ID: nht90-3.18

TYPE: Interpretation-NHTSA

DATE: July 13, 1990

FROM: S. Watanabe -- General Manager, Automotive Equipment Technical Coordination Dept., Stanley Electric Co., Ltd.

TO: Stephen P. Wood -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-30-90 from P.J. Rice to S. Watanabe (A36; Std. 108)

TEXT:

We would like to ask you a question about a configuration of combination rear lamp which fulfils both tail and rear side marker functions as sketched below.

(Graphics omitted)

In accordance with the requirement of S.5.5.7 of FMVSS No. 108, the two functions (ie. Tail & Side marker) are presented at the same time. Thus the light output of side marker lamp is also emanated toward the rear of the vehicle mixed with tail lamp ligh t, and similarly, the light output of tail lamp is also emanated toward the side mixed with side marker lamp light.

Please let us have your answers to the following questions.

1) Should the Tail lamp function of this lamp meet the photometric requirements for 2 lighted sections, or 3 lighted sections?

2) Should the Side marker function of this lamp meet the photometric requirement of SAE J592e by 3 lighted sections or 1 lighted section?

I greatly appreciate receiving your reply to the above as soon as possible.

ID: nht90-3.19

TYPE: Interpretation-NHTSA

DATE: July 13, 1990

FROM: J.P. Ravier -- R&D Director, Valeo; Guy Dorleans -- Regulatory Affairs Manager, Valeo

TO: P.J. Rice -- Chief Counsel, NHTSA

TITLE: Re Ref: 861 M 90

ATTACHMT: Attached to letter dated 12-13-90 to M.J.P. Ravier from Paul Jackson Rice (A36; Std. 108); Also attached to letter dated 7-30-90 to J.P. Ravier from Kathleen DeMeter

TEXT:

Valeo Lighting, manufacturer of car headlamps, hereby submits this request for an interpretation relating to the replaceable bulb headlamp aiming provisions in Federal Motor Vehicle Safety Standard 108, " Lamps, Reflective Devices and Associated Equipmen t."

In its issue of May 9th 1989, the Federal Register Vol. 54 No 88 in paragraph S.7.7.5.2. allows the use of a Vehicle Headlamp Aiming Device for lamps with moving reflectors. This possibility is an important step in the direction of world harmonization, since this concept is widely used in Europe and in Japan. Valeo lighting is determined to use this possibility as soon as possible, and in this purpose has studied the:

" Aiming concept for headlamps. Solution 2." The attached documents explain how our engineers have solved the problems of providing the aiming feature on each lamp, and summarize the instructions which will be written in the maintenance book of each car.

We would greatly appreciate if you would kindly treat all the drawings as confidential, because they involve our own idea for development of on-vehicle aiming which has something related to a patent application.

After our demonstration of a working prototype to NHTSA personnel on June 29th, we would ask you to provide us with your confirmation of our interpretation of Standard 108.

Upon your kind review to this matter, your promptly reply would be greatly appreciated.

Enclosure

July 13th, 1990

Aiming concept for Headlamps. Solution 2. 1) Description of the headlamp.

The lamp is composed of a lens with no aiming pads, a housing bolted on the car body and a reflector which moves independently inside the housing. The lens has a clear area which allows to observe a bubble spirit level fixed on the reflector. This cyli nder has its axis parallel to the longitudinal axis of the vehicle.

The horizontal aiming feature consists in two combined coaxial screws and nut, hereafter referred to as AH and BH. The cap which gives access to the AH screw can be removed by using simple tools. The clearly legible outer surface of BH has graduations representing less than .38 degrees and a total amplitude of .76 degrees to the left and .76 degrees to the right.

2) Vertical reaim.

On the assembly lines of the lamp manufacturer, each lamp is individually aimed thanks to photometric means. The car manufacturer, on its assembly lines, also aims each lamp with photometric means. The position of the seating plane of the housing is ch ecked carefully, and each bubble vial is set to zero and then blocked for life in this position by the lamp manufacturer. To reaim vertically:

2 1) Check the car fulfills the specifications of SAE J 599 May '81. 2 2) Measure the longitudinal angular value of the floor slope. Note the figure and its orientation, positive or negative. 2 3) Operate the aiming control until the bubble has slid by an equal number of fiducial marks in the appropriate direction. 2 4) Do the same for both lamps.

3) Horizontal reaim.

On the assembly lines of the car manufacturer, provisions are taken so that the zero position of the BH nut coincides with the specified aim. To reaim horizontally: Rotate the BH nuts until their fiducial mark coincides with the zero of their body counterparts.

4) Vertical reaim after accident dammage.

This procedure is not part of the normal maintenance of the car. It involves tools which are normally owned by dealers or repair shops. The floor of their premices must be rigid, flat and substantially horizontal.

4 1) Rotate the vertical aiming control until the bubble comes to the zero position. If, after severe dammage, the bubble can not reach the origin of the scale because the stroke of the aiming screw is too small, place shims between the body panel and t he housing.

5) Horizontal reaim after accident dammage.

The remarks of the preceeding paragraph also apply.

5 1) Set to zero the fiducial mark on BH, right hand side. 5 2) Remove the bulb service bonnets, and attach the string aimer to the reflector, as shown on section AA of attached documents. No mispositionning can happen, because the aimer for t he left hand lamp cannot fit into the right hand lamp.

5 3) Unroll the string from its right hand reel and affix it to the opposite string aimer. 5 4) Tightly prevent the BH nut from rotating, remove the cap 5 5) Operate the right hand screw AH until the string comes to the zero of

the fiducial marking on the right hand aimer. 5 6) Symetrizing the instructions, do the same for the left hand lamp, remove aimers, reinstall the bonnets.

It is important to note that this example does not exclude the use of conventionnal means, like the aiming screen or even the more modern fractionnal balance aiming machines. Like for vertical reaim after dammage, shims may be necessary if the stroke of the AH screw does not suffice.

Attachments

Drawing of string aimer left hand unit solution 2. (Graphics omitted.)

Drawing of horizontal aiming feature solution 2. (Graphics omitted.)

ID: nht90-3.2

TYPE: Interpretation-NHTSA

DATE: June 28, 1990

FROM: Satoshi Nishibori -- Vice President, Industry-Government Affairs, Nissan Research & Development, Inc.; Signature by Kazuo Iwasaki

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to drawing (graphics omitted); Also attached to letter dated 9-18-90 from P.J. Rice to S. Nishibori (A36; Std. 101)

TEXT:

This letter is to request NHTSA's interpretation of how the requirements of FMVSS 101 (Controls and Displays) would apply to two vehicle systems that Nissan is considering using. These systems are described below.

I. Car Phone

Nissan is considering offering a car phone for use in certain of its passenger cars. The car phone would be installed in the vehicle's console, in the lower, forward portion of the driver's field of vision. The car phone would have five visual displays, each of which is bright enough to be seen under all ambient lighting conditions. The illumination for these displays is not variable and the system may not be turned off while the vehicle ignition switch is in the "ON" position.

The first display shows the number that is being dialed (see Figure) through an LED. This display is illuminated whether or not the telephone is in use, and the number being dialed is shown during the time that the phone is in use.

The second display illuminates the push buttons for dialing numbers. This display is illuminated when the first button is pushed when dialing a number, and the display remains illuminated for a period of ten seconds.

Finally, the system uses three LED indicators. The first indicator (IU) is illuminated when the phone is "in use." The second indicator (NS) is illuminated when the system is outside an area where cellular phone service is available (i.e., "no service" ), as determined by the failure of the system's "roaming" function to lock on an available phone line. The third indicator (RM) is illuminated when this "roaming" function is operating, when outside the system's local operating area.

It is our understanding that this phone system would comply with FMVSS 101 requirements if the five information displays are considered to be "telltales." The term "telltale" is defined in section 4 of FMVSS 101 as "a display that indicates the actuatio n of a device, a correct or defective functioning or condition, or a failure to function." Since the displays used in the phone system indicate operation of various functions of the phone system, the displays may meet the definition of "telltale" in sec tion 4 of the standard. If so, the system would appear to be consistent with the requirement for telltales in section 5.3.4(a) of FMVSS 101, since the illumination of the displays is bright enough to be visible under all ambient lighting conditions. On the other hand, the system would not appear to meet the requirements of section 5.3.5 of the standard

if the displays are considered to be other "sources of illumination," since the displays do not have variable illumination, are brighter than "barely discernible" in night conditions, and may not be turned off without shutting off the vehicle.

Please inform us whether the displays used in this car phone system are "telltales" or other "sources of illumination," and whether the system is consistent with the requirements of FMVSS 101.

II. Air-conditioning Indicator Light

In certain vehicles, Nissan uses an indicator light that is illuminated whenever the air-conditioning system operating switch and the ignition switch are in the "ON" position. When the air conditioner or the ignition switch is turned "OFF," the indicato r light is extinguished.

Nissan believes that the air conditioner indicator qualifies as a "telltale," since it indicates the "actuation of a device." If the air conditioner indicator display is considered to be a "telltale," it would appear to meet the requirements of section 5.3.4, since the display is bright enough to be visible in all ambient lighting conditions.

On the other hand, this display would appear to be comparable to the radio display that is described in NHTSA's January 7, 1988, letter to Isuzu. In that letter, the Agency concluded that the illuminated radio display is considered to be one of the other "sources of illumination" in section 5.3.5 of FMVSS 101. Since the radio display can be turned off by turning off the radio, NHTSA considered it to be consistent with section 5.3.5(3). In the same manner, the air conditioner indicator display can be tu rned off by shutting off the air conditioner system. The radio display referred to in the Isuzu interpretation would also seem to meet the "telltale" definition, although the radio display serves the function of aiding tuning of the radio in addition to indicating whether the device is operating.

Please inform us as to whether the proposed air conditioner lighting display is considered to be a "telltale" or an "other source of illumination" under section 5.3.5 of the standard, and whether the display would be consistent with applicable requiremen ts.

If you require further clarification regarding the proposed Nissan systems, please contact Mr. Kazuo Iwasaki of my staff at 202/466-5284.

(Drawing attached).

ID: nht90-3.20

TYPE: Interpretation-NHTSA

DATE: July 16, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Delbert N. Pier -- Legislation and Compliance Coordinator, Hyundai America Technical Center, Inc. TITLE: None

ATTACHMT: Letter dated 2-27-90 to Stephen Wood from Delbert N. Pier; (OCC-4526) TEXT:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard No. 107, Reflecting Surfaces. (49 CFR 571.107). I apologize for the delay in our response.

You explained that Hyundai is planning to test the surface of a windshield wiper blade rail spring by using several rail springs gathered together because one spring would have a limited amount of area to reflect the light source. You asked the National Highway Traffic Safety Administration (NHTSA) to confirm your view that this method of compliance testing is a satisfactory method of complying with section S4 of Standard No. 107.

By way of background information, NHTSA has no authority to approve, endorse or offer assurances of compliance for any motor vehicle or item of motor vehicle equipment. Instead, the National Traffic and Motor Vehicle Safety Act of 1966 ("Vehicle Safety Act") makes manufacturers of motor vehicles or items of motor vehicle equipment responsible for certifying that each of its products conforms with all applicable safety standards. The following represents our opinion based on the facts provided in your l etter.

Each safety standard specifies performance requirements and test procedures used by the agency in its compliance testing to evaluate a vehicle or item of equipment. For instance, section S4 of Standard No. 107 specifies specular gloss requirements for c ertain vehicle components, including windshield wiper arms and blades. That provision requires that the specular gloss of the specified components must not exceed 40 units when measured by the 20 degree method of ASTM Standard D523-62T.

While the agency would follow ASTM Standard D523-62T for purposes of compliance testing, the Vehicle Safety Act does not require a manufacturer to test its products in the manner specified in a motor vehicle safety standard or even to test the product at all. A manufacturer may choose any means of evaluating its products to determine whether the vehicle or item of equipment complies with the requirements of that standard, provided, however, that the manufacturer exercises due care in ensuring that the vehicle or equipment will comply with Federal requirements when tested by the agency according to the procedures specified in the standard. In other words, the manufacturer must show that its chosen means of evaluating compliance is a reasonable surroga te for the test procedure specified by the standard.

In the event that the agency determines an apparent noncompliance exists with a vehicle or item of equipment tested in the agency's compliance program, the manufacturer must show the basis for its certification that the vehicle or equipment complies. Th e manufacturer may be subject to civil penalties unless it can establish that it exercised due care in its designing and manufacturing of the product and in its checking (through actual testing, computer simulation or otherwise) to ensure compliance, but nevertheless did not have reason to know that the vehicle or item of equipment did not in fact comply. Of course, notwithstanding the exercise of due care, the manufacturer would still be subject to the recall responsibilities of the Vehicle Safety Act for any noncomplying vehicles or equipment.

With these considerations in mind, you appear, based on the statements in your letter, merely to be testing a group of identical components with identical specular gloss levels at one time rather than separately. If this is the case, it appears that you r intended method of testing is consistent with the testing procedures in Standard No. 107.

I hope this informaiton answers your questions. Please contact Mr. Marvin Shaw of my staff at (202) 366-2992, if you have further questions.

ID: nht90-3.21

TYPE: Interpretation-NHTSA

DATE: July 18, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Michael O'Donnell

TITLE: None

ATTACHMT: Letter dated 4-18-90 to Chief Counsel's Office, NHTSA from Michael O'Donnell; (OCC 4690) TEXT:

This is in response to your letter to this office asking whether NHTSA's safety standards apply to vehicles in service on the public roads. Specifically, you were interested in the applicability of NHTSA requirements to a 1977 school bus that was convert ed to a "recreational vehicle/house coach" that is now only for personal and family use.

The Federal Motor Vehicle Safety Standards (FMVSS) promulgated by this agency apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. The requirement that a motor vehicle or item of motor vehicle equipment compl y with all applicable FMVSS applies only until the product is first sold to a consumer. Both before and after a vehicle or item of equipment is first sold to a consumer, any modifications to that product are affected by section 108(a)(2)(A) of the Natio nal Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(2)(A), which states:

No manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in co mpliance with an applicable Federal motor vehicle safety standard . . . .

If any of the commercial entities identified in section 108(a)(2)(A) were to make modifications that resulted in a "render inoperative" violation, the violating commercial entity would be liable for a civil penalty of up to $1,000 for each violation. Pl ease note that this "render inoperative" provision does not apply to a vehicle owner. The vehicle owner may modify his or her vehicle without violating any Federal requirements, irrespective of whether the modification affects the vehicle's compliance w ith a safety standard.

Please note also that the individual States have the authority to regulate the operation and use of motor vehicles within their borders.

Additionally, the individual States have the authority to regulate the modifications that may be made to a vehicle by its owner. You may wish to contact the Department of Motor Vehicles for the State of New York to learn if the State has established any requirements applicable to your use or registration of this vehicle in New York.

I hope you have found this information helpful.

ID: nht90-3.22

TYPE: Interpretation-NHTSA

DATE: July 19, 1990

FROM: T. Spingler, Robert Bosch, GmbH

TO: Rich v. Iderstine -- Office of Rulemaking, NHTSA

TITLE: FMVSS 108, S.3. Definitions

ATTACHMT: Attached to letter dated 8-2-90 to T. Spingler from P. J. Rice; (A35; Std. 108)

TEXT:

Five weeks ago (06/14/90) I discussed the word "bonded lens" with Larry Ayers, ETL, regarding headlamps with movable reflector and "VHAD". Usually we in Europe use rubber-seal and clips to fix the lens to the housing. To meet the requirements of FMVSS 108, Larry proposed to fix the lens of those headlamps by adding e.g. silicone-glue at four places between lens and housing to prevent the removal of the lens. Jerry Medlin, whom we called that day, agreed to that interpretation. To get an official int erpretation, I ask you to write me a letter regarding this "problem".

ID: nht90-1.23

TYPE: Interpretation-NHTSA

DATE: January 25, 1990

FROM: James R. Mitzenberg -- Project Engineer, The Flxible Corporation

TO: Steven P. Wood -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-26-90 from P.J. Rice to J.R. Mitzenberg (A36; Std. 108)

TEXT:

The Flxible Corporation is a city transit bus manufacturer and requests an interpretation concerning FMVSS 108, "Lamps, reflective devices, and associated equipment".

An air brake system is used on our bus. As the driver starts to apply the service brake pedal to stop the bus, a service brake stop lamp switch is activated. The stop lamp switch is installed to comply with Section S5.1.7 of FMVSS 121, "Air brake syste ms". The stop lights are activated by the stop lamp switch.

The Flxible Corporation offers an optional transmission retarder for supplemental braking, to increase brake lining life. This retardation is over and above the normal service brake system. The transmission retarder is electrically operated during the initial travel of the service brake pedal. As the service brake pedal is further depressed, air is emitted from the brake valve and the service brakes are activated.

A ruling is requested on whether a non-compliance with Section S4.5.4 of FMVSS 108 would result, if the stop lamps were activated by engagement of the retarder, prior to the activation of the service brakes. Section S4.5.4 states: "The stop lamps on eac h vehicle shall be activated upon application of the service brakes". The driver is depressing the service brake pedal to stop or slow down the vehicle. However, if the stop lights are activated by the retarder, the stop lights could be illuminated wit hout the service brakes actually being applied during that initial travel of the service brake pedal, and up until the point in time air is actually emitted from the brake pedal and into the service brake system.

ID: nht90-1.24

TYPE: INTERPRETATION-NHTSA

DATE: 01/26/90

FROM: Stephen P. Wood -- NHTSA Acting Chief Counsel

TO: John G. Sims -- Governmental Affairs Champion Motor Coach, Inc.

TITLE: NONE

ATTACHMT: LETTER FROM JOHN, G. SIMS -- CHAMPION MOTOR COACH INC. DATED 11/06/89 TO ROBERT F. HELLMUTH -- NHTSA; RE FMVSS 217; REFERENCE NO NEF-31 RSH; CIR 2996

TEXT: Dear Mr. Simms:

This responds to your November 6, 1989 letter to Robert Hellmuth, Director of NHTSA's Office of Vehicle Safety Compliance (OVSC). In that letter, you stated that OVSC had misinterpreted and misapplied the requirements of S5.5.1 and S5.5.2 of Standard No . 217, Bus Window Retention and Release (49 CFR @ 571.217). I conclude that OVSC correctly interpreted those sections of Standard No. 217 and correctly applied those sections to your company's buses.

The buses in question are not school buses and have a gross vehicle weight rating of more than 10,000 pounds. For such buses, section S5.5.1 of Standard No. 217 provides that: " . . . each emergency door shall have the designation 'Emergency Door' or 'E mergency Exit' . . . followed by concise operating instructions describing each motion necessary to unlatch and open the exit, located within 6 inches of the release mechanism."

Your company has designated the door immediately adjacent to the driver's seating position in these buses as an emergency exit. Operating instructions for that emergency exit are located within 6 inches of the release mechanism. However, the designation of this door as an emergency exit appears on a label located on a stanchion immediately behind the driver's seat, facing the passenger seating area. This designation does not appear within 6 inches of the release mechanism. You suggest that this arran gement complies with Standard No. 217, because S5.5.1 requires only the operating instructions, and not the emergency exit designation, to be located within 6 inches of the release mechanism.

I disagree with your suggestion. While it might be possible to construe the language of S5.5.1 in the manner you suggest, the agency has consistently interpreted S5.5.1 as requiring that both the emergency exit designation and the operating instructions be located within 6 inches of the release mechanism. Nothing in the correspondence you refer to undermines this conclusion.

2

Contrary to the assertion in your letter, there is a clear safety basis for requiring the emergency exit designation to be within 6 inches of the emergency exit release mechanism. This ensures that any person reaching the exit can quickly find both the release mechanism and the instructions. In an emergency, persons are used to finding an emergency exit where they see a label with the designation "Emergency Exit." In your company's buses, a person seeing the emergency exit label located on the driver' s seat stanchion could be misled into thinking that there is an exit somewhere behind the driver's seat, rather than at the driver's door, thus wasting valuable escape time. This is exactly the type of situation S5.5.1 is intended to prevent.

Your letter also suggests that requiring the emergency exit designation within 6 inches of the release mechanism would substantially reduce the visibility of the emergency exit sign, since the operating mechanism is frequently located below the shoulder level of seated passengers. While this may be true in some cases, I do not believe it would be likely to impede emergency egress. In an emergency situation, the occupants of the seat adjacent to the exit are likely to be the first ones out of the exit, and would thus no longer impede the visibility of the exit designation for other passengers seeking to exit.

We are only focusing on the designation here. Also, once it is open, the instructions aren't needed.

Your letter also suggests that the emergency exit requirements for school buses, contained in S5.5.3, support your interpretation of S5.5.1, because the school bus emergency exit requirements specifically authorize the separation of the emergency exit de signation and operating instructions. I must again disagree with you on this point. NHTSA recognized the considerable differences between school buses and other buses when Standard No. 217 was being developed. S5.5.3 addresses a very different set of circumstances. School buses typically have one emergency door, located at or near the rear of the bus. The requirement in S5.5.3 that the designation be in letters at least two inches high "at the top of or directly above the emergency exit" is designe d to ensure that school bus passengers will be able to locate this exit from any seating position in the bus. This is not the case for your company's buses, which feature several window exits located throughout the bus, in addition to the exit at issue here.

The second issue raised in your letter concerns the requirements of S5.5.2 of Standard No. 217. That section requires that emergency exit "markings" be visible to occupants in specified locations, under lighting and occupant visual acuity conditions set forth in S5.5.2. You suggested that the emergency exit "markings" referenced in S5.5.2 refers only to the designation of an exit as an emergency exit, and not to the operating instructions for that emergency exit. I disagree with this suggestion as wel l.

3

As we noted earlier, S5.5.1 sets forth requirements for both emergency exit designations and emergency exit operating instructions. Immediately following these requirements, S5.5.2 specifies that "each marking shall be legible . . ." (emphasis added). S5.5.2 nowhere draws any distinction between markings designating an exit as an emergency exit and markings setting forth operating instructions for the emergency exit. Neither is any such distinction inherent in the use of the term "marking." According ly, the ordinary meaning of the term "marking" and the background of this regulatory provision show that as used in S5.5.2, the word "markings" refers to both the emergency exit designation and the emergency exit operating instructions required by S5.5.1 .

If you have any further questions concerning these issues, please feel free to contact David Greenburg of this office at (202) 366-2992.

Sincerely,

ID: nht90-1.25

TYPE: INTERPRETATION-NHTSA

DATE: JANUARY 26, 1990

FROM: KENT D. SMITH

TO: OFFICE CHIEF COUNCIL -- NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 3-22-90 TO KENT D. SMITH FROM STEPHEN P. WOOD, NHTSA; [REDBOOK A35; STD. 108]

TEXT: I recently submitted an invention on a safety device to the Office of Crash Avoidance Research in the U.S. Department of Transportation. William A. Leasure, Jr., the Director of this office, responded to my letter but referred me to your office because there were some legal questions involved.

I believe that vehicles need some way of signaling following drivers if the headlamps of their vehicles are blinding you. I am a Driver Education teacher and whenever my students confront me with this problem there is no solution that up to now is ef fective. My invention, which is designed to deal with this problem is this: A button on the dashboard is attached to the backup lights. When the button is pushed the backup lights will go on and off in a matter of a second or less. The lights would not come back on again unless the button was pressed a second time. If necessary the button could be hooked up to only one of the backup lights. This would eliminate any confusion on the part of the driver of the following vehicle as to which direction th e car may be going. An alternative could be to hook the button up to the license plate lights. If this were done a double filament light would have to be installed so that the increase in intensity would be immediately observable by the driver of the f ollowing vehicle. This method of installation would not violate the SAE Standard for backup lights but I dont feel that it would be as effective as having the backup lights momentarily activated. I firmly believe that this new innovative concept would give the driver an effective means of informing the driver of the following vehicle that you were being blinded by his inconsiderate action.

I'm aware of the Federal law that states that the backup lights should not be on when the car is going in a forward direction. I believe that the intent of the law is to force people to make repairs so that those lights will not stay on and therby co nfuse people into thinking that the car is backing up rather than going forward. It would seem to me that this new concept could be added to an automobile without violating the intent of the federal law concerning backup lights.

I explained my idea to a gentleman from the Utah Department of Public Safety. He felt the idea was good enough that it should be pursued even if it meant making a revision in the Federal law that governed backup lights.

Would you please offer me any recommendations, either positive or negative, in regards to this invention. I thank you for your time and look forward to hearing from you in the very near future.

Please send your reply to: Kent D. Smith 12249 S. 1565 E. Draper Utah 84020

ID: nht90-1.26

TYPE: INTERPRETATION-NHTSA

DATE: January 26, 1990

FROM: Pat Crahan -- Director, U-Haul International

TO: A. L. Burgett -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7-9-90 to Pat Crahan from Paul J. Rice; A35; Std. 115 TEXT:

I had the pleasure of hearing you speak and meeting you during the AAMVA Engineering and Vehicle Inspection workshop at Lake Buena Vista, Florida in December.

I was particularly interested in the portion of your talk relating to VIN requirements for trailers. As I recall you stressed that a seventeen digit VIN was required even if a person made a trailer himself and sold it; however if it was not sold the VIN was not required.

I asked you if U-Haul was required to have the seventeen digit VIN on our trailers since we make them ourselves and they are never sold? You asked that I write to you, which is the reason for this letter.

LPDS 1989