ID: aiam5166

"Dear Mr. Byers: This letter responds to your inquiry regarding th alternate placement of a vehicle certification label in your 'Aeromate' van. I apologize for the delay in responding. As you noted in your letter, 49 CFR 567.4 requires that a motor vehicle manufacturer affix a certification label to each vehicle it makes, and permits the manufacturer to place the label in any one of the places listed in that provision. If none of the listed locations is practicable, 567.4 directs the manufacturer to suggest an alternate position for the affixed label, and to request National Highway Traffic Safety Administration (NHTSA) approval for that position. You explain in your letter that in your 'Aeromate' vehicle, the driver's door slides between an inner and outer metal panel, thus making it impossible to affix the label to the hinge pillar, door-latch post, or the door edge that meets the door-latch post. Based on the photographs you included with your letter, affixing the label to the inside of the driver's side door would be unacceptable because, when opened, the door slides between the two metal panels. Thus, when the door is in the open position, the label would be obscured from the view of any observer. You propose installing the label on the inner metal panel in front of the driver's side door opening, to the left of the driver's legs under the instrument panel, and include photographs showing the label affixed to the proposed position. You state, and your photographs appear to confirm, that the location would be visible from the driver's position, and for inspection by officials. In directing a manufacturer to put its certification label in those places set out in 567.4, NHTSA's purpose is to make these labels easy to see and read. Based on the information you supplied, the agency determines that for this particular vehicle design, installing the certification label as you propose will facilitate seeing and reading the label. On the other hand, placing the label as specified in 567.4 may not be practicable and might interfere with unobstructed viewing of the label. Therefore, on the condition that your company's label complies in all other respects with 567.4, NHTSA grants your request to install the certification label on the inner metal panel in front of the driver's door opening as shown in the photographs that you provided to us. I hope this information is helpful. If you have any further questions, feel free to contact David Elias of my office at the above address or by phone, at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel";

ID: aiam3424

Dear Mr. Sundelin: This responds to your recent letter asking for information concernin the requirements of Safety Standard No. 119 (49 CFR S 571.119), as it applies to motorcycle tires. Specifically, you asked what markings must be on the sidewalls of knobby motocross tires (motorcycle tires designed for off-road use) to satisfy the requirements of Standard 119.; If your company designs the tires exclusively for off-road use, with n expectation that they will be used when the motorcycle is on the public roads, Standard 119 is not applicable to the tires. Therefore, no markings would be required on the sidewall of the tires. On the other hand, if you believe the motocross tires will, in fact, be used on the public roads, as well as off-road, they must meet the marking requirements specified in section S6.5 of Standard No. 119 (copy enclosed).; Standard No. 119 and its marking requirements apply to all new tire designed for highway use on non-passenger-car motor vehicles. In response to the petitions for reconsideration of Standard 119, the agency stated that manufacturers of motocross tires would have to determine if the tires were designed for highway use (see 39 FR 5191, February 11, 1974, copy enclosed). In the absence of a showing to the contrary, however, this agency would assume that motorcycles equipped with motocross tires are ridden on the public highways to and from race competition or trail use, which would mean the tires are subject to the requirements of Standard 119.; Following the publication of the above-mentioned notice, a manufacture of motocross tires requested an interpretation of Standard 119, and stated that its motocross tires are not suitable for use on public roads, and are not designed for such use. The agency responded that such tires are not subject to the requirements of Standard 119, based on this set of circumstances.; However, as noted above, each manufacturer must make thi determination. Please note that if you decide that the tires are not subject to Standard 119, 49 CFR Part 574 prohibits the DOT certification label from appearing on the sidewall of the tire. Please further note that a manufacturer's determination of this point is not dispositive. That is, this agency has authority to independently re-examine the manufacturer's determination. If the manufacturer's determination was incorrect, the manufacturer would be liable for civil penalties of up to $1,000 for each tire imported into this county which did not meet all the requirements of Standard 119. If you need any further information on this subject, please do not hesitate to contact me.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0506

Dear Mr. Fetter: This is in reply to your letter of November 2, 1971, to Mr. Georg Shifflett of my staff, in which you ask questions relating to clearance lamp locations on your wrecker bodies.; I am concerned with your statement that 'there is no record of you department's approval on the clearance lamp corner mounting on the 750 and 850 bodies.' The National Highway Traffic Safety Administration does not 'approve' vehicles or equipment subject to the Federal motor vehicle safety standards. Conformance, and certification of that fact, are the manufacturer's responsibility under section 108(a) of the National Traffic and Motor Vehicle Safety Act of 1966. We are glad, however, to provide informal interpretations of the standards when requested to do so by manufacturers such as yourself.; Your first question is, 'Does the (low) location of the rear clearanc lamp meet the position requirements?'. Paragraph S4.3.1.5 of Federal Motor Vehicle Safety Standard No. 108 (effective January 1, 1972), permits a deviation in mounting height: 'When the rear identification lamps are mounted at the extreme height of a vehicle, rear clearance lamps need not meet the requirement of Table II that they be located as close as practicable to the top of the vehicle.' Thus, if the identification lamps are mounted at the extreme height of the vehicle, Standard No. 108 permits a location of clearance lamps at *any* height less than the extreme height of the vehicle. This does not change the requirement currently in effect (Table II).; Your second question is, 'Does the front clearance lamp location (o the body corner radius) on our 750 and 850 model bodies meet position requirements?'. Standard No. 108 currently requires front clearance lamps to be located 'as near as practicable to the upper left and right extreme edges of the vehicle.' The requirement effective January 1, 1972 is that these lamps be located 'to indicate the overall width of the vehicle . . . as near the top thereof as practicable.' It appears from the photographs you enclosed that the front clearance lamps should be mounted higher on the body front, unless you have a good reason for determining that it is not 'practicable' to do so.; I trust this will answer your questions. Sincerely, Francis Armstrong, Director, Office of Standard Enforcement, Motor Vehicle Programs;

ID: aiam3053

Dear Mr. Mulligan: This responds to your June 4, 1979, letter asking several question relating to manufacturer's responsibilities to maintain first purchaser lists and to certify vehicles in compliance with the safety standards.; Your first question asks whether a manufacturer is permitted to replac its first purchaser lists with lists of most recent purchasers when that information comes to a manufacturer's attention. You point out that Part 577, *Defect and Noncompliance Notification*, requires manufacturers to notify vehicle owners or the most recent purchaser known to the manufacturer.; The National Traffic and Motor Vehicle Safety Act of 1966 (as amended (15 U.S.C. 1381 *et seq*.) requires in section 158 (15 U.S.C. 1418) that manufacturers maintain lists of first purchasers of their vehicles. The purpose of this requirement is to facilitate the issuance of defect and noncompliance notifications to vehicle owners. Lists of the most recent purchasers of a manufacturer's vehicles would be even more efficient for recall purposes than would first purchaser lists. Accordingly, the National Highway Traffic Safety Administration has determined that maintaining lists of most recent purchasers of a manufacturer's vehicles satisfies the statutory requirement to maintain first purchaser lists.; In your second question, you ask about the labeling requirements o individuals that modify incomplete vehicles. IN the fact situation you present, International Harvester (IH) certifies a chassis-cab in accordance with the agency's certification regulations and transfers it to an IH dealer who performs some minor modifications on the chassis-cab prior to its delivery to a final-stage manufacturer. The IH dealership is either owned or controlled by IH. You ask what type of certification label the IH dealer should attach.; You suggest that an alterer's label might be the appropriate label t use. The other possibilities that you recommend are the use of an intermediate manufacturer's label or merely removing and amending the chassis-cab label attached to the incomplete vehicle. You suggest that the latter is more appropriate since the dealer modifying the chassis-cab is owned by IH, and therefore, it constitutes the same manufacturer that constructed the chassis- cab. You state further that to require an intermediate manufacturer's label appears to be inappropriate since that label would show that the chassis-cab and the intermediate manufacturer are both the same corporation.; Alterer's labels are only used by individuals or businesses modifyin vehicles that have been certified by a final-stage manufacturer. Therefore, an alterer's label would be inappropriate in this instance since the chassis- cab has not been certified as a completed vehicle.; The agency concludes that in the case where a manufacturer's wholl owned dealership is modifying a certified chassis, the label on the chassis-cab should be removed and a correct label should be added. In these instances, the chassis-cab is still within the control of the original manufacturer. Therefore, it is appropriate for that manufacturer to assume the responsibility for the modification made by its dealers. The dealer is not an independent business of the type that must attach an intermediate manufacturer's label. Accordingly, your dealer may amend the incomplete vehicle label as a result of its modifications.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam3054

Dear Mr. Mulligan: This responds to your June 4, 1979, letter asking several question relating to manufacturer's responsibilities to maintain first purchaser lists and to certify vehicles in compliance with the safety standards.; Your first question asks whether a manufacturer is permitted to replac its first purchaser lists with lists of most recent purchasers when that information comes to a manufacturer's attention. You point out that Part 577, *Defect and Noncompliance Notification*, requires manufacturers to notify vehicle owners or the most recent purchaser known to the manufacturer.; The National Traffic and Motor Vehicle Safety Act of 1966 (as amended (15 U.S.C. 1381 *et seq*.) requires in section 158 (15 U.S.C. 1418) that manufacturers maintain lists of first purchasers of their vehicles. The purpose of this requirement is to facilitate the issuance of defect and noncompliance notifications to vehicle owners. Lists of the most recent purchasers of a manufacturer's vehicles would be even more efficient for recall purposes than would first purchaser lists. Accordingly, the National Highway Traffic Safety Administration has determined that maintaining lists of most recent purchasers of a manufacturer's vehicles satisfies the statutory requirement to maintain first purchaser lists.; In your second question, you ask about the labeling requirements o individuals that modify incomplete vehicles. IN the fact situation you present, International Harvester (IH) certifies a chassis-cab in accordance with the agency's certification regulations and transfers it to an IH dealer who performs some minor modifications on the chassis-cab prior to its delivery to a final-stage manufacturer. The IH dealership is either owned or controlled by IH. You ask what type of certification label the IH dealer should attach.; You suggest that an alterer's label might be the appropriate label t use. The other possibilities that you recommend are the use of an intermediate manufacturer's label or merely removing and amending the chassis-cab label attached to the incomplete vehicle. You suggest that the latter is more appropriate since the dealer modifying the chassis-cab is owned by IH, and therefore, it constitutes the same manufacturer that constructed the chassis- cab. You state further that to require an intermediate manufacturer's label appears to be inappropriate since that label would show that the chassis-cab and the intermediate manufacturer are both the same corporation.; Alterer's labels are only used by individuals or businesses modifyin vehicles that have been certified by a final-stage manufacturer. Therefore, an alterer's label would be inappropriate in this instance since the chassis- cab has not been certified as a completed vehicle.; The agency concludes that in the case where a manufacturer's wholl owned dealership is modifying a certified chassis, the label on the chassis-cab should be removed and a correct label should be added. In these instances, the chassis-cab is still within the control of the original manufacturer. Therefore, it is appropriate for that manufacturer to assume the responsibility for the modification made by its dealers. The dealer is not an independent business of the type that must attach an intermediate manufacturer's label. Accordingly, your dealer may amend the incomplete vehicle label as a result of its modifications.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam2380

Dear Mr. Iinuma: This is in response to your January 26, 1976, question whether Standar No. 124, *Accelerator Control Devices*, requires that the throttle return to the 'idle position' within specified time limits in the case where an 'automatic speed control device' is in operation and a failure occurs in it.; The requirements of S5.1 and S5.2 of the Standard require a return o the throttle to the idle position when either one source of throttle 'return energy' or a component of the accelerator control system fails or is disconnected. In the case you describe, failure does not occur as outlines in S5.1 and S5.2. Therefore, this failure is not regulated by the standard. This is the case, because the NHTSA does not consider throttle-setting devices to be a component that 'regulate[s] engine speed in direct response to movement of the driver-operated control and that return[s] the throttle to the idle position upon release of the actuating force' as defined in S4.1. As set out in the definition of 'idle position', the agency considers the effect of a throttle-setting device to be a separate condition that affects the setting of the accelerator control system.; Yours truly, Frank Berndt, Acting Chief Counsel

ID: aiam1657

Dear Mr. Pieratt: This is in reply to your letter of October 1, 1974, in which you as whether a manufacturer who modifies a certified flat-bed trailer by adding beverage compartments and required lamps and reflectors may use the certification date of the trailer for determining conformity to applicable safety standards, rather than the date on which the modifications are completed.; We question your description of the trailer as certified by lacking floor, for this characterization would be unusual under the definitions provided in Part 568. It is difficult for us to envision a trailer being a 'completed vehicle' (requiring no further manufacturing operations to perform its intended function) if it lacks a floor, unless the floor is considered to be a readily attachable component, which we also view as unlikely. If, however, that is the case, the situation you describe is covered specifically in the requirements for vehicle alterers (49 CFR SS 567.7, 568.8). Section 567.7 of the Certification Regulations provides that a person who alters a vehicle that has been previously certified can certify the conformity of the altered vehicle as of any date between the date of manufacture of the original vehicle and the date the alterations are completed. This makes it unnecessary, unless the alterer chooses otherwise, for the vehicle to conform to standards which become effective after the date of the original certification.; This provision was intended to place the responsibility of alterers o a par with that of final-stage manufacturers for determining conformity to applicable standards. Some discussion of this point is contained in the preamble to the notice in which the vehicle alterer requirements were issued, and a copy is enclosed for your information.; The only other situation we can envision in which a trailer can b certified and still lack a floor would be one arising under S568.6, 'Requirements for manufacturers who assume legal responsibility for the vehicle.' If the incomplete or intermediate manufacturer has assumed responsibility for the vehicle, then the person adding the floor and beverage compartments, although a final-stage manufacturer, would be under no obligation to further certify the vehicle.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: nht87-1.12

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Chikada:

This is in reply to your letter of November 21, 1986, with reference to the distance between a front turn signal lamp and a lower beam headlamp.

In brief, SAE Standard J588e, incorporated by reference in Standard No. 108 requires a minimum separation distance of 4 inches between the optical axis (filament center) of the front turn signal lamp to the inside diameter of the retaining ring of the lo wer bean headlamp. You have pointed out that a replaceable bulb headlamp does not have a retaining ring, and you have presented two possible substitutes as a measuring point. The first (your Item A) is the outer edge of the headlamp, and the second (your Item B) is the end of the effective area of the reflector. You believe that Item B is the more appropriate.

We concur with your interpretation. Of the two options, the distance to the edge of the effective area of the reflector is the one most similar to the inside diameter of the retaining ring of the lower beam headlamp. The basis for this interpretation is the assumption that the headlamp lens between the outer edge of the headlamp and the edge of the effective area of the reflector is not used for production of the lamp's bean, has mo significant luminance, and therefore will not mask the turn signal.

Sincerely,

Erika Z. Jones Chief Counsel

November 21, 1986

Erika Z. Jones Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones,

Re : Distance between a front turn signal lamp and a low beam headlamp)

In Motor Vehicle Safety Standard N0.108, Paragraph 4.3.1.7, the following is prescribed:

S4.3.1.7 The requirement that there be not less than 4 inches between a front turn signal lamp and a low beam headlamp, specified in SAE Standard J588e, "Turn Signal Lamps," September 1970, shall not apply if the sum of the candlepower values of the turn signal lamps Measured at the test point within each group listed in Figure 1c is not less than two and one-half times the sum specified for each group for yellow turn signal lamps.

According to the SAE Standard J588e, the distance is defined as from the optical axis (filament center) of the front turn signal lamp to the inside diameter of the retaining ring of the headlamp unit providing the lower beam. This definition applies only to a standardized headlamp. What definition is appropriate for a replaceable bulb headlamp, in other words, an unstandardized headlamp? We think B in the following definition is appropriate.

A : From the filament center of the front turn signal lamp to the outer edge of a low beam headlamp

B : From the filament center of the front turn signal lamp to the end of the effective area of the reflector of a low beam headlamp

SEE HARD COPY FOR GRAPHIC ILLUSTRATION

ID: nht79-2.7

DATE: 02/13/79

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

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 15, 1978, petition asking for changes in Standard No. 222, School Bus Passenger Seating and Crash Protection, as that standard applies to the measurement of contact area. In particular, you ask the National Highway Traffic Safety Administration (NHTSA) to amend the standard adopting a specific test medium for measuring contact area and deleting the existing list of acceptable contact area test mediums currently established in the agency's compliance test procedures.

On July 19, 1978, the NHTSA responded to an earlier petition (December 20, 1977) submitted by you on this same issue. In that letter, the NHTSA denied your requested amendment of the standard. Your current petition presents no additional data or arguments supporting your suggested modification that were not presented and thoroughly considered in our determination of your first petition. Accordingly, for the reasons specified in our July 19, 1978, letter to you, the agency denies your suggested rulemaking.

In your August 15 petition, you suggested that Standard No. 222 should incorporate more detailed test procedures, because some of the agency's other safety standards specify test procedures in greater detail. Standard No. 222 currently specifies test procedures to be used by manufacturers in complying with the standard. However, like all of the agency's standards, Standard No. 222's compliance test procedures are even more detailed than the requirements specified in the standard.

The NHTSA writes safety standards as simply as possible while providing the necessary detail for manufacturers to comply with their requirements. A manufacturer is then permitted to develop its own test procedures as long as its procedures are compatible with the requirements of the standard. The NHTSA, itself, devises tests that it uses for testing a vehicle's compliance. Whenever possible, these tests are available to manufacturers, and manufacturers are free to adopt them or to proceed with their own test procedures. Your twice-submitted petition would have the NHTSA rewrite its standards in a manner that would specify test procedures in greater detail. Such an approach would increase the complexity of safety standards if done uniformly to all standards and would in fact be detrimental to small manufacturers. The purpose of allowing some variation in details of test procedures is to permit a manufacturer to develop test procedures that are tailored to that manufacturer's needs and constraints. For example, certain test procedures used by the NHTSA may be too costly for a small manufacturer. Under the current compliance system, any manufacturer can develop a less expensive alternative test methodology. Under the system that you propose, however, a manufacturer would be required to adopt the test procedures specified in the standard. Since your suggestion, if applied to all safety standard, could add costs to the agency's regulations without achieving any significant benefits, the NHTSA determines that your suggested amendment is not in the public interest.

SINCERELY,

BLUE BIRD BODY COMPANY

August 15, 1978

Joan Claybrook Administrator National Highway Traffic Safety Administration

PETITION

References: 1. W. G. Milby Petition of December 20, 1977. 2. J. J. Levin to W. G. Milby, NOA-30 July 19, 1978. 3. R & D 222 - MS - 78-01 - Impact Media Evaluation.

Dear Ms. Claybrook:

The purpose of this letter is to respond to reference 2 and to again petition the agency on the same subject as reference 1. The basis for this second petition is reference 3, which was not available when the first petition was submitted and apparently was not consulted by the agency before denying reference 1.

To quote a ranking NHTSA official, "regulation without enforcement is meaningless." We agree. But to have enforcement, there must be a repeatable procedure which all interested parties use. Otherwise test results are not comparable. When methodology causes significant variance in the test results, then, methodology must be addressed before rational enforcement can exist.

Today, as documented in reference 3, the allowable variations in test methodology regarding FMVSS 222 contact area cause significant variance in the test results and prevent rational enforcement. This is the reason we submitted reference 1, a petition requesting rulemaking action on FMVSS 222 which would require and allow only one transfer medium for measuring contact areas.

Reference 2 denies that petition. However, we believe the reasons which the agency set forth as a basis for the denial are not valid. Further, the agency did not address the content of the proposed amendment in reference 1. Each of the reasons the agency gave for denying reference 1 is discussed below with comments showing why they are not valid.

1. The first reason NHTSA gave for denial was that the agency does not specify the "details for manufacturer testing . . .", but instead, leaves it up to each manufacturer to determine how to test. We do not believe this is true in all cases. For example, FMVSS 121 goes into significant detail for air brake testing. FMVSS 209 goes into even more detail on seat belt assemblies, with the demonstration procedures alone requiring 11 pages. Therefore we conclude that the NHTSA does specify details in a standard when it is consisted with good rulemaking.

2. The second reason for denial was that the agency does adopt certain test procedures for use in its own compliance testing and that manufacturers are free to use these test procedures. It is true that NHTSA has published test procedures for FMVSS 222. However, these procedures are inadequate with respect to contact area measurement methodology as was spelled out in detail in reference 1. The basis of our petition, reference 1, was that the test procedures for FMVSS 222, as well as the standard itself, contains inadequate detail to insure consistent contact area measurements. Therefore, simply stating that NHTSA has published test procedures is not a valid reason for denying the petition.

3. NHTSA's third reason for denying the petition was that NHTSA makes the test procedures public and manufacturers are welcome to use them for their own testing. While it is true that the test procedures are eventually made public, reference 1 points out the fact that test procedures are sometimes not made public in time for manufacturers to use them for certification testing. In fact, we were not able to get the FMVSS 222 test procedures until December 9, 1977, and that was only in response to our request made under the Freedom of Information Act.

4. The fourth reason given for denial of the petition was that "the transfer medium specified in the NHTSA compliance test are for the purpose of convenience of NHTSA testing." We do not believe that the convenience of NHTSA testing should be given higher priority than the need for specifying procedures which will give repeatable results. In fact, as the standard and test procedures now allow more than one transfer medium, it results in inconvenience to all parties involved, including NHTSA, rather than convenience. This is so because allowing different transfer media causes different results which then generate false indications of non compliance. This is very costly as well as inconvenient to all parties involved.

None of these reasons, in our opinion, is a valid basis upon which to deny our petition reference 1. Since this issue must be resolved before enforcement of this part of the standard can occur, we hereby again petition NHTSA to amend FMVSS 222 as follows:

1. Change paragraph 6.8 to read "Except for during contact area measurement impacts, the head form and knee form, and contactable surfaces are clean and dry during impact testing."

2. Add a new paragraph 6.8.1 to read "Prior to each contact area impact, use a bristle brush to apply a cost of latex base exterior house paint to the entire sperical surface of the head or knee form. Wipe the head or knee form clean after each contact area impact."

3. Add a paragraph 6.8.2 to read "Immediately after each contact area impact, record the contact area pattern by holding a piece of vellum drafting paper stationary over the pattern and firmly rubbing it."

4. Add a new paragraph 6.8.3 to read "After allowing contact area patterns to dry on the vellum paper, draw non intersecting lines tangent to the outer bounds of areas of direct contact. the contact area is that area enclosed by the periphery of these lines and the area of direct contact. Measure this area by tracing the periphery with a direct reading planimeter."

We look forward to receiving an affirmative response to this petition within 120 days.

Thank you.

W. G. Milby Manager, Engineering Services

ID: aiam0985

Dear Mr. Lange: Mr. Paul Utans asked us to provide you with an interpretation o paragraph S5.3.3 of Motor Vehicle Safety Standard No. 105a, *Hydraulic Brake Systems.* Mr. Utans asks for confirmation of his understanding; >>>'that the indicator lamp shall remain activated either without th application of any pedal force or with one application of a pedal force (with a range of 25 or 50 pounds, as the case may be) if a failure of the kind described in S5.3.1(a) to S5.3.1(c) exists in the service brake system.'; This interpretation is only partially correct. Paragraph S5.3.3 state in pertinent part:; '...each indicator lamp, once activated, shall remain activated as lon as the condition exists, whenever the ignition switch is in the on position. An indicator lamp activated when the ignition turned to the 'start' position shall be deactivated upon return of the switch to the 'on' ...position... unless a failure of the kind described in S5.3.1(a) to S5.3.1(c) exists in the service brake system.'<<<; Paragraph S5.3.1(a) allows a brake pressure failure to be initiall indicated either before or upon application of pedal force, but thereafter the light must remain activated while the ignition switch is in the 'on' position. However, if the failure is present when the vehicle is first started, the indicator lamp must immediately be activated before any application of pedal force, until the failure condition no longer exists.This interpretation is subject to modification by response to petitions for reconsideration of Standard No. 105a, scheduled for publication around May 1, 1973; Yours truly, Richard B. Dyson, Assistant Chief Counsel