ID: nht93-2.48

DATE: April 9, 1993

FROM: Lawrence Hufstedler -- Kesler Research Enterprises, LTD.; Raymond Kesler -- Kesler Research Enterprises, LTD.

TO: John Womack -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-27-93 from John Womack to Lawrence Hufstedler and Raymond Kesler (A41; VSA 108(a)(2)(A); FMVSS 111)

TEXT: We would like to thank you for the meeting of April 8, 1993, concerning the Advanced Technology Rear View Mirror Concept. We have been researching and developing this product since 1986. It was indeed a pleasure to come in to your office and introduce you to the concept as well as the actual hardware.

Let us take a moment to also thank Mr. Marvin Shaw of your legal department for his guidance and legal expertise in helping us understand the governmental aspect of our improved concept. Also, Mr. Mike Perel from your Research and Development department for his input concerning federal testing procedures. Let us not forget Mr. Rich Van Iderstine and Mr. Pat Boyd, from the office of Rule making. They were able to guide us through positive and enlightening particulars in their area.

During the meeting your agency representatives spoke of Federal Motor Vehicle Safety Standard # 111. We would appreciate your written response confirming that FMVSS # 111 states, that a "passenger vehicle weighing under 10,000 lbs. and having a left side and an interior mirror (field of view) that comply with the specifications in the standard may use any mirror of the (OEM) manufacturers or owners choice or, use no mirror at all on the right side of their vehicle.

As this matter is of extreme urgency to us, ,we look forward to hearing from you soon. Again, we thank you for your unyielding thoughtfulness of public safety.

ID: nht76-5.7

DATE: 12/09/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Wayne Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 15, 1976, in which you ask whether emergency exits installed in school buses beyond those required in S5.2.3 of Standard No. 217, Bus Window Retention and Release, must meet the requirements of the standard.

The NHTSA has determined previously that only those exits required in S5.2.3 must meet the requirements specified for school bus emergency exits in Standard No. 217. All other emergency exits installed in school buses must comply with the requirements for emergency exits in buses other than school buses. These requirements are detailed in Standard No. 217.

In your letter, you ask specifically whether S5.2.3.1(b), S5.3.1, S5.3.2, S5.3.3, S5.4.1, S5.4.2.1(b), or S5.5.3 apply to a side emergency door in a school bus that already complies with S5.2.3.1(a) of the standard. The NHTSA concludes that this door would be required to comply with S5.3.1, S5.3.2, and S5.4.1 of the standard.

SINCERELY,

Wayne Corporation

November 15, 1976

Frank R. Berndt Office of Chief Counsel NHTSA

This inquiry is in reference to FMVSS 217, Bus Window Retention and Release, as applied to school buses with a GVWR of more than 10,000 pounds. In the case of a school bus equipped with a side emergency door, in addition to a rear emergency door furnished in compliance with the requirements of Sections S5.2.3.1(a), S5.3.3, S5.4.2.1(a) and S5.5.3, which if any of the following requirements must the side door comply with:

S5.2.3.1(b), S5.3.1, S5.3.2, S5.3.3, S5.4.1, S5.4.2.1(b) or S5.5.3?

Your prompt attention to this matter and an early reply will be greatly appreciated.

Robert B. Kurre Director of Engineering

ID: nht76-5.9

DATE: 05/28/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck Body and Equipment Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to the Truck Body Equipment Association's May 7, 1976, question whether S5.2.3.2 of Standard No. 217, Bus Window Retention and Release, requires that the engine starting system of a school bus not operate if an emergency exist other than an emergency door is locked. Section S5.2.3.2 applies to school buses manufactured on or after October 26, 1976.

Section S5.2.3.2 only specifies requirements for the relationship of the engine-starting system to the operation of emergency doors. Reference to "any emergency exit" in the first sentence of the section is in error, as the correct reference to "emergency door" in the second sentence of the section demonstrates. A correction of this error will be made in the text of the standard shortly.

SINCERELY,

TRUCK BODY AND EQUIPMENT ASSOCIATION, (Illegible Word)

May 7, 1976

Frank Berndt, Acting Chief Counsel NHTSA

A question concerning FMVSS 217 as it relates to "School Bus Emergency Exit Requirements" was discussed at our recent Engineering Meeting. Section S5.2.3.2 states:

"The engine starting system of a school bus shall not operate if any emergency exist is locked from either inside or outside the bus. For purposes of this requirement, 'locked' means that the release mechanism cannot be activated by a person at the door without a special device such as a key or special information such as a combination."

Our question concerns the use of the term "emergency exits" in this section with regards to the ignition interlock system.

Does this section require the installation of an ignition interlock system on push-out type emergency windows?

Thanking you in advance for your prompt reply.

Byron A. Crampton Manager of Engineering Services

ID: nht78-1.37

DATE: 01/26/78

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

TO: Sheller-Globe Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your December 6, 1977, letter asking which portions of the roof and sidewall structure of your small bus must comply with the head impact requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection.

In accordance with the head impact zone requirements outlined in paragraph S5.3.1.1 of the standard, the National Highway Traffic Safety Administration has determined that those portions of your bus constituting the bus sidewall and window structure are not required to comply with the head impact requirements. Only those portions of your bus which constitute part of the roof structure are included within the head impact zone requirements. We have marked in yellow on the enclosed drawing those areas that must comply with the head impact requirements.

SINCERELY,

SHELLER-GLOBE CORPORATION Vehicle Planning and Development Center

December 6, 1977

National Highway Traffic Safety Administration

Attention: Chief Counsel, Frank A. Berndt

Gentlemen:

Reference is made to S.5.3.1.1. of FMVSS 222 - School Bus Seating and Crash Protection, which states the bus sidewall, window, or door structure are not included in the impact zone.

Our question is, what all do you consider as window structure and if a side body pillar and the structure over the top of the window assembly to which the window is mounted, are also not included in the impact zone? The pillar and structure in question are marked in red for the Dodge and blue for a Chevrolet on drawing #K-4300021.

It would be appreciated if you would indicate on the extra copy of the drawing area needing or not needing to be included in the impact zone.

R. M. Premo - Director Vehicle Safety Activities

ID: nht73-1.35

DATE: 12/19/73

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Toyo Kogyo U.S.A.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 6 to Mr. Lewis Owen of this Office concerning the use of a special parking lamp bulb in one of your tail lamp assemblies.

The location of the subject bulb in the lamp assembly, regardless of whether the switch is removed to make it inoperative, is permitted, providing that the other required lamps function as specified in Federal Motor Vehicle Safety Standard No. 108.

Sincerely,

TOYO KOGYO U.S.A. REPRESENTATIVE OFFICE

December 6, 1973

Lewis Owen -- National Highway Traffic Safety Administration, U. S. Department of Transportation

Dear Mr. Owen:

This is in confirmation to our discussion on Nov. 27, 1973.

On one of our models, we are now considering to utilize the parts for, between U. S. A. and Japan.

In these rear combination lamps, there are No. 12 lamp, which is called with parking lamp which is different from FMVSS 108. Please find the attached sheet. The parking lamp is required in Japanese regulation, but not required in U. S. A.

We are now thinking it will become irregular if it works. So we want to remove the switch from this lamp and it cannot work. But, for the U. S. A., we want the bulb to remain ( 3.4 W ) and end of coupler and cord.

We must emphasize that there are no influences to another mechanism, ( Stop, tail, & backup lamp ). On the lamp housing, we want to put the caution. This parking lamp is only for Japan namely, "Japan 12 V, 3.4 W". We believe there is no mistake in user.

Warmest regards,

Gorou Utsunomiya -- Branch Manager, Detroit Branch

cc; Dr. Sakashita, Mr. Niguma

Enclosurer

ID: nht73-1.8

DATE: 08/20/73

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

TO: Renault, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 1, 1973, asking for clarification of S5.2.1 and S6.9 of Standard No. 105a.

You interpret the parking brake test as allowing "the vehicle to slide down the 30% incline (because of its weight) as long as the wheels remain locked". The parking brake must hold the vehicle on a 30% grade for 5 minutes. If vehicle weight distribution is such that the limit of traction is exceeded and the vehicle slides down the incline, no noncompliance would be indicated unless the parking brake failed to lock the wheels.

No skid number is specified for the "clean, dry, smooth, portland cement concrete" incline surface specified in S6.9.

Yours truly,

August 1, 1973

Lawrence R. Schneider -- Chief Counsel, Nat. Highway Traffic Safety Admins.

SUBJECT: FMVSS 105a - Docket 70-27, Notice 8

Dear Mr. Schneider:

Regie Nationale des Usines Renault would like to request a clarification regarding section S.5.2.1. and S.5.2.2.1 of the above Docket.

It is our understanding that in order for the parking brake to comply with these paragraphs, the wheels of the vehicle must remain locked, but the vehicle may slide down the 30% incline (because of its weight) as long as the wheels remain locked.

We would appreciate receiving a written confirmation of our interpretation.

In addition, we would appreciate the NHTSA informing us of the skid number of the "clean, dry, smooth, Portland cement concrete" referred to in paragraph S.6.9.

Thank you for your cooperation and consideration.

Very truly yours,

RENAULTINC --[Illegible Words] for Francois Louis, Manager, Technical Standards Dept.

ID: nht75-2.14

DATE: 08/19/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of April 10, 1975, requesting an interpretation of S4.3, the placarding requirement, of Federal Motor Vehicle Safety Standard No. 110, Tire Selection and Rims -- Passenger Cars.

You have proposed a format for presenting vehicle capacity weights which is designed to accommodate, with a single placard, several different model configurations. The NHTSA has no objection to this format, provided that the weights listed are correct.

Sincerely,

ATTACH.

VOLKSWAGEN OF AMERICA INC.

April 10, 1975

Mark Schwimmer, Esq. -- Office of the Chief Counsel, National Highway Traffic Safety Administration

Subject: N40-30 (MPP)

Dear Mr. Schwimmer:

This is in reference to our telephone conversation of Monday, April 7, concerning the format of our Standard 110 label. I am also referring to Mr. Dyson's letter of January 17, 1975, in which he suggested that we list on the same label alternate vehicle capacity weights applicable to models with or without optional equipment as long as we initially displayed the lowest vehicle capacity weight for the vehicle.

Our marketing representatives feel that the initial listing of the lowest weight may have competitive disadvantages in the small car market and have proposed a format which contains the vehicle capacity weight for each model configuration. I have enclosed for your review a copy of the new format which we plan to use and would appreciate your opinion concerning its acceptability pursuant to S4.3 of FMVSS 110.

Sincerely,

Gerhard P. Riechel -- Attorney

Enc.

(Graphics omitted)

ID: nht74-4.9

DATE: 07/03/74

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

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 26, 1974, question whether labeling information on hose installed in vehicles must remain legible after the vehicle is painted, and what "permanently labeled" means in S5.2.2.

The answer to the question of painting over label information will be answered in our upcoming notice in response to petitions for reconsideration of the amendments we have made to the standard.

"Permantly labeled" means affixed in such a manner that it is not easily removable, and is reasonably designed to remain affixed and legible for the normal life of the component.

Yours Truly,

Volvo of America Corporation

April 26, 1974

Lawrence Schneider, Chief Counsel National Highway Traffic Safety Administration

Volvo of America Corporation hereby requests an interpretation on amended FMVSS 106 published February 26, 1974 [Docket No. 1-5; Notice 10].

Volvo requests an interpretation on the extent which the markings on the brake hose, end fitting and band around the brake hose assembly must remain legible after the assembly is installed on the vehicle. Volvo has determined these markings may become illegible after the chassis is painted. Would the NHTSA find it acceptable to have one or more markings on the hose remain legible, and the markings on the fitting and the band, if not legible after painting, be legible when the paint is removed?

Volvo also requests a definition of "permanently labeled" as stated in Section S5.2.2

Volvo thanks you for your consideration on this matter and requests a reply as soon as practical.

Rick Shue Product Safety Engineer

cc: S. Larsson

ID: 86-1.31

TYPE: INTERPRETATION-NHTSA

DATE: 02/11/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Tony T.Y. Tu -- Fonnex Industrial Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Tony T.Y. Tu Fonnex Industrial Corp. P.O. Box 68-857 Taipei, TAIWAN

This is in reply to your letter of October 18, 1985, to this agency asking questions regarding test procedures for Federal Motor Vehicle Safety Standard No, 108, Lamps, Reflective Devices, and Associated Equipment.

Your questions indicate that you are under the impression that test samples must be submitted to this agency for testing. This is not correct; no testing or approval by this agency is required before a manufacturer of replacement lighting equipment may offer its product for sale in the United States.

Under the National Traffic and Motor Vehicle Safety Act, such a manufacturer is required by law to produce replacement lighting equipment that is designed to comply to the requirements of Standard No. 108, and to certify that the equipment does, in fact, meet the standard. It is the manufacturer's decision as to how many samples must be tested, whether they are prototype or production items, and so on, in order to assure himself that the item does meet Standard No. 108, before certifying that it does comply. Certification may be in the form of a DOT symbol on the item itself, or a statement of compliance on a label or tag affixed to the item itself, or to the container in which it is shipped.

As a general rule, under section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et. seq.), all items of motor vehicle equipment manufactured on or after the date any applicable Federal Motor Vehicle Safety Standard takes effect must conform to such standard in order to be imported into the United States. The regulation governing the importation of motor vehicles and items of motor vehicle equipment is Title 49, Code of Federal Regulations, Part 12.80 (19 CFR 12.80).

You should also note that under 49 CFR 566, you are required to submit certain identifying information and a description of your product to the Administrator, National Highway Traffic Safety Administration. Further, under section 151 et seq. of the Act, you are responsible for recall and remedy, at your expense, for any safety related defects in your product or noncompliances with Standard No. 108.

Prior to offering motor vehicle equipment for importation into the United States, a foreign manufacturer is required to register an "Agent-for-Service" of process as set forth in 49 CFR 551.45 as well as furnishing the information required by 19 CPR 566 for covered items of equipment.

You are advised to carefully examine the Act and FMVSS as well as other regulations listed below to insure that you fully understand the extent of the responsibilities you incur upon the manufacture/importation of a motor vehicle or item of motor vehicle equipment for which there is an applicable FMVSS.

Enclosed for your information and guidance is a copy of the following:

1. The National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.)

2. 49 CFR 551, "Procedural Rules"

3. 49 CFR 556

4. 19 CFR 12.80, "Importation of Motor Vehicles and Items of Motor Vehicle Equipment"

5. Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment

We also recommend that you contact the American Association of Motor Vehicle Administrators, 1201 Connecticut Avenue, N.W., Suite 910, Washington, D.C. 20036. It is a private organization that provides information regarding the requirements of the various States.

I hope that this answers your questions.

Sincerely,

Erika Z. Jones

Chief Counsel

Enclosures

October 18, 1985

U .S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh St., S.W. Washington, D.C. 20590, U.S.A.

Attn. Whom who concern

Dear Sir:

We are an Auto Lamps manufacturer in Taiwan, our products include Front Lamps, Side Lamps and Rear Lamps, etc.. We hope that our products could pass the Federal Motor Vehicle Safety Standard & Regulation test and sold to the market of your country. So, please offer us your instructions what are the procedure we have to take, such as:

1. Who is in charge of the testing to whom we have to contact. (Administration , Name and Address)

2. How many samples in each items we have to send for testing.

3. The other special instruction which are important to us if we want our products to be passed the testing.

We wish that our inquiry will not bring you too much trouble. Your earlier reply will be highly appreciated. Best regards.

Yours sincerely,

Tony T. Y. Tu FONNEX INDUSTRIAL CORP. T/nc

ID: 86-2.3

TYPE: INTERPRETATION-NHTSA

DATE: 03/03/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Bobbi Fiedler

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Bobbi Fiedler House of Representatives 1607 Longworth House Office Building Washington, D.C. 20515

Dear Ms. Fiedler:

Thank you for your letter enclosing correspondence from your constituent, Mr. William Griffiths of Newbury Park, who asked several questions about our regulations for safety belts on passenger motor vehicles, buses and school buses. Your letter has been referred to my office for reply.

Your constituent asked why safety belt designs vary between different seating positions and among different types of motor vehicles. He observes that some vehicles have a combination of pelvic and upper torso restraints ("lap and shoulder belts") in the front seats, while providing only lap belts for the rear seats. He further notes that safety belts are not required for passengers in buses and school buses. Apparently Mr. Griffiths believes that shoulder belts are uncomfortable and feels that they should not be installed in the front seats of passenger motor vehicles.

I am pleased to have this opportunity to clarify our requirements for your constituent. The National Highway Traffic Safety Administration (NHTSA) is responsible for developing safety standards for all new motor vehicles and items of motor vehicle equipment. Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection, establishes performance requirements for the protection of vehicle occupants in crashes. Under FMVSS No. 208, motor vehicle manufacturers must provide lap and shoulder belts for front outboard passenger positions in order to comply with the standard. Since persons in the front seating positions of an automobile should be protected from rigid structures forward of those positions, such as the windshield pillars, He believe that an upper torso restraint of some kind is necessary. Our requirements differ for the rear seating positions, where only a lap belt need be provided, because the area forward of those positions does not contain the relatively hard surfaces found in the areas surrounding the front seats.

As Mr. Griffiths has noted, our safety standards for buses and school buses do not require safety belts for passengers. NHTSA does not require safety belts for transit-type buses because the crash forces experienced by those vehicles are less severe than those of lighter vehicles in similar collisions. Also, the safety record for transit buses is good Accordingly, we believe that revising our requirements for their seating systems would not reduce injuries substantially. Safety belts are not required for passengers in large school buses because those vehicles are required to provide high levels of occupant crash protection through a concept called :"compartmentalization." Compartmentalization requires that the interior of large school buses by constructed so that children are protected without the need to use safety belts. The seating improvements include higher and stronger seat backs, additional seat padding, hand improved seat spacing and performance.

Your constituent might be interested to know that we have addressed his concern regarding the discomfort some passengers experience with safety belts equipped with shoulder restraints. We have taken steps to improve the comfort and convenience of safety belt Systems by a recent amendment to our safety standards. A copy of the amendment is enclosed.

I hope this information is helpful. Please do not hesitate to contact my office if you have further questions.

Sincerely,

Original Signed By

Erika Z. Jones Chief Counsel

Enclosure

Congress of the United States House of Representatives Washington D.C.

Dec. 20 1985

Nancy Miller Department of Transportation

Sir:

The attached communication is sent for your consideration. Please investigate the statements contained therein and forward me the necessary information for reply, returning the enclosed correspondence with your answer.

Yours truly,

M. C.

Please Return ATTN: Louise Gessford 1607 Longworth

Rep Fiedler

Why do the car manufacturers have different seat belt configurations, with the belt in the front seats going around the waist and over the shoulder and the back seat only around waist, some have front seat only around waist?

Why do the city buses not have seat belts for the passengers? Also school buses?

We the people are the testing area for the car industry.

These are a few of the negative views after talking to many people about new seat belt law.

Have they thought about people who have had heart surgery, and other people having surgery who still have very tender areas, also women with large breasts, the only relief is to ride with your hand under the belt in these irritating areas in order to obey the law. This seems quite stupid.

Summation: There definitely should be more research done on this problem: either have the car manufacturers install waist belts in all cars or resort to air bags.

Will await your reply

William Griffith 815 492-5432