ID: nht87-3.10

TYPE: INTERPRETATION-NHTSA

DATE: 10/07/87

FROM: ANDREW E. WOOLNER -- GENERAL MANAGER AUSTIN ROVER

TO: ERIKA JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: INTERPRETATION OF FMVSS NO. 101, CONTROLS AND DISPLAYS, SECTION S 5.3.5.

ATTACHMT: ATTACHED TO LETTER DATED 11/23/88, FROM ERIKA Z. JONES -- NHTSA, TO ANDREW E. WOLLNER -- AUSTIN ROVER, REDBOOK A33, STANDARD 101; BROCHURE FROM AUSTIN ROVER, UNDATED (RE CONTROLS AND DISPLAYS)

TEXT: Austin Rover Ltd. (ARG), the mamufacturer of the Sterling passenger car seeks an interpretation of FMVSS NO 101, Controls and Displays as of September, 1989.

1. All Sterling 825 vehicles have a fuel gauge and a speedodometer/odometer located in the instrument panel immediately in front of the driver as illustrated in Fig. 1.

2. The Sterling SL has in addition to the above-mentioned displays, a trip computer fitted in the center console (Fig. 2). This trip computer is able, among other functions to display supplemental information in relation to fuel consumption, (instan taneous and average), fuel used, average speed, trip distance and distance to arrival. The attachment shows the method of operation and the functions.

ARG interprets the illumination requirements of standard 101 as applicable to the trip computer display as being:

a. The illumination requirement not mandatory.

b. The illumination provided at the choice of the manufacturer is subject to the requirements of section S 5.3.5. and not section S 5.3.3.

The reasons for our interpretation are as follows:

a. The fuel section of the trip computer does not show the fuel level in the fuel tank.

b. The distance and speed functions cannot be considered as "speedodometer" because it does not indicate actual vehicle speed at any instant. Also there is no need to illuminate an odometer even if the distance function could be so considered.

Would you please confirm that ARG's interpretation for 1 and 2 above are correct. That is, that such displays contained in our trip computer which offer "supplemental information" to other gauges and displays that are clearly regulated by FMVSS NO. 101 will categorically fall under S 5.3.5 requirements for illumination.

Sincerely,

Enc.

ID: nht76-1.23

DATE: 12/06/76

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: The Japan Automobile Tire Manufacturers' Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 22, 1976, letter advising the National Highway Traffic Safety Administration that the tire standards of the Japan Automobile Tire Manufacturers' Association (JATMA) are being translated into English. You request that consideration be given to referencing JATMA standards in the Federal motor vehicle safety standards that regulate motor vehicle tire manufacture. I regret that we have not responded to your letter sooner.

Standard No. 109, New Pneumatic Tires, and Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, presently reference the Japanese Industrial Standards (JIS). Because the JATMA standards appear to be updated more often than the JIS standards, and because the JATMA standards will be issued in English, the agency intends to substitute a reference to JATMA standards in its regulations for the existing reference to JIS standards.

Thank you for providing us with the English translation of the motorcycle tire standards. We request that you provide us copies of all English translations of the standards for all vehicle types as often as they are updated.

Sincerely,

ATTACH.

THE JAPAN AUTOMOBILE TIRE MANUFACTURERS ASSOCIATION, INC.

J. B. Gregory -- National

J. B. Gregory -- National Highway Traffic Safety Administration, U.S. Department of Transportation

Dear Sir,

Re: The JATMA Standard.

The Japan Automobile Tire Manufacturers' Association has established the JATMA Standard as an association standard for tires in Japan.

To circulate it widely to the world we are now preparing its English version. Recently the JATMA Standard for motorcycle tires in English has been completed and we are sending you copies of it under the separate cover.

As to the JATMA Standards for other tires (for Truck & Bus, Light Truck and Passenger cars) translation into English is now under way taking this opportunity we would want you to consider to add the JATMA Standard to S 5.1(b) of FMVSS No. 119 and S 4.4(b) of FMVSS No. 109.

Yours faithfully, Keigo Ohgiya, Executive Director

ID: 86-4.3

TYPE: INTERPRETATION-NHTSA

DATE: 06/27/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Gary D. Clark

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Gary D. Clark John Deere Tractor Works P.O. Box 3500 Waterloo, Iowa 50704-3500

Dear Mr. Clark:

This responds to your letter dated February 27, 1986, concerning your projected sale of a strip chassis for the class A motor home industry. The identifying information submitted in your letter is being referred to the Office of Vehicle Safety Standards which keeps records of manufacturer identification in accordance with 49 CFR Part 566.

Under S114 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, each manufacturer is responsible for certifying that its motor vehicles and motor vehicle equipment comply with all applicable safety standards. This agency does not require that a manufacturer's documents and test data, which form the basis for this certification, be submitted unless requested by the agency.

I hope this information is helpful to you.

Sincerely,

Erika Z. Jones Chief Counsel

27 Feb. 1986

Office of Chief Counsel National Highway Traffic Safety Administration 400 7th S.W. Washington, D.C. 20590

Dear Sir,

Deere and Company will soon begin marketing a strip chassis suitable for the class A motor home industry. The chassis are designed for GVWRs of 16,000# and 18,000#. As an incomplete vehicle manufacture, we are aware of requirement testing such as FMVSS 105 and 124 and fuel emission testing by EPA and CARB.

I am uncertain as to our responsibility to present documentation to your office. Until word is received from you to do otherwise, we will document the FMVSS 105 and 124 tests internally. These documents and test data will be kept i our records department and will be made available upon written request from your office.

Sincerely,

Gary D. Clark O.E.M. Engineering (319/292-7162)

ID: 77-1.27

TYPE: INTERPRETATION-NHTSA

DATE: 02/22/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: BMW of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your January 17, 1977, letter concerning the requirements of Safety Standard No. 111, Rearview Mirrors, for passenger cars. You requested confirmation of your interpretation that the standard specifies no requirements for outside rearview mirrors on the passenger's side of the vehicle when the inside rearview mirror meets the field of view performance requirements of paragraph S5.1.1 of the standard.

Your interpretation is correct. If the inside rearview mirror of a passenger car meets the specified performance requirements, the vehicle is not required to be equipped with an outside rearview mirror on the passenger's side. However, a manufacturer is free to equip its vehicles with outside right-hand mirrors, either plane or convex, if he choses.

You should note that each passenger car whose inside rearview mirror does not meet the field of view performance requirements of paragraph S5.1.1 must have an outside rearview mirror of unit magnification installed on the passenger's side of the vehicle.

SINCERELY,

BMW OF NORTH AMERICA, INC.

January 17, 1977

Frank A. Berndt, Esq. Acting Chief Counsel U. S. Department of Transportation National Highway Traffic Safety Administration

Federal Motor Vehicle Safety Standard, FMVSS 111, Paragraph 5.3, states that "each passenger car whose inside rear view mirror does not meet the field of view requirements of S 5.1.1, shall have an outside rear view mirror of unit magnification installed on the passenger side . . . " (emphasis added).

In Paragraph S 5.3, the emphasis is placed on the inside rear view mirror, which does not meet the field of view requirements of S 5.1.1.

It is BMW's understanding that the outside rear view mirror on the passenger side, whether of unit or non-unit magnification, does not fall within the jurisdiction of FMVSS 111, when the vehicle's inside rear view mirror meets the field of view requirements of S 5.1.1.

Your confirmation in writing of this understanding would be appreciated.

Karl-Heinz Ziwica Manager, Safety Engineering

ID: 77-1.9

TYPE: INTERPRETATION-NHTSA

DATE: 01/18/77

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Oaklahoma Department of Public Safety

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your December 16, 1976, letter concerning tires marked "Reno Farm Tire--Farm Use Only" that are appearing on some passenger cars in Oklahoma. I understand that the DOT symbol is also marked on the sidewalls of these tires, as a certification of conformity to Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires -- Passenger Cars.

Paragraph S6 of the standard precludes the manufacture of farm tires in passenger car tire sizes unless those tires conform to and are certified as conforming to all aspects of the standard. There is not, however, any provision in Standard No. 109 that prohibits the additional marking that you have described on a tire that is manufactured and sold for passenger car use. No safety issue appears to be presented by this situation.

You have also asked who is responsible for compliance with the Tire Identification and Recordkeeping regulation (49 CFR Part 574, copy enclosed). That regulation creates various obligations for tire manufacturers, motor vehicle manufacturers, motor vehicle dealers, and others. Where a tire manufacturer sells tires to a trailer manufacturer, the presence of the "Farm Use Only" marking has no effect on those obligations.

SINCERELY,

Oklahoma Department of Public Safety

December 16, 1976

Frank Berndt Acting Chief Counsel NHTSA

In the State of Oklahoma, there is now appearing on some passenger cars tires which were manufactured by UniRoyal, Inc. These tires are labeled "Reno Farm Tire -- Farm Use Only". Apparently, these tires meet FMVSS 109, as they do bear DOT on the side wall. While we are fully cognizant that NHTSA has allowed the labeling "Reno Farm Tire", we would like to know why a tire manufacturer has the prerogative of labeling a tire with any type labeling such as Farm Use Only, Farm Implement, etc., even though the tire presumably meets FMVSS 109.

Additionally, assuming the tire manufacturer sold this type of tire marked "Farm Use Only" to a manufacturer of trailers, who becomes responsible for complying with Part 570 of FMVSS Tire Records and Identification?

Lt. C. R. Townsend, Director Motor Vehicle Inspection Division

ID: nht76-5.8

DATE: 12/03/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 3, 1976, in which you ask whether the label "Emergency Door," when placed on the glass near the top of a school bus emergency exit, complies with the requirements of Standard No. 217, Bus Window Retention and Release.

The positioning of this label will be regulated by S5.5.3 of Standard No. 217 in the case of school buses manufactured on or after April 1, 1977. That section, as it pertains to the location of the designation "Emergency Door," states in part that the designation shall be ". . .located at the top of or directly above the emergency exit. . ." The markings you describe, located at the top of the glass of the emergency door, would appear to be in compliance with the location requirements of S5.5.3 of Standard No. 217 (effective April 1, 1977).

SINCERELY,

BLUE BIRD BODY COMPANY

November 3, 1976

Frank Berndt Acting Chief Counsel National Highway Traffic Safety Administration

SUBJECT: EMERGENCY DOOR MARKING - FMVSS 217

We are considering a change in early 1977 to a double faced decal made of 3 mil Mylar with a pressure sensitive adhesive which would be applied to the upper inside of the emergency door glass as shown in the enclosed photograph reproductions. We plan to use the designation "EMERGENCY DOOR" two inches in height with black letters on a metallic silver background. We would like to make a location change at the same time.

This type application would be visible from the inside and outside and, of course, would be protected from the weather because of inside application. The viewing angle for a person standing on the ground would be much improved since the decal would be 8" lower than if applied on the header above the emergency door.

Since we need to make a decision as soon as possible, we would appreciate a ruling on whether the above proposal meets FMVSS 217 section S5.5.3 at your earliest convenience.

Thanks

W. G. Milby Manager, Engineering Services Interior

Exterior

(Graphic omitted)

ID: nht78-1.34

DATE: 01/25/78

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

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your October 24, 1977, letter asking whether the framework of a roof hatch must comply with the requirements of Standard No. 221, School Bus Body Joint Strength.

The terms which establish the applicability of the requirements of the standard to a particular section of school bus body are defined in S4 of the standard. Read together they establish the following test. If the edge of a surface component (made of homogeneous material) that encloses occupant space in a bus comes into contact or close proximity with any other body component, the requirements of S5 apply, unless the area in question is designed for ventilation or another functional purpose, or is a door, window, or maintenance access panel. Applying this test to the frame of a roof hatch, it appears that this joint need not comply with the requirements. This conclusion is reached because the National Highway Traffic Safety Administration concludes that a roof hatch is equivalent to a door or window for the purposes of the application of the requirements. The joint connecting the frame of a door, window, or roof hatch to a bus body falls within the exception to the applicability of Standard No. 221.

SINCERELY,

BLUE BIRD BODY COMPANY

October 24, 1977

Joseph J. Levin, Jr. Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Levin:

The purpose of this letter is to get an interpretation regarding the applicability of FMVSS 221 relative to roof hatch emergency exit components.

The attached photos show a roof hatch viewed from inside the bus and from the roof of the bus. We would like confirmation of our interpretation that the metal framework of the roof hatch opening, shown in the attached photos, enclosing the edges of the roof opening are for a "functional purpose" as used in FMVSS 221, paragraph S4 and are, therefore, not subject to the requirements of that standard.

We will appreciate your early reply.

Thank you.

W. G. Milby Manager, Engineering Services

CC: JIM MOORMAN; JIM SWIFT; GARY MOYSES; TOM TURNER

(Graphics omitted)

ID: nht73-1.43

DATE: 09/26/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Sekurit-Glas Union GmbH

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 19, 1973, requesting information regarding the marking requirements in FMVSS No. 205 for automobile safety glass.

With respect to your request for a copy of the marking requirements, they may be found in paragraph S6. of the enclosed copy of the standard, and in section 6 of American National Standard Z26.1 - 1966. The latter standard can be obtained by writing to the American National Standards Institute, 1430 Broadway, New York, New York 10018.

Information on various State requirements should be obtained from Mr. Armond Cardarelli, American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, D.C. 20036.

You ask whether marking requirements can be met using a specific format you include in your letter, and refer to "Approval" and "Supplemental" markings. It is not clear to us to what you refer, as we prescribe neither "approval" nor "supplemental" markings in the standard, and perhaps we will be better able to answer any questions you may have after you have had an opportunity to review the requirements.

Yours truly,

Enclosure

July 19, 1973

Administrator -- National Highway Traffic Safety Administration

Ref.: Markings of Safety Glass

Dear Sirs,

According to the FMVSS 205 all the safety glasses built in cars have to be marked. Beside the prescriptions of the Department of Transportation there are other special prescriptions for each state (for instance California). Please could you send us an exact list of all these special specifications.

Could you send us as well the concerned regulation or a list from which we can take the form and the contains of the markings.

Is it sufficient to write as Approval Markings

DOT . . . /M . . . /AS

and all other denominations, as for instance laminated, Kinonglas-Kristall-HI-BFG, plate in the Supplemental Markings?

We would be very grateful if you could answer our letter as soon as possible.

Yours sincerely,

SEKURIT-Glas Union GmbH

i.V. i.A.

ID: nht95-2.52

TYPE: INTERPRETATION-NHTSA

DATE: April 25, 1995

FROM: A. P. Corrado -- Director, Market Development Gen Corp Aerojet, Electronic Systems Division

TO: John Womack -- Acting Chief Council, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 6/14/95 LETTER FROM JOHN WOMACK TO A. P. CORRADO (A43; STD. 208)

TEXT: Dear Mr. Womack,

The purpose of this letter is to request clarification from NHTSA concerning the application of FMVSS 208, 49 CFR @ 571.208 (Occupant Crash Protection), with respect to an "Out-Of-Position) front outboard passenger.

As you know, S4.1.5.3 of FMVSS 208 requires that all passenger cars manufactured on or after September 1, 1997, comply with the automatic front/angular protection system of S4.1.5.1(a)(1) "by means of an inflatable restraint system at the driver's and right front passenger's position". The term "inflatable restraint system" is defined in S4.1.5.1(b) as "an air bag that is activated in a crash".

Some in the industry have interpreted this standard -- particularly the word "activated" -- as mandating a system that automatically deploys a passenger-side air bag under all circumstances. However, we do not believe the term "activate" in the defin ition of "inflatable restraint system" is intended to mean "deploy in all cases". Specifically, given the purpose and intent of the Standard, we do not believe that the Administration intended to require deployment of an airbag where the deployment itse lf is likely to cause serious injury or death.

This distinction is critical given the development of sophisticated sensing devices that offer the potential of discriminating between an In-Position passenger and an Out-Of-Position passenger. Such systems, being developed initially to detect the pr esence of rear facing infant seats, offer the prospect of reducing the likelihood of serious injury or death to Out-Of-Position passengers by purposely inhibiting or restricting full deployment of the passenger side air bag.

Because we are confident that NHTSA does not intend to preclude the development or application of such sophisticated sensor systems, we would appreciate your confirmation that FMVSS 208 does not preclude the use of inflatable restraint systems that by design inhibit deployment of a passenger air bag in those identified cases where the likelihood and severity of passenger injury would be greater with air bag deployment than without.

ID: nht88-2.3

TYPE: INTERPRETATION-NHTSA

DATE: 04/20/88

FROM: GEORGE ZIOLO -- DOT PAPERWORK PROCESSOR

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: HEADLAMP COMBINATIONS - REQUEST FOR CLARIFICATION, FMVSS 108

ATTACHMT: ATTACHED TO LETTER DATED 09/12/88 TO GEORGE ZIOLO FROM ERIKA Z JONES; REDBOOK A32, STANDARD 108;

TEXT: Dear Ms. Jones:

I assist graymarket automobile importers in conforming their vehicles.

Some foreign models come equipped with four headlamps two of which are 7" diameter and two 5 3/4" diameter.

My clients modify them by installing two Type 2D1 (7" dia) high & low beam units outboards, and two Type 1C1 (5 3/4" dia) high beam units inboards.

OVSC (NEF-32) rejects such installations because they are "nonconforming" "headlighting systems". It is my opinion that such rejection is without basis.

As I understand it, the FMVSS are "minimum standards". S4.1.1 confirms this by requiring that "...each vehicle...be equipped with at least the number of lamps...specified in Tables I and III,...."

My clients' installation of two Type 2D1 lamps satisfies the minimum requirement specified in Table III.

My clients' installation of two Type IC1 lamps in addition to the two Type 2D1 lamps is not counter to a "headlighting system" as I can find in the standard. In addition, S4.4 appears to permit such combination.

While it may have been necessary to ensure symmetry in headlighting systems combinations in motorcycles by way of S4.1.1.34, where Table III calls for only one lamp, such clarification relative to vehicles other than motorcycles is obviously not needed s ince symmetry in such will be natural.

I therefore kindly request that you determine whether or not FMVSS 108 allows lamp combinations as outlined above and advise me at your earliest convenience. The cited lamp combinations are desired by my clients for reasons of appearance. Also, modificat ion of such vehicles to delete the 2D1 (7") lamp in lieu of a 2C1 (5 3/4") lamp is costly, including replacement of the entire front grille.

Sincerely,

FEDERAL REGISTER VOL 52, NO 208 10/28/87 NHTSA 49 CFR PART 571 (DOCKERT 87-15 NOTICE 1) FEDERAL MOTOR VEHICLE SAFETY STANDARDS, VEHICLE CLASSIFICATION (TEXT OMITTED)