ID: nht68-2.47

DATE: 05/20/68

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

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 16, 1968, your reference 61.A218. A1115, to the National Highway Safety Bureau concerning applicability of Federal Motor Vehicle Safety Standards 108 and 205 to compers.

Your questions along with our corresponding answers are listed below: uestion: 1. Do Federal Standards Nos. 108 and 205 apply to Camper bodies which are not manufactured as a part of a vehicle but which may be purchased separately and later installed on a pickup truck by its owner? Answer: The enclosed Notice of Making Regarding Compare affirms the applicability of Federal Standard No. 205 to camper bodies. Federal Standard No.

108 is a standard applicable to chassis cabs and to complete motor vehicles. Question: 2. Do Federal Standards Nos. 108 and 205 apply to campers which are sold by the pickup truck dealer as part of a new vehicle even though the camper body itself is actually a load on the pickup and is designed to be recovered from the pickup when the owner decides to transport other types of loads? Answer: The applicability of Federal Standard No. 205 is covered in the enclosure. Federal Standard No.

108 is a requirement upon the dealer who sells a motor vehicle. If the vehicle is designed for more than one configuration in use, the dealer must provide that both configurations are in compliance with Federal Motor Vehicle Safety Standards.

The enclosed information on the National Traffic and Motor Vehicle Safety Act of 1966 are provided to further assist you.

ID: nht68-2.48

DATE: 09/27/68

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr.; NHTSA

TO: United States Senate

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 13, 1968, calling my attention to Mr. Paul Johnston's comments and suggestions on the requirements for school bus signal lamps as specified in Motor Vehicle Safety Standard No. 108.

As Mr. Johnston pointed out, Standard No. 108, effective January 1, 1969, provides for optional use of either the eight-lamp or four-lamp signal system. This optional provision was adopted after careful consideration of the comments and recommendations which were received in response to the Notice of Proposed Rule Making as published in the Federal Register on February 3, 1967. The "Minimum Standards for School Buses", as published by the National Conference on School Transportation, and the regulations governing minimum standards for school buses in various states were also considered during development of the optional provision for signal lamp systems. Results of our studies and investigations indicated that approximately forty states were using either the four-lamp or eight-lamp signal system. Other states were using the adopted system with only minor variations in the installation and operational requirements.

Standard No. 108, effective January 1, 1969, was published in the Federal Register on December 16, 1967. Under the procedural rules of the Federal Highway Administration, any person adversely affected by this order may petition the Administrator under Part 216, Subchapter B, Section 216.31 or Section 216.35, published in the Federal Register on November 17, 1967, a copy of which is enclosed. No petition of the adopted requirements for school bus signal lamps has been filed.

Although we do not dispute the safety benefits which Mr. Johnson claims for a six-lamp system, I must emphasize that our long-range objective is the adoption of one nationwide system. Even with the presently adopted systems, a motorist could be faced with the problem of interpreting two sets of signals during a very short time period. This problem will become more prevalent with the anticipated increase in rapid interstate traffic. To permit the use of a third optional system, six-lamp or other, would further complicate the situation.

Standard No. 108 applies only to new school buses manufactured on or after January 1, 1969. Retrofitting of buses presently in operation is not required. Since Iowa's fleet of buses is presently equipped with a six-lamp system, it appears that considerable data on the effectiveness of this system could be accumulated from this fleet during the next several years, or until such time that a single nationwide system is proposed. We will be pleased to carefully review and consider any such data which Mr. Johnson can provide in the future.

In summary, it is the position of this Bureau that the provision of Standard No. 108 permitting optional use of either the four-lamp or eight-lamp signal system is reasonable, practicable and in the interest of highway safety. Therefore, we do not believe that a change in this provision to permit optional use of a third or six-lamp system is justified.

We have reviewed our files with respect to the written and personal contacts Mr. Arthur Roberts, Director of Pupil Transportation, has had with this Bureau.

This review indicates that the correspondence from Mr. Roberts was submitted in response to the Notice of Proposed Rule Making on Standard No. 112 (subsequently combined with Standard No. 108) as published in the Federal Register on February 3, 1967. It is not the practice of the Bureau to reply individually to the numerous responses received from published rule making notices, which often run to thousands of pages. However, a summary of the comments represented by the responses and the disposition of these comments is presented in the preamble to Standard No. 108 as published in the Federal Register on December 16, 1967. With respect to Mr. Roberts visit on May 7, 1968, the topics of discussion related primarily to the technical requirements of Standard No. 108 and other information relative to the merits of converting Iowa's school buses to either the four-lamp or eight-lamp system. Our understanding was that Mr. Roberts received the information he was seeking at the time of his visit and that no follow-up correspondence was necessary on our part.

ID: nht68-2.49

DATE: 09/04/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: General Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 1, 1968, to Messrs. Eugene Laskin and J. E. Leysath of this Bureau, requesting comments on the Distributors Association's bulletins on lamps, reflective devices and associated equipment required by Motor Vehicle Safety Standard No. 108.

The five bulletins adequately illustrate the requirements of Standard No. 108 to the vehicles shown except as follows:

(1) Pages 1, 3, and 4 -- The statement "Identification, clearance and side market lights and side and rear reflectors are not required unless vehicle with body is 80 or more inches wide overall" should be changed, because Table III of Standard No. 108, effective January 1, 1969, specifics requirements for side marker lights and side and rear reflex reflectors on vehicles less than 80 inches wide.

(2) Page 2 -- The numbers indicating clearance and identification lamps in lower right view should be reversed, i.e., 10 and 11, respectively. Also, the turn, tail and stop lamps do not appear to be located as far apart as practicable.

(3) Page 4 -- The front clearance lamps mounted on the chassis cab are optional, because those on the van body meet the requirements of Standard No. 103.

(4) Page 5 -- (a) Identification and clearance lamps are not required if vehicle width is under 80 inches. (b) Two red reflectors are required on the rear of the vehicle.

(5) General, all pages -- Paragraph S3.1.1.6 permits vehicles less than 80 inches overall width manufactured before January 1, 1970, to be equipped with a combination of two side marker lamps and side marker reflectors on each side instead of two each as specified in Table III.

(6) General, Pages 1 through 4 -- Parking lamps are not required on vehicles that are 80 inches or were in overall width.

With respect to the requirements of Standard No. 108, 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 hat the assembled vehicle meets the requirements of the standard.

ID: nht68-2.5

DATE: 05/14/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Northern California Ready Mixed Concrete and Materials Association

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 8, 1968, to Mr. George Nield, concerning the location requirements for clearance lamps as specified by Federal Motor Vehicle Safety Standard No. 108.

Enclosed is a copy of the Federal Motor Vehicle Safety Standards (with amendments and interpretations through February 15, 1968). Standard No. 108 appears on page 39 of this publication. The location requirements for clearance lamps are included in Table II (page 50), of the standard. Since the requirements specify locations as near as practicable to the upper left and right extreme edges of the vehicle, the exact locations will vary, depending upon the design and utilization of the vehicle on which the lamps are mounted. When the rear identification lamps are mounted at the extreme height of the vehicle, rear clearance lamps may be mounted at optional heights. I would also point out that Standard No. 108 is applicable to new vehicles manufactured for sale on or after the effective date of the standard.

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: nht68-2.50

DATE: 04/16/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Hercules Galion Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 15, 1968, to the Director, National Highway Safety Bureau, concerning your interpretation of the requirements of Motor Vehicle Safety Standard No. 108.

The lamps and reflectors shown on your drawing(Illegible Words) dated March 8, 1968 appear to be in conference with the requirements of Initial Standard No. 108; however, since no dimensions are specified on your drawing, we can only assume that the locations are as specified in the standard.

The certification requirements for complete vehicles incorporating chassis and bodies manufactured prior to and after January 1, 1968, are correctly stated in the information bulletin attached to your referenced letter and dated March 15, 1968.

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 Standard No. 108.

ID: nht68-2.6

DATE: 05/14/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 16, 1968, to Mr. Lowell K. Bridwell, Administrator, Federal Highway Administration, requesting a clarification of the electrical circuity arrangements that may be used to meet the requirements of paragraph S3.4.3 of Motor Vehicle Safety Standard No. 108.

Truck-tractors wired in accordance with your customers' orders stating, "the brown trailer circuit shall be connected to the headlamp switch and the black trailer circuit shall be energized through a seperate switch," will meet the requirements of paragraph 53.4.3, provided the trailer circuits conform to SAE Standard J560a. With this circuitry, your responsibility as a truck-tractor manufacturer would be fulfilled, regardless of the number of trailers that are towed by the truck-tractor.

Thank you for writing.

ID: nht68-2.7

DATE: 06/19/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Robert Bosch Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 24, 1968, to Mr. J. E. Leysath of this Bureau, concerning the testing of automotive flasher devices.

Motor Vehicle Safety Standard No. 108 specifies that turn signal flashers and vehicular hazard warning signal flashers conform to SAE Standards J590b and J945, respectively. These SAE standards, in turn, require that the test circuitry and test instrumentation conform to SAE Standard J823a. As you noted, the distribution of the 0.10+/-0.01 ohm series resistance in the standard test circuit (Figure 1 of J823a) is not specified in SAE Standard J823a. Therefore, your recommended distribution, namely, 0.025+/-0.005 ohms resistance between the power supply (positive terminal) and flasher input terminal, and 0.075+/-0.005 ohms resistance between the flasher output terminal and the flasher bulbs, would be permitted by SAE Standard J823a.

Flasher units having a ground terminal that is connected with the negative terminal of the power supply may be tested in the standard test circuit of SAE Standard J823a, provided the ground circuitry does not change the required resistance of 0.10+/-0.01 ohm looking into terminals A-B with the removable shunts in place (see note for Figure 1, SAE J823a).

The above-stated test provisions in no way except the flasher units from meeting all performance requirements specified in Standard No. 108, including those specified in basically referenced SAE Standards J590b, "Automotive Turn Signal Flashers," and J945, "Vehicular Hazard Warning Signal Flasher."

ID: nht68-2.8

DATE: 05/15/68

FROM: JOSEPH R. O'GORMAN -- NHTSA SIGNATURE BY ANDREW K. NESS

TO: Cheetah Coaches

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 19, 1967, to the National Highway Safety Bureau, in which you request information governing vehicle width and safety glass installation requirements on the vehicles you manufacture.

Regarding your question on vehicle width, Safety Standard No. 108 relative to lamps, reflectors and associated equipment, for specified vehicles 80 or more inches wide overall, defines the term "overall width" as the nominal design dimension of the widest part of the vehicle, exclusive of signal lamps, marker lamps, outside rear view mirrors, flexible fender extensions and mud flaps, determined with doors and windows closed and the wheels in the straight ahead position. Therefore, if your vehicle measures less than the Safety Standard No. 108 requires, compliance is not required.

Your question regarding installation of safety glass as specified by Safety Standard No. 205, relative to Glazing Materials, can be answered by directing your attention to Standard No. 205. It specifies adherence by a multi-purpose Passenger Vehicle, a category into which your pick-up campers fall. A copy of the Federal Register, Volume 32, No. 23 and amendment to this regulation, Volume 32, No. 131, is enclosed for your information.

The application of Safety Standard No. 205 to pick-ups, is covered by the enclosed Federal Register, Volume 33, No. 59.

Thank you for your cooperation and response to the Federal Highway Administration request regarding the certification requirement.

The label sample and information as to its location that 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 the serial indentification system in order that vehicles manufactured (completed) after January 1, 1968, can be identified.

Your interest in the safety program of the Bureau is appreciated.

ID: nht68-2.9

DATE: 06/24/68

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

TO: Selma Trailer and Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 2, 1968, which included additional information for certification under Public Law 89-563 and your coments.

You will note that Federal Motor Vehicle Safety Standard No. 108 does not restrict the height of the identification lamps from the roadway. You may find it suitable to mount these lights at a lower level than indicated in your illustrations.

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 manufacture from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

I am enclosing a copy of the National Traffic and Motor Vehicle Safety Act of 1966 which defines the vehicles to which it applies.

ID: nht68-3.1

DATE: 05/17/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Berliner Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 10, 1968, addressed to Mr. William H. Risteen, concerning the requirement for headlamp dimmer switches as specified in Federal Motor Vehicle Safety Standard No. 108.

Paragraph S3.4.1 of Standard No. 108 requires that a means for switching between lower and upper headlamp beams shall be provided in accordance with SAE Recommended Practice J564a or J565a. This general requirement is applicable to all vehicles, including motocycles, that are required, by Standard No. 106, to be equipped with lower and upper bean headlamps, even though SAE Recommended Practice J564a is addressed only to passenger cars.

Thank you for writing.