ID: nht75-2.8

DATE: 09/19/75

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

TO: Ben Perchik

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 29, 1975, concerning tire identification markings, received by this agency on August 29, 1975.

I have attached two diagrams that illustrate the meaning of the tire code markings on new and retreaded tires. Immediately following "DOT" is a two- or three-letter code (marked in red on the diagrams) that indicates the manufacturer or retreader of the tire. I have also attached a list of the tire manufacturers and retreaders using each code. Following the manufacturer's code are two numbers representing the tire size (marked in blue on the diagrams). Next, some tires will have three letters or numbers which represent an optional tire type code mainly of use to the manufacturer (marked in yellow on the diagrams). The last three numbers represent the date of manufacture (marked in green on the diagrams).

I hope this information proves useful to you.

ID: nht68-2.32

DATE: 10/10/68

FROM: AUTHOR UNAVAILABLE; Eugene B. Laskin; NHTSA

TO: Marti; O'Cara; Dalton and Bruckner

TITLE: FMVSR INTERPRETATION

TEXT: Your letter of September 16, 1968, addressed to Mr. George C. Nield of the National Highway Safety Bureau has been forwarded to my office for reply.

From the brief description presented in your letter, it would appear that the proposed Cushman motor vehicle would be considered a "passenger car" under the definitions included in the Federal Motor Vehicle Safety Standards. At the present time, the standards do not apply to vehicles of 1,000 pounds or less curb weight. However, we are presently contemplating amendment of the Standards to include such vehicles in the near future as presented in the Advance Notice of Proposed Rule Making published October 14, 1967. The rated horsepower of the engine is not relevant in determining applicability of the standards.

Enclosed is a copy of the Advance Notice of Proposed Rule Making for your perusal.

ID: nht71-2.50

DATE: 05/13/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Harden Manufacturing Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 3, 1971, requesting an interpretation of the Tire Identification and Record Keeping Regulation. You indicated in your letter that you are a trailer manufacturer. As such, you are considered a motor vehicle manufacturer under both the regulation and section 102(3) and (5) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.) (copies enclosed).

As a manufacturer, you are required, by section 113(f) of the Act, to record the name and address of the first purchaser for purposes other than resale. Section 574.10 of the regulation requires that you maintain a record of the tires shipped on or in vehicles which you manufacture. In the event of a defect notification concerning either the vehicle or its tires, your responsibilities are enumerated in section 111 and 113 of the Act.

Enclosures

ID: nht72-2.18

DATE: 10/03/72

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

TO: Schlen Body and Equipment Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 22 to Mr. Ed Leysath of this Office regarding Interpretations of FMVSS No. 108 on required mounting of marker lights on your dump trailers.

In answer to your first problem, a combination front clearance and side marker lamp must meet the requirements for both; therefore, the full 180-degree visibility is required. If you determine that it is not practicable to mount the combination lamp in your alternate location, because of a greater possibility of damage, then separate lamps should be considered.

In answer to your second problem, because of the configuration and end use of your dump semi-trailers, your interpretation that rear clearance lamps mounted in a light box just below the rear trailer crossmember are as high as practicable is correct.

ID: nht71-5.25

DATE: 12/15/71

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Ambassador Trailers

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 4, 1971, to the Department of Transportation, concerning lighting requirements on your boat trailers.

A copy of Federal Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices and Associated Equipment" is enclosed for your information. The location of the lamps and reflectors shown on your drawing appears to meet the requirements of Standard No. 108, providing they are mounted to meet the height requirements.

Since the width of your trailer is more than 80 inches, front and rear clearance lamps and rear identification lamps are also required as specified in Table I and located as specified in Table II. Combination front and rear clearance lamps are allowed in paragraph S4.1.1.9.

There are no other requirements for trailers specified in the Federal Motor Vehicle Safety Standards.

Enc.

ID: nht81-1.1

DATE: 01/02/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Kux Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 25, 1980 asking whether any Federal regulation "prohibits the use of reflective red markings on the front of vehicles."

The Federal Motor Carrier Safety Regulation administered by the Federal Highway Administration of the Department of Transportation impliedly prohibit the use of red reflectors on the front of vehicles subject to its jurisdiction by requiring that all reflectors, other than those at the rear, be amber in color (49 CFR 393.26(d)). The common contract, private or exempt carriers covered by this requirement are found in 49 U.S.C. 303.

The Federal motor vehicle safety standard on vehicle lighting (49 CFR 571.108) applicable to the manufacture of all motor vehicles contains a general prohibition (paragraph S4.1.3) against installation of reflective devices that impair the effectiveness of required lighting equipment. Because of the generally accepted lighting coding of amber to the front and red to the rear, we would view installation of red reflective material on the front of a vehicle as prohibited by S4.1.3.

SINCERELY,

KUX MANUFACTURING COMPANY

November 25, 1980

Legal Counsel National Highway Traffic Safety Administration

Gentlemen:

Our Company is a manufacturer of vehicle graphics for the trucking and automobile industries. It has been our understanding that there is a Department of Transportation or other federal regulation prohibiting the use of reflective red markings on the front of vehicles. I would appreciate a response from your office as soon as possible verifying whether, in fact, such a prohibition exists. If so, please provide a citation for the provision.

Thank you for your assistance in this matter.

Eric C. Oppenheim Corporate Attorney

cc: J. JONES

ID: nht93-4.40

DATE: June 22, 1993

FROM: Jerry G. Thorn -- General Counsel, U.S. Consumer Product Safety Commission

TO: John Womack, Esq. -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/5/93 from John Womack (signature by Kenneth N. Weinstein) to Jerry G. Thorn (A41; VSA S102(4))

TEXT:

I am writing to request your assistance in determining whether an aerosol brake cleaning product marketed under the Solder Seal/Gunk brand is an item of "motor vehicle equipment," as that term is defined by section 102(4) of the National Traffic and Motor Vehicle Act, 15 U.S.C. S 1391(4). A promotional sheet for the product is enclosed for your information.

Under the Consumer Product Safety Act ("CPSA"), the Commission could regulate this product only if it is a "consumer product" as that term in defined in the CPSA. However, section 3(a)(1)(C) of the CPSA, 15 U.S.C. S 2052(a)(1)(C), provides that the term consumer product does not include "motor vehicles and motor vehicle equipment."

Thank you for your assistance in this matter. Please contact Harleigh Ewell in my office at 301-504-0980 if you need further information.

Attachment

Promotional sheet omitted.

ID: nht71-1.19

DATE: 04/01/71 EST

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Leasor & Leasor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 26, 1971, concerning regulations pertaining to automobile windshields.

Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses, a copy of which is enclosed, specifies the requirements of automotive glazing materials manufactured on or after January 1, 1963. ANSI Standard Z26.1-1966, incorporated by reference, can be obtained from the American National Standards Institute, 1430 Broadway, New York, New York 10013, at a cost of $ 4.00.

The marking of the windshield that you depict in your letter of March 26 is not sufficient to identify its manufacturer. However, based on the "63" in the marking and the fact that the windshield shape fit the 1969 Plymouth, it can be hypothesized that the material in question is a laminated windshield of the improved design that has been used in 1966 and later models of U.S. automobiles.

There is not a requirement that windshields of this type completely shatter leaving no jagged fragments upon collison.

Sincerely,

ID: nht95-2.28

TYPE: INTERPRETATION-NHTSA

DATE: April 10, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Ralph T. Welch

TITLE: NONE

ATTACHMT: ATTACHED TO 1/5/95 LETTER FROM RALPH T. WELCH TO NHTSA (OCC 10644)

TEXT: Dear Mr. Welch:

This responds to your request for an interpretation whether the Federal Motor Vehicle Safety Standards (FMVSS) specify "the type of odometer" placed in a motor vehicle. As explained below, the FMVSS do not so specify. If an odometer is provided, its mi leage may be stated in kilometers.

Standard No. 101, Controls and displays, specifies requirements for the location, identification, and illumination of motor vehicle controls and displays. Neither Standard No. 101 nor any other FMVSS specifies that an odometer be placed in a motor vehic le or that it register distance in miles, rather than kilometers. However, S5.3.1 (referencing Table 2 "Identification and Illumination of Displays") of Standard No. 101, specifies that if an odometer is provided and the odometer measures mileage in kil ometers, the mileage must be stated as "KILOMETERS" or "km."

I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.

ID: nht92-3.47

DATE: 09/21/92

FROM: KEVIN MITCHELL -- DEVELOPMENT ENGINEER, THE GOODYEAR TIRE AND RUBBER CO.

TO: PAUL JACKSON RICE -- CHIEF COUNCIL, NHTSA

COPYEE: J. GRAGG -- QUALITY ASSURANCE MANAGER; B. HENRY -- DEVELOPMENT MANAGER; R. ANDERSON -- PRODUCTION MANAGER; H. HILSON -- MARKETING MANAGER

TITLE: SUBJECT: CHANGE IN DOT PRINT LINE ON GOODYEAR HYDRAULIC BRAKE HOSE.

ATTACHMT: ATTACHED TO LETTER DATED 11-25-92 FROM PAUL J. RICE TO KEVIN MITCHELL (A40; STD. 106)

TEXT: Goodyear is currently in the process of improving the quality of our printing on hydraulic brake hose. The hose in question is used on passenger car brake systems and falls under the FMVSS 106 specification. The purpose is to improve the quality of the print by removing excess information which will improve the mechanical printing process.

Under section 5.2 labeling, Goodyear has in the past and is meeting all requirements of section 5.2.1 and 5.2.2. The question that has arisen involves section 5.2.2.c. Goodyear currently adds two additional letters to the date code for further traceability. The two additional letters spell out the "batch" and "shift" the hose was manufactured under, see below for current and new printing.

DOT print line old.

(1/16" Stripe) DOT - GY - 01/92 - 1/8 - HL

DOT print line new.

(3/32" Stripe) DOT GY 01/01/92 AA - 1/8 HL

SAE print line old.

(1/16" Stripe) GY - 1/8 - 5030 - 01/01/92 AA - SAE J1401

SAE print line new.

(3/32" Stripe) - 5030 SAE J1401

The batch and shift letters have always been added on the SAE line. To keep the information in a format which our customers are used to, we have moved them to the DOT and expanded the date to include month/day/year from month/year. Since section 5.2.2.c does not specifically say these letters can or cannot be added to the DOT print line, Goodyear is being proactive and asking for a written letter from the DOT committee to authorize these improvements before production starts.

We wish to begin the improved printing as soon as possible. If you could please expedite this request as quickly as possible it would be appreciated.