ID: aiam1191

Dear Mr. Hoag: This is in response to your letter of July 19, 1973, concernin odometer mileage statements, which questions the circumstances under which the transferor would check the statement indicating that actual mileage differs from the odometer reading. It appears from your examples that the problem arises in the transfer of vehicle ownership to you prior to auction.; The check-off provision is intended to warn the unprofessional buyer t ask for more information when the seller has checked the box indicating that he knows that the recorded mileage is incorrect. Your first example illustrates the case of a seller who considers the recorded mileage to be very low for a car of that age but has no certain information that the mileage is wrong. He should not check the box. Your second example illustrates a seller who has reasonable grounds to know (or perhaps certain knowledge) that the odometer is on its second time around, and he must check the box. The buyer is thereby warned to ask for further information about actual mileage.; Every buyer (including an auto auction) should insist on furthe information when the box is checked, so that it can make an accurate disclosure when it resells the vehicle. In the first example the auto auction would not check the box if the previous owner had not, but in the second example the auto auction would check the box, as the previous owner had and also be prepared to offer the explanation made by the original seller.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: nht71-4.35

DATE: 10/29/71

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Joseph Lucas (Electrical), Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to the petition of Joseph Lucas (Electrical) Ltd. dated October 13, 1971, for rulemaking to amend Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

Specifically, you have asked for an amendment of paragraph S4.1.2 either to reduce the(Illegible Word) test cycle of the warpage test for backup and stop lamps from 10 minutes to 5 minutes, or to conduct the test for these lamps using a continuously flashing filament.

Petitions for reconsideration of the 10 minute heat test cycle were filed following amendment of Standard No. 108 on October 31, 1970 (35 F.R. 16840). These petitions were denied on February 3, 1971 (36 F.R. 1896), because the Traffic Safety Administration had determined that the 10-minute cycle is appropriate in view of the frequency of usage of stop and backup lamps. I enclose a copy of the denial.

The Administrator has determined that your petition contains no new information such as to merit rulemaking on this issue, and we must therefore respectfully deny your petition.

ID: nht92-4.50

DATE: 08/06/92

FROM: CHRISTOPHER LEONE -- NEWBOLD DESIGN

TO: TAYLOR VINSON

TITLE: REGULATIONS FOR EXPERIMENTAL VEHICLE

ATTACHMT: ATTACHED TO LETTER DATED 11-9-92 FROM PAUL J. RICE TO CHRISTOPHER LEONE (A40; PART 555; VSA 102)

TEXT: Our company, NewBold Design, is an industrial design firm. We are in the process of designing and testing an experimental low emission vehicle which will be driven chiefly by means of electric power stored in batteries.

What we are seeking is the rules and regulations concerning the construction and licensing of this vehicle. Our goal is to create one of these vehicles, testing electric and/or electric/alternate fuel assisted vehicle ideas along the way.

Our specifications:

Experimental Vehicle (one)

2-3 passenger

Electric power

Batteries/solar cells

possible alternate fuel internal combustion assist

not for production

55 mph top speed, use on road

We need:

Rules and regulations concerning the licensing and use of the vehicle on streets/highways.

Thank you for your assistance,

ID: nht92-6.21

DATE: June 2, 1992

FROM: Jeffrey Puentes -- President, Sacramento Registration Service

TO: Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7/13/92 from Paul J. Rice to Jeffrey Puentes (A39; Std. 115; VSA 102(4))

TEXT:

We are agents for a client who is interested in manufacturing and selling to the retail public motorcycle frames.

These frames will be used to replace various types of damaged Harley Davidsons, whether they be burned, crashed, or whatever.

What federal laws must he recognize and adhere to?

Regarding serial numbers - how will frame numbers be properly identified?

What, if any, rules must he abide by and use in order to begin this type of a retail business?

Also, please note that these frames will be made for both on and off-road use. If this affects the laws he must obey, please include that as well.

If you have any questions or concerns, please feel free to contact us here at the below listed numbers.

Thank you for your time and attention to this matter.

ID: aiam5587

Dear Mr. Walton: This responds to your July 13, 1995 letter requestin an interpretation regarding the requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, 'Glazing Materials.' You stated in your letter that your client wants to know if Standard No. 205 permits the use of laminated AS-1 glass in motorcycle windshields. The answer to your question is yes. ANSI Z26.1-1977, which has been incorporated by reference into Standard No. 205, explicitly refers to item 1 glazing (defined as including laminated glass) as 'Safety Glazing Material for Use Anywhere in Motor Vehicle.' Motorcycles are motor vehicles. Therefore, item 1 glazing is permitted in that application. I hope this information is helpful. Please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992 if you have any further questions or need additional information. Sincerely, John Womack Acting Chief Counsel;

ID: aiam1150

Dear Mr. Pieratt: This is in reply to your letter of May 11, 1973, in which you ask abou the certification responsibilities for consecutive manufacturers of certain multi-stage vehicles that are intended for use by utilities. The facts as you present them are that a chassis-cab is purchased by a customer and delivered to a utility distributor, who installs a sub-base and a digger-derrick. The truck is then sent to a body-builder who installs a body consisting essentially of storage compartments, which are used to carry personal tools. The compartments are installed to the floor installed by the utility distributor. The unit is then returned to the utility distributor, who installs clearance and other lamps, reflectors, and other accessories, and hooks up hydraulic lines. Smaller vehicles are described as being manufactured in essentially the same manner.; It appears to us that the manufacturing operations you have describe fit quite readily into the manufacturing categories established by Parts 567 and 568. The utility equipment distributor is an intermediate manufacturer, he performs manufacturing operations, but does not complete the vehicle, as further manufacturing operations, the installation of the body, are clearly contemplated for the vehicle to perform its intended function. The body-builder is the final-stage manufacturer. When he completes his work the vehicle is ready to perform its intended function, except for the addition of the lighting equipment and the other operations performed by the utility equipment distributor. These latter operations appear to involve 'readily- attachable components' and if so the party performing them would not be a final-stage manufacturer.; The certification requirements do not operate differently because, i the case you describe, the utility equipment distributor performs operations on the vehicle at two separate times (installing the derrick, and later the lighting). His responsibilities each time are governed by the operation he then performs. However, inasmuch as the utility distributor appears to perform much of the heavy manufacturing, and because he is also the last person to modify the vehicle, he may wish to assume the responsibility for certification under section 568.7(b), in order that he may affix his name as the manufacturer to the certification label.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1151

Dear Mr. Pieratt: This is in reply to your letter of May 11, 1973, in which you ask abou the certification responsibilities for consecutive manufacturers of certain multi-stage vehicles that are intended for use by utilities. The facts as you present them are that a chassis-cab is purchased by a customer and delivered to a utility distributor, who installs a sub-base and a digger-derrick. The truck is then sent to a body-builder who installs a body consisting essentially of storage compartments, which are used to carry personal tools. The compartments are installed to the floor installed by the utility distributor. The unit is then returned to the utility distributor, who installs clearance and other lamps, reflectors, and other accessories, and hooks up hydraulic lines. Smaller vehicles are described as being manufactured in essentially the same manner.; It appears to us that the manufacturing operations you have describe fit quite readily into the manufacturing categories established by Parts 567 and 568. The utility equipment distributor is an intermediate manufacturer, he performs manufacturing operations, but does not complete the vehicle, as further manufacturing operations, the installation of the body, are clearly contemplated for the vehicle to perform its intended function. The body-builder is the final-stage manufacturer. When he completes his work the vehicle is ready to perform its intended function, except for the addition of the lighting equipment and the other operations performed by the utility equipment distributor. These latter operations appear to involve 'readily- attachable components' and if so the party performing them would not be a final-stage manufacturer.; The certification requirements do not operate differently because, i the case you describe, the utility equipment distributor performs operations on the vehicle at two separate times (installing the derrick, and later the lighting). His responsibilities each time are governed by the operation he then performs. However, inasmuch as the utility distributor appears to perform much of the heavy manufacturing, and because he is also the last person to modify the vehicle, he may wish to assume the responsibility for certification under section 568.7(b), in order that he may affix his name as the manufacturer to the certification label.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: nht89-1.72

TYPE: INTERPRETATION-NHTSA

DATE: 04/14/89

FROM: VIRVE AIROLA -- OY TOPPI AB FINLAND

TO: NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 05/31/90 FROM STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL TO VIRVE AIROLA; LETTER DATED 01/26/72 FROM RICHARD B. DYSON -- ASSISTANT CHIEF COUNSEL NHTSA TO K. NAKAJIMA -- TOYOTA

TEXT: Gentlemen;

Our company, Oy Toppi Ab, is a Finnish producer of plastic tubes and hoses. One of our most important products is Air Brake Tubing made of Polyamide PA 11. We produce this tubing both conforming to SAE J 844 and to the German standard DIN 74324.

For some time ago we quoted our tubes to the Swedish truck and bus producer Saab-Scania AB and received their product standard. Among other things this standard states following:

Quote: the manufacturer shall be registered at NHTSA in USA and the symbol DOT constituting certification by the manufacturer that the hose conforms to all applicable FMVSS standards. quote

We have no doubt that we will fullfill the requirements for the register and would appreciate it if you could send us the application formula as soon as possible.

In case any information or details are needed, please let us know and we will send them for you immediately.

Brochures [OMITTED]

ID: klein.rbm

Mr. Richard H. Klein
Consulting Engineers
P.O. Box 527, Fairway Drive
Johnson, NY 10933

Dear Mr. Klein:

This responds to your letter to the National Highway Traffic Safety Administration asking about the recordkeeping obligations of a motor vehicle manufacturer under 49 CFR 574.10. I apologize for the delay in our response. You wrote on behalf of your client, the National Association of Trailer Manufacturers (NATM). You stated that you believed only tire manufacturers are required to retain records on purchasers of new tires.

49 CFR Part 574 has two separate recordkeeping requirements. Both sections have been in effect, largely unchanged, since 1971. The first, 49 CFR 574.7, applies to tire manufacturers and requires them to maintain tire registration records that they receive from tire dealers and distributors. The second section, 49 CFR 574.10, applies to motor vehicle manufacturers and requires them to maintain registration records on tires that they install on motor vehicles prior to first sale. These two recordkeeping requirements are separate requirements. Thus, NATM's members are required to keep records of all new tires they place on their motor vehicles prior to first sale subject to the requirements of 49 CFR 547.10.

I hope this information is helpful. Please contact Rebecca MacPherson of my staff at this address or by telephone at (202) 366-2992 if you have further questions.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:574
d.3/16/00

ID: nht81-1.41

DATE: 03/16/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Columbia Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 16 1981

NOA-30

Mr. David R. Stevens Quality Control Manager Columbia Manufacturing Company Westfield, Massachusetts 01085

Dear Mr. Stevens:

In response to your recent letter, this is to advise you that the 4 mm height requirement for vehicle identification numbers (VIN) does not apply to mopeds (S4.3.1, Federal Motor Vehicle Safety Standard No. 115, 49 CFR 571.115). The letters and number used must be clear, however (S4.3). You should also be aware that if the VIN is to appear on the certification label, it must be at least three thirty-seconds of an inch high (49 CFR 567.4(g)).

Sincerely,

Frank Berndt Chief Counsel

December 29, 1980

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 Seventh Street, S. W. Washington, D. C. 20590

Attn: Mr. Fred Schwartz

Dear Mr. Schwartz:

This is to confirm our phone conversation in that we may use a 3/32 character height for our V.I.N., and that the 4 mm character height doesn't apply to mopeds.

Please find enclosed a sample of cur new V.I.N.

Sincerely,

David R. Stevens Quality Control Manager

DRS/aco

Enc.