ID: aiam1816

Dear Mr. Tanaka:#This responds to your letter of February 15, 1975 requesting an interpretation of the adhesion requirements of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*.#You have presented a diagram of multilayer air brake hose and suggested that S7.3.7 of the standard applies only to the adhesion between the outer cover and the upper braid of the hose. That interpretation is incorrect. The requirement of S7.3.7 is that:>>>An air brake hose shall withstand a tensile force of 8 pounds per inch of length before separation of adjacent layers (S8.6).<<<#The NHTSA interprets this requirements as applying to each pair of adjacent layers of the hose, not merely to the outermost pair.#Yours truly, James C. Schultz, Chief Counsel;

ID: nht71-3.20

DATE: 06/21/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: D. R. Elder

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to a carbon copy of a letter you sent to Mr.(Illegible Word) Office of Consumer Affairs and Public Information of the National Highway Traffic Safety Administration, concerning the Tire Identification and Record Keeping regulations (49 CPR Part 574).

In the last paragraph of your letter you state that the regulation "has absolutely no bearing on the manufacture and (Illegible Word) of of any off-highway vehicles such as, wheeled form or industrial tractors, wheeled motor scrapers, tractor drawn scrapers, garden tractors, "terre tigers", wheeled agricultural equipment, lift trucks, etc.", (emphasis added). This appears to be a broadening of the interpretation given to you by Mr.(Illegible Word). This letter is to make it clear that the regulation applies unless the product you manufacture is not a motor vehicle within the definition of the National Traffic and Motor Vehicle Safety Act. Enclosed is a copy of the Act. Your specific attention is directed to the definition of a motor vehicle found in Section 102(3).

While vehicles used primarily for-off-rond purposes are not considered motor vehicles within the meaning of the Act, I suggest you request an interpretation from this office (enclosing brochures) concerning the specific vehicles you manufacture.

ID: nht72-2.8

DATE: 05/03/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Clark Equipment Company

TITLE: FMVSR INTERPRETATION

TEXT: This will serve to confirm the opinion which you were given by telephone on April 24, 1972, to the effect that the filing of timely petitions for reconsideration of Motor Vehicle Safety Standard No. 121 (37 F.R. 3905, February 24, 1972) will prolong the period within which Clark Equipment Company may seek judicial review of the standard until 60 days after the NHTSA's response to the petitions appears in the Federal Register. You may therefore wait until after disposition of the petitions without losing the right to judicial review as to each of the issues raised in your petition.

ID: nht78-1.18

DATE: 06/19/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of May 1, 1978, to Mr. Tilton of this office requesting our interpretation of the requirement of Standard No. 110, Tire Selection and Rims, that a placard displaying specified information be "permanently affixed to the glove compartment door or an equally accessible location." (S4.3) Specifically, you inquire whether the back side of the lid of the center console box is an acceptable location for the placard within the meaning of S4.3.

We have interpreted "equally accessible location" as requiring a location where the placard (1) can be referred to easily, as it can when located on the glove compartment door; and (2) will be relatively free from exposure to substances which may destroy it or render it illegible, as it is when located on the glove compartment door. The back side of the lid of the center console box as depicted in the diagram attached to your May 1 letter fulfills these two requirements, and is therefore an "equally accessible location" within the meaning of S4.3.

Sincerely,

ATTACH.

NISSAN MOTOR CO., LTD.

May 1, 1978

Roger S. Tilton -- Office of the Chief Counsel, NHTSA

Dear Mr. Tilton:

This letter is to request your interpretation concerning a location of the tire placard which is specified in S.4.3. of FMVSS 110 "Tire selection and rims". We are planning to affix the tire placard to the back side of the lid of the center console box in one of our future models as shown in the attachment.

We would like to know whether this location is acceptable or not under the requirement of "A placard, permanently affixed to the glove box compartment door or an equally accessible locations" in S.4.3.

We would appreciate your reply as soon as possible

Thank you.

Very truly yours, Tokio Iinuma Staff, Safety

Enclosure

(Graphic omitted)

ID: nht90-1.7

TYPE: Interpretation-NHTSA

DATE: January 7, 1990

FROM: Perry E. Faulkner -- Foremost Tire & Retreading

TO: William "Bill" McCollum -- Fifth Congressional District

TITLE: None

ATTACHMT: Attached to letter dated 3-13-91 from Jamie McLaughlin Fish to Bill McCollum (A37; Std. 117; Std. 119); Also attached to letter dated 6-18-81 from Frank Berndt to Roy Littlefield (Std. 119)

TEXT:

The following question was submitted to the Department of Transportation for verification.

"Are casings purchased overseas, for recapping in the United States, required to have the Department of Transportation, D.O.T. number on the casing. This D.O.T. number signifies that the Federal Excise tax has been paid and that the tire meets or exceed s Federal standards?"

Your office gave me the phone number for Tire Compliance at 1-915-655-0546, Yates Galloway. He confirmed that in the Code of Federal Regulation, 571.117-S 5.2.3, that any tire that is recapped in the United States must have imprinted from the Factory of origination the Size of the tire and D.O.T. number. Any casing brought into the United States without the D.O.T. number cannot be sold recapped.

For our records, this is my formal request for an official letter from Mr. Galloway, for our protection. There are numerous tire dealers who are trying to sell large volume of tires from overseas market without the D.O.T. number. If the casing was to b lowout and a death was the result the person that sold the casing would have the total responsibility for selling a casing that does not meet Federal Standards.

Thanking you in advance for your valued time and consideration on this very important and life safety request. If you have any questions or need additional information, please do not hesitate to contact me at the office.

ID: nht71-5.45

DATE: 09/16/71

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

TO: Electrical Testing Laboratories, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 8, 1971, concerning the recent amendment of Standard 108 concerning turn signal and hazard warning flashers (36 F.R. 17343, August 28, 1971).

You noted that test-condition temperatures are listed without tolerances, and asked what tolerance is acceptable for testing.

In the case of motor vehicle safety standards, the testing that a manufacturer may perform or have performed on its products is not an end in itself, but is done to enable the manufacturer to certify that the products meet the required performance levels under the specified conditions. Thus, the requirement that a product meet or exceed certain values at 75 degrees F. refers to a legal conclusion that is to be drawn from appropriate testing, and no tolerance is necessary or appropriate in the text of the standard. In practical terms, it is up to the manufacturer to determine what tests will enable him to certify his products as conforming. Normally, this is done by testing his products under slightly more adverse conditions than those specified in the standard. If, for example, higher temperatures constitute more adverse conditions for a flasher, the laboratory should test at a temperature slightly higher than that specified. In sum, the testing should be sufficient to support the conclusion that, if tested under the specified conditions, the product would perform as required.

RB

cc

ELECTRICAL TESTING LABORATORIES, INC.

September 8, 1971

Docket Section National Highway Traffic Safety Administration

Re: Docket No. 71-12588

69-18, notice 5

We have reviewed the above mentioned notice to amend Motor Vehicle Safety Standard No. 108 relative to automotive turn signal and hazard warning signal flashers. We find that in Section S4.6.1.3, subparagraphs (b)(ii) and (c)(ii) have been interchanged relative to current testing procedures. We also note that paragraph S4.6.1.3, subparagraph (c)(iv) 11 volts is shown as 11.00. The additional zero indicates accuracy beyond normal testing procedure.

We find that in all cases the ambient temperature is shown as 75 degrees F. without a tolerance. We would like to ask what tolerance is acceptable for testing.

W. Glenn Pracejus Manager Electrical/Electronic Division

ID: nht70-2.28

DATE: 09/29/70

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Aractho Motors Distributors

TITLE: FMVSR INTERPRETATION

TEXT: I wish to express my apology for the fact that you have not received a response to your letter of August(Illegible Words) of our correspondence records does not indicate that it ever reached my office.

From information available on the Bureau Mini-bike, it would appear that it would fall within the scope of the Mini-Bike interpretation,(Illegible Words)(Illegible Word) -- October 3, 1969), a copy of which is enclosed for your information and guidance.

Each manufacturer must decide whether his vehicles are manufactured primarily for off-the-road use. This is usually determined by the manufacturer after his review of the aforementioned interpretation.

Your attention is directed to the fourth paragraph of that document which states in part, "Thus, if a vehicle is operationally capable of being used on the public thoroughfares, and in fact, a substantial proportion of the consuming public actually view it that way, it is a 'motor vehicle' without regard to the manufacturer's intent, however(Illegible Word)."

At this time, the Bureau would have no reason to challenge your off-the-road(Illegible Word) only" classification.(Illegible Word) on the other hand, we find that the vehicles are in fact being used for other than the intended purpose, your classification could be questioned by the Bureau.

Thank you for your letter and I trust this will answer your question.

ID: aiam2613

Dear Mr. Kolb: This responds to your April 18, 1977, letter asking whether ou regulations pertaining to truck-camper loading apply to trucks designed to haul fifth-wheel trailers.; Truck manufacturers are required to supply information pertaining t the cargo weight rating and longitudinal limits for the center of gravity of those vehicles capable of accommodating slide-in campers (Code of Federal Regulations, Volume 49, Part 575.103, *Truck-camper loading*). Slide-in camper is defined as 'a camper having a roof, floor, and sides, designed to be mounted on and removable from the cargo area of a truck by the user.' The purpose of this information requirement is to lessen the possibility of vehicle overloading. Since fifth-wheel trailers do not fall within the definition of slide-in camper, the regulations pertaining to truck-camper loading do not apply to vehicles designed to haul these trailers.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam2612

Dear Mr. Kolb: This responds to your April 18, 1977, letter asking whether ou regulations pertaining to truck-camper loading apply to trucks designed to haul fifth-wheel trailers.; Truck manufacturers are required to supply information pertaining t the cargo weight rating and longitudinal limits for the center of gravity of those vehicles capable of accommodating slide-in campers (Code of Federal Regulations, Volume 49, Part 575.103, *Truck-camper loading*). Slide-in camper is defined as 'a camper having a roof, floor, and sides, designed to be mounted on and removable from the cargo area of a truck by the user.' The purpose of this information requirement is to lessen the possibility of vehicle overloading. Since fifth-wheel trailers do not fall within the definition of slide-in camper, the regulations pertaining to truck-camper loading do not apply to vehicles designed to haul these trailers.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: 77-1.7

TYPE: INTERPRETATION-NHTSA

DATE: 01/18/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Kelsey-Hayes Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Kelsey-Hayes Company's November 29, 1976, question whether an antilock valve (incorporating the function of a relay valve) is subject to the requirement of S5.7.1 of Standard No. 121, Air Brake Systems, that a truck or bus be capable of stopping within a specified distance following failure in the service brake system of a part designed to contain compressed air or brake fluid (with the exception of certain parts that are common to both sides of a "split" service brake system).

From your description, the antilock valve in question, whether or not it incorporates the function of a relay valve, is a part of the service brake system designed to contain compressed air, and would be one of the components whose failure would be subject to the requirement of S5.7.1. I assume that the value would be in the subsystem to the front axle or to the rear axles of a truck or bus and, as such, would not be a value that is common to both sides of a "split" service brake system.

Sincerely,

ATTACH.

KELSEY-HAYES COMPANY

November 29, 1976

Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration

RE: Request For Interpretation FMVSS-121 Air Brake Systems S 5.7.1 Emergency Brake System Performance

Dear Mr. Berndt:

Kelsey-Hayes Company hereby requests an interpretation of the above cited provision. Specifically, we ask whether an antilock air valve, which incorporates the function of a relay valve, constitutes a part designed to contain compressed air, such that a failure of this valve requires conformance to the emergency brake system performance requirements.

Your prompt attention to this request will be appreciated.

Very truly yours, John F. McCuen -- COUNSEL