed multicompartment lamps; however, the manufacturers were concerned that they would then be squeezed between a high minimum value for each compartment and a low maximum value which did not allow sufficient(Illegible Word) for normal design and production.

The SAE studies indicated that with the types of multiple compartment lamps(Illegible Word) were in use about three years ago, the values in SAE(Illegible Word) applying to the total light output of the multicompartment lamp were reasonable. This standard did not cover every combination of brightness and lens area that might be involved in providing anytime effectiveness while limiting nighttime brightness to reduce annoyance, but it was a first step in this direction.

Manufacturers who have attempted to comply with both(Illegible Words) and SAE(Illegible Word) have differences in interpretation of your requirements. We would like to have the following points clarified so we do not cause the manufacturers unnecessary difficulties when we test devices for compliance with Federal and State standards:

1. Section(Illegible Words) specifies in part that the photometric requirements "shall be provided by one or a combination of the compartments or lamps".

(a) Does this mean that if one compartment or lamp meets the minimum and maximum requirements, the other compartments or lamps can have photometric output either below the minimums required or above the maximum permitted?

(b) Does this mean that one lamp may be used to meet the minimum requirements with the others adding stray light, provided the maximum requirement of 15 candlepower in the case of taillamps and(Illegible Word) candlepower in the case of turn signal lamps is not exceeded when all lamps or compartments are lighted simultaneously?

(c) Does the manufacturer have the choice in interpreting this section as to which method is most favorable to him for his particular design?

2. Mr. Baker's letter of May 12 states that "The sums of the measured candlepowers at the test points of separately photometered lamps or compartments of a combination shall not be acceptable", whereby implying that all lamps or compartments shall be photometered simultaneously.

(a) What was the purpose of stating in Section 3.1.1.7 that photometric requirements shall be provided by "one" or a combination of compartments if individual tests are not permitted to determine whether one compartment actually does comply?

(b) If it is the intent that the compartments shall be measured simultaneously, should not the above section be(Illegible Word) to eliminate the implied alternative of having only one of the lamps comply?

3. FMVSS No. 198 makes no mention of the method of testing multicompartment and multilamp taillamps and steplamps, as Section 3.1.1.7 applies only to turn signals.

(a) Do the standards require each compartment of a taillamp or steplamp to be tested separately to show compliance with(Illegible Word), or are they to be tested simultaneously as required of turn signals?

(b) Must each separate lamp or individual compartment meet the taillamp-to-steplamp ratio, or is it sufficient that the compartments when lighted together meet the ratio even though a particular lamp or compartment does not comply individually.

4. The California Vehicle Code contains a Section(Illegible Word) which prohibits a motor vehicle from being equipped with any lamp or illuminating device not specifically required or permitted by the Code. The manufacturers would like to interpret Section(Illegible Words) as permitting any number of additional taillamps and stoplamps on each side, provided only the lamp meets the requirements of J575c. The only limitation they propose is that all of the lamps taken together do not exceed the maximum candlepower requirements(Illegible Words), as an example of nonimpairment of the effectiveness of the single required lamp. They would also use photometric data showing that the total stoplamp to total taillamp output complies with the ratio requirements of J575c; again, to prove nonimpairment.

(a) Do the Federal standards preempts states from enforcing present requirements that each rear lamp on a vehicle must perform a specific function and to approved for that function?

(b) Are all of the separate lamps in the multiple rear lamp arrangement considered by the Bureau as comprising one lamp and(Illegible Word) to be taken as such by the states in enforcing identical standards?

(c) Does the Federal standard merely require the minimum of one stoplamp and taillamp on each side of the vehicle to meet the requirements of(Illegible Word), with the additional optional lamps to be provided at the manufacturers discretion regardless of whatever standards the states may have for any such supplemental lamps?

5. Some modern designs of multicompartment lamps have three compartment configurations where the large(Illegible Word) compartment is a backup lamp and on each side of it is a taillamp-stoplamp combination. Other configurations include a three compartment lamp centered on the rear of the vehicle where the middle compartment as a taillamp-stoplamp combination and the compartments on each side of it perform only taillamp functions.

(a) Where one rear lamp compartments are separated by a backup lamp compartment, as the entire lamp to be tested as a single unit as though the rear lamp sections were adjacent to each other?

(b) With respect to the device where a taillamp is on each side of a center-mounted stoplamp, are the taillamps considered a part of the physically integral three-compartment center lamp for the purposes of determining compliance with minimum and maximum specifications and ratio requirements? Or, is the taillamp on each side of the stoplamp to be tested simultaneously with the other taillamps on that particular side of the vehicle for the purposes of determining compliance?

The manufacturers have been quite ingenius in developing different variations of multiple lamps and multicompartment lamps and each has his own interpretation as to how his particular arrangement might be considered as complying with a specific Federal or SAE standard. We have been asked a number of questions such as those above as a result of our program of purchasing and testing devices for conformance to the standards.

We would very much appreciate your giving consideration to this problem and providing us with specific information that we can use in answering inquiries from foreign and American manufacturers and on using the correct test procedure for determining compliance of a specific device with the requirements.

Very truly yours,

ID: nht69-1.24

DATE: 05/28/69

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

TO: Cony America

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of May 2, 1969 in which you asked whether the Cony vehicle, model AF11SFC, which you import, must be equipped with a windshield defrosting and defogging system in compliance with Motor Vehicle Safety Standard No. 103.

You describe the vehicle as a multipurpose passenger vehicle having an open cab configuration, and your letter states that defrosting and defogging of its windshield is accomplished by natural air currents while the vehicle is operating. You also indicate that the vehicle will be operated on the public highways.

On the basis of the information contained in your letter and study of the two photographs of the Cony that accompanied it, it is our view that, subject to the exceptions noted below, models of this vehicle that have windshield or are fitted for installation of windshields must also have windshield defrosting and defogging systems.

Vehicles which are operated in the continental United States may encounter icy or snowy conditions in which the absence of a windshield defrosting system may pose an unreasonable safety hazard. The fact that the vehicle lacks an enclosed cab does not appreciably reduce that hazard. However, we do not interpret Standard No. 103 as requiring a defrosting and defogging system in a vehicle that has no windshield and on which a windshield cannot be installed without such major modifications as would make the installer himself a motor vehicle manufacturer. One of the photographs you submitted shows your vehicle without a windshield, but it does not contain enough detail to enable us to determine whether the vehicle falls into the latter category I have described.

You should be aware of two exceptions to the requirements of Standard No. 103, either of which may apply to the Cony. First, section 371.7 of our regulations provides that the standards apply only to vehicles which have a curb weight of more than 1,000 pounds. Hence, the Cony need not conform to the requirements of the standard if its curb weight is 1,000 pounds or less. Second, Standard No. 103 applies only to vehicles manufactured for sale in the continental United States. Therefore, your vehicle could be imported into jurisdictions such as Hawaii and the Virgin Islands even though it fails to conform to the requirements of that standard. The contents of your letter do not furnish enough information to permit us to ascertain whether either exception would apply.

If I can be of further assistance, please do not hesistate to call upon me for it.

ID: nht69-1.25

DATE: 02/19/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Trico-Folberth, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 1, 1969, concerning your windsheild washer system.

Apparently our letter of October 3, 1968, to Mr. B. C. Johnson was misunderstood. In Mr. Johnson's inquiry of August 23, 1968, he stated "it is easy to deliver 15 cc's of fluid inside the three seconds specified." The wording of our reply acknowledged that this performance would be acceptable--it was not intended to be a literal interpretation of our requirements or the SAE Recommended Practice.

We learned that the SAE Windshield Wiping Subcommittee plans to revise J942, Passenger Car Windshield Washer Systems, to clarify the particular points you question. Meanwhile, we think the intent of Section S4.2 of Standard No. 104 is satisfied by the following interpretation of the referenced SAE Recommended Practice:

1. Paragraph 3.1 of J942 requires that 75% of the effective wiped area be cleared in 10 wiper cycle or less. Section S4.2.1 of Standard No. 104 requires that these areas be established in accordance with subparagraph S4.1.2.1 of Standard No. 104.

2. The requirement to wipe 75% clear must also be not within 15 seconds as stipulated in paragraph 4.1.3(c) of J942.

3. A washer cycle is defined in paragraph 2.11 of J942 as "The system actuation sufficient to deliver approximately 15 cc of fluid to the windshield glazing surface." Note this definition does not actually define the number of actuation necessary to deliver the 15 cc, although the use of the word "actuation" appears to be singular. It is obvious that the intent of paragraph 4.1.3(c) is that this amount of fluid shall be delivered during the 15 second test period.

4. In paragraph 4.4.2(b) of J942 (under the durability test) the Recommended Practice requires: "For manual systems a single actuation shall consist of actuation of the control for a period not to exceed 3 seconds." It is important to note that this specifies the time required for the driver to operate the control--not the total time for the washer system to actuate. It appears this definition refers to a control actuation; whereas, the definition for "washer cycle" refers to a system actuation. This is borne out in paragraph 2.2 of J942 which defines "controls" as "A means for actuating and arresting the windshield washer system. The actuation may be coordinated or semicoordinated with components of the windshield wiper or may be fully independent."

5. Note that the following sentence in paragraph 4.4.2(b) states: "For automatic systems an actuation shall consist of one actuation of the control." This seems to indicate, by inference, that more than one control actuation is acceptable for manual systems.

6. Therefore, the intent of the referenced SAE Recommended Practice by Section S4.2 of Standard No. 104 is that manual washer systems may be actuated more than once to provide the 15 cc of fluid as long as it does not require the operator more than 3 seconds to operate the control for any single system actuation--and the washer system must deliver 15 cc of fluid to clear 75% of the wiped area within 10 cycles and within 15 seconds.

7. Note that any additional system actuations needed to meet the 15 cc requirement will also require that the manufacturer increase accordingly the total number of control actuations for the durability test in Table I, "Test Sequence" in J942.

We assume that your windshield washing system meets these requirements based upon your explanation of your manual system. However, we wish to point out our concern that the existing regulations do not adequately define washer system performance requirements, since it is possible under the current regulations for the driver to be needlessly occupied with the washer controls during a period of reduced visibility. Accordingly, we expect to up-grade the washer system performance requirements as soon as practicable.

ID: nht69-1.26

DATE: 08/27/69

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

TO: Rubber Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of August 1, 1968, to the National Highway Safety Bureau, requesting the addition of test rims for certain tire size designations to Table II of the Federal Motor Vehicle Safety Standard No. 110.

With your letter your transmitted data indicating satisfactory completion of the test requirements specified in the Federal Motor Vehicle Safety Standards No. 109 and No. 110. On the basis of this information, your request for the approved equivalent rims is granted.

Accordingly, the following approved equivalent rims will be added to Table II of the Federal Motor Vehicle Safety Standard No. 110.

Tire Size Designation Alternate Rim E70-14 7JJ E70-15 8JJ G78-14 7JJ E70-15 7JJ

ID: nht69-1.27

DATE: 06/06/69

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

TO: Rubber Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of May 14, 1969, to the National Highway Safety Bureau requesting the addition of the 6JJ alternative rim size for the E78-14 tire size designation to Table I of 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, 1968, the 6JJ alternative rim size for the E78-14 tire size designation will be listed within Table I of Appendix A of Standard No. 110. This change will be published in the Federal Register in the near future.

The addition of new alternative rim size designations to the table is accomplished through an abbreviated procedure consisting of the publication in the Federal Register of petitioned alternative rim size. If no comments are received, the amendment becomes effective 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.