ID: nht79-1.10

DATE: 12/05/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Theodore Bargman Company

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Edward F. Tannery Theodore Bargman Company 129 Industrial Avenue Coldwater, Michigan 49036

Dear Mr. Tannery:

This responds to your recent letter asking whether doors on aftermarket top covers for American Motors Jeeps would have to comply with Safety Standard No. 206, Door Locks and Door Retention Components.

Safety Standard No. 206 applies to passenger cars, trucks and multipurpose passenger vehicles, which would include Jeeps. The standard applies only to completed vehicles, however, and not to aftermarket motor vehicle equipment. Therefore, the doors on aftermarket Jeep top covers would not have to have locks. Further, doors on new Jeep vehicles would also not have to comply with the standard if they are "designed to be easily attached to or removed from" the vehicle, as provided in section S4 of the standard.

Please contact Hugh Oates of my office if you have any further questions.

Sincerely,

Frank Berndt Chief Counsel

October 30, 1979

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

Attention: Mr. Hugh Oates Legal Counsel

Dear Mr. Oates:

On October 29, 1979 I had a phone conversation with Mr. William Smith discussing the legalities of door latches and their requirements for Jeep Motor Vehicles. I know the requirements for automotive, motor homes, etc., all all under the FMVSS No. 206 and test procedures of S.A.E. for transverse, longitudinal, inertia testing but on the American Motor Jeep, it has no top cover or a canvas type cover. There is only a handle latch without a first and second stop strike, and no locking mechanism. My question is, where can we find information covering such a top if they were to be manufactured or fabricated for the aftermarket by an independent company. Would this type of application require a safety lock or come under a different category?

I would appreciate any help you can give on door restraint handles and latches for either canvas tops with side curtains and canvas doors, or fiberglas tops with side doors (entrance doors) for Jeeps.

Sincerely,

THEODORE BARGMAN COMPANY

Edward F. Tannery Vice President of Manufacturing

iw

ID: nht89-2.86

TYPE: INTERPRETATION-NHTSA

DATE: 08/30/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: DAN TREXLER -- SPECIFICATIONS ENGINEER THOMAS BUILT BUSES, INC.

TITLE: NONE

ATTACHMT: LETTER DATED 05/08/89 FROM DAN TREXLER -- THOMAS BUILT BUSES TO ERIKA Z. JONES -- NHTSA; OCC 3560

TEXT: Dear Mr. Trexler:

This is in reply to your letter of May 8, 1989, to the former Chief Counsel of this agency, Erika Jones. You have received requests "to install a master electrical disconnect switch on many buses." When the switch is turned to the "off" position "it ren ders inoperative the warning signals (to the driver) required by FMVSS 105, 121 and 217. It also inactivates the hazard warning flasher required by FMVSS 108." You ask whether installation of the switch would constitute a noncompliance, or a "safety rel ated hazard." if it is accessible to the seated driver, or if remotely located in the battery or engine compartment, without ready access to the driver.

Although you have not explained the purpose of such a device, we understand that a battery disconnect switch of this nature is deemed desirable by many bus owners to prevent drains on the battery when the bus is at rest. When the switch is activated, th e bus cannot be started and driven because electric power is not available. Under this circumstance we do not believe that the switch either creates a noncompliance with any of the standards listed, nor constitutes a safety related defect, regardless of its location. When the bus is in operation the warning systems of the standards are not affected. The possibility of inadvertent activation when the bus is in use does not constitute a defect in performance, construction, components, or materials such as to create a safety related defect. To forestall any possibility of inadvertent activation, however, you may find it preferable to locate the switch away from the driver.

We understand that a purpose of this switch is to reduce the likelihood of fire after accidents in which there has been fuel spillage. In this circumstance, it is likely that the bus would be positioned either in the roadway or adjacent to it. Safety w ould be enhanced if the hazard warning signal power source were separate from the batteries inactivated by the disconnect switch, so that these warning lamps could continue to operate.

Sincerely,

ID: nht92-8.47

DATE: February 21, 1992

FROM: Masashi Maekawa -- Director, Technical Division, Ichikoh Industries, Ltd.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re: Request for the interpretation of photometric output requirements for tail/stop lamps on passenger cars

ATTACHMT: Attached to letter dated 4/10/92 from Paul Jackson Rice to Masashi Maekawa (A39; Std. 108)

TEXT:

Thank you for your answering letter dated Dec. 18, 1991 to our questions concerning the interpretation of photometer output requirements for tail/stop lamps on passenger cars dated Nov. 27, 1991.

We had some questions as follows regarding positions stated in the letter from NHTSA.

1. NHTSA stated in the letter dated Dec. 18, 1991 as follows;

" It is not possible to consider the two adjacent lamps as one lamp for purpose of measuring the minimum photometrics required under standard No. 108."

But another letter from NHTSA dated June 28, 1985 addressed to Mazda (North America), Inc. stated as follows;

" We also discuss the implications of a stop lamp and tail lamp constructed so that a portion is fixed to the body of the vehicle adjacent to the decklid opening and the remaining portion is mounted on the outboard area of the decklid.

Compliance of a vehicle is determined with respect to its normal driving position, that is to say, with the tailgate, hatch, or decklid closed."

We realized the noticeable difference between those two letters. We have been designing and testing lamps until now according to the interpretation dated June 28, 1985.

2. As the interpretation of the testing method concerning photometer output requirements of lamps mounted onto both the moving vehicle part and the rigid vehicle part is not written in FMVSS No. 108, we have been designing those lamps to comply with photometer output requirements by using both lamps mounted onto the moving vehicle part (Lamp-B) and the rigid vehicle part (Lamp-A), in accordance with the sentence "The device shall be mounted in its normal operating position." of J (Photometry) of SAE J575e incorporated in FMVSS No. 108.

For the reason mentioned above, we would like to ask whether your stance concerning the interpretation of those lamps has been changed or not.

Kindly let us know your opinion concerning the above matters.

ID: nht94-8.10

DATE: February 15, 1994

FROM: Thomas D. Turner -- Manager, Engineering Services, Blue Bird Body Company

TO: George Entwistle -- Office of Vehicle Safety Compliance, NHTSA

COPYEE: Robert Hellmuth -- OVSC, NHTSA; Thomas Turner -- Specialty Manufacturing Co.

TITLE: NEF-31GEn/NCI 3302

ATTACHMT: Attached to letter dated 4/8/94 from John Womack to Thomas Turner (A42; Std. 131); Also attached to letter dated 1/26/83 from Frank Berndt to Thomas D. Turner

TEXT:

Last Week I received by FAX an advanced copy of NCI 3302 concerning an apparent non-compliance of stop arms with strobe lights to FMVSS 131 Section S6.2.2, "Flash Rate." Blue Bird is forwarding a copy of NCI 3302 to our supplier of stop arms, Specialty Manufacturing Company in Pineville, North Carolina, so that they can determine if a non-compliance exists.

In studying the requirements of S5.3, a question has arisen. S5.3 Conspicuity states "The stop signal arm shall comply with either S5.3.1 or S5.3.2, or both." Some of the stop arms we install are reflectorized and have strobe lights. Based on NCI 3302, it appears that the strobe lights do not comply with S6.2.2, so these stop arms do not comply with the "S5.3.2" or the "both" option of Section S5.3. However, these stop arms fully comply with the S5.3.1 option of Section S5.3; and the use of the strobe lights could be considered as optional lighting, not required by FMVSS 131 and therefore not required to meet the requirements of S6.2.

NOTE: As a general rule, supplemental lighting is permitted by Standard No. 108 as long as it does not "impair the effectiveness of lighting equipment" required by the standard. (See attached letter from Chief Counsel dated January 26, 1983.)

It is our understanding that a stop signal arm that fully complies with the requirements of S5.3.1 has satisfied the requirements of S5.3 Conspicuity, even if it has optional strobe lights installed that do not meet S5.3.2.

WE REQUEST CONFIRMATION THAT THE OVSC CONSIDERS A REFLECTORIZE STOP SIGNAL ARM THAT FULLY COMPLIES WITH S5.3.1 AS COMPLIANT WITH S5.3 WITH OR WITHOUT STROBE LIGHTS INSTALLED.

Your immediate response is needed so that we can proceed with work on our response to NCI 3302.

ID: nht93-6.20

DATE: August 18, 1993

FROM: Jack McIntyre -- V.Pres., Tie Tech Inc.

TO: John Womack -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 11/23/93 from John Womack to Jack McIntyre (A41; Std. 209; Std. 222) and letter dated 9/15/93 from Jack McIntyre to John Womack (OCC-9123)

TEXT:

In January 1993, the National Highway Traffic Safety Administration issued requirements for wheelchair securement systems that are used on school buses. These requirements are included in Federal Motor Vehicle Safety Standard 222. As stated in the comments that were provided to the Proposed Rule, these standards are needed.

In reviewing the final requirements, however, it appears that a particular requirement for the wheelchair securement system was adopted that is inconsistent with the securement systems being manufactured by most wheelchair securement manufacturers. Also, this requirement does not appear to be directly relevant to the crash performance of a wheelchair securement belt. The specific requirement I am referring to appears in S5.4.2, which references the requirements of Type 1 safety belts of FMVSS 209, and requires that the belt webbing be not less than 1.8 inches wide.

There is no apparent need to specify a minimum belt width for wheelchair securement belts as there is for occupant restraint belts. I understand that the belt width requirements for occupant restraint systems is to spread the crash forces over a larger area of the body. There is no such need for securement belts. Currently the industry standard for securement belts is a 1 inch wide belt made from polyester that easily meets the 6,000 pound force requirements of FMVSS 209 and 222. Additionally, the 1 inch wide belts made from polyester have less stretch than the 1.8 inch nylon belts.

Finally, it is noted that 1 inch wide securement belts and related hardware are easier and less cumbersome to connect to a wheelchair, particularly in the tight circumstances that exist on school buses in many instances, than are the 1.8 inch wide belts and their larger pieces of hardware.

Based on the above, I petition to change the requirement that the wheelchair securement belt must be at least 1.8 inches wide. The cost to the wheelchair securement industry to retool for the wider belts would be significant, without any added benefits in terms of safety to occupants of wheelchairs in school buses.

Thank you for your consideration.

ID: nht76-4.17

DATE: 12/10/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Great Dane Trailers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Great Dane Trailer's November 4, 1976, question whether the "controlled lockup" exception in S5.3.2 of Standard No. 121, Air Brake Systems, is available to a manufacturer who equips a "tri-axle" trailer suspension with one set of wheel speed sensors on the center axle (or, alternatively, on the front axle) and one antilock valve and logic module that meters air pressure to the two rearmost axles.

Your question appears to be similar to questions about tandem-axle suspensions that prompted an interpretation of the "controlled lockup" exception to the "no lockup" requirements of S5.3.1 and S5.3.2. A copy is enclosed for your information. You will note that the closing statement in the interpretation states that ". . . the controlled lockup exception is not dependent on the number or location of sensors used in an antilock installation." It is left to the manufacturer to decide what placement of the sensors will provide the best performance.

Sincerely,

Enclosure

Great Dane Trailers, Inc.

November 4, 1976

Thomas Herlihy Office of Chief Counsel National Highway Traffic Safety Administration

Subject: FMVSS 121-Air Brake Systems

Dear Mr. Herlihy:

In Section S5.3.2 of the 121 requirements, there are indications that anti-lock controls be applied to the two rearmost, nonliftable, nonsteerable axles. In the more recent interpretation, there are indications that if it is possible to predict which of the two axles will lock first during braking, sensors may be placed on this axle only; however, they both must be controlled.

My question involves a tri-axle unit. In this case, where must the sensors be used? By the first interpretation, controls need not be on the front axle of this suspension, only on the last two. Of these last two, the center axle will always lock before the rear axle, meaning that the control sensors should be installed on this center axle. However, in a tri-axle suspension, the front axle will lock first, the center axle will lock second and the rear axle will be the last to lock.

We would appreciate your early reply.

Sincerely,

Dudley E. DeWitt Manager/R & D

ID: nht73-1.31

DATE: 12/04/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Young Daybrook, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 16, 1973 asking about the proper location of indentification lamps on one-man truck-tractor cabs that are offset from the vertical centerline of the vehicle. In your view "when the Law is applied to one (1) man cabs, the possibility exists that oncoming traffic would interpret the truck as not being in its proper traffic lane."

As you have pointed out, front identification lamps are required by Table II of Standard No. 108 to be "as close as practicable to the tope of the vehicle . . . as close as practicable to the vertical centerline. . . ." The "vertical centerline" is that of the vehicle which is usually that of the cab as well. However, an identification lamp arrangement around the vertical centerline of an offset cab is considered to meet the standard.

We are not aware that an actual safety problem is presented by the current practice of mounting identification lamps around the centerline of offset cabs, and the fact that you produce less than 1,000 vehicles per year does not relieve you of the requirement of providing these lamps.

Yours truly,

ATTACH.

Young Daybrook Inc.

November 16, 1973

U.S. DEPARTMENT OF TRANSPORTATION -- NATIONAL HIGHWAY SAFETY ADMINISTRATION

Gentlemen:

We request your assistance in interpreting FMVSS #108; Lamps etc., as applied to the vehicles we manufacture under the "OTTAWA" name and illustrated in the attached brochure #30-2500-4/73. These vehicles are all over 10,000# GVW; all over 80" in width; and all have one (1) man cabs, either 37" or 48" wide; located left of centerline of the vehicle.

The Law requires all truck tractors to have three (3) amber identification lamps "As close as practicable to the verticle centerline". When the Law is applied to one (1) man cabs, the possibility exists that oncoming traffic could interpret the truck as not being in its proper traffic lane.

Your earliest possible response would be appreciated and should it be pertinent, we produce fewer than 1000 trucks per year.

Very truly yours, James H. Swinghammer -- Assistant Chief Engineer

Attachment

ID: nht75-1.33

DATE: 08/25/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: John H. Mueller -- Manager, Engineering Standards

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of March 25, 1975, which suggested an inconsistency in the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses.

S5.1 of the standard requires each hydraulic brake hose assembly to be equipped with end fittings which are attached by means of crimping or swaging. You have correctly pointed out that S5.2.3 specifies labeling requirements for "hydraulic" end fittings which are neither crimped nor swaged, even though at present there are no hydraulic fittings that fit that description. This language appears as part of S5.2 because S5.2 is incorporated by reference in and assemblies used in air and vacuum brake systems, respectively. Although there is thus no inconsistency, the National Highway Traffic Safety Administration is considering a clarifying amendment along the lines you have suggested, which would eliminate S5.2.3 and specify the labeling requirements directly in S7.2 and S9.1.

Thank you for pointing out this potential source of confusion.

Sincerely,

March 25, 1975

Reference: MUE-534

Richard B. Dyson -- Assistant Chief Counsel, National Highway Traffic Safety Administration

Subject: FMVSS 571.106 Para. S5.2.3 Labeling Hydraulic Brake Hose End Fittings

Dear Mr. Dyson:

The standard erroneously specifies labeling for certain end fittings that are not allowed by the standard's construction requirements. Please consider the following explanation and recommendation.

Notice 16 reiterates that hydraulic brake hose assemblies must be made with the end fittings crimped or swaged onto the hose. Consistent with the Notice, Paragraph S5.1 requires all assemblies to be crimped or swaged. Unfortunately, Paragraph S5.2.3 then explains how to label end fittings that are not crimped or swaged.

Since the standard does not allow end fittings for hydraulic brake hose that require labels, no label should be described. An appropriate correction would be to drop Paragraph S5.2.3 from the standard. Air brake hose end fittings that do require labels could then be regulated under Paragraph S7.

Yours very truly,

THE WEATHERHEAD COMPANY --

John H. Mueller,

Manager, Engineering Standards

ID: nht75-2.27

DATE: 03/11/75

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

TO: Joseph Lucas North America Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 7, 1975, in which you ask whether the control lever/throttle arm of diesel fuel injection equipment is considered part of the pump mechanism or part of the "linkage," i.e. the accelerator control system, within the meaning of Standard No. 124.

The control lever/throttle is similar to the throttle lever referred to in Docket 69-20, Notice 5 (copy attached). In that notice, we established that the throttle lever is not part of the "driver-operated accelerator control system", but rather part of the fuel metering device and therefore does not fall within the ambit of Standard No. 124.

Yours truly,

ATTACH.

February 7, 1975

Fred Schwartz -- Attorney Advisor, Office of the Chief Counsel, National Highway Traffic Safety Admin.

Dear Mr. Schwartz:

FMVSS 124 - Accelerator Control Systems

Joseph Lucas North America Inc. is a subsidiary of Joseph Lucas (Industries) Ltd. of England. Two other subsidiaries, CAV Limited and Simms Motor Units Limited manufacture diesel fuel injection equipment, some of which is exported to the United States fitted to engines, or as sold by Joseph Lucas North America Inc.

A question has arisen concerning the control lever/throttle arm on these pumps. Is this lever/arm part of the pump or it is part of the linkage?

Enclosed are two publications:

1. Publication No. 2067/4 - CAV DPA Distributor Type Fuel Injection Pump with Mechanical or Hydraulic Governor. The Green arrows on pages 2, 66, 67, 68, and 69 point out the item in question.

2. Publication P29E - Simms Mechanical Fuel Injection Pump. The green arrows on pages 2 and 3 point out the item in question.

We feel that this lever/arm is part of the injection pump, and not the linkage. Would you please confirm that our interpretation is correct?

Any help which you could give us in correctly interpreting the definition of such a pump mounted lever/arm would be appreciated, so that we may correctly appraise the arrangements on other such pumps.

Yours truly, JOSEPH LUCAS NORTH AMERICA INC. -- A. J. Burgess, Vice President (Technical)

Enclosures

ID: nht75-4.13

DATE: 08/25/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Dana Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Dana Corporation's July 11, 1975, question whether a system which controls a truck engine throttle from a remote location by means of compressed air from the truck's brake system would violate the requirements of Standard No. 121, Air brake systems.

The answer to your question is no. Standard No. 121 does not contain a prohibition on the use of air pressure from the air brake system for powering auxiliary devices. The vehicle must of course conform to Standard No. 121 following installation of the device, if the installation occurs prior to the first purchase in good faith for purposes other than resale. For example, the compressor build-up pressure would still be required to meet S5.1 of the standard.

Although not a requirement of the standard, the NHTSA does consider it appropriate that a pressure protective valve be placed in the line to the auxiliary device so that a rupture of an auxiliary line does not cause depletion of air pressure in the brake system.

SINCERELY,

DANA CORPORATION . TECHNICAL CENTER

July 11, 1975

Chief Council U.S. Department of Transportation

We are presently involved with the design and development of a system used in the control of truck engine throttles. The system will require compressed air for its actuation which will be obtained from the air supply used in the vehicle's air brake system. This system will primarily be used on refuse packers during the pack cycle. The time per pack cycle will be one minute or less with a system's air consumption of .375 cubic feet at a regulated pressure of 35 pounds per square inch and having a free air flow of .358 cubic feet.

With data available to you, I would like to know if, when using our system, the manufacturers will be in any violation of the FMVSS No. 121, Air Brake Systems. I am mostly concerned with paragraphs S5.1.1, S5.1.2, and S5.1.2.1 referring to compressors and reservoirs.

Having this information, we can assure the truck manufacturers that our system will not in any way put them in jeopardy of any vehicle safety standards set forth by the U.S. Department of Transportation.

If you have any questions, please feel free to contact me.

Robert J. Ostrander Development Engineer