ID: nht95-1.69

TYPE: INTERPRETATION-NHTSA

DATE: February 15, 1995

FROM: Tilman Spingler -- ROBERT BOSCH GMBH

TO: Chief Counsel -- NHTSA

TITLE: FMVSS 108, S.4 Definitions, bonded [Illegible Words]

ATTACHMT: ATTACHED TO 3/8/95 LETTER FROM PHILIP R. RECHT TO TILMAN SPINGLER (REDBOOK 2; STD. 108)

TEXT: Request for interpretation:

Dear Chief Counsel,

We ask you kindly to check if this proposal for a lens-reflector-joint can be considered as conforming to the appropriate definition in FMVSS 108.

Thanks in advance for your efforts Best regards

ID: aiam1751

Dear Mr. Farrelly: This is in reply to your letter of December 23, 1974, asking whether person who installs a 'Steering Stabilizer' manufactured by Safety Products, Inc., is required to recertify the vehicle in which it is installed. You enclose a copy of a letter from me dated August 24, 1972, in which I stated that we would accept a determination that the installation of a 'Safti-Stabilizer' (the previous name of the Steering Stabilizer) did not constitute remanufacturing, and that a person who installed such a device need not recertify the vehicle on which it is installed.; Since my earlier letter, the NHTSA has issued regulations covering th alteration of completed, certified motor vehicles before their sale to a purchaser for purposes other than resale. These regulations (49 CFR SS 567.7, 568.8, copy enclosed) supersede opinions such as the one we provided you, which was based solely on the more general provisions of the National Traffic and Motor Vehicle Safety Act and the certification regulations in effect at that time. Under the new regulations, which were effective February 1, 1974, an alteration which either (1) invalidates a vehicle's existing weight ratings or (2) involves installation of other than 'readily attachable' components gives rise to a responsibility for affixing an alterer label, which identifies the alterer and contains some additional information.; From the description of your device, and the enclosed literature, i appears to require no special expertise or tools to install, and is thus probably readily-attachable. It would also seemingly not affect a vehicle's weight ratings. If this assessment is correct, we would accept as reasonable a manufacturer's determination that an alterer label is not required when a 'Steering Stabilizer' is installed on a completed vehicle before its sale for purposes other than resale.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: 22705.drn

Mr. Bob Douglas
American Transportation Corporation
751 S. Harkrider
Conway, AR 72032





Dear Mr. Douglas:

This responds to your request that we write a letter to the Government of Israel's Minister of Transportation. You wrote that you needed this letter because you are:

working to secure a bid for commercial buses to be built here in Conway Arkansas and to be exported to Israel. They have requested that we provide them a letter that states that FMVSS 220 is an official regulation and that the regulation only pertains to school buses. They require that this letter come from NHTSA.

The following provides the information you request.

The National Traffic and Motor Vehicle Safety Act was enacted on September 9, 1966,

(P.L. 85-563), in order to reduce traffic accidents, deaths and injuries resulting from traffic accidents. This law, now codified as chapter 301 of title 49, United States Code, directs the U.S. Secretary of Transportation to establish Federal motor vehicle safety standards (FMVSSs), to which motor vehicles and motor vehicle equipment must conform and to which the manufacturers of such vehicles or equipment must certify compliance. The responsibility to establish FMVSSs has been delegated (by regulation) to the National Highway Traffic Safety Administration (NHTSA).

It is my understanding that the Israeli Government wishes to procure buses that are not school buses. There are no Federal motor vehicle safety standards on rollover protection that apply to non-school buses. NHTSA has issued FMVSS 220 (49 CFR Section 571.220), School bus rollover protection to establish performance requirements for school bus rollover protection, but does not apply this standard to non-school buses.

If you wish further information, please write to me at this address or contact Dorothy Nakama of my staff at: (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel
ref:220
d.3/6/01

ID: nht81-2.16

DATE: 04/22/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: PolyDyne Engineering

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. O. Vandewege, President PolyDyne Engineering Box 3517 Scottsdale, Arizona 85257

Dear Mr. Vandewege:

This responds to your letter of March 6, 1981, to Joseph Zemaitis, Motor Vehicle Program Director, Region IX, regarding Safety Standard No. 125, Warning Devices. You wish to obtain approval of your warning device (the "short stop") for use on trucks and trailers. Your device is a collapsible reflective triangle that is designed to be permanently mounted on the side or rear of a vehicle.

The National Traffic and Motor Vehicle Safety Act of 1966, as amended (the Act), authorizes the National Highway Traffic Safety Administration to issue Federal motor vehicle safety standards which are applicable to motor vehicles or motor vehicle equipment. Safety Standard No. 125, Warning Devices, establishes requirements for devices that are designed to be carried in motor vehicles and used to warn approaching traffic of the presence of a stopped vehicle. The rule does not apply to warning devices that are designed to be permanently affixed to the vehicle, and thus does not apply to your device. Hence, it is not necessary for you to obtain the "approval" of this agency before you may manufacture or sell a "short stop" or before an owner may use such a warning device on his vehicle.

However, the Federal Highway Administration (FHWA) has promulgated a regulation (49 CFR S 393.95) regarding the use of emergency equipment on heavy duty trucks and buses that are used in interstate commerce. This standard may prohibit the use of warning devices such as the "short stop" on certain types of vehicles. Since the FHWA can best address this issue, we have forwarded your letter to that agency's Chief Counsel for response. The address of that office is Room 4213, 400 Seventh Street, S.W., Washington, D.C. 20590.

We hope you find this information helpful. Please contact this office if you have any questions.

Sincerely,

Frank Berndt Chief Counsel

ID: nht94-1.8

TYPE: Interpretation-NHTSA

DATE: January 5, 1994

FROM: Stephen M. Monseu -- General Manager, Schroth Restraint Systems Corp.

TO: Mary Versailles -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/21/94 from John Womack to Wolf Ebel (A42; Redbook; Std. 208)

TEXT:

I would like to add one more request for response in addition to my previous letter.

If one of our belt systems were installed as original equipment would they meet the provisions of FMVSS 208 and what would we have to do to remain in compliance?

Your response will be greatly appreciated.

ID: nht75-1.35

DATE: 04/29/75

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

TO: Cummins Sales & Service Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of March 25, 1975, to Mr. Francis Armstrong of this agency, concerning the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, as applied to brake hose assemblies.

The labeling requirements for brake hose assemblies became effective on March 1, 1975. On March 4, the NHTSA proposed a change in the definition of "brake hose assembly" which would exclude certain assemblies from the requirements of the standard (40 F.R. 8962, copy enclosed.) Notice of a final decision on this proposal will be published in the Federal Register.

ID: nht94-5.31

DATE: May 16, 1994

FROM: Alberto Negro -- Chief Executive Officer, Fiat Auto R&D U.S.A.

TO: John Womack -- Acting Chief Counsel, United States Department Of Transportation, NHTSA

TITLE: Subject: 49 CFR 571.208 S4.5.1 Request For Interpretation

ATTACHMT: Attached To Letter Dated 6/8/94 From John Womack To Alberto Negro (A42; Std. 208)

TEXT: Dear Mr. Womack:

I need to know whether NHTSA allows the advisory information required by 49 CFR 571.208 S4.5.1 to be printed in English and also in one or more foreign languages on the same sun visor label.

I look forward to your reply.

Sincerely,

ID: nht71-3.1

DATE: 05/14/71

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: Mrs. Barbara G. Rothschild

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 28, 1971, in which you asked whether modifications to a "forced-action" belt could make it into a system that would satisfy the passive restraint requirements of Standard No. 208. Although we cannot at this time comment on the changes to which you refer, a passive belt system can be used to satisfy the requirement that protection be provided by means that require no action by vehicle occupants.

As you requested, we have enclosed copies of the Standard as published March 10, 1971.

ID: nht71-4.11

DATE: 09/16/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Alex Feigelson Company

TITLE: FMVSR INTERPRETATION

TEXT: In response to your letter of August 23, 1971, the NHTSA neither requires nor provides forms by which manufacturers must submit quarterly reports pursuant to @ 573.5 of the Defect Reports regulations (49 CFR Part 573). Manufacturers are free to use any form they wish in submitting the required information. However, a suggested format is enclosed for your guidance.

Please note that the effective date of the regulation has been extended to October 1, 1971. A copy of the Federal Register notice extending the date is also enclosed.

ENCLS.

ID: nht68-3.26

DATE: 04/24/68

FROM: AUTHOR UNAVAILABLE; G. C. Nield; NHTSA

TO: The Standard-Triumph Motor Company, Limited

TITLE: FMVSS INTERPRETATION

TEXT: This letter is in response to your February 29, 1968, request for approval of equivalent rims for use in the following tire and rim combinations:

A. Bias Ply Tires

1. 5.20-13 on 4 1/2J rim.

2. 5.60-13 on 3 1/2J rim.

B. Radial Ply Tires

1. 145-13 on 3 1/2J rim.

2. 145-13 on 4 1/2J rim.

3. 185-15 on 4 1/2J rim.

On the basis of the supporting information submitted, your request for approval of the equivalent rims and proposed tire combinations listed above is granted.