ID: aiam0143

Dear Mr. Rosso: This is in response to your letter of February 14, 1969, in which yo seek information concerning possible overloading of Seiberling 8.25-20 ten ply rating truck tires manufactured in approximately 1963.; The Federal Highway Administration has issued a Federal motor vehicl safety standard for passenger car tires manufactured after January 1, 1968 requiring them to meet certain tests when loaded to prescribed weights. (49 C.F.R. S371.21 Standard 109). Performance requirements for truck tires are presently under consideration. Comments have been received in response to an Advance Notice of Proposed Rule Making on this matter but regulations have not as yet been issued.; The Bureau of Motor Carrier Safety regulates the safety and operatio of interstate motor carriers. Its regulation regarding tires (49 C.F.R. S393.75) is not relevant to your inquiry.; One fruitful source of information may be the Tire and Rim Associatio Yearbook. This publication provides data on tires and suggests standards for tire load limits. It is published by the Tire and Rim Association, Inc., Comand Building, 34N. Hawkins Avenue, Akron, Ohio 44313.; I hope this information will be of value to you. Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel fo Regulations(sic);

ID: aiam4157

Dear Mr. Tan: This is in reply to your letter of April 15, 1986, asking for ou approval of different types of rear stop lamps you wish to import.; The lighting devices depicted in the brochures that you enclosed ar not intended as original or replacement motor vehicle equipment, and therefore are not covered by Federal Motor Vehicle Safety Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*. If you are required to execute a Form HS-7 at the time of entry, the proper declaration is that provided by Box 1: the equipment was manufactured on a date when no Federal standards applied to it. In any event, this agency has no authority to approve or disapprove items of motor vehicle equipment since the National Traffic and Motor Vehicle Safety Act provides for self- certification by manufacturers of their products subject to Federal standards.; In the absence of Federal requirements, whether the devices you wish t import are legal for installation and use would be determinable under the laws of the individual States where the devices will be sold and installed.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam1669

Dear Mr. Wahlin: This responds to your October 15, 1974, letter to the Bureau of Moto Carrier Safety asking if a trailer is subject to Standard No. 121, *Air brake systems*, if its buyer certifies, for tax purposes, that the vehicle in fact uses the highways only incidentally.; I have enclosed a discussion of our regulatory authority over moto vehicles, which does not include vehicles intended and sold solely for off-road use. However, we do regulate vehicles which use the highway on a necessary and recurring basis, whether or not this use is infrequent and incidental to the vehicle's working function.; We do not base this distinction on the same considerations as underl excise tax regulations and laws. The statutory definition of 'motor vehicle' and the regulations in the tax area differ from ours, as they are only directed to taxing regular highway users who should bear the burden of maintaining the roads. In contrast, our statute and regulations are directed to safe vehicle design, which is important for all vehicles designed to use the highways, whether or not their use is on a regular basis. We conclude that the revenue considerations involved in tax cases are not relevant to our safety regulation requirements.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: aiam3789

Dear Mr. McDonnell: This is in response to your letter of January 6, 1984 regarding whethe South Carolina has received approval from the National Highway Traffic Safety Administration (NHTSA) for use of its title documents in lieu of the Federal odometer disclosure statement.; South Carolina submitted its motor vehicle title forms to this agenc for approval, but its odometer disclosure statement was unacceptable. South Carolina was advised that before its title form could be approved, certain additional information must be incorporated. We do not know if the recommended changes were made.; Please note, however, that if South Carolina has incorporated th required information into its title, it need not obtain the approval of this agency in order to use that title in lieu of a separate Federal form. If you have additional questions regarding South Carolina's title documents, please submit them to my attention. I will be glad to review them.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam2035

Dear Mr. McNeil: #This responds to your letter of August 12, 1975 concerning the application of Federal Motor Vehicle Safety Standard No 106-74, *Brake Hoses*, to an anchor coupling. #You enclosed a diagram depicting the installation of two of these couplings, and suggested that they are not subject to the labeling requirements of the standard. This interpretation is correct. 'Brake hose end fitting' is defined in Standard No. 106-74 as: #>>>a coupler, other than a clamp, designed for attachment to the end of a brake hose.<<< #The anchor couplings which you have described are attached to the ends of completed brake hose assemblies, rather than to the ends of brake hoses. Therefore, they are not 'brake hose end fittings' subject to the standard's requirements. #It appears from your letter that you might not consider the nylon tubing to be 'brake hose'. If the nylon tubing is flexible, However, such an interpretation would be incorrect. 'Brake hose' is defined in the standard as: #>>>a flexible conduit manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.<<<# Thus flexible chassis plumbing and other flexible conduits, in addition to rubber brake hoses, are subject to the standard's requirements. #Sincerely Frank A. Berndt, Acting Chief Counsel;

ID: aiam1420

Dear Mr. Rein: We have reviewed the revised defect notification letters i International Harvester campaigns numbers 73505, 73503, 73511, 73513, G-73520 and G-73521 which you forwarded to us. We believe these revised letters conform to 49 CFR Part 577. However, we believe the letters in campaigns 73505, 73513, and 73521, which involve an accelerator problem, should, in response to the requirements of S 577.4(c)(4), include some guidance as to how the driver can stop the vehicle.; While we find the letters you submit to conform to the requirements, w are of the opinion that, in general, the format you use to describe the defect (577.4(c)) goes little further than meeting the regulation's literal requirements. We suggest you review the letters we have received from other companies in order to obtain an indication of other, more complete approaches to meeting the requirements. While we had indicated that we might furnish you specific letters as examples, we prefer not to recommend any specific letter as a model or to imply that it is preferable to others.; Sincerely, Lawrence R. Schneider, Chief Counsel

ID: aiam1025

Dear Mr. Daniel: This is in response to your letter of February 27, 1973, concerning th method of giving the odometer disclosure statement required by 49 CFR Part 580, Odometer Disclosure Requirements.; The odometer disclosure statement must contain the informatio specified in S 580.4 of the requirements. The statement must be in the form specified in S 580.6, but it does not have to be separate from the other transfer documents. Your clients may incorporate the statement into the bill of sale, as long as the resulting document contains the information specified by S 580.4.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: nht93-7.10

DATE: October 5, 1993

FROM: Mark Archer -- Orbital Engine Company Pty. Ltd.

TO: NHTSA, U.S. DOT

TITLE: Regulations concerning vehicles at idle

ATTACHMT: Attached to letter dated 4/5/94 from John Womack to Mark Archer (A42; Std. 102)

TEXT:

The VW Golf Ecomatic recently released in Europe automatically cuts its engine during extended periods at idle for the purpose of reducing exhaust emissions and fuel consumption.

We would like to know if there are any regulations which affect a vehicle of this nature being sold in the US.

ID: aiam1783

Dear Mr. Chancey: This responds to Trail-O-Matic's January 21, 1975, question whether trailer manufactured from the running gear and suspension of an existing trailer and a newly- fabricated frame and upper structure would qualify as a rebuilt vehicle that would not have to be certified as conforming to the requirements of Standard No. 121, *Air brake systems*.; The answer to your question is no. In determining that a buildin operation constitutes the repair of an existing vehicle, and not the manufacture of a new vehicle, the NHTSA requires that, as a minimum, the running gear and frame of the existing vehicle be used in the building operation. For your information, I have enclosed a letter which discusses a similar operation in the trailer industry.; Standard No. 121, therefore, applies to the manufacture of trailer described in your letter.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1449

Dear Mr. Sornson:#This is in response to your March 13, 1974, reques for confirmation that the intake manifold connector and the brake booster check valve used in connecting the engine intake manifold and the vacuum power brake booster are not subject to Standard No. 106, *Brake hoses*.#A brake hose and fitting is defined in Standard 106 as 'a coupler other than a clamp, designed for attachment to the end of a brake hose.' As pictured in your schematic, the couplers are the clamps, and the intake manifold connection and brake booster check valve are engine components to which the brake hose has been attached by clamp couplers. Therefore your interpretation is correct that neither component is subject to Standard 106.#Sincerely,Lawrence R. Schneider,Chief Counsel;