ID: aiam0424

Dear Mr. Kennebeck: This letter will serve to confirm the interpretation of Standard No 215, Exterior Protection, that we gave you at our meeting of July 19, 1971. As we advised you at that time, the standard does not require the vehicle's bumpers to touch the impact line on the test device. The vehicle must touch the impact ridge, but it is permissible to do so without also touching the impact line.; If you have further questions of interpretation, please advise us. Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: 16613.ztv

Mr. Yanichi Yoshimoto
Deputy General Manager
Technical Administration Dep't.
Koito Manufacturing Co., Ltd.
Shizuoka Works
500,Kitawaki
Shmimzu-Shi, Shizuoka-ken
Japan

Dear Mr. Yoshimoto:

This is in reply to your letter of November 28, 1997, to the Associate Administrator for Safety Performance Standards, asking for an interpretation of the humidity test requirements of Federal Motor Vehicle Safety Standard No. 108. For your future reference, requests for interpretation should be addressed to the Chief Counsel.

After a humidity test, paragraph S7.4(h)(6) of Standard No. 108 requires the inside of a headlamp to "show no evidence of delamination or moisture, fogging or condensation visible without magnification." You ask whether moisture is nevertheless permissible if it is located in an area of the interior where it cannot affect the photometric performance of the headlamp.

The requirement is absolute: no moisture that is visible without magnification is permitted on the interior of a headlamp after the humidity test, whether or not it is located in an area related to the photometric performance of the headlamp. Thus, moisture is not permissible in the situation shown in your Case 1 (moisture on the lens area of the turn signal lamp portion of a single compartment lamp) or your Case 2 (moisture in a location outside the photometric effective area of the headlamp).

Sincerely,
John Womack
Acting Chief Counsel
d.1/8/98
ref:108

ID: volvo.crs

Mr. William Shapiro
Director, Regulatory Compliance
and Environmental Affairs
Volvo Cars of North America, Inc.
Volvo Drive
Rockleigh, NJ 07647-0913

Dear Mr. Shapiro:

This responds to your letter of March 11, 1998, requesting the National Highway Traffic Safety Administration (NHTSA) to approve an alternate location for placement of the certification label on vehicles within a new car line, currently designated as "P23," that Volvo plans to introduce into North America beginning in model year 1999. Although you requested confidential treatment of the information contained in the March 11, 1998 letter and in its enclosure, you subsequently withdrew that request. Accordingly, this letter makes reference to certain of that information.

NHTSA's regulations at 49 CFR 567.4(c) prescribe specific locations for the installation of vehicle certification labels, and provide that if none of those locations are practicable, the manufacturer may suggest an alternate location for the agency's approval. As identified in your letter, and in an accompanying drawing, the alternate location for which you have requested approval is on the vehicle's B-pillar, facing the door opening of the rear door on the driver's side. In a subsequent letter, dated March 23, 1998, you state that it is not possible for the certification label to be placed in any of the locations specified in 49 CFR 567.4(c) owing to the size of the label, the corresponding surface geometry of each of those locations, and adhesion difficulties owing to the surface properties at some of those locations.

In specifying locations for the placement of vehicle certification labels, NHTSA's objective is to ensure that those labels may be easily read. The location that you have proposed for vehicles in the P23 new car line would meet this objective. NHTSA therefore approves your request.

If you have any further questions regarding vehicle certification requirements, feel free to contact Coleman Sachs of my staff at 202-366-5238.

Sincerely,
John Womack
Acting Chief Counsel
Ref:567
d.4/29/98

ID: aiam0454

Dear Mr. Flynt: Your letter of September 29, 1971, to the National Highway Traffi Safety Administration requesting an interpretation of Federal Motor Vehicle Safety Standard No. 117, has been referred to this office for reply.; Within S5 of Standard No. 117, it states that retreaded tires mus conform to S4.2.1 of Standard No. 109 requires a treadwear indicator that will provide a visual indication that the tire has worn to a tread depth of 1/16 inch. For your information, we have enclosed copies of Standard No. 109 and No. 117.; Sincerely, E.T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;

ID: nht73-3.27

DATE: 02/15/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Kelsey-Hayes Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of October 23, 1972 and January 25, 1973, concerning the intent of the antilock performance requirements of Motor Vehicle Safety Standard No. 121. I apologize for our delay.

Your question arises from an amendment to S5.3.1 of the standard. As originally adopted in February 1971, the section required that the vehicle be capable of stopping without wheel lockup except for "momentary" lockup allowed by an antilock system. As amended in February 1972, the word "controlled" is used in place of "momentary", so that the section now provides that stops are made

without lockup of any wheel at speeds above 10 m.p.h. except for controlled lockup of wheels allowed by an antilock system . . . .

In making this change, the agency had in mind the type of antilock system that was designed to permit one wheel on an axle to lock under some circumstances while the other wheels continued to turn. It was thought that adequate control could be attained by such systems, and the standard was amended accordingly.

The question you raise is whether a system could be designed in which all wheels could be permitted to lock for substantial periods, so long as they are "controlled" by an antilock system. As you correctly indicate, the term "controlled", unlike "momentary", is not a time-related word. Our answer, therefore, is that such an antilock system would be permitted under the standard as it now stands.

It is our present opinion, however, that such a system would probably not provide an acceptable level of performance. If it appears that such a system would be installed, it is likely that we would undertake rulemaking action to prohibit it.

ID: nht71-5.41

DATE: 12/27/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: By letter of December 6, 1971, you have asked our opinion as to how S6.1 of Standard 208 applies to two hypothetical situations. S6.1 requires that "all portions of the test device shall be contained within the outer surfaces of the passenger compartment throughout the test."

Your first situation involves a vehicle in which the impact of the dummy's head causes the windshield to bulge beyond its original location but does not penetrate the windshield. It is our opinion that in this case the vehicle has contained the occupant and would conform to S6.1.

In your second situation, the dummy's head pushes the windshield loose its base and opens a gap between the windshield and the vehicle. It is our opinion that this drawing also shows the dummy to be satisfactorily contained.

In either situation, however, a manufacturer would have to assure himself that the windshield behaviour shown in the drawings would be consistent and would not lead to failure in tests in which the test dummy strikes it in a different manner.

NISSAN MOTOR CO., LTD.

December 6, 1971

Lawrence R. Schneider Chief Counsel National Highway Traffic Safety Administration

Re: Interpretation of MVSS 208

If possible, could you give us your opinions on the following two cases, we would like to know whether such cases meet MVSS 208, S.6.1.:

After frontal barrier crash test, the head of the anthroponorphic test device is contained within the outer surface of the windshield glass, which, (case 1.) was deformed as shown in Fig. 1. (case 2.) was remved in part as shown in Fig. 2. by the head impact on the windshield glass. Although the test devices' head is out of the original outer surface of the vehicle passenger compartment.

Your kind cooperation and assistance in this matter would be greatly appreciated.

Satoshi Nishibori Engineering Representative Liaison Office In U.S.A.

Attachments

(Graphics omitted) (Graphic omitted)

ID: aiam1738

Dear Mr. Wilson: This responds to your December 9, 1974, question whether the 'pre-loa unit' of the Page 'Logging Simi' qualifies for an exemption from the requirements of Standard No. 121, *Air brake systems*, until September 1, 1976.; Based on the enclosed description, the 'pre-load unit' appears to be a air- braked trailer without particular brake-line or bed-height characteristics which would qualify it as a Heavy hauler trailer entitled to an exemption until September 1, 1976. Therefore, we conclude that the trailer is subject to the requirements of the standard if manufactured on or after January 1, 1975.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: 3200yy

Mr. Michael D. Incorvaia
Manufacturing Engineering Manager
Wagner Lighting
P.O. Box 4650
Sevierville, TN 37864

Dear Mr. Incorvaia:

This responds further to your letter of July 3, 1991, which we informed you on August 20, will be accorded confidential treatment.

Paragraph 4.5 of SAE Standard J588e, Turn Signal Lamps, September 1970, states that "failure of one or more turn signal lamps to operate should be indicated by a 'steady on', 'steady off', or by a significant change in the flashing rate of the illuminated indicator." Electronic flashers available today provide a "significant change" in flash rate by doubling it as an outage indication. Wagner Lighting has developed a lamp outage indication that will remain within the performance parameters of Standard No. l08, but provide an outage flash rate that appears to be slightly less than 50% greater than that of normal operation. However, there will be "a recognized change in flashing rate." You have asked whether these changes may be regarded as "significant" within the meaning of SAE J588e.

Your letter indicates that the design contemplated by Wagner Electric is for application in new motor vehicles. Although SAE J588e remains in effect as a replacement equipment standard, Standard No. l08 has been amended to incorporate by reference new SAE standards for turn signal lamps, and it is these standards that now apply to turn signals on new motor vehicles. Specifically, on and after December 1, l990, a motor vehicle must be manufactured to meet either SAE Standard J588 NOV84, Turn Signal Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width, or SAE Standard J1395 APR85, Turn Signal Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width. The outage indication requirement of SAE J588e was not adopted in either of the SAE standards, and has not been incorporated directly in Standard No. l08. This means that outage indication is no longer a requirement on new motor vehicles, and that Wagner Electric, under Standard No. l08, may adopt such change in flash rate as its design may call for.

We are returning the tape that you enclosed.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosure

/ref:l08 d:ll/l2/9l

ID: nht91-7.6

DATE: November 12, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Michael D. Incorvaia -- Manufacturing Engineering Manager, Wagner Lighting

TITLE: None

ATTACHMT: Attached to letter dated 7-3-91 from Michael D. Incorvaia to NHTSA

TEXT:

This responds further to your letter of July 3, 1991, which we informed you on August 20, will be accorded confidential treatment.

Paragraph 4.5 of SAE Standard J588e, Turn Signal Lamps, September 1970, states that "failure of one or more turn signal lamps to operate should be indicated by a 'steady on', 'steady off', or by a significant change in the flashing rate of the illuminated indicator." Electronic flashers available today provide a "significant change" in flash rate by doubling it as an outage indication. Wagner Lighting has developed a lamp outage indication that will remain within the performance parameters of Standard No. 108, but provide an outage flash rate that appears to be slightly less than 50% greater than that of normal operation. However, there will be "a recognized change in flashing rate." You have asked whether these changes may be regarded as "significant" within the meaning of SAE J588e.

Your letter indicates that the design contemplated by Wagner Electric is for application in new motor vehicles. Although SAE J588e remains in effect as a replacement equipment standard, Standard No. 108 has been amended to incorporate by reference new SAE standards for turn signal lamps, and it is these standards that now apply to turn signals on new motor vehicles. Specifically, on and after December 1, 1990, a motor vehicle must be manufactured to meet either SAE Standard J588 NOV84, Turn Signal Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width, or SAE Standard J1395 APR85, Turn Signal Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width. The outage indication requirement of SAE J588e was not adopted in either of the SAE standards, and has not been incorporated directly in Standard No. 108. This means outage indication is no longer a requirement on new motor vehicles, and that Wagner Electric, under Standard No. 108, may adopt such change flash rate as its design may call for.

We are returning the tape that you enclosed.

ID: nht88-4.6

TYPE: INTERPRETATION-NHTSA

DATE: 11/09/88

FROM: JAMES A. LUTES -- KENTUCKY MANUFACTURING COMPANY

TO: ERIKA Z. JONES -- CHIEF COUNSEL N.H.T.S.A.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/19/88 FROM STEPHEN P. WOOD -- NHTSA TO JAMES A. LUTES; REDBOOK A33 [4]; VSA 102; STANDARD 108; LETTER DATED 10/28/88 FROM THOMAS A. COZ TO JIM LUTES RE CALIFORNIA CITATIONS HIGH MOUNTED TRAILER STOP LAMPS

TEXT: Dear Erika,

Kentucky Manufacturing Company at the request of numerous customers, including North American Van Lines of Fort Wayne, Indiana has been installing high mount stop and turn lights in the rear doors of van-type trailers; the height of these lights is appro ximately 12'-0" above ground level.

The above lights are in addition to the standard stop, tail, and turn lights that are located within the specified dimension range of 15" to 72" above ground level, as specified by F.M.V.S.S. #108.

Our interpertation of F.M.V.S.S. #108 is that all lights that are required by law have a specified location within given dimensions; extra lights may be installed on a trailer in any location as long as the extra lights do not obscure or hinder the ident ification of the lights required by law.

We are attaching a photograph showing the extra stop and turn lights in the rear doors. We are also attaching copies of citations issued to North American Van Lines drivers by California Highway Patrol. Also enclosed is a letter addressed to myself fro m North American Van Lines dated October 28, 1988 and signed by Mr. Thomas A. Coz, Senior Attorney at North American.

As stated on the citations, stop & turn signals mounted higher than 72" above ground are in violation (24603CVC).

We would appreciate very much your interpretation and/or clarification of the above situation.

Very truly yours,

Enclosures

[PHOTOGRAPHS OMITTED]