ID: 11697DRN

Mr. Christophe Malaterre
Project Manager, International
PIVCO AS
Stanseveien 4
N-0975 Oslo, Norway

Dear Mr. Malaterre:

This responds to your question whether the National Highway Traffic Safety Administration (NHTSA) requires U.S. motor vehicles to carry the Standard No. 125 warning device. The answer is no.

As you indicated in your letter, Standard No. 125, Warning devices, establishes requirements for devices, without self-contained energy sources, that are designed to be carried in motor vehicles and used to warn approaching traffic of the presence of a stopped vehicles. Nothing in Standard No. 125 requires that a warning device be placed in a new motor vehicle.

Please note that the Federal Highway Administration, our sister agency in the U.S. Department of Transportation, establishes requirements for commercial vehicles and commercial drivers. That agency may have requirements for the Standard No. 125 device, when used in commercial vehicles. For information on warning device requirements for commercial vehicles, please contact: Mr. James E. Scapellato, Director, Office of Motor Carrier Research and Standards, Federal Highway Administration, 400 Seventh St., S.W., Washington, D.C. 20590.

In addition, some states may have requirements for use of the Standard No. 125 warning device. You may be able to receive relevant information about various state requirements from: Automotive Manufacturers Equipment Compliance Agency, Inc., 888 16th St., N.W., Suite 700, Washington, DC 20006. Their telephone number is: (202) 898- 0145.

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992. Our FAX number is (202) 366-3820.

Sincerely,

Samuel J. Dubbin Chief Counsel ref:125 d:4/12/96

ID: nht70-1.21

DATE: 06/03/70

FROM: Rodolfo A. Diaz; signature by George Nield -- NHTSA

TO: Export Vehicle Engineering Dept.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 20 in which you ask "whether the Station Wagon should be construed as a Passenger Car or a Multipurpose Passenger Vehicle".

You are correct in your interpretation that a station wagon "does not normally fall under" the category of multipurpose passenger vehicle. However, if a station wagon "is constructed on a truck chassis" or "with special features for occasional off-road operation", such as four-wheel drive, it would be considered a multipurpose passenger vehicle. I hope this clarifies the matter for you.

ID: nht68-1.35

DATE: 01/23/68

FROM: Howard A. Haffron; signature by Dowell H. Anders

TO: Thomas S. Foley; House of Representatives

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 8 to Congressional Liaison, Department of Transportation, in which you enclosed a letter of December 20 from your constituent James B. Mitchell of Spokane. Mr. Mitchell protests regulations then proposed and new adopted, promulgated jointly by the Department of Transportation and the Department of Treasury, which cover importation of motor vehicles subject to the National Traffic and Motor Vehicle Safety Act of 1966.

These regulations, in essence, implement section 108 of the Act and state that motor vehicles subject to the Federal motor vehicle safety standards (such as passenger cars including sports cars, but not including competition racing cars) cannot be imported into the United States unless they conform to all applicable standards prior to entry or are brought into conformity after entry. Consequently, any Ferrari manufactured on or after January 1, 1968, and intended primarily for use on the public roads will be admitted to the United States if it conforms to all applicable standards or, in the alternative, if it can be brought into conformity within 90 days after entry or such other period as the district director of customs of the port of entry may allow for good cause shown.

ID: nht70-1.39

DATE: 02/02/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Holan; Division of Ohio Brass Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 19, 1970, in which you asked whether section 371.13, Labeling of Chassis-Cabs, requires chassis-cab manufacturers to indicate the date of manufacture b month, day and year, or whether mouth and year alone is sufficient.

The wording of the section is "date of manufacture", without further elaboration. While in most contexts this phrase refers to a specific day, the present scheme of labeling and certification lands as to the conclusion that the month and year will be sufficient to satisfy the intent of the regulation.

The main regulator purpose of the requirement is to make it clear which standards are applicable to the chassis-cab and therefore to the complete vehicle under our rulings. A similar purpose is fulfilled by the date-of-signature require out in the Certification Regulations, 49 CFR Part 367, and there the requirement is simplicitly stated as month and year only. It is the practice of the National Highway Safety Bureau to make standards effective on the first day of month and therefore it is unnecesary to require manufacturers to incur the extra expense of a daily lable change.

We are pleased to be of assistance.

ID: nht72-6.14

DATE: 11/10/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Equipment & Body Manufacturers Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letters of September 25 and October 19, 1972. In your letter of September 25, you ask whether persons performing intermediate manufacturing operations are subject to the Defect Reports regulations, specifically that part of the regulations which requires the quarterly reporting of production figures (@ 573.5(b)). The defect reports regulations apply to all manufacturers of complete or incomplete motor vehicles. We consider intermediate manufacturers to be within the latter category, and the reguations therefore apply to them.

Your letter of October 19 asks whether a person who installs a fifth wheel in a pickup truck is considered a "remanufacturer." Under existing regulations, we would not consider the installation of a fifth wheel on a pickup truck to be a significant enough alteration to constitute remanufacturing. Under the recently proposed amendment to the Certification Regulations regarding the certification of altered vehicles (37 F.R. 22800, October 25, 1972), whether such a person would be an alterer and required to affix a new label to the vehicle would depend upon whether the fifth-wheel is a readily attachable component.

ID: nht71-1.7

DATE: 06/01/71 EST

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Volkswagen of America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of June 7, 1971, you asked for confirmation of your understanding that under the NHTSA regulation (49 CFR @ 553.39) interpreting section 105(a)(1) of the National Traffic and Motor Vehicle Safety Act, a petition for judicial review of Standard No. 208 would be considered timely if filed within 60 days after the publication in the Federal Register of the Administrator's decision on any petitions for reconsideration of that standard.

Your understanding is correct. As the standard currently stands, we consider it (that is, the standard as it becomes effective January 1, 1972) a "single rule", to use your phrase, and the judicial review period will not begin to run until the publication of the decision on any timely-filed petitions for reconsideration of any part of it. If at a future date we wish to sever any portion of the standard for judicial review purposes, and consider it "final" despite pending action on other portions, we will give explicit notice of that action in the Federal Register.

We are pleased to be of assistance.

ID: nht71-5.50

DATE: 07/01/71 EST

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of June 7, 1971, you asked for confirmation of your understanding that under the NHTSA regulation (49 CFR @ 553.39) interpreting section 105(a)(1) of the National Traffic and Motor Vehicle Safety Act, a petition for judicial review of Standard No. 208 would be considered timely if filed within 60 days after the publication in the Federal Register of the Administrator's decision on any petitions for reconsideration of that standard.

Your understanding is correct. As the standard currently stands, we consider it (that is, the standard as it becomes effective January 1, 1972) a "single rule", to use your phrase, and the judicial review period will not begin to run until the publication of the decision on any timely-filed petitions for reconsideration of any part of it. If at a future date we wish to sever any portion of the standard for judicial review purposes, and consider it "final" despite pending action on other portions, we will give explicit notice of that action in the Federal Register.

We are pleased to be of assistance.

ID: nht90-1.16

TYPE: INTERPRETATION-NHTSA

DATE: JANUARY 12, 1990

FROM: SAMUEL KIMMELMAN -- ENGINEERING PRODUCT MANAGER, IDEAL CORPORATION

TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TITLE: N

ATTACHMT: ATTACHED TO LETTER DATED 3-30-90 TO SAMUEL KIMMELMAN FROM STEPHEN P. WOOD; (A35; STD. 108) TEXT:

Several vehicles manufactured in the last several years contain dash board turn signal indicators in the shape of arrows that increase in size, through three (3) growth stages, during the "on" time of the corresponding flashing turn signal lamps. When th e turn signal lamps go "off" the dash board arrow goes "off" and begins the next growth cycle when the turn signal lamps go "on". The dash board turn signal arrow follows the "on-off" cycling of the corresponding turn signal lamps.

In turn signal operation when a turn signal lamp fails the original equipment flasher changes to a higher flash rate, shorter "on" and "off" times, thereby preventing the corresponding dash board indicator arrow from reaching the 3rd growth stage. This is an indication to the driver that a turn signal lamp has failed.

We manufacture aftermarket variable load turn signal flashers and hazard warning flashers, certified as meeting the requirements of FMVSS-108, for use as replacements to original equipment flashers. However, due to differences in operating characteristi cs between our variable load flashers and the original equipment flashers used in these vehicles, we cannot guarantee our flashers will provide sufficient "on" time to allow the dash board indicator arrows to reach the 3rd stage as the corre- sponding tu rn signal lamps flash within the requirements of FMVSS-108.

Can we list our valuable load flashers as replacement flashers for vehicles having three (3) growth stage dash board turn signal arrows?

ID: nht94-7.50

DATE: March 9, 1994

FROM: Doug Bereuter -- U.S. House of Representatives

TO: Howard Smolkin -- Acting Administrator, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/12/94 from Christopher A. Hart to Doug Bereuter (A42; Part 303)

TEXT:

I am writing to convey my continuing intense interest in the National Highway Traffic Safety Administration's rulemaking concerning compressed natural gas vehicle fuel systems and fuel containers. As I have made absolutely clear to you and other Department of Transportation officials, ANY FURTHER DELAYS IN THE COMPLETION OF THE RULEMAKING SIMPLY WILL NOT BE TOLERATED. Every day that goes by without a final rule creates further hardship for Brunswick Corporation and its employees. CLEAR PROGRESS ON THIS MATTER IS IMPERATIVE! Let me know the status of the rulemaking.

ID: nht72-4.49

DATE: 10/25/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Manitowoc Engineering Company

TITLE: FMVSR INTERPRETATION

TEXT: I apologize for the delay in answering your letter regarding Part 566, Manufacturer Identification and Part 567, Certification. You describe the machines you manufacture and ask whether you are a final-stage manufacturer within the meaning of the regulation and therefore required to submit information regarding your products.

Parts 566 and 567 apply to manufacturers of motor vehicles and motor vehicle equipment to which a motor vehicle safety standard applies. "Motor vehicle" is defined in the National Traffic and Motor Vehicle Safety Act as "any vehicle driven or drawn by mechanical power for use on the public streets, roads, and highways."

Since the truck cranes you describe appear from the information you provide us to have a primary purpose of transporting the cranes on public highways, you are considered a manufacturer of motor vehicles and thus you are covered by Parts 566 and 567. Because you "mount the crane upperworks and outrigger assemblies to the carrier" you are a final-stage manufacturer as defined in Part 568, Vehicles Manufactured in Two or More Stages, and are required to submit information to us under these regulations. As a manufacturer of motor vehicles you are also required to submit information under Part 573, Defect Reports.

I enclose copies of Parts 566, 567, 568, and 573 for your reference. I have also attached a description of Government Printing Office documents services which cover NHTSA rulemaking developments.