ID: aiam2097

Dear Mr. Robbins: This is in response to your letter of June 5, 1975, enclosing a copy o your patent for a tire described as a 'Radial, Bias Ply Tire' and requesting an interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 109, *New Pneumatic Tires--Passenger Cars*. The tire would be constructed with three full body plies: two bias plies (angle 35 degrees) and on radial ply (angle 90 degrees).; S4.3(g) of the standard requires permanent molding of the word 'radial into or onto both sidewalls if the tire is a radial ply tire and, by implication, prohibits the use of the word 'radial' if the tire is not a radial ply tire. In S3., 'radial ply tire' is defined as:; >>>a pneumatic tire in which the ply cords which extend to the bead are laid at substantially 90 degrees to the centerline of the tread.<<<; The tire you have described is not within the scope of this definitio because it includes ply cords extending to the beads which are not laid at substantially 90 degrees to the centerline of the tread. Therefore, the word 'radial' must not appear on either sidewall.; Sincerely, Frank Berndt, Acting Chief Counsel

ID: aiam4620

Dear Ms Arthur: This is in reply to your letter to Taylor Vinson o this Office. You have asked if 'detachable, lighted novelty items are legally allowable on passenger cars,' specifically 'for the exterior roof.' You appear to have in mind an item of aftermarket equipment, that is to say, an item which is not original equipment on a car, but one that the vehicle owner purchases during the course of his ownership. There is no restriction under Federal law as to roof-mounted novelty items if they are installed by the vehicle owner. If they are installed by a manufacturer, distributor, dealer, or motor vehicle repair business, they are permissible as long as they do not render inoperative, in whole or in part, equipment that is installed pursuant to a Federal motor vehicle safety standard. For example, if installation of the novelty light affected the wiring and hence the performance of lighting equipment installed on the vehicle by its manufacturer, that would be a 'rendering inoperative' within the meaning of the prohibition. Use of the novelty light would be determined by the laws of a State in which it is operated. We are unable to advise you on State laws, and suggest that, for further information, you consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, VA 22203. Sincerely, Stephen P. Wood Acting Chief Counsel;

ID: aiam3926

Dear Mr. Strickland: I am responding to your February 20, 1985 request for informatio regarding Federal regulation of trailer manufacturing.; There is no Federal licensing requirement for the manufacture o trailers, which are considered motor vehicles under Federal law. As a manufacturer of a motor vehicle, however, you must submit identification information to the National Highway Traffic Safety Administration under 49 CFR Part 566, *Manufacturer Identification*. You must also certify that each trailer complies with all applicable Federal regulations. The procedure is specified in 49 CFR Part 567.; At this time, the only safety standards applicable to all trailers ar Safety Standard No. 108, *Lamps, reflective devices, and associated equipment*, Safety Standard No. 120, *Tire Selection and rims for motor vehicles other than passenger cars*, and Safety Standard No. 115, *Vehicle Identification Number-Basic Requirements*. The content requirements for the vehicle identification number are found at Part 565. Trailers with certain braking systems also must meet Safety Standard No. 106, *Brake hoses*, Safety Standard No. 116, *Motor vehicle brake fluids*, and Safety Standard No. 121, *Air brake systems*. These standards are found in Part 571 of 49 CFR.; I am enclosing an information sheet that explains how you can obtai copies of these regulations. If you have any further questions, please feel free to contact me.; Sincerely, Jeffrey R. Miller, Chief Counsel

ID: aiam1002

Dear Mr. Moore: This is in reply to your letter of February 1 to Mr. B.M. Crittenden Regional Administrator, concerning emergency flashers.; Effective January 1, 1969, all new automobiles were required to mee Federal Motor Vehicle Safety Standard No. 108, 'Lamps, Reflective Devices and Associated Equipment,' which in turn required the vehicular hazard warning signal operating unit to meet Society of Automotive Engineers Standard J910, January 1966. Prior to January 1, 1969, automobiles were required to meet the standards and regulations of the individual States. Since New York required hazard warning signals (4-way flashers) in 1966, most automobiles manufactured for sale throughout the United States were similarly equipped.; SAE J910 did not contain requirements relating the activation of th signal to the position or rotation of the steering wheel. Several States prohibited the operation of the subject signal on a moving vehicle, therefore, on many cars, this signal was cancelled by the rotation of the steering wheel, and consequently could not be activated even with the vehicle stopped with the steering wheel in certain positions.; We are unaware of similar complaints on the activation of the hazar warning signals.; Sincerely, E. T. Driver, Director, Office of Operating Systems, Moto Vehicle Programs;

ID: aiam1844

Dear Mr. Shriver: This is in response to your letter of March 6, 1975, forwardin correspondence from one of your constituents, Mr. Dick Robbins, Jr., commenting on a proposed weakening of the bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a *Federal Register* notice (copy enclosed) proposing to reduce the current 5 mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would then be increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a *Federal Register* notice that was published on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Your interest and that of Mr. Robbins in this matter is appreciated. Sincerely, James C. Schultz, Chief Counsel

ID: aiam0704

Dear Mr. Livingston: This is in reply to your letter of May 2, 1972, requesting a lette from NHTSA to the effect that tire manufacturers are free to sell you new repairable tires which you plan to repair and sell. We have assumed that the manufacturers of the tires do not believe that they conform to Motor Vehicle Safety Standard No. 109. 'New Pneumatic Tires,' and that they have not certified conformance to the standard, as this is apparently the reason for their reluctance to sell you these tires.; Paragraph S6. of Standard No. 109 provides, among other things, tha passenger car tires that are not certified, defined as 'reclassified tires,' must bear a label (specified in the standard) stating that they are not to be sold for use on passenger cars.; If you wish to purchase reclassified tires, repair them, and resel them for passenger car use, you must ensure that they conform to the performance requirements of Standard No. 109 (paragraphs S1. through S5.). and relabel and certify them in accordance with paragraph S4.3.; You should be aware that the NHTSA has proposed, in a notice date November 27, 1971 (36 F.R. 22688, copy enclosed) to prohibit the sale for any purpose of reclassified tires.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1683

Dear Mr. Lugash: This responds to your October 30, 1974, questions whether th Department of Transportation or any 'private establishment' requires manufacturers to file specifications for automobile, motorcycle, and airplane tires, whether Standard No. 119, *New pneumatic tires for vehicles other than passenger cars*, lists these specifications, and what the number '222474 7MRR' means on the bead of a motorcycle tire.; The Department of Transportation's National Highway Traffic Safet Administration has issued Standard No. 119 (effective March 1, 1975), which establishes minimum performance and labeling requirements with which the manufacturer must comply. A copy of the standard is enclosed. Certain tire specifications must appear on the sidewall, and certain rim-matching specifications must be published by the manufacturer or appear in a publication of at least one private tire organization.; It is the general practice of the tire industry to list specification of tires in a private publication, such as the 'Year Book' of the Tire and Rim Association in the United States. Their address is: The tire and Rim Association, Inc., 3200 West Market Street, Akron, Ohio 44313.; The NHTSA Tire and Wheel Division has determined that the number whic you cite is of significance only to the manufacturer of the tire.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: aiam2791

Dear Mr. Arquin: This responds to your recent letter asking what loading conditions ar applicable for purposes of measuring the wheelbase of passenger cars, under the new phased-in passive requirements of Standard No. 208, *Occupant Crash Protection*. Apparently, the wheelbase of one of Peugeot's vehicles having an independent rear suspension varies as a function of the vehicle loading.; The phased-in passive requirements of Standard No. 208 were based on determination of the lead time necessary to engineer passive restraints into each size class of automobile. Wheelbase was chosen as a measure to delineate the phasing requirements because it is directly related to vehicle size and because it is a well-defined quantity that does not vary significantly within a given car line.; For purposes of measuring wheelbase, the vehicle is loaded according t the general test conditions of Standard No. 208. These test specifications, including loading, are meant to approximate the likely condition of the vehicle under normal driving circumstances. Since a vehicle having a variable wheelbase will generally carry the same weight as the average automobile of its size, it is appropriate that the wheelbase on such a vehicle be determined under the loading conditions specified under Standard No. 208. Therefore, Peugeot should measure the wheelbase of its vehicle under the loading conditions specified in paragraph S8.1.1(a) of the standard.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam1847

Dear Senator Symington: This is in response to your letter of March 5, 1975, requesting ou comment on inquiries you have received concerning a proposed weakening of the bumper standard.; On January 2, 1975, the National Highway Traffic Safety Administratio (NHTSA) issued a *Federal Register* notice (copy enclosed) proposing to reduce the current 5 mph bumper impact requirements to 2.5 mph until the 1979 model year. The impact requirements would then be increased to 4 mph for 1979 and later model year cars.; The proposal was based primarily on the results of two agency-sponsore studies which indicated that the cost and weight of many current production bumpers, in light of inflation and fuel shortages, made the bumpers no longer cost beneficial. Information presented at public hearings on the bumper notice and comments submitted to the docket in response to the proposal have brought to light additional data. The NHTSA has carefully examined all of this evidence and reviewed its studies in light of the new information. As a result, the agency has concluded that the 5 mph protection level should not be reduced. This decision is contained in a *Federal Register* notice that was published on March 12, 1975 (Docket No. 74-11, Notice 7, Docket No. 73-19, Notice 6).; Your interest in this matter is appreciated. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: nht75-4.50

DATE: 12/03/75

FROM: AUTHOR UNAVAILABLE; MaRK Schwimmer; NHTSA

TO: For Interpretation file

TITLE: FMVSR INTERPRETATION

TEXT: On December 1, 1975, I received a telephone call from Mr. Nakajima of Bridgestone Tire Co. (213-320-6030) concerning the meaning of the March 1, 1975, effective date of Standard No. 119. He wanted confirmation that tires, for vehicles other than passenger cars, that were manufactured before that date are not subject to the standard's labeling requirements. I explained that his understanding was correct, citing 49 CFR @ 571.7.