ID: nht76-3.17

DATE: 10/08/76

FROM: STEPHEN P. WOOD FOR FRANK BERNDT -- NHTSA

TO: Fachnormenausschuss Kraftfahrzeuge - FAKRA

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 31, 1975, in which you recommended a modification of the testing procedures pursuant to Standard No. 302, Flammability of Interior Materials. Your modification would require the presence of support wires in all tests. After consideration of the recently-complied test data on the use of support wires in the testing procedures, the NHTSA has decided that modification of the standard should be considered along the lines you suggest.

The NHTSA has interpreted Standard No. 302 to permit the use of support wires when any bending of the tested material occurred. At the time of that interpretation, it was believed that support wires would not influence the test results. More recent testing by the agency indicates that the use of support wires does significantly affect burn rates. For this reason, the agency is considering various possibilities in addition to the one you suggest.

Thank you for sending us a copy of your Draft International Standard. We appreciate your concern in this matter.

SINCERELY,

ID: nht72-3.10

DATE: 09/07/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Kennedy, Holland, DeLacy and Svoboda, Attorneys at Law

TITLE: FMVSS INTERPRETATION

TEXT: Your letter dated July 27, 1972, to the Department of Commerce, regarding information pertaining to the National Traffic and Motor Vehicle Safety Act of 1966, initial standards, was referred to this office for reply.

The National Traffic and Motor Vehicle Safety Act of 1966, in establishing the legislative basin for the Federal Motor Vehicle Safety Standards, required that the initial standards, to the maximum extent possible, be based on existing safety standards. An Advance Notice of Proposed Rule Making, soliciting suggestions, opinions, and proposals for consideration in promulgating the initial standards, was published in the Federal Register on October 8, 1966. Paragraph S3.3(d) of the initial Motor Vehicle Safety Standard No. 201 was based on Paragraph S3.2.5 of Federal Standard No. 515/3a, which was published in the Federal Register on July 15, 1966, (31 F.R. 9628), after consideration of the comments received in response to the Advance Notice. I have enclosed a copy of Standard No. 515/3a.

Thank you for your letter. Your interest in automotive safety is appreciated.

ID: 1985-02.6

TYPE: INTERPRETATION-NHTSA

DATE: 03/28/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Mr. Gordon Bonvallet

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Gordon Bonvallet Manager, Photometric Division ETL Testing Laboratories, Inc P.O. Box 2040 Cortland, NY 13045-2040

Dear Mr. Bonvallet:

This is in reply to your letter of February 13, 1985, to this Office asking whether the agency intended to eliminate the maximum allowable value for parking lamp candlepower in the amendments of November 26, 1984 which established Figure 1b.

Thank you for calling this matter to our attention. The amendment appears to have the effect you ascribe to it, though it was not the agency's intention that it do so. The maximum values of SAE J222 December 1970 are those that should apply, and we shall reinstate them in the near future.

Sincerely,

Original Signed By

Jeffrey R. Miller Chief Counsel

February 13, 1985

Office of Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590

Gentlemen:

Subject: Interpretation of Rule Making 49CFR Part 571 (Docket No. 83-12: Notice 2)

Figure 1b in the reference Docket shows a minimum allowable candlepower value of 4.0 for a one section "Parking" lamp. No maximum is indicated.

Is the intent to eliminate the allowable maximum candlepower for parking lamps or should the maximum values as listed in SAE J222 Dec. 70, referenced in FMVSS 108, be used? (SAE J222 JAN77 eliminated the maximum values.)

Very truly yours,

Gordon Bonvallet, Manager Photometric Division

GB/mm

ID: nht70-2.31

DATE: 10/23/70

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: American Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 12, 1976, to Mr. Charles A. Baker of this office in which you requested an interpretation of the phrase "affective projected illuminated area."

Class A turn signal lamps are required by Section S3.1 of Federal Motor Vehicle Safety Standard No. 108, which references SAE Standard J588d in Tables I and III for there lamps. The requirements for the illuminated area of a turn signal lamp are specified in J588d as follows:

"The effective projected illuminated area measured on a plane at right angles to the side of the lamp must not be less than 12 sq. in. for Class A and 36 sq/ in. for Class B."

In the 45 degree visibility requirements, this standard further states "To be considered Visible, the lamp must provide an instructed projected illuminated area of outer less surface, excluding reflex, . . .".

Our interpretation of affective projected illuminated area follows; The affective projected illuminated area is that area of the lent measured on a plane as that angles to the axis of the lamp, excluding reflex reflector, noted is not obstructed by an opaque object such as a mounting(Illegible Words)

The above interpretation allows the area of rings or other configurations ((Illegible Word) portions) applied in the lane to be considered part of the total effective from, even if this area does not contribute significantly to the total light output.

ID: 2640o

Mr. Toshio Maeda
Executive Vice President
& Chief Operating Officer
Nissan Research & Development, Inc.
P.O. Box 8650
Ann Arbor, Michigan 48104

Dear Mr. Maeda:

This is in reply to your letter of June 30, 1987, asking for an interpretation of paragraph S4.1.1.36(b)(3) of Motor Vehicle Safety Standard No. l08.

That paragraph specifies in pertinent part that a replaceable bulb headlamp shall be designed to conform to Section 6.1-Aiming Adjustment Test, of SAE Standard J580 AUG79 Sealed Beam Headlamp Assembly. Section 6.1.1 states that "when the headlamp assembly is tested in the laboratory, a minimum aiming adjustment of +/-4 deg. shall be provided in both the vertical and horizontal planes." You have asked whether the aiming adjustment is to be achieved by the headlamp assembly, or by both the headlamp assembly "and by the headlamp when it is mounted on the vehicle."

SAE J580 applies to the design of headlamp assemblies, including the functional parts other than the headlamps, such as aiming and mounting mechanisms and hardware. The assembly may include one or more headlamps. Although the headlamp assembly is tested in the laboratory, its design must be identical to the headlamp assembly used on the vehicle. Thus, if the aiming adjustment requirement is met by the headlamp assembly in the laboratory, it should also be met when the assembly is installed on the vehicle. An individual headlamp installed on the vehicle need not meet the aiming adjustment test unless that headlamp is part of a headlamp assembly comprising only one headlamp.

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel ref:l08 d:1/14/88

ID: nht74-4.9

DATE: 07/03/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 26, 1974, question whether labeling information on hose installed in vehicles must remain legible after the vehicle is painted, and what "permanently labeled" means in S5.2.2.

The answer to the question of painting over label information will be answered in our upcoming notice in response to petitions for reconsideration of the amendments we have made to the standard.

"Permantly labeled" means affixed in such a manner that it is not easily removable, and is reasonably designed to remain affixed and legible for the normal life of the component.

Yours Truly,

Volvo of America Corporation

April 26, 1974

Lawrence Schneider, Chief Counsel National Highway Traffic Safety Administration

Volvo of America Corporation hereby requests an interpretation on amended FMVSS 106 published February 26, 1974 [Docket No. 1-5; Notice 10].

Volvo requests an interpretation on the extent which the markings on the brake hose, end fitting and band around the brake hose assembly must remain legible after the assembly is installed on the vehicle. Volvo has determined these markings may become illegible after the chassis is painted. Would the NHTSA find it acceptable to have one or more markings on the hose remain legible, and the markings on the fitting and the band, if not legible after painting, be legible when the paint is removed?

Volvo also requests a definition of "permanently labeled" as stated in Section S5.2.2

Volvo thanks you for your consideration on this matter and requests a reply as soon as practical.

Rick Shue Product Safety Engineer

cc: S. Larsson

ID: nht76-1.10

DATE: 06/29/76

FROM: AUTHOR UNAVAILABLE; J. Womack for F. Berndt; NHTSA

TO: General Motors Corporation

COPYEE: GEORGE NIELD -- AUTOMOBILE IMPORTERS ASSOC.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to General Motors Corporation's May 27, 1976, petition to commence rulemaking to amend Standard No. 105-75, Hydraulic Brake Systems, in order to return one sentence to the text of S5.1.5.2(a) that was omitted in a September 17, 1975, revision of that section (40 FR 42872). The sentence reads: "However, the maximum control force for the fifth stop in the case of a vehicle manufactured before September 1, 1976, shall be not more than plus 60 pounds of the average control force for the baseline check (but in no case more than 110 pounds)."

The National Highway Traffic Safety Administration considers a petition to amend the standard to be unnecessary because the omission was inadvertent and did not constitute a substantive change to the requirements of the standard. Therefore, an interpretative amendment to conform the language to that intended will be forthcoming in the near future. Interested persons are notified that the interim control force value has been in effect for all vehicles of 10,000 pounds gross vehicle weight rating or less despite the omission of the sentence on September 17, 1975.

Thank you for bringing this omission to the attention of the agency.

ID: nht76-1.32

DATE: 05/11/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood; NHTSA

TO: Intercraft Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your March 29, 1976, letter concerning regulations applicable to farm tractor tires whose importation is contemplated by one of your clients.

Farm tractors are not "motor vehicles" as that term is defined in the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1391 et Seq.). Accordingly, tires designed exclusively for use on farm tractors are not "motor vehicle equipment." Therefore, the importation of such tires and tubes is not subject to Federal motor vehicle safety standards or other regulations issued by the National Highway Traffic Safety Administration. We are unaware of any other regulations of the Department of Transportation concerning such tires.

Yours truly,

ATTACH.

Intercraft Corporation

March 29, 1976

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

Dear Mr. Berndt:

A foreign tire manufacturer has indicated to us that he is interested in exporting certain agricultural tires and matching tubes to one of our clients in the United States. If a transaction can be concluded, these tires and tubes would be imported to the U.S. by our client and would be sold by him in this country.

Two sizes of farm tires and tubes would be involved: 15.5-38 (6 and 8 PR) and 18.4-38 (8 PR). We understand that both of these sizes of tires and tubes are made for the rear wheels of farm tractors for field use only and are considered "Off The Road" in the tire industry.

We would like to ask if there are any U.S. Department of Transportation regulations concerning motor vehicle safety standards, tire identification and recordkeeping, or manufacturer identification that apply to the importation to the United States of tires and tubes of those two size designations? Do any DOT regulations apply to any other facet of the importation of such tires and tubes to the U.S.?

Sincerely, Robert M. Brodkey -- President

ID: nht68-1.24

DATE: 05/09/68

FROM: SIGNATURE UNAVAILABLE; NHTSA

TO: Counihan, Casey and Loomis

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 4, 1968, to Mr. Edwin L. Slagle, concerning Federal Motor Vehicle Safety Standard No. 205.

Standard No. 205 requires that glazing materials manufactured for use in passenger cars, multipurpose passenger cars, multipurpose passenger vehicles, trucks, buses, and motorcycles for sale in the United States on or after January 1, 1968, meet the requirements of ASA standard 226.1966. In addition, passenger cars, multipurpose passenger vehicles, trucks, buses, and motorcycles manufactured on or after January 1, 1968, for sale in the United States, must contain glazing materials that meet the requirements of ASA Standard 226.1-1966.

The following information is offered in answer to your qeustions:

Q. "We would appreciate your advice as to whether under Section (sic) 205, our members may install windshields manufactured prior to January 1, 1968, and containing a plastic interlayer of 0.015" subsequent to January 1, 1968?"

A. Yes, preformed or presized windshields manufactured prior to January 1, 1968, of 0.015 plastic interlayer may be used as replacement glass in used vehicles after January 1, 1968.

Q. "We would also appreciate your advice as to whether the fact that a glass dealer cuts a windshield to size from material manufactured prior to January 1, 1968, would alter your answer to our first question."

A. A dealer who cuts a windshield to size is considered a manufacturer, hence after January 1, 1968, 0.015 plastic interlayer

[Page 2 Is Missing.]

ID: nht71-1.42

DATE: 07/22/71

FROM: E. T. DRIVER -- NHTSA OFFICE OF OPERATING SYSTEMS MOTOR VEHICLE PROGRAMS

TO: LOUIS C. LUNDSTROM -- DIRECTOR, AUTOMOTIVE SAFETY ENGINEERING GENERAL MOTORS ENVIRONMENTAL STAFF

TITLE: NONE

TEXT: Dear Mr. Lundstrom:

This is in reply to your letter of July 12, 1971, to Mr. Douglas W. Toms, Acting Administrator, concerning replacement equipment covered in FMVSS No. 108, effective January 1, 1972.

The requirements for original and replacement equipment in FMVSS No. 108 cover those items listed in Tables I and III, namely: Headlamps Turn signal operating units Tail lamps Turn signal flashers Stop lamps Vehicular hazard warning signal License plate lamps operating units Reflex reflectors Vehicular hazard warning signal Parking lamps flashers Side marker lamps Identification lamps Backup lamps Clearance lamps Turn signal lamps Intermediate side marker lamps Intermediate reflex reflectors

In addition the requirements cover the following items specified in the text of the standard:

School bus warning lamps

Headlamp beam switching devices

Headlamp upper beam indicator lamps

Turn signal pilot indicator lamps

Hazard warning signal pilot indicator lamps

Plastic lenses

Sincerely,