ID: nht72-6.52

DATE: 12/15/72

FROM: AUTHOR UNAVAILABLE; David Schmeltzer; NHTSA

TO: Pirelli Tire Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 27, 1972, requesting what date code should be assigned to tires manufactured during the week of December 31, 1972 through January 6, 1973.

Section 574.5(d) of the Tire Identification and Record Keeping regulation provides in pertinent part that:

"This first two symbols should identify the week of the year using '01' for the first full calendar year in each year. The final section of each year may include not more than six days of the following year." (emphasis added).

Therefore, the last three digits of tires manufactured during the week in question should contain the numerals 532 for the date code.

ID: nht73-4.8

DATE: 04/11/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Fiat Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 22, 1973, requesting confirmation of your understanding that automobile manufacturers may continue to use glazing materials manufactured before April 1, 1973, that do not conform to the recent amendment to Standard No. 205, "Glazing Materials", effective on that date, in motor vehicles manufactured after that date.

Standard No. 205, an "equipment standard", applies to glazing materials for use in motor vehicles. It does not apply directly to vehicles in which such materials are used. As a consequence, a vehicle manufacturer may use glazing materials that do not conform to Standard No. 205 as it exists on the date the vehicle is manufactured. The glazing material must, however, conform to the standard as it exists on the date that the material is manufactured.

ID: nht93-8.21

DATE: November 17, 1993

FROM: David Shapiro -- RV Designer Collection, Woodbridge, Inc.

TO: Chief Counsel -- NHTSA

TITLE: Motor Vehicle Safety Standard No. 302

ATTACHMT: Attached to letter dated 2/10/94 from John Womack to David Shapiro (A42; Std. 302)

TEXT:

We are in the process of preparing a line of decorative products for sale in the recreational vehicle aftermarket.

Products will include drapes and other fabric window coverings, and bedspreads and other fabric bedding.

The products will be designed for use in motorhomes, travel trailers and similar multipurpose passenger vehicles.

All of these products will be sold in the recreational vehicle aftermarket, to consumers who already own recreational vehicles.

We have been told by your department that motor vehicle safety standard 302 does not apply to aftermarket products. We would appreciate receiving a letter from you confirming this.

ID: nht71-2.21

DATE: 03/24/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Distributors Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of March 1, 1971, in which you inquired whether a "crew-cab" truck is classified as a multipurpose passenger vehicle or a truck.

You said in your letter, "It was our reasoning that the prime purpose of an MPV was to carry passengers, rather than to haul something, and that the addition of a crew cab which would accommodate an additional three persons, onto a chassis-cab which contains a dump body or utility body would not necessarily change the classification."

The above statement is essentially correct. A crew-cab truck combines the purposes of both multipurpose passenger vehicle and a truck. Where a vehicle has a significant capability for carrying either persons or cargo, its manufacturer may exercise his own discretion in classifying the vehicle.

We are pleased to be of assistance.

ID: nht74-2.44

DATE: 05/11/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Adams & Westlake Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 13, 1974, asking whether S5.3.2 of Motor Vehicle Safety Standard No. 217, "Bus Window Retention and Release," permits the use of more than one release mechanism on any one opening if each mechanism requires a separate motion to release.

Standard No. 217 does not prohibit the use of more than one separate release mechanism for a single opening. However, S5.3.2 does limit to two the number of total force applications, and this limits the number of separate release mechanisms to two. If two release mechanisms are used, each must be operated by only one force application, and one of these force applications must differ by 90 degrees to 180 degrees from the direction of the initial push-out motion of the emergency exit.

Of course, in using this configuration, the other requirements pertaining to emergency exists and release mechanisms in Standard No. 217 must also be met.

YOURS TRULY,

March 13, 1974

Office of Chief Consul National Highway Traffic Safety Administration

Attention: Mr. Larry Schneider

In regards to Motor Vehicle Safety Standard #217, "Bus Window Retention & Release", please refer to S5.3.2 which states:

"The release mechanism or mechanisms shall require for release one or two force applications."

Is this to be interpreted that more than one mechanism, each requiring a separate motion to release, can be used on any one opening?

This question is prompted by reason of a car body structural member, at center line of rear window opening, which makes a single mechanism unsuitable.

Your earliest reply will be appreciated.

Earl V. Gordon -- Manager of Engineering, THE ADAMS & WESTLAKE CO.

cc: H. C. Gildner, Vice-President, Transportation Sales; C. M. Miller, Vice-President, Engineering

ID: nht73-2.4

DATE: 01/24/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Chesapeake Marine Products

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 13, 1972, requesting information as to how a distributor who assembles a boat trailer may certify the trailer under NHTSA requirements, when the weight ratings for the trailer when assembled differ from those anticipated by the fabricator, due to the distributor's use of components (tires and springs) of a greater weight-carrying capability than those envisioned by the fabricator.

The certification requirements applicable to the manufacture of boat trailers are found at section 567.4, "Requirements for Manufacturers of Motor Vehicles". The fabricator may affix the required label to a trailer in certain cases (section 567.4(f) (ii); but in the case you describe, where the distributor assembles the vehicle in a manner not specifically anticipated by the fabricator, the assembler is the appropriate person, pursuant to @ 567.4(g)(1), to certify the vehicle and affix the certification label. The label should state the name of the assembler (the distributor) as the manufacturer and reflect the weight ratings of the vehicle as assembled.

ID: nht72-5.13

DATE: 03/22/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: White River Distributors Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of March 6, 1972, forwarded to us by Tom Pieratt, wherein you discuss certain situations which have arisen regarding the GVWR of chassis you have purchased for completion by adding bodies.

As far as I can determine from the facts you provided in your letter, the chassis manufacturers are doing nothing that is contrary to our regulations. Your complaints seem to be that (a) some chassis that you believe to be identical bear differing weight ratings in their accompanying literature; and (b) you have received some chassis that do not have the weight ratings that you want and believed you were ordering. Both problems appear to be matters of communication between you and the manufacturers or their dealers, which might be resolvable by clearly specifying the desired weight ratings in your purchase order.

Your general statements concerning the effect of the Vehicle Safety Act and the regulations issued thereunder are essentially correct.

ID: nht94-4.16

TYPE: Interpretation-NHTSA

DATE: August 31, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Guy Dorleans -- Legal Compliance Department, Valeo Vision (France)

TITLE: None

ATTACHMT: Attached to letter dated 7/15/94 from Guy Dorleans to Office of Chief Council, NHTSA

TEXT:

We have received your letter of July 15, 1994, asking whether certain front lamp designs would be permissible under Federal Motor Vehicle Safety Standard No. 108.

In the basic front lamp design, the upper beam photometrics of Figure 17A would be provided by Lamps A and B. You have asked whether it is possible to add Lamp D, "an auxiliary driving beam." In this variation "all three A, B and D filaments would be p ermanently energized together in high beam mode and table 17a (sic) of FMVSS 108 is then fulfilled." Lamp D meets the photometric requirements of SAE Standard J581 JUN89 Auxiliary Driving Lamps.

The photometrics of Figure 17A apply to two-lamp integral beam or combination headlighting systems, and the design in your drawing is that of a four-lamp system, subject to the photometrics of Figure 15A. This configuration is not permissible under Stan dard NO. 108.

ID: nht76-3.3

DATE: 05/05/76

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your April 14, 1976, letter concerning the meaning of the effective dates of Federal motor vehicle safety standards.

You are correct in your understanding that a vehicle's date of sale is irrelevant to a determination of which standards are applicable to it. 49 CFR @ 571.7(a), Applicability, specifies in relevant part:

. . . each standard . . . applies according to its terms to all motor vehicles or items of motor vehicle equipment the manufacturer of which is completed on or after the effective date of the standard.

For vehicles that you complete by mounting a body on a chassis, you are permitted by 49 CFR @ 567.5(a) (7) to treat as the time that manufacture is "completed" for the purposes of @ 571.7(a) any date no earlier than the manufacturing date of the incomplete vehicle and no later than the date of completion of final-stage manufacture, regardless of when the body or chassis was sold. Please note that you must be consistent in your choice of completion date, e.g., you may not choose one date to determine applicability of certain standards while choosing another date for other standards.

ID: nht68-1.31

DATE: 07/03/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Horseless Carriage Corp.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of June 11, 1968, concerning the applicability of Federal motor vehicle safety standards to motor vehicles which have a curb weight of 1000 pounds or less.

Your reference to section 255.7 of the Federal motor vehicle safety standards and the present applicability of the standards to motor vehicles 1000 pounds or less curb weight is correct. However, we are enclosing a copy of an Advance Notice of Proposed Rule Making, Docket No. 5-1, which was published in the Federal Register on October 14, 1967. As you can see from the Advance Notice of Proposed Rule Making, the Administrator is considering adding new standards applicable to motor vehicles of 1000 pounds or less curb weight.

Sincerely,

HORSELESS CARRIAGE CORP.

June 11, 1968

Administrator Federal Highway Administration

ATTENTION: Robert M. O'Mahoney Assistant Chief Counsel

Gentlemen:

Thank you for the attention and assistance found in your letter of 31 May.

In reviewing the Federal Motor Vehicle Standards, we note that sub-part 255.7, "Applicability", paragraph (a) "General", specifies that the standards apply to ". . . motor vehicles over 1000 pounds curb weight; . . .".

Since our Replica antique automobiles have a curb weight of less than 350 pounds, it would appear that by definition and reference they are excluded, which obviates our petitioning for exemption under PL 90-283.

We would appreciate your comment or interpretation.

Very truly yours,

Ferris M. Smith, Jr. -- President