ID: aiam2767

Dear mr. Reed: This responds to your December 22, 1977, letter asking whether the tir information label required by Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*, must contain the rim size of the rim that is mounted in the vehicle.; Paragraph S5.3.2. of the standard states that the label must contai 'the size designation and, if applicable, the type designation of rims (not necessarily those on the vehicle) appropriate for those tires.' This paragraph specifically permits a manufacturer to equip a vehicle with rim sizes that differ from those listed on its tire information label.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam0209

Dear Mr. Curran: This is in reply to your letter of January 13, 1970, to Mr. W. S Scott, and to your recent inquiry to Mr. James Gilkey, concerning your safety belt system.; Federal Motor Vehicle Safety Standard No. 210 specifies the number o belt anchorages that must be provided and the performance and location requirements of these anchorages in passenger cars. This standard does not apply to seat belt assemblies.; Seat belt assembly performance requirements are specified in Federa Motor Vehicle Safety Standard No. 209.; I am enclosing copies of Standards Nos. 209 and 210 for your reference. Thank you for your interest in motor vehicle safety. Sincerely, Clue D. Ferguson, Director, Office of Standards o Crash-Injury Reduction, Motor Vehicle Safety Performance Service;

ID: aiam1883

Dear Mr. Nakajima: This responds to Toyota's March 25, 1975, request for confirmation tha the top surface of a 'console' (a box-like unit mounted between the front bucket seats of your passenger cars) is not considered to be an armrest for purposes of the requirements of Standard No. 201, *Occupant Protection in Interior Impact*.; Your interpretation is correct. As described in your letter, th console top would not be an 'armrest' to which the requirements of Standard No. 201 apply.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1436

Dear Mr. Linkous: This responds to your request for information on Standard 119, *Ne pneumatic tires for vehicles other than passenger cars,* and on a 'Petition No.2' concerning exemption of 'Mopeds' from the motor cycle regulatory category.; Standard 119 applies to tires, not vehicles, and therefore it regulate only the manufacturer of the tire, not a retailer of vehicles like yourself.; The 'Petition No. 2' to which you refer was files by Mr. Robert Smit of Ohio Bikes, 631 Broad Street, Columbus, Ohio 43215, asking for a redefinition of 'motorcycle' to exclude Moped-type vehicles, and a change in the lighting standard to exclude Moped-type vehicles from he present motorcycle requirements.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1206

Dear Mr. Allen: This is in reply to your letter of July 19, 1973, to the Administrator. The exemption provided vehicles with a curb weight of 1,000 pounds o less will cease to exist as of January 1, 1974, and lightweight vehicles manufactured on or after that date will be required to meet all Federal motor vehicle safety standards applicable to their vehicle category, *e.g.* passenger cars.; Under the circumstances you indicate, you would be the final-stag manufacturer of a vehicle manufactured in two or more stages, under 49 CFR Parts 567 and 568 of our regulations. We refer you specifically to sections 567.5 and 568.6 of those regulations.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1375

Dear Mr. Bruner: Dr. Gregory asked me to respond to your January 3, 1974, letter askin whether the National Highway Traffic Safety Administration proposal to modify the definition of Multipurpose Passenger Vehicle would affect importation of The Thing.; The proposed modification would reclassify vehicles like The Thing a passenger vehicles, but it would not prohibit their importation. Volkswagen would have to incorporate several additional safety features in The Thing to meet the higher standards for passenger cars.; We have not made a final decision on the proposed redefinition Volkswagen as the manufacturer of The Thing might be able to give you a better evaluation of The Thing's future than we have at present.; Sincerely, Lawrence R. Schneider, Chief Counsel

ID: nht71-5.54

DATE: 06/30/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Trailer Coach Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of June 7 requesting interpretations of Standard No. 207, Seating Systems, and Standard No. 208, Occupant Crash Protection.

First, with respect to Standard No. 207, you have asked whether designated seating positions must be labeled as such. Our response is that the labeling section requires labels on seats not designated for occupancy while the vehicle is in motion but does not require designated seating positions to be labeled.

With respect to the nature and content of the label on a seat not designated for occupancy, the standard states that the seat must be "conspicuously labeled to that effect." There are thus two general requirements: that the label be conspicuous and that it indicate that the seat is not to be occupied while the vehicle is in motion. The requirement for conspicuousness relates to the location of the label and the prominence of its lettering. Generally speaking, it would have to be located so that it could be seen by a person preparing to occupy the seat and of a size that could be read by the occupant-in the normal motion of sitting. The statement on the label must clearly indicate that the seat is not to be occupied while the vehicle is in motion, but the exact wording is left to the manufacturer.

Standard No. 208 requires that MPV's and trucks with a GVWR of less than 10,000 pounds, manufactured from January 1, 1972 to August 15, 1975, must elect either a passive protection system or a seat belt system that requires Type 2 seat belt assemblies

at outboard designated seating positions that include the windshield header within the head impact area. A similar requirement, without the passive option, goes into effect July 1, 1971, for these vehicles. Your question is whether, if a seating position does not have the windshield header within the head impact area, it is permitted to have a Type 1 seat belt assembly. Our response is that the standard permits a Type 1 belt for such a position.

Please advise us if we can be of further assistance.

Sincerely

TRAILER COACH ASSOCIATION

7 June 1971

Administrator National Highway Traffic Safety Administration

Attention: Office of the Chief Counsel

Enclosed are the following requests for interpretation relative to Federal Motor Vehicle Safety Regulations and Standards: TCA-RI-1-71 - Request for Interpretation (7 June 1971) 49 CFR Part 574, Tire Identification and Record Keeping; TCA-RI-2-71 - Request for Interpretation (7 June 1971) Motor Vehicle Safety Standard 207, Seating Systems Passenger Cars, Multi-Purpose Passenger Vehicles, Trucks and Buses; Motor Vehicle Safety Standard 208 Occupant Crash Protection.

The requests for interpretation formats and contents have been developed to facilitate interpretation by the Administrator, National Highway Traffic Safety Administration.

Trailer Coach Association wishes to develop an optimum standard system for requesting interpretations and would appreciate any comments from the Administrator, NHTSA, concerning improvements in format and content.

Richard I. Moss Washington Representative Trailer Coach Association

7 June 1971

REQUEST FOR INTERPRETATION 1-71 (TCA-RI-1-71)

SUBJECT: 49 CFR Part 574 Tire Identification and Record Keeping

This document constitutes a formal request from the Trailer Coach Association to the Administrator, National Highway Traffic Safety Administration for interpretation relative to the application of 49 CFR Part 574 Tire Identification and Record Keeping to the mobile home and recreation vehicle industry.

This document is designed to simplify arrival at an interpretation by the Administrator, NHTSA, and consists of the following paragraphs:

1.0 Background

2.0 Problem

2.1 Development of the problem situation

2.2 The specific problem

3.0 Request for Interpretation

Please forward the interpretation to the following office:

Washington Representative Trailer Coach Association 1800 North Kent Street, Suite 922 Arlington, Virginia 22209.

RICHARD I. MOSS Washington Representative Trailer Coach Association

REQUEST FOR INTERPRETATION 1-71 (TCA-RI-1-71)

SUBJECT: 49 CFR Part 574, Tire Identification and Record Keeping Regulation (Part 574)

1.0 Background

In the recreation vehicle manufacturing process, the flow of tires and vehicles from the tire manufacturer to the customer is often complex. This complexity occurs primarily because several types of recreation vehicles are manufactured in two or more stages.

Figure - 1 -- Flow chart Type I Sequence of Tire Identification and Record Keeping Activity portrays one typical flow of tires and vehicles from the tire manufacturer to the customer.

Figure - 2 -- Coding Chart for Tire Identification and Record Keeping Activity provides a key to the activities performed by each organization along the flow (boxes 1 through 6 inclusive) as interpreted by the staff, Trailer Coach Association

2.0 Problem

2.1 Development of the Problem Situation

In Figure - 1 there is no tire dealer. There are, however, two motor vehicle dealers in the flow of tires and vehicles, namely, the truck dealer and the motor home dealer.

Paragraph 574.7 (Tire Distributors and Dealers) of the tire identification and record keeping regulations requires the tire distributors and dealers to provide tire information to the tire manufacturer.

Paragraph 574.8 establishes motor vehicle dealers as tire dealers when (1) he sells a used motor vehicle for purposes other than resale or leases a motor vehicle for more than 60 days that is equipped with new tires or newly retreaded tires; or (2) he sells a new motor vehicle to first purchaser that is equipped with tires that were not on the vehicle when shipped by the vehicle manufacturer.

There is no specific requirement appearing in 574 Tire Identification and Record Keeping for the motor vehicle dealer selling a new vehicle to the first purchaser equipped with tires when shipped by the manufacturer to report information to the motor vehicle manufacturer or the tire manufacturer.

A study of Figure - 1 flow chart indicates that: (1) There is no tire dealer in the chain; and (2) There are two motor vehicle dealers in the chain. Neither dealer is specifically required to report tire data by the provisions of 574, the tire identification and record keeping regulation.

Paragraph 574.9 requires the motor vehicle manufacturer to maintain a record, by identification number, of tires on or in each vehicle shipped by him to a motor vehicle distributor or dealer and to maintain a record of the name and address of the first purchaser for purposes other than resale of each vehicle equipped with such tires.

2.2 The Specific Problem

The tire identification and record keeping regulations as written and as applied to Flow Chart Type I, Sequence of Tire Identification and Record Keeping Activity, present the recreation vehicle manufacturer with the following problems.

(1) The vehicle manufacturer is required to report tire information, but, in the case of a vehicle equipped with tires provided by the manufacturer, the vehicle dealer is not specifically required to provide tire data to the vehicle manufacturer.

(2) The vehicle manufacturer is not considered a tire dealer and is not required to provide tire data to the tire manufacturer.

(3) The vehicle manufacturer cannot comply with 574 if the vehicle dealer refuses to provide tire data.

(4) The tire reporting chain is broken (Fig-1) and 574 the tire identification and reporting regulation becomes ineffective.

3.0 Request for Interpretation

It is requested that the following questions be answered in order to provide a sound basis for recreation vehicle industry compliance with 49 CFR Part 574 Tire Identification and Reporting Requirements.

3.1 Is there a specific regulation requiring the motor vehicle dealer to report tire data to the motor vehicle manufacturer when the motor vehicle is equipped with new tires installed by the motor vehicle manufacturer?

3.2 Would the Administrator apply Section 113f, National Traffic and Motor Vehicle Safety Act of 1966 as the means

to the motor vehicle manufacturer when the motor vehicle is equipped with new tires installed by the motor vehicle manufacturer?

3.3 What specific regulation requires the motor vehicle manufacturer to report tire data to the tire manufacturer when new tires have been procured for motor vehicles direct from the manufacturer?

3.4 If a motor vehicle manufacturer who sells a motor vehicle to a motor vehicle dealer which is equipped with new tires installed by the manufactured has documented proof (such as a registered letter) that the motor vehicle dealer refused to provide the required tire records:

3.4.1 Has the motor vehicle manufacturer shown "due care" by having documentary evidence of the dealer's refusal to provide the tire records?

3.4.2 If the motor vehicle manufacturer informs the Administrator, NHTSA, concerning the dealer's refusal to provide tire records and provides documentary evidence of the dealer's refusal to provide tire records, what assistance will the Administrator, NHTSA, provide for the motor vehicle manufacturer?

Fig.

(FLOW CHART OMITTED)

NOTES 1. LETTERS (A,B,C) ARE CODES INDICATING SPECIFIC ACTIVITY [SEE CODING CHART]

2. NUMBER IN PARENTHESES [(2), (3)] INDICATES ORGANIZATION TO WHICH INFO IS PASSED.

FLOW CHART TYPE I SEQUENCE OF TIRE IDENTIFICATION AND RECORD KEEPING ACTIVITY

CODING CHART FOR TIRE IDENTIFICATION RECORD KEEPING ACTIVITY Item Description of Tire Identification and Record Keeping Activity Provides means of record keeping Records information concerning purchasers Maintains records concerning all tire purchasers Maintains records concerning distribu- tors and dealers purchasing tires directly from him Submits purchaser information to tire manufacturer Maintains record of tires on or in each vehicle shipped to motor vehicle distributor or dealer Maintains records for three years Maintains name and address of first vehicle purchaser

Item Code Remarks A This is a form containing the information in item 2 below B Name and address of tire purchasers Tire identification number Name and address of tire seller C Same remarks as for Item #2 D Name and address Number of tires purchased Number of tires for which reports received Total number of tires sold by manufacturer Total number of tires reported on E Same information as for item #2 A record of all purchasers is not required F Record is by tire identification number G H

TRAILER COACH ASSOCIATION

7 June 1971

REQUEST FOR INTERPRETATION 2-71 (TCA-RI-2-71)

SUBJECT: Motor Vehicle Safety Standard 207, Seating Systems

SUBJECT: Motor Vehicle Safety Standard 207, Seating Systems Passenger Cars, Multi-Purpose Passenger Vehicles, Trucks and Buses; Motor Vehicle Safety Standard 208; Occupant Crash Protection.

This document constitutes a formal request from the Trailer Coach Association to the Administrator, National Highway Traffic Safety Administration, for interpretation relative to the application of Federal Motor Vehicle Safety Standards 207 and 208 to the mobile home and recreation vehicle industry.

This document is designed to simplify arrival at an interpretation by the Administrator, NHTSA, and consists of the following paragraphs:

1.0 Background

2.0 Problem

2.1 Development of the Problem Situation

2.2 The Specific Problem

3.0 Request for Interpretation

Please forward the interpretation of the following office:

Washington Representative Trailer Coach Association 1800 North Kent Street, Suite 922 Arlington, Virginia 22209

RICHARD I. MOSS Washington Representative Trailer Coach Association

REQUEST FOR INTERPRETATION 2-71 (TCA-RI-2-71)

SUBJECT: Motor Vehicle Safety Standard 208, Occupant Crash Protection, Motor Vehicle Safety Standard 207, Seating Systems Passenger Cars, Multi-Purpose Passenger Vehicles, Trucks and Buses.

1.0 Background

Paragraph S 4.2.1.2 (b) of Motor Vehicle Safety Standard 208 states that "The vehicle shall have seat belt assemblies that conform to Standard 209 as follows:

(a) . . . .

(b) In all vehicles except those for which requirements are specified in S 4.2.1.2 (a), a type of seat belt assembly shall be installed for each outboard designated seating position that includes the windshield header within the head impact area, and a type 1 or type 2 seat belt assembly shall be installed for each other designated seating position."

There appears to be no requirement for labeling designated seating positions Standard 207, paragraph S 4.4 states that

"Seats not designated for occupancy while the vehicle is in motion shall be conspicuously labeled to that effect."

2.0 Problem 2.1 Development of the Problem Situation

The problem confronting the recreation vehicle industry has developed relative to: (1) The requirement for type 2 seat belts if the windshield header is not in the head impact area; (2) The requirements for labeling designated seating positions; and (3) The requirement for labeling seats other than designated seating positions.

2.2 The Specific Problem

Does paragraph S 4.2.1.2(b) Standard 208 mean that if the windshield header is not in the head impact area, type 1 seat belt assemblies are satisfactory?

Are there labeling requirements for designated positions?

What are the specific requirements relative to labeling seats not designated for occupancy while the vehicle is in motion?

3.0 Request for Interpretation

It is requested that the following questions be answered in order to provide a sound basis for recreation vehicle industry compliance with Standard 207, Seating systems - Passenger Cars, Multi-Purpose Passenger Vehicles, Trucks and Buses; and Standard 208 - Occupant Crash Protection:

3.1 If the windshield header is not within the head impact area, is a type 1 seat belt satisfactory for the designated seating position?

3.2 Is labeling required for designated seating positions? If so, what are the requirements for:

3.2.1 Label Contents?

3.2.2 Lettering Size?

3.2.3 Contrast?

3.2.4 Location?

3.2.5 Number of labels per designated seating position?

3.3 What are the requirements for the labels required by paragraph S 4.4 standard 207? Specifically, what are the requirements for:

3.3.1 Label Contents?

3.3.2 Lettering Size?

3.3.3 Contrast?

3.3.4 Location?

3.3.5 Number of Labels?

ID: aiam2269

Dear Senator Hartke: This is in response to your letter of March 30, 1976, enclosing letter from Mr. Dennis Oser concerning the effective date of Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles Other Than Passenger Cars.*; Standard No. 119 became effective March 1, 1975, and applies t non-passenger-car tires manufactured on and after that date. From his reference to 'April 1, 1976', Mr. Oser appears to be concerned with the effective dates of 49 CFR 393.75, a regulation issued by the FEderal Highway Administration's Bureau of Motor Carrier Safety (BMCS). That regulation addresses the type of tires with which motor vehicles in use in interstate commerce must be equipped. Accordingly, I have forwarded your letter to the BMCS for further reply.; Sincerely, James B. Gregory, Administrator

ID: aiam2499

Dear Senator Hatfield: With regard to my letter to you of July 1, 1976, concerning th application of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other than Passenger Cars*, to the paver manufactured by Layton Manufacturing Company of Salem, Oregon, I would like to advise you of a clarification of the requirements of the standard that may be relevant to Layton's product.; Essentially, it has been clarified that the requirement of S5.1.1 o the standard accommodates a manufacturer's decision to equip its motor vehicle with tires other than 'tires for highway service.' This means that Layton can choose to use tires that do not conform to the requirements set forth in S5.1.1 of the standard. I have enclosed a copy of the notice that contains a detailed discussion of this clarification.; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam2681

Dear Mr. McNeil: This responds to your July 20, 1977, letter asking whether you certification labels comply with Part 567, *Certification*, and Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*.; As stated to you in an earlier letter, the National Highway Traffi Safety Administration does not issue approvals of compliance with Federal safety standards and regulations. The agency will, however, give you an informal opinion as to whether your labels appear to comply with the requirements. The agency has determined that the two labels that you submitted do not follow the format established in the regulations and, therefore, do not comply with the requirements. If 'R' denotes radial ply and 'F' denotes load range, the tire designation should be 10.00 R 20(F).; Sincerely, Joseph J. Levin, Jr., Chief Counsel