ID: nht76-3.1

DATE: 11/08/76

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: E. Edelman & Co.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 19, 1976, to Dr. James D. Gregory, requesting information on aftermarket gas caps as they relate to compliance with Federal Motor Vehicle Safety Standard (FMVSS), No. 301. Your inquiry has been forwarded to this office for reply. Apparently your letter of May 26, 1976, was either lost or misdirected, as we can find no record of it in our files, and we sincerely apologize for this delay in responding to your inquiry.

The National Highway Traffic Safety Administration does not regulate vehicle fuel tank caps as such; however, FMVSS No. 301, Fuel System Integrity, specifies performance requirements to assure the integrity of the entire vehicle fuel system (which includes the fuel tank cap) in various crash modes.

Thus, if installation of your replacement cap is accomplished prior to the first purchase of the vehicle for purposes other than resale causing the vehicle's fuel system not to be in compliance with the applicable safety standard, the person installing the cap or offering the vehicle for sale would be in violation of S103(2)(1) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-503). That would make the installer or seller subject to civil penalties of up to $ 1,000 for each violation.

Recent amendments to the Traffic Safety Act (Pub. L. 93-492) prohibit any manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable motor vehicle safety standard (S108(a)(2) (A)). Thus, it is illegal for any of the above named persons to install a fuel tank cap that he knows will cause the vehicle to be in non-compliance with the fuel system integrity standard. Federal Law does not, however, prohibit the owner of a vehicle from purchasing and installing a fuel tank cap of his choice on his own vehicle, even though he may compromise the Fuel System Integrity Standard.

We are interested in any information regarding safety problems associated with replacement gas caps as a basis for further action. If you could provide any such information, we would be most grateful.

Thank you for sharing your thoughts with us.

SINCERELY,

May 26, 1976

James B. Gregory, Administrator U.S. Department of Transportation National Highway Traffic Safety Administration I am writing to you for some clarification on Motor Vehicle Safety Standard No. 301-75 (part 571; S 301-75. This standard spells out original equipment manufacture's responsibilities for designing automobiles against fuel spillage after crash tests. This implicitely means that manufactures of gas caps for OEM customers are required to provide gas caps which conform to the roll-over requirements.

My question is, do the Federal Motor Vehicle Standards in any way impose requirements on parts manufacturers who make gas caps for after-market retail outlets to market caps which meet the OEM roll-over specifications?

For any company to volentarily follow the practice of meeting the roll-over specifications when others do not, self-imposes a severe marketing penalty because of the additional large number of caps which are needed for complete market coverage. This poses warehouse customer inventory stocking problems. Since some companies are using one cap for the OEM which meets roll-over requirements, and a different cap for the after-market at a decided competative advantage, it is imperative to us that this question of applicability of the Federal Motor Vehicle Safety Standard be answered.

I await your early reply.

Ronald W. Cooke Engineering Manager

ID: 8559a

Mr. Lanny Kness
Coach Design Engineer
Chance Coach, Inc.
4219 Irving, Box 12328
Wichita, KS 67277-2328

Dear Mr. Kness:

This responds to your request for an interpretation of two sections of Federal Motor Vehicle Safety Standard (FMVSS) No. 101, Controls and displays (49 CFR 571.101). You ask whether S5.1 requires a turn signal control to be hand operated. As explained below, the answer is no. You also ask whether S5.3's illumination requirements can be met by two different means: reflected light, and an overhead light. The answer is no.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.

Your first question asks whether S5.1 requires a turn signal control to be hand operated. S5.1 specifies location requirements for each control listed in S5.1 "that is furnished." S5.1 does not require manufacturers to furnish any control, such as a hand-operated turn signal control, or prohibit manufacturers from providing an unlisted control, such as a foot-operated turn signal control. While FMVSS No. 108, Lamps, reflective devices, and associated equipment (49 CFR 571.108) specifies the "turn signal operating unit" as required equipment, it does not specify that the unit be hand operated. (See S5.1.1 and Table I of FMVSS No. 108.)

Your second question asks whether the following proposed method of illuminating the windshield wiper/washer control complies with S5.3.3 of Standard No. 101. You state that the wiper/washer control is located on the dashboard and at night, the "control knob's identification" can be barely seen from indirect lighting coming from other controls and displays. The wiper washer control would become "very discernible" by turning on an "overhead driver's controlled light."

For the following reasons, the above described method of illuminating the wiper/washer control would not comply with Standard No. 101. S5.3.3(a) requires means to be provided to make controls visible to the driver under all driving conditions. S5.3.3(b) states that "the means" (emphasis added) for providing the required visibility:

(1) Shall be adjustable, except as provided in S5.3.3(d), to provide at least two levels of brightness, one of which is barely discernible to a driver who has adapted to dark ambient roadway conditions.

S5.3.3(b) therefore requires that a single control (i.e., "the means") be adjustable to provide at least two levels of brightness. Under your proposal, however, two different means must be used to provide two levels of brightness. The overhead driver's light would provide one level of brightness, that makes the control "very discernible." The other level of brightness (one barely discernible to the driver) is provided from reflected light given off by other controls and displays located on the dashboard. Since no single "means" that you propose for illumination would be adjustable to provide at least two levels of brightness, your proposal would not comply with S5.3.3 of Standard No. 101.

I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:101#108 d:7/7/93

ID: nht94-3.87

TYPE: INTERPRETATION-NHTSA

DATE: August 5, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA; Stamped signature by Kenneth N. Weinstein

TO: William G. Franz -- Vice President Fabrication, Wells Aluminum Corporation

TITLE: NONE

ATTACHMT: Attached to letter dated 4/4/94 from William G. Franz to Walter Myers (OCC 9857)

TEXT: Dear Mr. Franz:

This responds to your letter addressed to Mr. Walter Myers of this office requesting an interpretation of window opening size as provided in paragraph S5.1.2, Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus Emergency Exits and Window Retention and Release. I apologize for the delay in responding.

You explained that Wells Aluminum Corporation manufactures pushout windows for the school bus industry. You asked whether the 8-inch window opening size referred to in paragraph S5.1.2 applies to the "total outside frame dimension" or to each pane of gl ass. "In other words, would a pane of glass which measures less than 8 inches across need to be subject to the retention test [of S5.1 of FMVSS No. 217]?" To illustrate your question, you enclosed with your letter a picture of an upper/lower-pane pushou t window which was positioned for a retention test.

To be excluded from Standard No. 217's window retention requirement, the entire window, and not just a pane of the window, must be less than the 8-inch window opening size described in S5.1.2 of the standard. Section 5.1 of FMVSS No. 217 specifies reten tion requirements for windows other than windshields in buses. Paragraph S5.1.2 provides that those requirements do not apply to "a window whose minimum surface dimension measured through the center of its area is less than 8 inches." This exemption of 8 -inch windows was included in the standard in the final notice establishing the standard, published in the Federal Register on May 10, 1972 (37 FR 9394). In the preamble to that notice the agency stated at 37 FR 9395:

Since there is little likelihood of passenger ejection or protrusion from window openings whose minimum surface dimension measured through the center of the area is less than 8 inches, an exemption for windows of this size has been granted (emphasis adde d).

2

It is clear that the intent of the agency in providing this exemption was to exempt window openings, as measured by the perimeter of the window, not just individual panes of glazing material. A window can be composed of more than one pane of glazing mat erial, such as the window in the picture you provided, where 1 or more individual panes may have a minimum dimension smaller than 8 inches, but the whole window is larger than 8 inches. Regardless of the size of the individual panes which make up a wind ow, passenger ejection or protrusion could occur through such a window opening. Since ejection through such a window is precisely what the standard was intended to prevent, S5.1 would apply.

We note that you did not explain what you meant by "total outside frame dimension" and the meaning of the quoted phrase is not entirely clear. We assume you meant the entire window opening which, for the window in your picture, would include the combina tion of both panes and the window frame. Thus, for purposes of S5.1.2, we would measure both the pane and the window frame.

I hope this information is helpful to you. Should you have any further questions or need any further information, please feel free to contact Mr. Myers at this address or at (202) 366-2992.

ncc-20WMyers; mar:7/25/94:62992:OCC 9857 Ref:217 U: NCC20 INTERP 217 9857.WKM Greenbook: (2); Interps: Std. 217 Coord: NRM, NEF

ID: nht94-4.11

TYPE: Interpretation-NHTSA

DATE: August 26, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Richard Kreutziger -- Executive Director, New York School Bus Distributors Association (Penn Yan, NY)

TITLE: None

ATTACHMT: Attached to letter (fax) dated 7/19/94 from Richard Kreutziger to John Womack (OCC 10194)

TEXT:

This responds to your facsimile transmittal letter to me of July 19, 1994.

Your letter referred to Federal Motor Vehicle Safety Standard (FMVSS) No. 217, Bus Emergency Exits and Window Retention and Release (49 CFR 571.217), and asked whether emergency exits on school buses with a gross vehicle weight rating (GVWR) of less that 4,536 kilograms (10,000 pounds) and a passenger capacity of 2 to 16 seated and/or wheelchair positions, are required to be outlined with retroreflective tape as specified in paragraph S5.5.3(c) of the standard.

In 49 CFR 571.3, this agency defines a bus as a motor vehicle, except a trailer, designed to carry more than 10 persons, and further defines a school bus as

(A) bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportati on.

Whether or not a vehicle is a school bus, therefore, depends on its use (transporting the specified students) and seating capacity (more than 10), and not GVWR. Accordingly, if the seating capacity of a vehicle is 10 or less, it is not a bus and likewis e not a school bus, regardless of use or GVWR. Such a vehicle would not be required to comply with the requirements of FMVSS No. 217.

Vehicles meeting the definition of school bus would be subject to the requirements of FMVSS No. 217. Section S5.5 of the standard, Emergency Exit Identification, specifies the marking requirements for emergency exits on all buses. Sections S5.5.1 and S 5.5.2 apply to non-school buses, while section S5.5.3 applies to all school buses, without regard to GVWR.

Paragraph S5.5.3(c) provides:

Each opening for a required emergency exit shall be outlined around its outside perimeter with a minimum 3 centimeters wide retroreflective tape, either red, white, or yellow in color, that when tested under the conditions specified in S6.1 o f 571.131, meets the criteria specified in Table 1.

We would like to emphasize two points with regard to your letter. The first is that only those emergency exits that are required by the standard are subject to this provision. Extra emergency exits added as options are encouraged, but not required, to be outlined with the tape. The other point is one that I made

in May 18, 1994 letter to you. A technical amendment is pending publication which will amend the size requirement for the width of the retroreflective tape, from a minimum of 3 centimeters (cm.) to a minimum of 2.5 cm. That amendment is necessary becau se retroreflective tape is not commercially available in 3 cm. widths. Until the correction is issued, NHTSA will not take enforcement measures regarding tape width size against a manufacturer who uses one inch wide (minimum 2.5 cm.) retroreflective tap e.

In closing, bear in mind that all school buses are required to have a specified number of emergency exits, the number and location of which depend on the seating capacity of the vehicle, regardless of the GVWR, and all REQUIRED emergency exits must be ou tlined with the retroreflective tape.

I hope this information is helpful to you. Should you have any further questions or need any additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992.

ID: nht93-5.10

TYPE: INTERPRETATION-NHTSA

DATE: July 7, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Lanny Kness -- Coach Design Engineer, Chance Coach, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 4/14/93 from Lanny Kness to John Womack

TEXT:

This responds to your request for an interpretation of two sections of Federal Motor Vehicle Safety Standard (FMVSS) No. 101, Controls and displays (49 CFR S571.101). You ask whether S5.1 requires a turn signal control to be hand operated. As explained below, the answer is no. You also ask whether S5.3's illumination requirements can be met by two different means: reflected light, and an overhead light. The answer is no.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its motor vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.

Your first question asks whether S5.1 requires a turn signal control to be hand operated. S5.1 specifies location requirements for each control listed in S5.1 "that is furnished." S5.1 does not require manufacturers to furnish any control, such as a hand-operated turn signal control, or prohibit manufacturers from providing an unlisted control, such as a foot-operated turn signal control. While FMVSS No. 108, Lamps, reflective devices, and associated equipment (49 CFR S 571.108) specifies the "turn signal operating unit" as required equipment, it does not specify that the unit be hand operated. (See S5.1.1 and Table I of FMVSS No. 108.)

Your second question asks whether the following proposed method of illuminating the windshield wiper/washer control complies with S5.3.3 of Standard No. 101. You state that the wiper/washer control is located on the dashboard and at night, the "control knob's identification" can be barely seen from indirect lighting coming from other controls and displays. The wiper washer control would become "very discernible" by turning on an "overhead driver's controlled light."

For the following reasons, the above described method of illuminating the wiper/washer control would not comply with Standard No. 101. S5.3.3(a) requires means to be provided to make controls visible to the driver under all driving conditions. S5.3.3(b) states that "the means" (emphasis added) for providing the required visibility:

(1) Shall be adjustable, except as provided in S5.3.3(d), to provide at least two levels of brightness, one of which is barely discernible to a driver who has adapted to dark ambient roadway conditions.

S5.3.3(b) therefore requires that a single control (i.e., "the means") be adjustable to provide at least two levels of brightness. Under your proposal, however, two different means must be used to provide two levels of brightness. The overhead driver's light would provide one level of brightness, that makes the control "very discernible." The other level of brightness (one barely discernible to the driver) is provided from reflected light given off by other controls and displays located on the dashboard. Since no single "means" that you propose for illumination would be adjustable to provide at least two levels of brightness, your proposal would not comply with S5.3.3 of Standard No. 101.

I hope that this information is useful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.

ID: nht95-1.63

TYPE: INTERPRETATION-NHTSA

DATE: February 13, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: G. Brandt Taylor -- President, Day-Night Mirrors, Inc.

TITLE: None

ATTACHMT: ATTACHED TO 12/6/94 LETTER FROM G. BRANDT TAYLOR TO PHILIP R. RECHT (OCC 10553)

TEXT: This responds to your letter asking about the requirements applicable to multiple reflectance mirrors in Federal Motor Vehicle Safety Standard (FMVSS) No. 111, Rear View Mirrors. You stated that your mirror can change its reflectivity either by mechanica lly rotating a shaft or by actuating an electrical motor.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue safety standards for new motor vehicles and new items of motor vehicle equipment. NHTSA does not, however, approve or certify any veh icles or items of equipment. Instead, each manufacturer is responsible for "self-certifying" that its products meet all applicable safety standards. The agency periodically tests vehicles and items of equipment for compliance with the standards.

FMVSS No. 111 specifies requirements for the performance and location of rearview mirrors. Section S11, which specifies requirements for mirror construction, provides in relevant part that

All single reflectance mirrors shall have an average reflectance of at least 35 percent. If a mirror is capable of multiple reflectance levels, the minimum reflectance level in the day mode shall be at least 35 percent and the minimum reflectance level in the night mode shall be at least 4 percent. A multiple reflectance mirror shall either be equipped with a means for the driver to adjust the mirror to a reflectance level of at least 35 percent in the event of electrical failure, or achieve such refl ectance automatically in the event of electrical failure.

You asked several questions about the requirement for adjusting the mirror in the event of electrical failure. You first asked if a manual override knob could be removable. You then asked whether a removable manual override could be supplied by the car manufacturer along with the car keys or with the owner's manual for insertion into the mirror and use only in the event of an electrical failure. You also asked about whether "west coast" mirrors and mirrors on trailer trucks could have a removable man ual override.

The answer to each of your questions is that a removable manual override knob would not be permitted. In the preamble to the final rule amending the mirror construction requirements in FMVSS No. 111, NHTSA stated that the agency's goal is to assure that multiple reflectance mirrors are capable of providing adequate images at all times during the vehicle's operation, including electrical failure situations where the mirror is unpowered. (see 56 FR 58513, November 20, 1991)

The manual override knob you discuss would serve as the means for the driver to adjust the mirror's reflectance level. However, a removable manual override knob would not always serve this purpose, since it would not necessarily always be with the mirro r. We are concerned that a removable override device may become lost or otherwise not available when a mirror's reflectance needs to be adjusted. Accordingly, since the agency's goal of providing adequate images at all times during the vehicle's operat ion would only be achieved by requiring this device to be permanent, a removable override would not be permitted.

I hope this information is helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992.

ID: Silverman1

Howard A. Silverman, Esq.
General Motors Corporation
Legal Staff
Mail Code: 482-C24-D24
300 GM Renaissance Center
Detroit, MI 48265-3000




Dear Mr. Silverman:

This responds to your letter of January 7, 2005, asking us to reconsider our February 4, 2003 letter of interpretation to Ms. Erika Z. Jones regarding the definition of the term "Model Year" in 49 C.F.R. Part 565, Vehicle Identification Number Requirements (VIN). In our letter to Ms. Jones, we addressed whether 49 C.F.R. 565.6(d)(1) permits a manufacturer to designate vehicles as belonging to a single Model Year, where the production period for such vehicles falls within three different calendar years, but runs for less than 24 months in total. In our letter, we said the answer was no. We interpreted "Model Year," as defined in 49 C.F.R. 565.3(j), as a production period of less than two calendar years (i.e. , a time period limited by year designation rather than a maximum number of days). For the reasons that follow, we have decided to rescind our earlier letter and instead to interpret "Model Year" as a period not to exceed 24 months.

In your letter, you explained how our February 2003 interpretation of the term "Model Year" for VIN recordation purposes was contrary to actual, long-standing industry practices, and discussed the substantive impacts of the interpretation. According to your letter, it had been the industrys understanding that the National Highway Traffic Safety Administration has granted vehicle manufacturers flexibility in determining when to start production for a given Model Year, provided that such period may not exceed 24 months, and manufacturers scheduled their production in a manner consistent with this timeframe.

As discussed in our earlier letter, the VIN requirements were originally contained in Federal Motor Vehicle Safety Standard (FMVSS) No. 115, until the agency promulgated a final rule shifting such requirements to a new regulatory section at Part 565 (48 FR 22567, May 19, 1983). The exact definition of "Model Year" did change slightly in its migration from FMVSS No. 115 to Part 565, adding the word "calendar" to the requirement that the actual period of production be "less than two calendar years. "However, the final rule stated that "[t]he basic substantive requirements of Standard 115 are unchanged by this action". 48 FR 22567, 22567. It also stated, "The new Part 565 would not have any requirements not in FMVSS 115 prior to today". Id. at 22569. That is, it was not the agencys intention to change the substantive requirements of the VIN regulation or to alter existing industry practices.

When drafting the letter to Ms. Jones, we did not fully appreciate the impacts that our interpretation would have on vehicle manufacturers production processes. These impacts suggest that our February 2003 interpretation would result in substantive changes to the VIN requirements, the type of changes that, according to the 1983 notice, were not intended to result from the addition of the word "calendar" to the regulation. Substantive changes to our regulations are conducted through the rulemaking process, with an opportunity for public notice and comments.

Accordingly, we have decided to rescind our earlier interpretation of the definition of "Model Year" contained within Section 565.3(j), and instead, we will interpret that term as any 24-month period from the starting point determined by the manufacturer, thereby permitting a full two-year period for all such manufacturer designations. To do otherwise would change the substance of the VIN requirement and could result in widely disparate treatment of different vehicles in terms of VIN requirements related to Model Year designation, depending upon when the manufacturer begins production, and would unnecessarily restrict manufacturers discretion in setting their own production schedules.

If you have any questions, please feel free to contact Eric Stas of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

cc: Erika Z. Jones, Esq.
ref:565
d.2/15/05

ID: armor23160

Mr. Charlie Cao
Armor USA, Inc.
611 Forest Hill Drive
Coppell, TX 75019





Dear Mr. Cao:

This responds to your letter received on May 22, 2001 asking for information about the application of glazing marking requirements. More specifically, you ask whether it is optional or mandatory to have a DOT number for bullet-resistant glass to be used for the windshield of armored vehicles. As discussed below, a DOT number is required for the bullet-resistant glass to be used for the windshield of all vehicles, including armored vehicles.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the statutory authority to issue Federal motor vehicle safety standards (FMVSSs) applicable to new motor vehicles and new items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment or pass on the compliance of a vehicle or item of equipment outside the context of an actual enforcement proceeding. Instead, Federal law establishes a self-certification system under which motor vehicle and equipment manufacturers themselves certify that their products comply with all applicable standards.

FMVSS No. 205, Glazing materials (49 CFR 571.205), specifies requirements for glazing in each new motor vehicle. The standard permits bullet-resistant glazing to be used anywhere in a motor vehicle, provided such glazing meets specified performance, location, marking, and certification requirements. Therefore, the glazing to be used for the windshield of armored vehicles, whether bullet-resistant or not, must be marked in accordance with the marking requirements of FMVSS No. 205, as discussed below.

S6 of Standard No. 205 establishes marking and certification requirements for manufacturers and distributors of glazing materials. S6.1 requires every Aprime glazing material manufacturer@ (defined in S6.1 of Standard No. 205 as Aone who fabricates, laminates, or tempers the glazing material@) to mark all glazing materials it manufactures in accordance with section 6 of American National Standard ASafety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways@ Z-26.1-1977, January 26, 1977, as supplemented by Z26.1a, July 3, 1980 (AANS Z26"). S6.3 requires each prime glazing manufacturer to certify each piece of glazing designed to be cut into components for use in motor vehicles pursuant to the requirements of our statute at 49 U.S.C. ' 30115.

Each manufacturer or distributor who would not be considered a Aprime glazing material manufacturer,@ but who cuts a section of glazing material to which Standard No. 205 applies, must comply with the requirements set forth in S6.4 and S6.5 of Standard No. 205. For sections of glazing that are cut by the manufacturer or distributor, the manufacturer or distributor must mark it in accordance with section 6 of ANS Z26 (S6.4) and certify it in accordance with 49 U.S.C. ' 30115.

For your further information, I am enclosing a fact sheet we prepared entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, and Where to Obtain NHTSA=

s Safety Standards and Regulations.

I hope this information is helpful. If you have any questions or need additional information, feel free to contact Nancy Bell of my staff at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel

Enclosure
Ref:205
d.8/1/01

ID: nht92-5.13

DATE: July 23, 1992

FROM: Takashi Odaira -- Chief Representative, Emissions & Safety, Isuzu Technical Center of America, Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

COPYEE: Mr. Sakai

TITLE: FMVSS 214 Side Impact Protection Quasi-static Door Strength Test

ATTACHMT: Attached to letter dated 10/5/92 from Paul Jackson Rice to Takashi Odaira (Std. 214)

TEXT:

The side door strength test procedures specified in FMVSS 214 are not quite clear as they relate to pickup trucks. In the attached sheets, we have described three alternative procedures that Isuzu Motors Limited, Japan, plans to follow.

Isuzu Motors requests your agency's view and/or comment on each of these procedures.

I would appreciate receiving your prompt reply.

(Attachments omitted)

ID: nht90-3.22

TYPE: Interpretation-NHTSA

DATE: July 19, 1990

FROM: T. Spingler, Robert Bosch, GmbH

TO: Rich v. Iderstine -- Office of Rulemaking, NHTSA

TITLE: FMVSS 108, S.3. Definitions

ATTACHMT: Attached to letter dated 8-2-90 to T. Spingler from P. J. Rice; (A35; Std. 108)

TEXT:

Five weeks ago (06/14/90) I discussed the word "bonded lens" with Larry Ayers, ETL, regarding headlamps with movable reflector and "VHAD". Usually we in Europe use rubber-seal and clips to fix the lens to the housing. To meet the requirements of FMVSS 108, Larry proposed to fix the lens of those headlamps by adding e.g. silicone-glue at four places between lens and housing to prevent the removal of the lens. Jerry Medlin, whom we called that day, agreed to that interpretation. To get an official int erpretation, I ask you to write me a letter regarding this "problem".