ID: aiam2621

Dear Mr. Gromer: This responds to your May 6, 1977, letter asking whether your tir information label complies with the requirements of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars, and Part 567, *Certification*. Further, you request that the National Highway Traffic Safety Administration (NHTSA) expedite treatment of Docket No. 73-31, Notice 1, which, if implemented would simplify the certification and information labels.; Concerning Docket 73- 31, the NHTSA published on June 20, 1977, notice (42 FR 31161) implementing Notice 1 which proposed the use of the designation 'all axles' rather than listing each axle individually on the certification label. The implementation of this regulation should resolve many of your problems.; Regarding the sample information label you submitted with your letter the NHTSA does not give advance approvals of compliance with Federal safety regulations or standards. We will, however, give an informal opinion of whether your label appears to comply with the requirements. The label you submitted does not appear to comply with the requirements of Part 567 or Standard No. 120. I have enclosed copies of both of these regulations for your information.; Your certification label should use the designation 'all axles' no 'each axle.' The tire and rim information should follow that designation stated in the form presented in the examples in Standard No. 120 and Part 567.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam2949

Dear Mr. Conner: We understand that a question has arisen concerning the testing o 'P-type' tires under the traction grading procedures of the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104(f)(2)). Under the terms of the regulation, candidate tires are to be inflated to 24 psi prior to the traction test (49 CFR 575.104(f)(2)(i)(B) and (D), and (f)(2)(viii)), and are to be loaded to 85 percent of the load specified in Appendix A of FMVSS No. 109 (49 CFR 571.109), for the tires' size designation, at a cold inflation pressure of 24 psi (49 CFR 575.104(f)(2)(viii)). However, Appendix A lists cold inflation pressures for 'P-type' tires in kilopascals, with no stated inflation pressure corresponding precisely to 24 psi.; NHTSA chose 24 psi as the stated inflation pressure for UTQG tractio testing since it represents the recommended tire inflation pressure for most passenger cars. In the situation where no cold inflation pressure exactly equivalent to the specified pressure of 24 psi is stated in Appendix A of FMVSS No. 109 for a tire size designation, the tires to be tested are inflated to the pressure, listed for the tire size designation in Appendix A, which is nearest to 24 psi, *i.e.*, 180 kPa for tires with inflation pressures measured in kilopascals. The tires are then loaded to 85 percent of the load specified in Appendix A for the inflation pressure thus determined. The agency plans to issue an interpretive amendment to the regulation clarifying this point.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam0489

Dear Mr. Eckstein: This is in reply to your letter of August 27, 1971, which was forwarde to this office October 20, 1971, by the Federal Trade Commission, regarding Government specifications for retreaded tires. You refer to problems you believe result from 'out of roundness,' specifically, abnormal wear and blowouts at normal boulevard and highway speeds. You wish to determine whether this problem results from 'too lenient' Government requirements, or whether 'manufacturers are negligent.'; Out-of-roundness can occur in a retreaded tire for numerous reasons and its presence does not necessarily indicate negligence on the part of the manufacturer. Moreover, while an out-of-round tire may affect vehicle handling it generally does not blow out at normal boulevard or even highway speeds, as result of the out-of-round condition. Thus, a blow out in an out-of-round tire could have resulted from other factors. Many tire dealers, in addition, have machines that can eliminate out-of-roundness by cutting of excess tread.; With reference to Federal regulations of retreaded tires, the firs such regulation will become effective January 1, 1972. This regulation, Motor Vehicle Safety Standard No. 117, 'Retreaded Pneumatic Tires,' specifies size and performance requirements for retreaded tires for use on passenger cars. There requirements are similar to those that have been applicable to new passenger car tires since January 1, 1968. None of these requirements specifically concern 'out-of-roundness.' We do not have evidence that this characteristic, by itself, is a safety problem.; Sincerely, Richard B. Dyson, Assistant Chief Counsel

ID: 77-4.43

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your telephone conversation of November 9, 1977, with Roger Tilton of my staff concerning the applicability of the tire performance standard (Standard No. 109. New Pneumatic Tires -- Passenger Cars) to temporary-use spare tires.

The National Highway Traffic Safety Administration has permitted the manufacture of temporary-use spare tires because they are smaller than regular spare tires and thus when carried in the automobile reduce its overall weight. A reduction in motor vehicle weight can result in increased fuel efficiency of the vehicle. These tires must comply with all of the safety requirements applicable to passenger car tires.

ID: nht68-3.1

DATE: 05/17/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Berliner Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 10, 1968, addressed to Mr. William H. Risteen, concerning the requirement for headlamp dimmer switches as specified in Federal Motor Vehicle Safety Standard No. 108.

Paragraph S3.4.1 of Standard No. 108 requires that a means for switching between lower and upper headlamp beams shall be provided in accordance with SAE Recommended Practice J564a or J565a. This general requirement is applicable to all vehicles, including motocycles, that are required, by Standard No. 106, to be equipped with lower and upper bean headlamps, even though SAE Recommended Practice J564a is addressed only to passenger cars.

Thank you for writing.

ID: nht71-5.1

DATE: 11/17/71

FROM: AUTHOR UNAVAILABLE; J. W. Carson for E. T. Driver; NHTSA

TO: Ward School Bus Mfg., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of October 28, 1971, to Mr. Stan Haranski, Truck Body and Equipment Association, Inc., concerning switching arrangements for school bus red signal lamps, has been forwarded to this Office for reply.

Paragraph S4.1.4(a) of Federal Motor Vehicle Safety Standard No. 108 requires that the four red signal lamps be controlled by a manually actuated switch. A two-way switch, whereby all four lamps are activated when the switch is in one position, and the two rear lamps only are activated when the switch is in the opposite position, would not be in violation of this requirement of Standard No. 108.

ID: nht73-4.47

DATE: 08/13/73

FROM: AUTHOR UNAVILABLE; Richard B. Dyson; NHTSA

TO: SCARTI

TITLE: FMVSR INTERPRETATION

TEXT: 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 or 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-stage 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.

ID: nht91-1.8

DATE: January 3, 1991

FROM: S.V. Kaaria

TO: NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 2-11-91 from Paul Jackson Rice to S.V. Kaaria (A37; Std. 108); Also attached to letter dated 1-16-91 from Marvin A. Leach, to S.V. Kaaria (OCC 5648)

TEXT:

I am the designer of the taillights placed near the rear window of passenger cars. In attempting to negotiate a settlement with auto manufacturers, they all point to the law which requires these new placements of elevated brake lights (Standard 108.1.1.27). They claim since you made the requirements you should negotiate with me for 1% of replacement cost of these taillights.

Would you please clarify your position in this matter, and notify me. Thank you.

ID: nht92-7.39

DATE: April 16, 1992

FROM: Neil Friedkin -- Attorney at Law

TO: Marvin Shaw -- NHTSA, U.S. DOT

TITLE: None

ATTACHMT: Attached to letter dated 6/15/92 from Paul J. Rice to Neil Friedkin (A39; Std. 108; Std. 208; Std. 216); Also attached to letter dated 4/13/92 from Paul Jackson Rice to Neil Friedkin

TEXT:

Enclosed is a copy of the letter provided to me by Paul Jackson Rice on April 13, 1992.

I would appreciate your providing me with the applicable 1986 standard for convertible passenger cars, if possible.

Once again, thank you for your courtesy and cooperation.

Attachment

NHTSA interpretation letter dated 4/13/92 from Paul J. Rice to Neil Friedkin. (Text omitted here.)

ID: nht75-3.13

DATE: 06/25/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Emmons Brothers

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 1, 1975, concerning Federal Motor Vehicle Safety Standard No. 302, Flammability, and in amplification of your telephone conversation with Mr. Schwartz of my office.

As Mr. Schwartz advised you, Standard No. 302 applies to passenger cars, multipurpose passenger vehicles, trucks, and buses. Thus, the standard would apply to mattresses used in trucks. Further, it has been proposed to extend Standard No. 302 to campers and trailers other than those sold exclusively for the transportation of cargo (copy enclosed). Consequently, as you requested, I have enclosed a copy of Motor Vehicle Safety Standard No. 302, a recent amendment to that standard, and a proposed amendment which may also be of interest to you.