ID: nht75-2.3

DATE: 10/28/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Swan and Woodford

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 27, 1975, request for standards applicable to glass-belted tires with the size designation H78-15 which were standard equipment on a 1973 Ford automobile. Such tires are subject to Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires -- Passenger Cars, a copy of which is enclosed.

YOURS TRULY,

SWAN & WOODFORD

August 27, 1975

National Highway Traffic Safety Administration

Re: Standards for Firestone Brand Tires

This letter is to inquire of any available information regarding standards for the below listed equipment.

Size H-78-15 glass-belted Firestone brand tires; standard equipment on 1973 Ford automobile.

I am particularly interested in a standard as it applies to "blow outs" at 65 miles per hour on an improved road with tires having been driven 14,000 miles. ("Blow-out" occurred in inner sidewall

Thanking you in advance for your cooperation.

C. BRAD WOODFORD

ID: nht71-1.19

DATE: 04/01/71 EST

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Leasor & Leasor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 26, 1971, concerning regulations pertaining to automobile windshields.

Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses, a copy of which is enclosed, specifies the requirements of automotive glazing materials manufactured on or after January 1, 1963. ANSI Standard Z26.1-1966, incorporated by reference, can be obtained from the American National Standards Institute, 1430 Broadway, New York, New York 10013, at a cost of $ 4.00.

The marking of the windshield that you depict in your letter of March 26 is not sufficient to identify its manufacturer. However, based on the "63" in the marking and the fact that the windshield shape fit the 1969 Plymouth, it can be hypothesized that the material in question is a laminated windshield of the improved design that has been used in 1966 and later models of U.S. automobiles.

There is not a requirement that windshields of this type completely shatter leaving no jagged fragments upon collison.

Sincerely,

ID: nht89-1.25

TYPE: INTERPRETATION-NHTSA

DATE: 02/23/89

FROM: HARRY REID -- SENATE

TO: DIRECTOR OFFICE OF CONGRESSIONAL AFFAIRS DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 05/25/89 FROM STEPHEN P. WOOD -- NHTSA TO HARRY REID -- SENATE; REDBOOK A33 [4]; VSA 108 [A] [2] [A]; STANDARD 208; LETTER DATED 03/08/89 FROM PATRICIA KLINGER WATHEN -- DOT TO HARRY REID -- SENATE; LETTER DATED 02/03/8 9 FROM STEVEN P. ELLIOTT TO HARRY REID -- SENATE RE AUTHORIZATION TO DISCONNECT AUTOMOBILE AIR BAGS; REPORT FROM DAVID J. ROMEO AND JOHN B. MORRIS, DRIVER AIR BAG POLICE FLEET DEMONSTRATION PROGRAM A 24 MONTH PROGRESS REPORT AT EXPERIMENTAL SAFETY VEHICL E CONFERENCE OXFORD, ENGLAND, JULY 1-5, 1985; RESEARCH NOTES ON CRASH EXPERIENCE OF GOVERNMENT SPONSORED AIR BAG VEHICLES THROUGH 03/31/89, FROM VERNON ROBERTS

TEXT: Dear Director:

The City of Sparks Police Department has a problem with the air bags that are equipped in their patrol cars.

The Police would like the United States Department of Transportation to authorize them to disconnect the bags. I would appreciate it if you could look into this matter. A copy of a letter from the Sparks City Attorney is enclosed for your review.

Thank you for your kind assistance.

Sincerely,

ID: nht75-2.23

DATE: 12/23/75

FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA

TO: FILE

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: VEHICLE REQUIREMENTS AND STANDARD NO. 119

On December 10, 1975, I received a telephone call from Mr. Dan Warner of Transportation Manufacturing Corporation in New Mexico (505 347-2011), concerning the scope of Standard No. 119.

Mr. Warner asked whether the standard required vehicles to be equipped with tires conforming to it. I explained that Standard 119 applies only to tires, while vehicles would be the subject of Standard No. 120. I declined to predict the issue date or effective dates of Standard 120, but assured him that the scheme of effective dates would take into account the realities of production and inventories.

Meaning of effective date of Standard No. 119

Attorney Advisor

Interps. file

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.

Mark Schwimmer

ID: nht70-1.28

DATE: 02/11/70

FROM: CLUE. D. FERGUSON -- OFFICE OF VEHICLE STRUCTURES, MOTOR VEH. PROGRAMS, NHTSA; SIGNATURE BY F.C. KOCH

TO: Mr. Eddie E. Barnes

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your recent letter concerning the number of safety belts in your 1969 Chevrolet nine-passenger station wagon.

The present Federal Motor Vehicle Safety Standard No. 208 requires that seat belt assemblies be installed in each forward-facing designated seating position in passenger cars. The standard does not apply to side-facing or rear-facing seats. The manufacturer is not required to install safety belts for such seats: however, in the interest of safety, most manufacturers usually install lap belts for the seating positions most commonly used.

A Notice of Proposed Rule Making was issued on September 15, 1969, which would extend the applicability of Standard No. 208 to apply also to side-facing and rear-facing seats. The comments of those who responded to the Notice have been analysed and the final rule is now being developed.

I am enclosing a copy of our present Standard No. 208 and a copy of the Notice of Proposed Rule Making for your reference.

Thank you for your interest in motor vehicle safety.

ID: nht73-3.33

DATE: 02/22/73

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Morino and Moore

TITLE: FMVSS INTERPRETATION

TEXT: 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 meet 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, automobile 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 the 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 hazard warning signals.

ID: aiam2773

Dear Ms. Schulte: This responds to your January 13, 1978, letter asking several question about a manufacturer's certification responsibilities under Part 568, *Vehicles Manufactured in Two or More Stages*.; In your letter, you enclosed a copy of a TBEA form and ask whether i complies with Federal regulations and where you can obtain copies. This form is supplied by TBEA to assist manufacturers in their own recordkeeping. It is not required by any Federal regulation. You should consult TBEA for copies of the form.; Secondly, you ask whether Standard No. 120, *Tire Selection and Rim for Motor Vehicles Other Than Passenger Cars*, has altered the responsibilities of the intermediate manufacturer. An intermediate manufacturer's responsibility for compliance with Standard No. 120 is the same as his responsibility for compliance with any other Federal motor vehicle safety standard.; In your third question, you ask whether the addition of a 'tag' o 'pusher' axle to a used chassis requires compliance with Standard No. 121, *Air Brake Systems*. The addition of one axle to a used chassis does not constitute the manufacture of a new chassis. Therefore, if the chassis were manufactured prior to the time that Standard No. 121 became effective, modification of the chassis would not need to comply with the standard. If the chassis already complies with the standard, you would be prohibited from rendering inoperative the compliance of the vehicle with the standard.; You ask what the penalties are for violation of the Federa certification requirements. Under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 *et seq*.) violations of the Act or regulations are punishable by $1,000 per violation up to a maximum of $800,000 for a related series of violations.; In your last question you ask whether the incomplete vehicle documen should remain with the intermediate or final stage manufacturer on completion of a vehicle. The final stage manufacturer should retain the incomplete vehicle document.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam2879

Dear Mr. Utans: This is in reply to your letter of September 12, 1978, with respect t Subaru's intention to offer 'a retracting center auxiliary lamp' on one of its models. You have asked us to comment on the lamp's nomenclature, switching, and compliance problems.; The lamp in question is not an item of lighting equipment required b Federal Motor Vehicle Safety Standard No. 108 and may be added as standard equipment provided it does not impair the effectiveness of equipment that the standard does require. Whether this device would cause impairment we cannot say since you have told us nothing of its candlepower output or its color. If it is operable by a separate on/off switch it could be viewed as impairing the effectiveness of the headlights by causing the operator to use it and rely on it at a time when the headlamps should be in use. We have no opinion on what you should call the lamp.; Even if permissible and not prohibited under Federal lightin requirements we believe that you should be aware of possible problems at the State level. An auxiliary driving light similar to the one you describe (though positioned closer to the right headlamps) was offered as optional equipment on 1960 Dodge cars, named the 'Super Lite', and intended to be used in conjunction with low beam headlights to increase the strength of the headlamp system without producing glare effects associated with high beams. The States of New Hampshire, New York, and Vermont prohibited the lamp primarily because its bluish color was judged close to that of the color reserved for use on emergency vehicles (see *Chrysler Corp. v. Rhodes*, 294 F. Supp. 665 (1968) and *Chrysler Corp. v. Tofany*, 419 F.2d 499 (1969)). We therefore suggest that Subaru review its plans with State officials.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam2264

Dear Mr. Adams: This is in response to your letter of March 17, 1976, requestin information concerning steps which you, as a manufacturer of wheel equipment which will be offered for importation into the United States, must take in order to comply with all applicable National Highway Traffic Safety Administration regulations.; You should be aware of 49 CFR Part 566, *Manufacturer Identification* and 49 CFR Part 573, *Defect Reports*. In addition, Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles Other Than Passenger Cars*, may be of interest to you. Copies of these rules and an information sheet entitled 'Where to Obtain Federal Motor Vehicle Safety Standards and Regulations' are enclosed for your convenience.; Section 110(e) of the National Traffic and Motor Vehicle Safety Act (1 U.S.C. S 1399(e)) requires every manufacturer who offers a motor vehicle or item of motor vehicle equipment for importation into the United States as his agent, upon whom service of all processes, orders, notices, decisions, and requirements may be made.; The procedural regulations (49 CFR 551.45) for designation of agen pursuant to the Act require that it include:; >>>(1) A certification by its maker that the designation is binding o Dunlop Limited under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made,; (2) The full legal name, principal place of business and mailin address of Dunlop Limited,; (3) Trade names or other designations of origin of the products o Dunlop Limited that do not bear its legal name,; (4) A provision that the designation of agent remain in effect unti withdrawn or replaced by Dunlop Limited,; (5) A declaration of acceptance duly signed by the agent appointed which may be an individual, a firm, or a U.S. corporation, and; (6) The full legal name and address of the designated agent.<<< A copy of the procedural regulation for designation of agent i enclosed for your convenience.; Sincerely, John Womack, Assistant Chief Counsel

ID: aiam3052

Dear Mr. Hiribarren: This responds to your May 21, 1979, letter asking whether the tw vehicles that you manufacture, the Comtesse and the Super-Comtesse, would be considered as mopeds for the purpose of applying Federal motor vehicle safety standards.; The National Highway Traffic Safety Administration (NHTSA) define motor-driven cycle (moped) as 'a motorcycle with a motor that produces 5-brake horsepower or less.' A motorcycle is defined as 'a motor vehicle with motive power having a seat or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground.' Further, the application of some standards to mopeds depends upon their having a maximum speed obtainable in 1 mile of 30 mph or less.; The Super-Comtesse that you manufacture, since it has 4 wheels, woul not qualify as a motorcycle or as a moped. Since this vehicle has many of the aspects of a passenger car, it would be required to comply with the passenger car safety standards. The Comtesse, since it operates on three wheels, would be considered a motorcycle. If the Comtesse meets the other definitional requirements applicable to mopeds, it would be required to comply with the standards applicable to motorcycles or motor-driven cycles.; All Federal motor vehicle safety standards are located in Volume 49 o the Code of Federal Regulations in Part 571. Many of the standards are applicable to passenger cars. Only a few standards apply to motorcycles or motor-driven cycles. I am enclosing a package of information pertaining to the applicability of safety standards to mopeds.; The NHTSA has studied three-wheeled vehicles in the past and has ha serious reservations about the safety of these vehicles. I am enclosing a copy of an agency notice issued on this subject. We hope that your vehicle does not have similar safety problems.; Sincerely, Frank Berndt, Chief Counsel