ID: nht74-2.50

DATE: 07/10/74 EST

FROM: RICHARD B. DYSON -- NHTSA ASSISTANT CHIEF COUNSEL

TO: K. NAKAJIMA -- DIRECTOR/GENERAL MANAGER, FACTORY REPRESENTATIVE OFFICE - TOYOTA

TITLE: N40-30

ATTACHMT: OCTOBER 9, 1988 LETTER FROM JONES TO BURKARD, EBNER, AND TEVES, OCTOBER 9, 1981 LETTER FROM BERNDT TO KAWANO, FEBRUARY 3, 1981 LETTER FROM KAWANO TO BERNDT, MAY 24, 1974 LETTER FROM TEVES TO GREGORY, AND MAY 27, 1988 LETTER FROM TEVES TO JONES

TEXT: This is in reply to your letter of May 24, 1974 to Dr. Gregory asking whether the five master cylinder reservoir designs indicated would meet the requirements of S5.4.1 of Motor Vehicle Safety Standard No. 105-75.

Each of these designs appears to conform to S5.4.1 providing that the reservoir capacity requirements of S5.4.2 are met. It appears that Designs (3) and (4) would require additional fluid for the clutch.

ID: nht90-3.46

TYPE: Interpretation-NHTSA

DATE: August 2, 1990

FROM: S. Watanabe -- General Manager, Automotive Equipment Technical Coordination Dept., Stanley Electric Co., Ltd.

TO: Richard L. Van Iderstine -- Safety Standards Engineer, NHTSA

TITLE: Re The effective date of the downward torque deflection requirements for external mechanical aiming of replaceable bulb headlamps (S7.7.5.1(a))

ATTACHMT: Attached to letter dated 8-30-90 to S. Watanabe from P. J. Rice; (A36; Std. 108)

TEXT:

We would like to have your advice on the effective date of the downward torque deflection requirements for external mechanical aiming of replaceable bulb headlamps (Paragraph S7.7.5. 1 (a)).

In our understanding, the effective date is September 1, 1990 and on or after this date, Lamp manufacturers (such as Stanley, not car manufacturer), have to manufacture the external mechanical aiming of replaceable bulb headlamps which conform the downwa rd torque deflection requirements (Paragraph S7.7.5.1 (a)). Are they correct understandings?

Your kind advice will be highly appreciated.

ID: nht80-1.38

DATE: 03/21/80

FROM: JAMES W. LAWRENCE -- MANAGER ENGINEERING RELIABILITY & GOVERNMENT STANDARDS DEPT. WHITE MOTOR CORPORATION

TO: FRANK BERNDT -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMIN.

TITLE: FMVSS-115 REQUEST FOR INTERPRETATION VEHICLE IDENTIFICATION NUMBERS FOR GLIDER KITS

TEXT: Dear Mr. Berndt:

White Motor Corporation manufactures Glider Kits which are sold through its Service Department for use in rebuilding used and wrecked vehicles. FMVSS-115 does not apply to these kits because they are not new vehicles as manufactured.

There are, however, some states which allow the rebuilt vehicle to carry the identity of the kit, rather than that of the scrapped vehicle. To facilitate the registration of these vehicles, White issues a Manufacturers' Statement of Origin and a vehicle identification number. Registration as a White also provides traceability for recall should the need arise.

White believes, and requests confirmation that, although the standard does not apply to these vehicles, the standard does not prohibit the application of VIN to a Glider Kit.

ID: nht89-2.97

TYPE: INTERPRETATION-NHTSA

DATE: 09/08/89

FROM: ELIZABETH M. LUCAS -- MANAGER, PRODUCT DEVELOPMENT

TO: DELL RANDLE -- SHIKARI CONSULTANT FIRM, LTD.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12/1/89 FROM STEPHEN P. WOOD -- NHTSA TO U.S. CONGRESSMAN GEORGE MILLER; REDBOOK A34; STANDARD 125; LETTER DATED 10/17/89 FROM NANCY L. BRUCE -- D.O.T. OFFICE OF CONGRESSIONAL AFFAIRS TO GEORGE MILLER, U.S. HOUSE OF REP RESENTATIVES; LETTER DATED 10/12/89 FROM GEORGE MILLER, U.S. CONGRESSMAN TO NANCY BRUCE -- D.O.T. OFFICE OF CONGRESSIONAL AFFAIRS; LETTER DATED 10/4/89 FROM DELL RANDLE TO CONGRESSMAN GEORGE MILLER

TEXT: Dear Mr. Randle:

The New Products Committee recently reviewed your Shi-Lite Holder. We are declining your offer to sell this product because it does not meet federal requirements as set by the Department of Transportation.

We wish you luck in your endeavors.

Very truly yours,

ID: nht91-6.6

DATE: September 23, 1991

FROM: Lawrence A. Beyer -- Esq.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10-16-91 from Paul Jackson Rice to Lawrence A. Beyer (A38; VSA Sec. 112)

TEXT:

This office, as well as my clients, have been advised by an office of NHTSA that attorneys cannot submit documentation and make declarations on behalf of clients unless they submit formal power of attorney documentation which authorizes such representation.

I have been under the assumption that as an attorney I have the right to fully represent my clients before the federal government. Such representation includes the preparation and submission of completed documentation on their behalf.

Please advise me if, in order to represent my clients, it is NHTSA's policy that I have to provide proof to NHTSA that my statement that I represent a party is true.

Thank you for your time.

ID: nht71-1.15

DATE: 12/30/71

FROM: Richard B. Dyson; NHTSA

TO: Gurley Refining Company

TITLE: FMVSS INTERPRETATION

TEXT: We have examined the proposed label for "GRC" brake fluid you have submitted to us for comment.

Generally, the label appears to meet the requirements of paragraph S5.2.2 of [Illegible Word] Vehicle Safety Standard No. 116 (36 f.r. 11987, June 24, 1971, as amended, 36 F.R. 21594, November 11, [Illegible Date]. The words "or [Illegible Word]" in your conformity statement are redundant; since the standard is a minimum requirement, "conforming to" and "exceeding" it mean exactly the same thing. If the fluid packager is an entity other than Curley, the packager's name or code identification must appear either below Gurley's name or on the bottom of the can. We assume that the required serial number identifying the packaged lot and date of packaging will be stamped either below Curley's name or on the bottom of the can.

ID: nht92-6.19

DATE: June 2, 1992

FROM: Jeffrey Puentes -- President, Sacramento Registration Service

TO: Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6/30/92 from Paul J. Rice to Jeffrey Puentes (A39; Part 567; VSA Sec 102(3))

TEXT:

We are the agents for a client who would like to sell kits to the retail public.

What is your definition of a Kit Car? How far into the manufacturing process can a party assemble a kit before it is classified as an automobile?

What definitions and/or rules (laws) must he follow in order to begin selling kits for kit cars to the retail public?

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

We thank you for your time and attention to this matter. We look forward to hearing from you.

ID: 11373JEG

B. Michael Korte, Esq.
Law Firm of John Schwabe II
St. Louis Office
The Locust Building--Suite 900
1015 Locust Street
St. Louis, MO 63101

Dear Mr. Korte:

This responds to your letter asking about Federal standards concerning the deployment of air bags. You asked whether AFederal regulations establish a minimum speed that vehicles must be traveling, below which an air bag will not deploy.@

The answer to your question is no. Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, establishes a number of performance requirements for air bags and air-bag-equipped vehicles. However, neither that standard nor any other Federal motor vehicle safety standard specifies that air bags must not deploy in crashes below a specified vehicle speed.

I hope this information is helpful. If you have any other questions, please contact Edward Glancy of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Ref:208 d:1/29/96 NCC-20 Eglancy:mar:1/3/96:OCC 11373

ID: nht94-6.20

DATE: April 20, 1994

FROM: Doug Bereuter -- Member Of Congress, U.S. House Of Representatives

TO: Christopher Hart -- Acting Administrator, NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 5/10/94 From Christopher Hart To Doug Bereuter (A42; Std. 303) And 1/1/94 (EST) Letter From Christopher Hart To Doug Bereuter

TEXT: Dear Mr. Hart:

I recently received your response to my earlier letter regarding the long-delayed National Highway Traffic Safety Administration's rulemaking concerning compressed natural gas vehicle fuel systems and fuel containers. In your letter, you mention that the final rule is being prepared and will be sent to the Office of Management and Budget (OMB) for review. I want to know as soon as the rule is sent to OMB so that I can impress upon them the importance of this matter. It is also critical that you inform OMB of the need for a prompt review. This rule cannot be allowed to languish on someone's desk while Brunswick and its employees continue to suffer due to the lack of a final rule.

ID: nht93-2.46

DATE: April 7, 1993

FROM: Donald W. Vierimaa -- Vice President, Engineering, Truck Trailer Manufacturers Association

TO: Dorothy Nakama -- Office of Chief Counsel, NHTSA

TITLE: Subject: Vehicle Identification Number (VIN)

ATTACHMT: Attached to letter dated 6-29-93 from John Womack to Donald W. Vierimaa (A41; Std. 115; Part 567).

TEXT: Section 4.6 of TTMA's Recommended Practice Number 56-91, "Trailer Vehicle Identification Number," states the following:

4.6 Rebuilt Trailers

If a rebuilt trailer meets the requirements of 49 CFR 571.7(f) as being newly manufactured, the rebuilder must furnish a new VIN. If the rebuilt trailer is considered not new by this requirement, the VIN of the original trailer shall be used in the legal paperwork, but there is no legal requirement to physically retain the VIN on the trailer.

A person has questioned whether the statement that "there is no legal requirement to physically retain the VIN on the trailer" is correct. Please inform us as to whether this statement is correct. It is my understanding that an owner of a motor vehicle is not prohibited from removing a VIN label from his motor vehicle.