ID: aiam3290

Dear Mr. Boyd: This responds to your recent letter requesting confirmation that larg commercial truck tractors do not have to comply with Federal Motor Vehicle Safety Standard No. 216, *Roof Crush Resistance*. You also asked whether large trucks should be designed to comply with the 'belt system' option under Safety Standard No. 208, *Occupant Crash Protection*.; You are correct in your assumption that large commercial trucks woul not have to comply with Safety Standard No. 216 since that standard only applies to passenger cars. You are also correct in stating that trucks with a GVWR greater than 10,000 pounds may meet the seat belt option of Safety Standard No. 208 found in paragraph S4.3.2 Under S4.3.1, manufacturers do have the option of meeting the crash protection requirements of S5 by means that require no action by vehicle occupants (with current technology this means air cushion restraints or automatic seat belts). Further, vehicles manufactured prior to August 15, 1977, were permitted to comply with Safety Standard No. 216 in lieu of the 'rollover' requirements of Standard No. 208, and for large trucks this would have been a simple test to meet. However, since the vehicle would also have been required to meet the 'frontal' and 'lateral' requirements by automatic means if option S4.3.1 were taken, no truck manufacturer chose to comply with the 'rollover' requirements of Standard No. 208 via the Standard No. 216 option. Rather, seat belts were installed on all large trucks.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0048

Dear Mr. de Castelet: Thank you for your letter of December 1, 1967, concerning tests make o the Renault 10 model for compliance with Federal Motor Vehicle Safety Standard No. 203.; We recognize the validity of a system which takes advantage of th energy absorbing characteristics of the surrounding vehicle structure as on alternative to the more conventional approach of employing an energy absorbing column and/or wheel. As you mentioned, SAE J944 was not written with that type of energy absorbing system in mind. The structure which you intend to employ to provide the energy absorbing requirements specified in Federal Motor Vehicle Safety Standard No. 203 might in reality first be severely stressed and deformed in a crash situation. Therefor any laboratory test used to evaluate such a system should recognize this detrimental influence. In the event that you would wish to submit a proposed alternative test procedure which incorporates a barrier test as specified in Standard No. 204 prior to testing for compliance with Standard No. 203, we would be pleased to consider such a request.; Your second point concerns the need for a more explicit definition o translational motion. SAE J944 states that the body-block *contracts* the wheel in translational motion. It does not say that this motion must continue after impacting the wheel Your magnetic release mechanism appears to impart approximately translational motion to the body-block at impact and is a satisfactory procedure. The fact that the body-block is free to rotate forward after impact is a simulation of an actual crash restrained in translational motion *after* impact. Since the body motion in an actual crash situation will vary somewhat the Bureau feels that a more explicit definition of translational motion is unnecessary.; The third series of test as described in Report No. 207.397 using rigid test fixture and the free flying body-block are compatible with the SAE J944 test procedure.; Your interest in motor vehicle safety is appreciated. Sincerely, William Haddon, Jr., M.D., Director

ID: aiam1616

Dear Mr. Hamilton: NHTSA Regional Administrator Hall has forwarded your letter of Augus 27, 1974 for our comments.; I enclose a copy of an information sheet: 'Where to Obtain Moto Vehicle Safety Standards and Regulations.' The standards that apply to 'motorcycles' are those that apply to mopeds. Some of these standards contain lesser requirements for 'motor-driven cycles'--motorcycles with 5 H.P. or less. I also enclose a copy of recent amendments to the standards, specifically directed towards motor-driven cycles including mopeds. We have no standard for snowmobiles as they are not 'motor vehicles' under our jurisdiction.; Our current fuel system integrity standard (No. 301) does not cove buses. The new standard effective September 1, 1975 (No. 301-75) will include a wider range of motor vehicles including buses of 10,000 lbs. or less gross weight, but only those that use fuel with a boiling point above 32 degrees F.; Four-wheel drive 'jeep'-type vehicles such as the Haflinger hav generally been classified by their manufacturer as 'multipurpose passenger vehicles.' This category of vehicle, is defined as a vehicle 'designated to carry 10 persons or less which is constructed either as a truck chassis or with special features for occasional off-road operation.' A Haflinger model 'designed primarily for the transportation of property or special purpose equipment,' however, would be a 'truck.'; I hope this answers your questions. Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: nht74-4.5

DATE: 06/20/74

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

TO: Wagner Electric Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 7, 1974, request to know whether check valves or equivalent devices must be placed immediately adjacent to or within each service reservoir in a trailer air brake system to comply with S4.2.1.5 of Standard No. 121, Air brake systems, and whether the standard intends each axle subsystem to have a separate service reservoir and check valve system, with particular regard to arrangements for liftable axle systems. S5.2.1.5 states:

S5.2.1.5 Each service reservoir shall be protected against loss of air pressure due to failure or leakage in the system between the service reservoir and its source of air pressure by check valves or equivalent devices.

The answer to both of these questions is no. In an April 3, 1974, letter to Great Dane Trailers, Inc., we interpreted S5.2.1.5 to permit location of the check valve at the isolated reservoir, permitting that valve to also guard the service reservoirs on that axle system. The language of S5.2.1.5 is unclear in this regard, and may be amended in the future. In response to your specific question, it is permissible to use a single check valve to protect more than one reservoir in a subsystem.

Standard No. 121 does not require a separate service reservoir check valve for each axle system in a tandem axle. As you point out this could decrease total vehicle reliability, and abuse in this area could lead to amendment of the provision. In answer to your fourth question, a single check value could be utilized to protect the air reservoir or reservoirs required for a liftable axle system or subsystem.

Yours truly,

WAGNER ELECTRIC CORPORATION

May 7, 1974

National Highway Traffic Safety Administration

Attention Lawrence R. Schneider, Chief Counsel

Re: Docket 74-10; Notice 1 49 CFR 571.121

SUBJECT: Request for Interpretation

As a supplier to the motor vehicle industry of air brake equipment designed to meet the requirements of FMVSS-121, we find ourselves faced with a constant responsibility to provide this equipment in the most economical form. Competitive influences and customer confidences demand this response from the equipment suppliers. The possible combination of several components essential to the FMVSS-121 trailer air brake system and related economies hinges on the degree of latitude allowed in the meaning intended for Section 5.2.1.5. We realize, however, that economy should not prevail if, in fact, there is any significant reduction in overall safety or system protection.

In designing and constructing air brake systems to meet the requirements of FMVSS-121, we have considered several approaches to the means of complying with Section S5.2.1.5, particularly with regard to the definition of the system connecting the trailer service reservoir with its source of air pressure. For convenience in reference, we reprint S5.2.1.5 below with the word "system", which is specifically in question, underlined.

S5.2.1.5 Each service reservoir shall be protected against loss of air pressure due to failure or leakage in the system between the service reservoir and its source of air pressure by check values or equivalent devices.

It has been difficult for us to assess how much of the trailer air brake system is considered by NHTSA to be included in the wording . . . between the service reservoir and its source of air pressure . . .", particularly when the ultimate source of air pressure to charge said reservoir is located on another vehicle, the self-propelled towing vehicle, in the form of its air compressor.

In the case of a vehicle application where it is advantageous to use several reservoirs in a separate but connected subsystem, the possibility is presented of using a single check valve conveniently placed to protect the subsystem.

Question #1: Is it permissible to use a single check valve to protect a plurality of reservoirs in a subsystem?

One interpretation is that all of the air lines existing between the point of coupling to the towing vehicle (the supply air line coupler) and the service air reservoir are subject to failure or leakage, and that the protecting check valve or equivalent device is to be placed immediately adjacent to or within the reservoir.

This location of the check value or equivalent device would give the required protection for all failures or leakages occurring between the air reservoir and any source of air pressure notwithstanding a failure in the check value itself.

We have interpreted the "source of air pressure" for a service reservoir to be the last connection to that reservoir. This precludes the use of tubing or hose between some remotely-located device and the reservoir port.

Question #2: Must the check valve or equivalent device be either (1) immediately adjacent to [coupled at the reservoir port] or (2) within the service reservoir?

Any alternative location allowed for the protective device gives rise to either a need for redefinition of the intent of S5.2.1.5 or an interpretation of the meaning of the one word "system" as used in this particular section, hence our request for clarification.

We have read several preamble statements in 121-related Dockets (73-13, Notice 1; 73-13, Notice 3; 74-10, Notice 1) which emphasize the Administration's opinion that axle-by-axle systems, i.e. separate systems for each axle of a truck, enhance the total vehicle reliability. Does this same safety philosophy apply to trailers and to the service reservoirs on trailer axles? To paraphrase this, we submit

Question #3: Is it intended for each axle subsystem to have separate service reservoir and check valve provisions?

If the answer to Question #3 is negative, there is a further possibility that a separate definition is required to differentiate between (1) protection for a single-axle trailer and (2) protection for tandem or multiple-axle trailers.

To extend this idea further for installations on multiple-axle trailers where one or more "liftable" axles are employed, an additional question arises.

Question #4: May a single check valve be utilized to protect the air reservoir or reservoirs required for the "liftable" axle system or subsystem?

We have asked for interpretations rather than for rule changes so that these matters will not give cause for delaying the effective date for FMVSS-121 Air Brake Systems.

John W. Kourik

Chief Engineer, Automotive Products

ID: aiam1410

Dear Mr. Gerth: This is in reply to your letter of December 11, 1973, asking whethe each of the following tire labeling formats used by the Michelin Tire Corporation complies with Motor Vehicle Safety Standard NO. 109:; 1. '2 steel tread plies/ 2 rayon body plies', 2. 'max. load 1,310 lbs at 36 psi max press.' We find that the first label format fails to conform to the standard Paragraph S4.3(e) requires the tire to be labeled with, 'the actual number of plies in the sidewall, and the actual number of plies in the tread area, if different.' The labeling format used by Michelin creates the impression, contrary to the stated requirements, that the number of plies in the sidewall and the tread area is the same. *viz.* '2'. We consider the body plies, running from bead to bead and lying under the plies in the tread area, to be counted also as plies in the tread area. Thus, the number of plies in the tread area is '4', 2 steel and 2 rayon. Moreover, while we understand the words 'body plies' to be essentially synonymous with 'sidewall plies', we fell there is little justification for departing from the word of the standard, which uses the word 'sidewall' in referring to plies.; We find the second labeling format, that dealing with maximu permissible inflation pressure and maximum load rating, to conform to Standard No. 109. The words 'permissible,' 'inflation,' and 'rating' are not essential to conformity as long as the appropriate values, clearly identified, are provided.; For your information, I point out that NHTSA test laboratories ar without authority to interpret Federal motor vehicle safety standards or provide such interpretations to companies whose products they test. Only interpretations issued in the form of correspondence signed by authorized NHTSA personnel or by notice published in the *Federal Register* are considered by this agency to be binding.; Sincerely, Lawrence R. Schneider, Chief Counsel

ID: nht80-1.3

DATE: 01/08/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Honorable Harold Runnels, House of Representatives

TITLE: FMVSS INTERPRETATION

TEXT: This further responds to your November 14, 1979, letter to the Secretary of Transportation concerning Mr. Richard D. Browning's interest in the conversion of automotive engines to run on propane.

From Mr. Browning's letter, I gather that he seeks to produce and market a converter system which will allow conversion of gasoline motors to propane. I have described below the way in which the legislation and regulations under which the National Highway Traffic Safety Administration operates might apply to Mr. Browning's venture. This agency lacks the authority to deal with any emissions control issues arising from production and use of a propane converter system, but the Environmental Protection Agency may have requirements which would apply to such a system. Therefore, we have also referred your letter to that agency in an attempt to expedite a response on this issue.

To date, the National Highway Traffic Safety Administration (NHTSA) has not exercised its authority pursuant to the National Traffic and Motor Vehicle Safety Act, as amended 1974 (14 U.S.C. 1381 et seq.) (the Act), to issue a safety standard applicable to propane-powered vehicles. Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity, applies only to vehicles which use fuel with a boiling point above 32 degrees F., and propane has a boiling point well below this temperature. Despite the absence of safety standards specifically applicable to propane-powered engines, a manufacturer or installer of these systems may be subject to other Federal requirements.

Under the Act (sections 151-158), the manufacturer of a propane fueled engine or of the components used for converting a gasoline-fueled engine to propane would be responsible for any safety-related defects in that equipment regardless of whether it were installed in new or in used vehicles. Upon discovery of a safety-related defect by either the Secretary of Transportation, the NHTSA Administrator, or the manufacturer himself, the manufacturer would be required to notify vehicle owners, purchasers and dealers and provide a free remedy for the defect.

Under NHTSA safety regulations, a person who alters a new vehicle prior to its first purchase in good faith for purposes other than resale is required to attach an additional label to the vehicle certifying that, as altered, the vehicle remains in compliance with all applicable safety standards (49 CFR 567.7). This requirement would apply to a person who alters a new vehicle to install a propane fuel system. (See the enclosed pamphlet listing the Federal motor vehicle safety standards and an information sheet explaining where to obtain copies of the standards.) Additionally, should noncompliance be caused by the modification, the alterer could be liable for a civil penalty unless he or she could establish that he or she did not have actual knowledge of the noncompliance and that he or she did not have reason to know in the exercise of due care that the vehicle did not comply. (Section 108(b)(2)).

A person who installs a propane-fueled engine or converts the gasoline-fueled engine in a used vehicle is not required to affix an alterer's label. However, if that person is a manufacturer, distributor, dealer, or motor vehicle repair business, he must not in the course of installing the propane components knowingly render inoperative any device or element of design originally installed in the vehicle in compliance with applicable Federal motor vehicle safety standards. (Section 108(a)(2)(A) of the Act)

I hope that you will find this response helpful. If you or your constitutent have any further questions on this issue, I will be happy to answer them.

SINCERLY,

RUIDOSO STATE BANK

November 7, 1979

Congressman Harold Runnels

Dear Harold,

Earlier today, I talked with your administrative assistant, Larry Morgan, in connection with a business venture which I am involved in.

The nature of the venture itself is one of an alternate energy type, being the invention and perfection of a converter system which will allow conversion of gasoline motors to propane. As you are aware, I'm sure, these propane conversion kits are already on the market; however, there is some draw-back to their use in the fact that they are not as efficient as they might be.

The unit which we have under consideration at this time appears to have a great deal of advances in its design, both in simplicity and effectiveness which we feel further benefits the use of such a unit in replacement for gasoline.

Our first question of you is, what regulatory authority will we need to pursue to get an approval for the unit in relation emission control, etc.? Through our conversations with other people, they felt that the Environmental Protection Agency in Washington would be the agency that we dealt with; however, we are not totally sure that that is the only agency that we have to deal.

Secondly, considering the clean-burning quality of propane gas, we don't feel that there will be a great deal of problem in getting an approval from the EPA; however, we need to know exactly what steps should be taken in reference to that approval.

Through the use of this new unit, we hope to use a product for fuel which, as you well know, is presently a by-product and is often a waste product of the petroleum industry. It becomes apparent that if large companies convert massive numbers of delivery vehicles, etc. to the system, that their fuel cost can be cut by approximately two-thirds thereby cutting the inflationary spiral of gasoline cost. Not even to consider the fact that the propane is not presently being used to its utmost capability; and is often being wasted.

We would consider it a personal favor from you if you will make the inquiry for us to whatever agency is appropriate and ask that they respond in some short time period. Time is of the essence to us in the fact that the sooner that we get all the necessary approvals and the unit into production, the sooner all the benefits which are available from the unit can begin to be reaped.

Harold, I would like to take this opportunity to thank you for your many considerations in reference to all of our problems in southeastern New Mexico; and I hope that when and if you get to Ruidoso, you will "holler" at us so that we might show you the unit in person.

I hope that everything is going well for you and that your endeavors in Washington are beneficial for both you and the State.

Thank you for your time and attention.

Richard D. Browning Executive Vice President

ID: aiam0081

Dear Mr. Ruegg: Thank you for your letter of May 2, 1968, which included additiona information for certification under Public Law 89-563 and your comments.; You will note that Federal Motor Vehicle Safety Standard 108 does no restrict the height of the identification lamps from the roadway. You may find it suitable to mount these lights at a lower level than indicated in your illustrations.; With respect to the requirements of Standard No. 108, I must point ou that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.; I am enclosing a copy of the National Traffic and Motor Vehicle Safet Act of 1966 which defines the vehicles to which it applies.; Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service;

ID: aiam3993

Dear Mr. Greenhaus: Thank you for your letter of July 8, 1985, to Stephen Oesch of m staff. You asked us to confirm your understanding of how our regulations would affect the alteration of a new vehicle prior to its sale.; Your question specifically relates to a situation in which a deale wants to switch, prior to sale of the vehicle, the bucket seats from one new motor vehicle to another new vehicle of the same model. You explained in a phone conversation with Mr. Oesch that changing the seats might involve some cutting and welding of the seats or their tracks. Under Part 567.7 (49 CFR Part 567.7) of our regulations, we would consider the dealer to be an 'alterer'. After completing the alteration, the dealer would be required by Part 567.7 to certify that the vehicle, as altered, complies with all applicable Federal Motor Vehicle Safety Standards. Depending on the specific design of the vehicle seat and the actual alterations performed, the replacement of a seat would be affected by Federal Motor Vehicle Safety Standard No. 207, *Seating Systems*, and could be affected by Standard No. 208, *Occupant Crash Protection*, and Standard No. 210, *Seat Belt Assembly Anchorages*.; Thank you for providing us with the information on glass tinting. hope this information on vehicle alteration is of assistance to you. If you have further questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel

ID: aiam3994

Dear Mr. Greenhaus: Thank you for your letter of July 8, 1985, to Stephan Oesch of m staff. You asked us to confirm your understanding of how our regulations would affect the alteration of a new vehicle prior to its sale.; Your question specifically relates to a situation in which a deale wants to switch, prior to sale of the vehicle, the bucket seats from one new motor vehicle to another new vehicle of the same model. You explained in a phone conversation with Mr. Oesch that changing the seats might involve some cutting and welding of the seats or their tracks. Under Part 567.7 (49 CFR Part 567.7) of our regulations, we would consider the dealer to be an 'alterer'. After completing the alteration, the dealer would be required by Part 567.7 to certify that the vehicle, as altered, complies with all applicable Federal Motor Vehicle Safety Standards. Depending on the specific design of the vehicle seat and the actual alterations performed, the replacement of a seat would be affected by Federal Motor Vehicle Safety Standard No. 207, *Seating Systems*, and could be affected by Standard No. 208, *Occupant Crash Protection*, and Standard No. 210, *Seat Belt Anchorages*.; Thank you for providing us with the information on glass tinting. hope this information on vehicle alteration is of assistance to you. If you have further questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel

ID: aiam3992

Dear Mr. Greenhaus: Thank you for your letter of July 8, 1985, to Stephen Oesch of m staff. You asked us to confirm your understanding of how our regulations would affect the alteration of a new vehicle prior to its sale.; Your question specifically relates to a situation in which a deale wants to switch, prior to sale of the vehicle, the bucket seats from one new motor vehicle to another new vehicle of the same model. You explained in a phone conversation with Mr. Oesch that changing the seats might involve some cutting and welding of the seats or their tracks. Under Part 567.7 (49 CFR Part 567.7) of our regulations, we would consider the dealer to be an 'alterer'. After completing the alteration, the dealer would be required by Part 567.7 to certify that the vehicle, as altered, complies with all applicable Federal Motor Vehicle Safety Standards. Depending on the specific design of the vehicle seat and the actual alterations performed, the replacement of a seat would be affected by Federal Motor Vehicle Safety Standard No. 207, *Seating Systems*, and could be affected by Standard No. 208, *Occupant Crash Protection*, and Standard No. 210, *Seat Belt Assembly Anchorages*.; Thank you for providing us with the information on glass tinting. hope this information on vehicle alteration is of assistance to you. If you have further questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel