ID: nht72-3.43

DATE: 08/02/72

FROM: JAMES E. HOFFERBERTH FOR ROBERT L. CARTER--NHTSA

TO: Peugeot-Renault

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your teletype of July 8, 1972, regarding the question of a manikin's neck. In response to your specific need, and for your general information, I am enclosing a procurement specification for a 50th percentile test dummy recently let out for bid by the National Highway Traffic Safety Administration. This specification represents our present thinking on some of the desirable aspects of a test dummy. We are also working on the development of a proposed regulation that will define the dummy more precisely than standard No. 208 presently does, and, of course, that regulation may differ from the procurement specification.

In the meantime, as we have stated in the Federal Registar, any dummy that meets the requirements of Standard No. 208 may be used by a manufacturer to test its vehicles.

SINCERELY,

DEPARTMENT OF TRANSPORTATION

U.S. COAST GUARD TELECOMMUNICATIONS CENTER

NO 9499 Nov. 7, 1972 10#05

M. BUREAU PEGLEMFNTATION

A. M. ROBERT L CAPTER ASSOCIATE ASMINISTPATOR NHTSA

FOLLOWING PRESSING QUESTIONS ASKED TO MR TOMS AND YOU AT SAE CONFERENCE OF DETROIT IN MAY CONCERNING FMVSS 208 WE HAVE A VERY POSITIVE FIRST ANSWER IN DOCKET 69-7 NOTICE 19

HOWEVER, WE ARE STILL UNABLE TO COMPLETE OUR CONFIRMATION TESTS ON RESTRAINT SYSTEMS FOR 73 MODELS SINCE WE ARE NOT AWARE OF THE EQUIPMENT TO BE PROPOSED FOR DYNAMIC RESPONSE OF MANIKINS' NECK

CAN YOU ALREADY GIVE US SOME MORE DETAILS ON THESE SPECIFICATIONS SINCE OUR HOMOLOGATION SERVICES CANNOT GO ON WITH THEIR WORK

BEST THANKS

N. BUREAU CHIEF REGULATIONS DEPARTMENT AUTOMOBILES PEUGEOT

ID: nht72-3.44

DATE: 05/12/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Kangol Magnet Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your telegram of April 4, 1972, in which you asked whether it is permissible for the engine starting system of a vehicle conforming to the interlock requirements of Motor Vehicle Standard No. 208 to be operable when there are no occupants in the front seats by reaching through an open door or window to turn the ignition key.

Our reply is that the standard does not prohibit a system that operates in this way. Such a system is therefore permissible.

ID: nht72-3.45

DATE: 08/23/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Fairchild Semiconductor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 26, 1972, on the subject of the situations in which S7.4.3 of Motor Vehicle Safety Standard No. 208 permits operation of the engine starting system, notwithstanding the ignition interlock requirements of S7.4.1 of the standard.

Your first question is whether the engine may be restarted if the ignition switch is turned off after the driver has left the seat. Our reply is that restart would not be permitted except within a period of three minutes after the switch has been turned off. There is no sequential relationship between the operation of the switch and the driver's leaving the seat, so that the starting system will have to become inoperable if the driver has left the seat and has turned the ignition off, regardless of whether he turned the switch before or after leaving the seat.

Your second question is whether the engine may be restarted if the ignition switch is turned off, then on, and then the driver leaves his seat. Our reply is again that restart would not be permitted. S7.4.3 refers to operation "if the ignition has not been turned off". Once the ignition has been turned off, turning it on again will not revive the restart mode unless the engine is actually started again and then stopped with the ignition "on".

We have forwarded your check for a Federal Register subscription to the Superintendent of Documents. Enclosed you will find a copy of Notice 20, as you requested.

ID: nht72-3.46

DATE: 03/17/72

FROM: J.E. LEYSATH FOR E.T. DRIVER -- NHTSA

TO: U.M. Electrical Distributers Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 6, 1972, concerning warning buzzers for the automobile industry.

The National Highway Traffic Safety Administration has issued two safety standards which specify warning requirments. These requirements are given in Paragraph S4.4 of Standard 114 and Paragraph S7.3.1 of Standard 208. A copy of these two standards are enclosed for your review and further information.

You will note that these standards do not stipulate minimum requirements for the warning devices, and, at the present time, we have no plans to specify such requirements. The data sheet, however, which you enclosed will be useful to us should we specify such requirements in future amendments to these standards.

We appreciate your writing to us, and if we can be of any further service, please let us know.

ID: nht72-3.47

DATE: 10/13/72

FROM: CHARLES H. HARTMAN FOR DOUGLAS W. TOMS -- NHTSA

TO: Mr. Jesse R. Hollins

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your petition of August 15, 1972, as supplemented by your brother's letter of August 28, 1972, requesting our consideration of your seat belt warning system as a substitute for the warning and interlock systems currently specified in Motor Vehicle Safety Standard No. 208.

As we understand the operation of your system, one of its operating modes resembles the mode presently specified in S7.3.1 of the standard. Your system provides for the operation of a warning signal when the ignition is "on" and the seat belts at occupied front positions have not been operated. Section S7.3.1, considered by itself, would permit such a system, even though that section does not require the warning to operate unless the engine is operating and the vehicle is in a forward gear.

However, your system does not meet the requirement of S7.3.3 that the warning not operate when the vehicle is idling with the transmission in park or neutral position and the belts have not been operated. The argument presented in your brother's letter is that the sudden operation of the warning system when the transmission is placed in a forward gear would be an annoyance to occupants and would result in circumvention of the system.

The NHTSA position is that the convenience of being able to sit unbuckled in a parked car without the warning is such that this "quiet" period should continue to be required. It may be that some occupants will be bothered when the warning begins to sound as they place the car in gear. However, we are persuaded that the current system would be less likely to be circumvented than a system that has no period of non-operation.

The other operating mode of your system has no direct counterpart in Standard 208. As you describe it, returning the ignition to the "off" position will activate the warning system, even after removal of the key, until the belts are returned to their stowed positions. Our letter of August 17, 1972, explained that this will not conform to the requirement of S7.3.2 that the warning must not operate when the belts at occupied front positions have been operated.

We recognize that there are other possible alternative to the required interlock system as a means of encouraging seat belt usage, and several have been suggested. We consider it important, however, that these systems work in a substantially uniform manner, for maximum public safety, acceptance and convenience. On the basis of all the material we have received to date, including yours, we have decided that our present requirements represent the best combination for the alternative to passive restraints in the period 1973-1975. I therefore must deny your petition to substitute your system, or allow it as an alternative, for the interlock system.

ID: nht71-3.17

DATE: 06/08/71

FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY DAVID SCHMELTZER

TO: British Leyland Motors Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 20, 1970, requesting an interpretation of the Tire Identification and Record Keeping Regulation (49 C.F.R. 574).

The proposals you described in your letter, paragraphs 1 and 2, will certainly meet the minimum requirements of the regulation and are perfectly acceptable. The regulation requires that a record be kept of the type of tire shipped on or in the vehicle. It does not require that the individual tire identification number be(Illegible Word) with the name and address of the purchaser.

If a vehicle dealer sells a vehicle equipped with tires which were not shipped on or in the vehicle, the vehicle dealer is considered a tire dealer under section 574.9(b) and as such, he is required to record the name and address of the first purchaser along with the tire identification number, and forward this information to the tire manufacturer. However, the tire manufacturer may designate someone else to maintain the required records by section 574.7. Therefore, it would be acceptable to have your vehicle dealers forward the required information to you instead of to the tire manufacturer, if the tire manufacturer designates you to maintain the records of tires installed on your vehicles.

If we can be of any further assistance, please feel free to write.

ID: nht71-3.18

DATE: 06/09/71

FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL; SIGNATURE BY DAVID SCHMELTZER

TO: Lynd-Talin Tire Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 10, 1971, concerning the Tire Identification and Record Keeping Regulation. Please accept my apology for not responding earlier.

The National Highway Traffic Safety Administration considers each enforcement case on an individual basis. If a retreader could demonstrate that good faith attempts had been made to obtain the tin plate by May 22, 1971, and due to circumstances beyond his control he was unable to mark tires manufactured after May 22, 1971, with the required information, we would certainly take this into consideration before beginning any enforcement action.

ID: nht71-3.19

DATE: 06/10/71

FROM: L. R. SCHNEIDER -- ACTING CHIEF COUNSEL, NHTSA; SIGNATURE BY DAVID SCHMELTZER

TO: Triplex Safety Glass Co. Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 28, 1971, concerning the marking requirements in the proposed amendment to Standard No. 205, "Glazing Materials" (Docket No. 71-1; Notice 1). These requirements are only proposed at present, as is their effective date, and do not represent the agency's final decision on the matter. If the agency determines to amend the standard, and before any compliance with new requirements is required, a "final rule" will be issued that is based on the proposed rule but may differ in some respects from it. The final rule will specify an effective date for these new requirements which, in this instance, will probably be later than the effective date proposed.

You ask whether the effective date of the proposed standard would apply to the manufacture of the glazing, or to the fitting of the material into the vehicle. Standard No. 205 applies to "glazing materials for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses", and the effective date of any amendment to this standard refers to the date of manufacture of the glazing material, and not to its fitting into the vehicle.

Your second question, whether we will accept your marking without a hyphen between the "DOT" symbol and your code mark, has been answered in our letter to you of May 26, 1971.

I hope this clarifies the situation.

ID: nht71-3.2

DATE: 05/14/71

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: J. A. Kackney & Sons, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 3, 1971, to Mr. Julian E. Leycath of this Administration, concerning the installation of supplementary stop and rear turn signal lamps on your van type delivery bodies.

Installation of the supplementary stop and rear turn signal lamps, in the manner described in your letter and as shown on your drawings 69C-81, and 69C-41 (enclosed with your letter). would not impair the effectiveness of lamps, reflective devices, and associated equipment required by Federal Motor Vehicle Safety Standard No. 108 and would not be prohibited by that standard.

Standard No. 108 presently specified that the required stop lamps be mounted at a height "not less than 15 inches nor more than 72 inches". No mounting heights are presently specified for the required rear turn signal lamps. Effective January 1, 1972, the mounting height of required rear turn signal lamps will be "not less than 15 inches nor more than 83 inches". These limitations on mounting heights for the required lamps are not applicable to supplementary stop and rear turn signal lamps.

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.