ID: nht68-4.18

DATE: 09/18/68

FROM: AUTHOR UNAVAILABLE; Eugene B. Laskin; NHTSA

TO: Department of California Highway Patrol PAR=LOCATION

TITLE: FMVSR INTERPRETATION

TEXT: Your letter of August 19, 1968, addressed to Mr. David A. Fay, of the National Highway Safety Bureau has been forwarded to my office for reply.

The original list of definitions of vehicles was published in the Federal Register as part of a Notice of Proposed Rule Making dated December 3, 1966. Comments were requested from interested parties. Subsequently, the definition of a multipurpose vehicle as added to the Federal Motor Vehicle Safety Standards in response to a number of comments received from industry requesting a different category for certain utility vehicles. Under the previous classification, there were a number of special purpose vehicles which did not fit into any single category. It was agreed that certain types of motor vehicles, such as Dune Buggies, the Carryall, Travelall, Compact Van, Jeep Wagoneer, Ford Bronco, and Scout type vehicles comprised a hybid class of motor vehicle which possessed the characteristics of more than one of the motor vehicle categories previously established. The "special features" include such items as 4-wheel drive amphibious equipment. Due to the differences in body construction, load time requirements, and general vehicle purpose, it was not considered reasonable to require those dual purpose vehicles designed to carry ten persons or less to meet all of the passenger car requirements, as would have been required by the Notice. For those reasons, the new category of "multipurpose passenger vehicle" use added to Section 245(b).

Your interest in the automotive safety program of the Federal Highway Administration is greatly appreciated.

ID: nht88-2.55

TYPE: INTERPRETATION-NHTSA

DATE: 06/23/88

FROM: LARRY P. EGLEY

TO: RALPH HITCHCOCK -- OFFICE OF VEHICLE SAFETY STANDARDS NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/09/89 FROM STEPHEN P. WOOD -- NHTSA TO LARRY P. EGLEY; REDBOOK A33 [2]; STANDARD 108; LETTER DATED 01/17/89 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 3028; LETTER DATED 05/23/89 FROM LARRY P. EGLEY TO KAT HLEEN DEMETER -- NHTSA; LETTER DATED 09/10/88 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 2530; REPORT DATED 09/10/88 FROM LARRY P. EGLEY, REQUEST FOR EVALUATION / INTERPRETATION OF PROPOSED INVENTION SUDDEN STOP FLASHER [SSF]; REPORT DATED 09/ 07/88 FROM LARRY P. EGLEY, AN APPEAL FOR VARIANT INTERPRETATION OF NHTSA STANDARDS AS THEY RELATE TO BRAKE LIGHTS AND THE SUDDEN STOP FLASHER [SSF]; LETTER DATED 07/13/88 FROM KATHLEEN DEMETER -- NHTSA TO LARRY P. EGLEY; LETTER DATED 06/20/88 FROM LEWIS S. BUCHANAN -- EPA TO LARRY P. EGLEY; OCC 2199; LETTER DATED 06/09/88 FROM LARRY P. EGLEY TO LEWIS BUCHANAN

TEXT: Dear Mr. Hitchcock:

I was advised by Mr. Lewis Buchanan that he had forwarded my letter regarding my "Sudden Stop Flasher" (SSF) to you for response. In the event his letter did not reach you yet, I am enclosing another copy.

I should mention to you that I have conceived of several additional features which I did not mention in my letter to Mr. Buchanan because my intent was to communicate the basic concept only. However, I might briefly mention one of them. This the "Cr ash Lock-up Mode." This feature would cause the system to "lock-up" in the rapid warning flash sequence whenever an "impact-level" deceleration is encountered. When drivers have an accident, they are often confused and disoriented and fail to take measu res to protect themselves, such as turn on the hazard warning flashers. The Crash Lock-up feature would automatically send out a continuous warning when an actual crash occurs, thus possibly preventing yet another crash. Several years ago, I read of a 56-car pile up on a Florida Interstate on a very foggy night. I believe if only a few cars in that string of smashed up vehicles had this feature, that major disaster could have been significantly less severe. The Crash Lock-up would remain actuated un til the ignition switch was recycled.

Please accept my apologies for not addressing my original letter to you instead of Mr. Buchanan. Unfortunately, I was advised by the Kansas City Office that Mr. Buchanan would be the proper recipient.

Thank you very much for your attention.

ID: nht81-2.22

DATE: 05/08/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: R. F. Gordon, Esq.

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 8, 1981 NOA-30

Richard F. Gordon, Esq. 610 Arendell Street P.O. Box 489 Morehead City, North Carolina 28557

Dear Mr. Gordon:

This responds to your recent request for information on any safety standards this agency may have published for retreaded tires. We have a Standard No. 117 (49 CFR S 571.117) which applies to all retreaded passenger car tires. I have enclosed a copy of this standard and Standard No. 109 (49 CFR S 571.109), which is referenced in Standard No. 117.

As you will see, Standard 117 requires that the retreaded tires pass certain size and strength requirements, that the casings of the original tires which are retreaded meet certain requirements, and that certain information be labeled on the retreaded tires.

I hope that this information will be useful. If you have any further questions in this area or need further information on tire safety standards, feel free to contact Mr. Stephen Kratzke of my staff (202-426-2992).

Sincerely,

Frank Berndt Chief Counsel

Enclosures

March 18, 1981

General Counsel U. S. Dept. of Transportation Washington, D. C. 20590

RE: Regulations governing the manufacture of retread automobile tires.

Dear Sir:

We earlier wrote your department seeking copies of the regulations governing the manufacture of retread automobile tires. We got back a pamphlet on Uniform Tire Quality Grading.

What we are seeking are the regulations promulgated pursuant to 15 USCS 1426. There is not a set of CFR's in this county. We have a situation where a young girl was injured when a recently retreaded radial tire failed on a paved surface and examination of the tire disclosed rusty steel in the wall of the tire. We need to determine whether the manufacturer should have retreaded that tire.

Your assistance is appreciated.

Very truly yours,

Richard F. Gordon Attorney at Law

RFG/lmw

ID: nht72-6.8

DATE: 02/08/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Lathrop; Koontz; Righter; Clagett; Parker & Norquist

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 25, 1972, concerning the confidentiality of information on manufacturers' quarterly production figures that is submitted pursuant to section 573.5(b) of the Defect Reports regulations (49 CFR Part 573).

Manufacturers' quarterly production figures submitted pursuant to section 573.5(b) will be kept confidential if the manufacturer so requests. This will be true except in those cases where the NHTSA determines that disclosure is necessary to carry out the purposes of the National Traffic and Motor Vehicle Safety Act.

In the event it is decided to make public such information the NHTSA will, before release of the information, notify the manufacturer in question.

ID: 9450

Mr. J. Frank Haasbeek
President
International Transquip Industries, Inc.
6131 Brookhill Drive
Houston, TX 77087-1131

Dear Mr. Haasbeek:

Thank you for your recent letter to Vice President Gore, concerning a rulemaking related to your product. You believe that this agency has proceeded too slowly in the rulemaking. The Vice President has forwarded your letter to me for a reply.

I understand your concern over this issue, but please be assured that this agency is working diligently to reach a final decision concerning this rulemaking. As you know, the notice of proposed rulemaking was published in March of this year, and the agency received a number of conflicting comments. We must carefully assess all of the arguments raised by the commenters before reaching a final decision. We are nearing the completion of that process and expect to announce a final decision in January 1994.

I hope this information is helpful and appreciate your patience in this matter.

Sincerely,

Howard M. Smolkin Acting Administrator

ref:121 d:12/23/93

ID: 05-009139drn-2

Dr. Jane van Tilborg
Manager, Brake Fluids
Castrol Corporation
Technology Center
Whitchurch Hill
Pangbourne Reading
United Kingdom RG8 7QR




Dear Dr. van Tilborg:

This responds to your inquiry related to Federal Motor Vehicle Safety Standard (FMVSS) No. 116, Motor vehicle brake fluids (set forth in Volume 49 of the U.S. Code of Federal Regulations (CFR)) (49 CFR 571.116). You noted that the standard has a section related to labeling of brake fluid containers. While you recognize that this requirement applies in the United States, you asked if we could advise you about the situation for the "rest of the world". Specifically, you indicated that you may wish to "claim performance specifications FMVSS 116 DOT 3, DOT 4, etc". outside the United States, while meeting the local national labeling requirements but not the FMVSS No. 116 labeling requirements.

We regret that we cannot advise you about the brake fluid requirements of countries other than the United States.

We are concerned, however, that to the extent that you make claims about performance related to our standard, that the claims not be misleading. This would be a concern wherever the brake fluid is sold, and we assume that it would be a concern to other countries as well as to us. If the brake fluid meets all of the applicable requirements of FMVSS 116 other than labeling, you might include a statement to that effect on the label. Also, you must not certify that brake fluid meets FMVSS 116 if it does not meet all of the standards requirements. In addition to concerns related to the country in which the brake fluid is sold, purchasers might rely on such certification to import the brake fluid into the United States.

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

Sincerely,

Stephen P. Wood
Acting Chief Counsel

ref:116
d.1/24/06

ID: nht79-4.20

DATE: 10/15/79

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood; NHTSA

TO: Federal Trade Commission/PC

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of September 11, 1979, asking whether the National Highway Traffic Safety Administration (NHTSA) has adopted the Rubber Manufacturers Association (RMA) definition of mud and snow tire or has made any official statement regarding the validity of that definition. NHTSA has not adopted the RMA definition for use in any agency regulations, relating either to safety standards or to tire quality grading, nor has NHTSA made any official statement regarding the validity of the definition. If I can be of further assistance, do not hesitate to contact me.

Sincerely,

ATTACH.

FEDERAL TRADE COMMISSION/PC

SEPTEMBER 11, 1979

Dick Hipolit, Esquire -- Office of Chief Counsel, National Highway Traffic Safety Agency

Dear Mr. Hipolit:

Pursuant to our conversation of September 11, 1979, I would appreciate if you would inform me whether N.H.T.S.A. has adopted the industry standard of the Rubber Manufacturers Association's definition of a mud and snow tire or has offered any opinions regarding its validity.

The definition states that: "The characteristics of a mud and snow tire are:

(a) A substantial portion of the lug, block, or rib edges in the tread design are at an angle greater than 30 degrees to the tire circumferential center line.

(b) On at least one side of the tread design, the shoulder lugs protrude at least 1/2" in a direction generally perpendicular to the direction of travel."

The above information may be sent to Jeff Jacobovitz, Federal Trade Commission/PC, 6th & Pennsylvania Avenue, N.W., Washington, D.C. 20580.

Thank you.

Sincerely, Jeff Jacobovitz -- Legal Intern, Division of Compliance

ID: nht75-3.7

DATE: 11/18/75

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 15, 1975, in which you request an interpretation of paragraph S7.1.3 of Standard No. 301, as to whether it is permissible to stop an electric fuel pump prior to the rollover test.

Paragraph S7.1.3 provides that "If the vehicle has an electrically driven fuel pump that normally runs when the vehicle's electrical system is activated, it is operating at the time of a barrier crash." The static rollover test specified by S6.4 is not a barrier crash, and therefore is not covered by S7.1.3. In the amendments to Standard No. 301 published on October 15, 1975 (40 FR 48352), the addition of the phrase "In meeting the requirements of S6.1 through S6.3" to S7.1.3 clarifies the intent of the agency not to require that an electric fuel pump be operating at the time of the rollover test, because the rollover test is required by paragraph S6.4. Therefore, you may turn off the pump if it is still working at the time of the static rollover test.

SINCERELY,

October 15, 1975

Frank Berndt Office of Chief Council National Highway Traffic Safety Administration

I would like to ask your interpretation of the following phrase which is found in MVSS 301, S.7.1.3 :

"at the time of the barrier crash"

My understanding is that this phrase means that we should turn on the electric system which activates the electric fuel pump before the barrier crash test and leave it on through the subsequent roll over test.

The breakage of the battery and the wiring disconnection, due to the crash, may or may not stop the electric fuel pump, but if it is still working, we should not turn off the switch.

Is my understanding on the above mentioned phrase correct, or may we turn off the pump if it is still working during the roll over test?

Your interpretation on the above will be greatly appreciated.

There may have been a discussion on this matter before. It would be a great help if you could send us the documents on the resolution of that discussion.

Thank you.

NISSAN MOTOR CO., LTD.

Naoyoshi Suzuki

Staff, Safety

ID: nht93-9.24

DATE: December 23, 1993

FROM: Howard M. Smolkin -- Acting Administrator, NHTSA

TO: J. Frank Haasbeek -- President, International Transquip Industries, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 10/10/93 from J. Frank Haasbeek to Albert Gore, Jr.; Also attached to letter dated 12/14/93 from Bill Mason (Director of Correspondence, Office of the Vice President, to the Director, Office of Executive Secretariat, U.S. DOT (OCC 9450)

TEXT:

Thank you for your recent letter to Vice President Gore, concerning a rulemaking related to your product. You believe that this agency has proceeded too slowly in the rulemaking. The Vice President has forwarded your letter to me for a reply.

I understand your concern over this issue, but please be assured that this agency is working diligently to reach a final decision concerning this rulemaking. As you know, the notice of proposed rulemaking was published in March of this year, and the agency received a number of conflicting comments. We must carefully assess all of the arguments raised by the commenters before reaching a final decision. We are nearing the completion of that process and expect to announce a final decision in January 1994.

I hope this information is helpful and appreciate your patience in this matter.

ID: nht71-4.31

DATE: 10/22/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: National Association of Motor Bus Owners

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 2 to which you attached a letter from Mr. W. Dershko of Motor Coach Industries concerning the certification regulations that go into effect January 1, 1972. (Perhaps by error, you referred to a letter from Mr. Stieber of Greyhound Lines.) Rulemaking concerning gross axle weight rating and gross vehicle weight rating was in process at the time, hence the reason for our delay.

Mr. Dershko asked whether the gross vehicle weight rating must equal the sum of the gross axle weight ratings. The answer is no. The practice described, of stating a GVWR less than the sum of the GAWR's, will be quite proper under the new regulations.

Mr. Dershko also said that he was concerned as to how to interpret the definition of gross axle weight rating, and that "several factors to consider are the tire capacities, axle assembly capacity, and the coach frame structure capacity." We agree that all those factors must be considered. The manufacturer must set his gross axle weight ratings in view of the weakest elements in the load-bearing systems of the vehicle.

Let us know if we can be of further assistance.