ID: aiam0032

Dear Mr. Busby: In your letter of July 13, 1967, you requested clarification of severa issues relating to the location and size of turn signals as specified in the Initial Federal Motor Vehicle Safety Standards. Initial Standard No. 108, entitled, 'Lamps, reflective Devices, and Associated Equipment - Multipurpose Passenger Vehicles, Trucks, Trailers, and Buses, 80 or More Inches Wide Overall,' specifies that turn signal lamps shall conform to Class A of SAE Standard J588d. As stated in the enclosures to your letter, SAE Standard J588d specifies that the optical axis (filament center) of the front turn signal lamp shall be at least 4 inches from the inside diameter of the retaining ring of the headlamp unit providing the lower beam. This requirement of the SAE Standard is addressed to a single lamp with only one bulb. For a combination of lamps, such as that shown on the sketch enclosed with your letter, the intent of this requirement could be met if the optical center produced by the two bulbs is outside the 4-inch limit. The location of this optical center must be determined from laboratory test data, which was not presented in your letter.; *Proposed* Initial Standard No. 112, entitled, 'Lamps, Reflectiv Devices, and Associated Equipment - Passenger Cars, Motorcycles, and Multipurpose Passenger Vehicles, Trucks, Trailers, and Busses of less than 80 Inches Wide Overall,' would permit the use of Class B (SAE J588d) turn signal lamps until January 1, 1969. Under this provision, lamp No. 1 on your sketch would conform to the 4-inch spacing requirement. Combining lamp no. 1 and No. 2 to obtain a Class A Area would again result in the situation previously described with respect to location of the optical center.; Since your letter makes frequent reference to 'cars,' we assume tha you are primarily interested in the requirements of Standard No. 112. In this respect, we would caution you that the requirements specified therein are presently only proposed requirements, and are subject to change prior to issuance of the final standard.; Thank you for your interest in the motor vehicle safety standards. Sincerely yours, George C. Nield, Acting Director, Motor Vehicle Safet Performance Service;

ID: aiam1102

Dear Mr. Mitchell: Thank you for your letter of March 27, 1973, requesting informatio concerning Federal Motor Vehicle Safety Standards with special emphasis on those standards pertaining to fuel systems.; Enclosure 1 is a brochure which gives a brief summary of all safet standards issued through June 1972, and a subscription Order Form, should you wish to purchase a complete edition of the standards from the Superintendent of Documents on a subscription basis.; Enclosure 2 is a copy of Federal Motor Vehicle Safety Standard No. 301 'Fuel Tanks, Fuel Tank Filler Pipes, and Fuel Tank Connections - Passenger Cars.' This standard is currently undergoing amendment that will include rollover and rear-end impact requirements in addition to the fixed barrier collision which is currently required.; The Bureau of Motor Carrier Safety regulates vehicular interstat commerce. Enclosure 3 is an Advanced Notice of Proposed Rule Making concerning plastic fuel tanks (*Federal Register,* Volume 36, No. 178, September 14, 1971) which was recently issued by this Bureau. Further information may be obtained by contacting this Bureau as follows:; >>>Director, Bureau of Motor Carrier Safety, Department o Transportation, 400 Seventh Street, S.W., Washington, D.C. 20590<<<; In response to your question: 'I particularly wish to know if th relevant Safety Standard in force in America requires the fuel tanks to be located outside the main body shell of the vehicles or if it is permissible under this Safety Standard for fuel tanks to be situated in the interior of the vehicles,' the standards as written do not specifically require that the fuel system be external to the passenger compartment. These standards, in accordance with Public Law 89-563 which authorized their development, emphasize performance rather than design considerations.; Another standard which may be of interest to you is Standard No. 302 'Flammability of Interior Materials in Passenger Cars, Multipurpose Passenger Vehicles, Trucks and Buses,' which was effective September 1, 1972. Enclosure 4 is a copy of this standard along with two proposed amendments.; We trust your inquiry has been satisfactorily answered. If there ar any other questions or we can be of further service, please do not hesitate to contact this office. I am also returning the amount you enclosed for postage, etc.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: 1982-3.37

TYPE: INTERPRETATION-NHTSA

DATE: 12/30/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: ANONYMOUS (CONFIDENTIAL)

TITLE: FMVSS INTERPRETATION

TEXT:

Dear

This responds to your recent request for an interpretation of the requirements of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. Specifically, you asked if that standard allows a manufacturer to equip a motorcycle with passenger car tires and rims.

Standard No. 120 permits a motorcycle to be equipped with passenger car tires and rims, provided that those tires and rims meet all the requirements of the standard. Section S5.1.1 of Standard No. 120 requires all motorcycles equipped with tires that meet either the requirements of Standard No. 109, which applies to new passenger car tires, or Standard No. 119, which applies to new tires for use on motor vehicles other than passenger cars. Thus, passenger car tires can be used on new motorcycles, as long as those passenger car tires are certified as complying with Standard No. 109.

Motorcycle rims are subject to two requirements. First, section S5.1.1 requires that the rims be listed by the manufacturer of the tires installed on the motorcycle as suitable for use with those tires. If you use rims which are the proper size for the passenger car tires to by used, this requirement is easily met by passenger car rims. Second, rims used on motorcycles must meet the rim marking requirements, because the rim manufacturers do not mold the required information onto passenger car rims. However, if you can obtain passenger car rims marked with the information set forth in section S5.2 and listed by the passenger car tire manufacturer as appropriate for use with the passenger car tires, those rims could be used on new motorcycles.

A copy of this letter with your name and address deleted, along with your request for an interpretation of Standard No. 120, has been placed in the public docket under interpretations of Standard No. 120. Should you have any further questions or need further information on this matter, please contact Mr. Stephen Kratzke of my staff at (202) 426-2992.

Sincerely,

Original Signed By Frank Berndt Chief Counsel

This request for interpretation is with reference to Federal Motor Vehicle Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. We would like to confirm that Standard No. 120 permits the use of passenger car tires and rims on a motorcycle.

We believe that the use of passenger car tires and rims on a motorycle is permitted because Section S5.1.1 of Standard No. 120 states that "...each vehicle equipped with pneumatic tires for highway service shall be equipped with tires that meet the requirements of Standard No. 109 ( 571.109) or Standard No. 119 ( 571.119), and with rims that are listed by the manufacturer of the tires as suitable for use with those tires...". In our opinion, this permits the use of passenger car tires and rims on motorcycles, provided the tires comply with Standard No. 109 and the rims are an appropriate match for the tires and also comply with Standard No. 110.

ID: aiam0613

Dear Mrs. Hicks: This is in reply to your letter of December 14, 1971, in which you as certain questions relating to 'Gross Vehicle Weight Rating' (GVWR) as it would apply to our regulations, 49 CFR 567 and 568. Our requirement that certain weight ratings be applied to a label by vehicle manufacturers is a regulation and not a Federal motor vehicle safety standard.; Gross vehicle weight rating as defined in S 568 of the regulation 'means the value specified by the manufacturer as the loaded weight of a single vehicle.' This was further clarified in the *Federal Register* on October 8, 1971, 36 FR 14583, 'To preclude the possibility of understating a vehicle's GVWR, however, the certification regulation is herewith amended to provide that the stated GVWR shall not be less than the sum of unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity.' Unloaded vehicle weight has been defined as '. . . the weight of a vehicle with maximum capacity of all fluids necessary for operation of the vehicle, but without cargo or occupants,' 36 FR 2511.; From the standpoint of the regulation itself, the only other limit o GVWR would be that it should not be more than the sum of the gross axle weight ratings (although it may be less), since otherwise the vehicle would obviously be supplied with axle systems inadequate for its carrying capacity.; Good engineering practice would dictate that weight ratings be based o the weakest component in the system regardless of what it, the weakest component, might be. Of course, weight distribution is one of the factors that must be considered in making these calculations. In the example you have cited, if a manufacturer supplied a rear axle on his vehicle with a stated axle weight rating of 13,000 pounds with tires on the axle having a sum total rating of something less he would be overstating the GAWR of a particular axle on his certification label. GVWR's should not be greater than the total tire capacity or as stated before the sum of the gross axle weight ratings.; If you have further questions, I will be pleased to answer them. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs;

ID: aiam4177

Dear Mr. McEntire: I regret the delay in responding to your letter to this office askin whether certain 'mini-vans' designed to carry a maximum of eight persons are classified by NHTSA as 'passenger cars' or 'multipurpose passenger vehicles' (MPV's), for purposes of complying with the Federal motor vehicle safety standards.; I would like to begin by clarifying that the classification of particular vehicle is determined in the first instance by its manufacturer, and not by NHTSA. Under our certification requirements (49 CFR Part 567), manufacturers are required to specify the type of their vehicles in accordance with the definitions set forth in Part 571.3 of our regulations and must certify that their motor vehicles comply with all the motor vehicle safety standards applicable to that type. We define an MPV in Part 571.3 as 'a motor vehicle ... designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.'; Information we have received regarding manufacturer certificatio discloses that manufacturers classify *cargo- carrying* models of the Ford Aerostar, and G.M. Astro and Safari as 'trucks.' A 'truck' is defined in Part 571.3 as 'a motor vehicle...except a trailer, designed primarily for the transportation of property or special purpose equipment.' We understand that *passenger* models of mini-vans designed to carry up to eight passengers utilize the same type of chassis used in truck models. It is likely, therefore, that the passenger model mini-vans you asked about would be classified as MPV's instead of passenger cars. This is verified by the 'MPV' classification given by manufacturers to the Chrysler mini-van and Toyota Van.; On a related matter, you asked for our comments on your Department' recommendation to your school boards that they not condone parents' use of conventional vans (i.e., vans not meeting Federal or State school bus safety regulations) to transport school children to school-related events. Mr. Arnold Spencer of Rockledge, Florida, recently wrote to our office concerning the above recommendation and requested us to explain how our school bus regulations apply to persons owning vans. I have enclosed a copy of our April 25, 1986, response to Mr. Spencer which you might find helpful.; I hope this information is helpful. If you have further questions please feel free to contact us.; Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam4176

Dear Mr. McEntire: I regret the delay in responding to your letter to this office askin whether certain 'mini-vans' designed to carry a maximum of eight persons are classified by NHTSA as 'passenger cars' or 'multipurpose passenger vehicles' (MPV's), for purposes of complying with the Federal motor vehicle safety standards.; I would like to begin by clarifying that the classification of particular vehicle is determined in the first instance by its manufacturer, and not by NHTSA. Under our certification requirements (49 CFR Part 567), manufacturers are required to specify the type of their vehicles in accordance with the definitions set forth in Part 571.3 of our regulations and must certify that their motor vehicles comply with all the motor vehicle safety standards applicable to that type. We define an MPV in Part 571.3 as 'a motor vehicle ... designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.'; Information we have received regarding manufacturer certificatio discloses that manufacturers classify *cargo- carrying* models of the Ford Aerostar, and G.M. Astro and Safari as 'trucks.' A 'truck' is defined in Part 571.3 as 'a motor vehicle...except a trailer, designed primarily for the transportation of property or special purpose equipment.' We understand that *passenger* models of mini-vans designed to carry up to eight passengers utilize the same type of chassis used in truck models. It is likely, therefore, that the passenger model mini-vans you asked about would be classified as MPV's instead of passenger cars. This is verified by the 'MPV' classification given by manufacturers to the Chrysler mini-van and Toyota Van.; On a related matter, you asked for our comments on your Department' recommendation to your school boards that they not condone parents' use of conventional vans (i.e., vans not meeting Federal or State school bus safety regulations) to transport school children to school-related events. Mr. Arnold Spencer of Rockledge, Florida, recently wrote to our office concerning the above recommendation and requested us to explain how our school bus regulations apply to persons owning vans. I have enclosed a copy of our April 25, 1986, response to Mr. Spencer which you might find helpful.; I hope this information is helpful. If you have further questions please feel free to contact us.; Sincerely, Erika Z. Jones, Chief Counsel

ID: 3325o

Mr. Wes Sprunk
Saf-Tee Siping & Grooving, Inc.
l4l80 West 78th, Suite l02
Eden Prairie, MN 55344

Dear Mr. Sprunk:

This responds to your letter concerning the siping of tires. You asked whether "there is any possible problem with the siping of new, used, truck, passenger, or light duty tires," under Department of Transportation regulations. Your question is responded to below, to the extent that it concerns regulations of the National Highway Traffic Safety Administration (NHTSA). We note that your letter indicates that you have also discussed this issue with officials of the Federal Highway Administration.

By way of background information, NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act (Vehicle Safety Act), it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment meet applicable standards.

As noted by your letter, the term "siping" should be distinguished from "grooving." You stated that grooving is a "process of removing rubber from the tire to give it an additional space for water release." You stated that siping is "a process of cross cutting the tread, never deeper than the original tread depth of the tire; and in most cases, l/32" or less, with a fine knife--either four or five cuts to the inch--that does not remove rubber."

Section l08(a)(l) of the Vehicle Safety Act prohibits any person from manufacturing for sale, selling or offering for sale, introducing or delivering for introduction in interstate commerce, or importing into the United States, any item of motor vehicle equipment unless it is in conformity with Federal motor vehicle safety standards. The prohibitions of section l08(a)(l) do not apply after the first purchase in good faith for purposes other than resale. (Section l08(b)(l).)

NHTSA has issued several safety standards for tires. Standard No. l09 specifies performance and labeling requirements for new pneumatic tires for use on passenger cars; Standard No. ll7 specifies performance and labeling requirements for retreaded pneumatic tires for use on passenger cars; and Standard No. ll9 specifies performance and labeling requirements for new pneumatic tires for vehicles other than passenger cars.

The siping of new tires (including retreaded tires) is permissible only if that operation does not adversely affect the compliance of the tire with Standard No. l09, ll7 or ll9, as applicable. If a dealer offers for sale or sells new tires (including new retreaded tires) that have been siped and those tires do not comply with Standard No. l09, ll7 or ll9, as applicable, the dealer would be subject to a civil penalty of up to $l,000 for each tire that did not comply.

Section l08(a)(2)(A) prohibits any manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative, in whole or part, any device or element of design installed on or in an item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. Thus, any persons or businesses within the above categories that perform siping should ensure that the siping does not render inoperative the compliance of tires with applicable Federal motor vehicle safety standards.

You should also be aware that the agency's regulation on regrooved tires (49 CFR Part 569) specifies requirements concerning regrooved tires and regroovable tires which have been siped. See sections 569.7(a)(2)(vii) and 569.7(b).

I hope this information is helpful.

Sincerely,

Erika Z. Jones Chief Counsel

ref:l09#ll7#ll9 d:l2/30/88

ID: nht73-1.3

DATE: 04/05/73

FROM: R. B. Dyson; NHTSA

TO: Holiday Rambler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 20, 1973, to this agency asking about the applicability of paragraph S4.1.2 of Federal Motor Vehicle Safety Standard No. 104 to vehicles other than passenger cars.

Your understanding is correct that the standard establishes wiped area requirements only for passenger car windshields. The NHTSA is engaged in research with the intent of establishing as all-weather visibility standard, combining Standards No. 103 and 104, that would among other things extend the windshield wiped area requirements to vehicles other than passenger cars. However, it is not possible to say when we will issue a rulemaking proposal on this subject.

ID: nht94-4.39

TYPE: INTERPRETATION-NHTSA

DATE: September 29, 1994

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

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: 49 CFR Part 583 - Automobile Parts Content Labeling Request for Interpretation

ATTACHMT: ATTACHED TO 3/14/95 LETTER FROM PHILIP R. RECHT TO ALBERTO NEGRO (PART 583; REDBOOK (2))

TEXT: I am writing to ask that you verify whether the 1000 unit threshold of 49 CFR 583.5(g) applies to the Alfa Romeo and Ferrari marques separately or collectively, as those marques are both owned by Fiat S.p.A. Fiat S.p.A. is the stockholder of Fiat Auto S. p.A., which produces Alfa Romeo cars, and of Ferrari S.p.A. which produces Ferrari cars.

I thank you for your consideration and I remain at your disposal for all additional information that you require.

ID: nht90-4.48

TYPE: Interpretation-NHTSA

DATE: October 19, 1990

FROM: Tom Wiatrak -- Century Products Company

TO: Deidre Fujita -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 1-3-91 from Paul Jackson Rice to Tom Wiatrak (A37; Std. 213)

TEXT:

We are enclosing pictures of a suggested location for the warning and instruction labels for a new carseat pad. This surround pad covers the sides of the casting thus hiding the labels installed in the normal position. We would like to add tyvek warnin g and instruction labels sewn to the pad as shown in addition to the labels that appear on the casting.

Please advise at your earliest convenience if this proposal meets the requirements of FMVSS 213.

Attachment

Photos of label location on carseat pad. (Photos omitted.)