ID: nht95-3.69

TYPE: INTERPRETATION-NHTSA

DATE: August 3, 1995

FROM: Thomas K. O'Connor -- Chief of Maintenance and Operations, Metropolitan Water Reclamation District of Greater Chicago

TO: Office of the Chief Counsel -- NHTSA

TITLE: Verification of Seat Belt Regulations for Step Vans Over 10,000 Pounds GVW-Federal Motor Vehicle Safety Standards (FMVSS) 207, 208, 209, and 210

ATTACHMT: ATTACHED TO 10/11/95 LETTER FROM JOHN WOMACK TO THOMAS K. O'CONNOR (A43; STD. 208)

TEXT: We are requesting written verification on the type of seat belt needed for our step van vehicles in order to comply with FMVSS 207, 208, 209, and 210. At issue is whether a lap-only seat belt versus a shoulder harness seat belt is needed for compliance. In a phone conversation between members of our respective staffs, we were informed that a lap-type belt would comply. We were further informed that written verification of this could be obtained by writing to your office.

In our field work, we use step vans with a Gross Vehicle Weight over 10,000 pounds, equipped with two front seats, a passenger's seat and a driver's seat. The passenger's seat is mounted on a metal pedestal which allows the seat to tilt forward, making e asier access to the rear. The driver's seat is stationary. If both the passenger and driver seats are certified by the manufacturer to comply with FMVSS 207, 208, and 210 when properly installed, and if a certified seat belt (FMVSS 209) is properly ins talled, the question arose as to whether a lap-only seat belt would comply with FMVSS 207, 208, 209, and 210, or whether a shoulder harness type belt had to be used.

If there are any questions concerning our request for written verification on this matter, please contact Sally Yagol of my staff at (708) 222-4080, from 7:00 a.m. to 3:00 p.m., CST, Monday-Friday.

Thank you for consideration.

ID: aiam2105

Dear Mr. Hunter: "This is in response to your letter of j September 22, 1975 requesting information concerning the applicability of Federal motor vehicle safety standards to automatic cruise control devices."; As you were advised by telephone, Motor Vehicle Safety Standard No 124, *Accelerator Control Systems*, does not preclude the use of cruise control units. while Standard No. 124 requires that the accelerator control device return to 'idle' when the operator removes his foot from the accelerator or when the system itself fails, the term 'idle position' is defined in S4.1 of the standard to include the position set by a throttle setting device. The rationale for not regulating automatic speed control devices is found in the preamble to the standard, issued in April 8, 1972 (37 FR 7097), which states:; >>>The rule does not contain requirements for automatic speed contro devices. It was found that although nine recall campaigns involving 61,176 vehicles have concerned these devices, no relationship to accelerator overspeed accidents could be established from automatic speed controls. Of the 540 multi-disciplinary accident reports that were studied in formulating the final rule, none mentioned the automatic system.<<<; There are no other Federal motor vehicle safety standards which ar concerned with the use of automatic cruise control devices.; I trust this information will be useful to you. I have enclosed a cop of Standard No. 24 for your future reference.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam0969

Dear Mr. Bornhauser: By letter dated October 2, 1972, you were advised by Andrew Detrick Director, Office of Defects Investigation, that the defect reports required by 49 CFR Part 573 are required to be filed with this agency when a safety related defect has been determined in a class of vehicles regardless of whether or not these vehicles were sold to the general public. In his letter, Mr. Detrick had directed his inquiry as to why no defect report had been filed with respect to certain 1973 model year Chrysler Corporation vehicles which appeared to have a safety problem in their ball joint assemblies. In your letter of response dated October 23, 1972, you advised that although Chrysler had undertaken to repair some 11,998 vehicles upon which the ball joint assembly in question had been installed through a notice to dealers dated August 17, 1972, the corporation had made a determination that no defect report was required to be filed under 49 CFR 573 because all of these vehicles were either in the hands of the manufacturer or the dealer and had not passed to the first purchaser. This is contrary to the position taken by this agency. Subsequently, on November 3, 1972, you advised us that some 2,560 vehicles had not been repaired an undetermined number of which had passed into the hands of purchasers. With respect to these 2,560 vehicles you filed an untimely defect report on November 3 and issued a notification to the purchasers. No defect report, however, has been received regarding the remainder of the vehicles in this class.; This is to advise you that we do not agree with your lega interpretation to the effect that defect reports are only required if the vehicles have passed into the hands of the purchasers. In our view, the reports are required to be furnished to this agency within five days of the determination of the existence of a safety related defect with respect to all vehicles subject to the defect that have been delivered to the distributor or dealer in addition to those which have been sold to the general public. Accordingly, Chrysler Corporation has failed and refused to file a timely defect report for the remainder of the vehicles in the defined class. You are hereby directed to file such report within five days of receipt of this letter.; In addition to the foregoing, we have been advised informally by Mr Kittle of your staff that in the future Chrysler Corporation will file timely defect reports irrespective of whether or not the vehicles have passed into the hands of the purchasers. Please advise us in writing within ten days of the date of receipt of this letter of whether or not Chrysler Corporation intends to comply with the defect reports regulation by filing timely defect reports with respect to all vehicles subject to a safety related defect that have been delivered to a distributor or dealer in addition to those which have been sold to the general public.; We have fully considered the legal arguments, contentions and fact presented in mitigation of any legal remedies this agency might seek, including injunctive sanctions or civil penalties, for Chrysler's not having filed a timely defect report regarding those of the 11,998 vehicles in question which had been delivered to the distributor or dealer and have rejected Chrysler's position. Accordingly, before we accept any offer in compromise regarding the amount of civil penalties to be imposed for the violation or violations of the National Traffic and Motor Vehicle Safety Act of 1966, we will await your response regarding the matters hereinabove mentioned.; Sincerely, Lawrence R. Schneider, Chief Counsel

ID: nht92-8.42

DATE: February 28, 1992

FROM: Stephen E. Selander -- Attorney, GM Legal Staff

TO: Paul Jackson Rice -- Office of the Chief Counsel, NHTSA

TITLE: Re: General Motors Corporation; FMVSS 114; Request for Interpretation

ATTACHMT: Attached to letter dated 5/22/92 from Paul J. Rice to Stephen E. Selander (A39; Std. 114)

TEXT:

General Motors Corporation (GM) is designing an electronic key locking ignition system which we would like to offer for sale in the near future. GM believes that this system meets the requirements of Federal Motor Vehicle Safety Standard (FMVSS) 114 without using a conventional mechanical key. In view of the novelty of this approach, GM would like to have the concurrence of the NHTSA with our opinion.

FMVSS 114 S.3 Definitions includes the following definition of a "Key":

Key includes any other device designed and constructed to provide a method for operating a locking system which is designed and constructed to be operated by that device.

An electronic "Key" is consistent with the preamble to the Final Rule - FMVSS 114 (33 Fed.Reg. 6472 (1968)) where the following appears at the top of the middle column:

The term "key" is defined so as to include methods of activating the locking system other than the commonly accepted concept of a key.

This electronic key locking system would be operated by a key (an electronic code) entered and removed by the operator. When the key is entered into the locking system by the operator, a match is made with an electronic code stored in the system's memory. This match is analogous to the tumblers of a conventional lock cylinder matching the cut of a conventional key.

When a correct key match occurs, the person could then move the locking system out of the lock position to other positions such as accessory, off, on, or start, in order to activate the vehicle's engine, motor, or accessories.

With the locking system out of the lock position, the transmission can be shifted out of the "PARK" position in order to operate the vehicle. The transmission shift lever must be returned to the "PARK" position in order to place the locking system back into the lock position.

Placement of the locking system back into the lock position by the operator would automatically cause removal of the key from the system. At that time, re-entry of the correct key (electronic code) would be necessary to operate the vehicle.

SUMMARY

A key locking system, using an electronic key code other than a conventional mechanical key, has been developed which, GM believes, will meet the requirements of FMVSS 114.

However, GM requests the concurrence of the NHTSA regarding the definition of "Key" so that design work can continue and the system can be offered to the public in a timely manner.

If helpful, we would be pleased to demonstrate an example of the system under development.

If the agency has any questions or requires additional information, please contact me on (313) 974-1704.

ID: nht76-2.16

DATE: 07/30/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Thomas Built Buses, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Thomas Built Buses' June 4, 1976, question whether the requirements in S5.1.3 and S5.1.4 of Standard No. 222, School Bus Seating and Crash Protection, to "Apply additional force . . . through the . . . loading bar until (a specified number) of inch-pounds of energy has been absorbed in deflecting the seat back . . ." can be satisfied in part by the energy that is returned to the load bar as it is withdrawn from the seat back. You also ask if there are minimum or maximum time limits on withdrawal of the loading bar from the seat surface.

The requirement for the absorption of a minimum amount of energy in (Illegible Word) the seat back in the forward and rearward directions is calculated to provide adequate measurement of the energy involved in the impact between the bus occupants and the seating in a percentage of school bus crashes. The agency calculated the amount of energy to be consumed by the seat back that would result in adequate protection. The specification requires the seat to "absorb" (i.e., receive without recoil) a specific amount of energy. This value is represented by the amount of energy that is not returned to the loading bar as it is withdrawn. Described graphically, the area that represents returned energy under the seat back force/deflection curve must be subtracted from the entire area that lies under the curve in order to calculate the energy "absorbed" by the seat back.

With regard to your second question, no time limits have been established for withdrawal of the loading bar. The agency intends to utilize a withdrawal time that is not more than five minutes so that creep will not be a significant factor in determining energy absorption. Because the time is not specified, the manufacturer is free to use any reasonable time that does not significantly affect the elastic and plastic components of the seat back loading.

thomas BUILT BUSES, INC.

June 4, 1976

Mr. Bob Krause Office of Standards Enforcement Motor Vehicle Programs U.S. Dept. of Transportation National Highway Traffic Administration

Re: Part 571 - Federal Motor Vehicle Safety Standards - Para. 571.222 S5.1.4.1 & S5.1.4.2

Our engineering department is in the process of developing testing and analysis techniques for demonstration of compliance with the referenced section of FMVSS. To ensure that these techniques will meet all requirements, we are in need of further clarification of the paragraphs pertaining to seat back load application. Accordingly, we would appreciate answers from your department on the following specific questions:

(1) Para. 571.222 S5.1.4.2 specifies energy absorption of the seat back deflection during load application. What is the significance of or treatment required of the energy returned during the backing off of the loading bar?

(2) Are there any requirements regarding elapsed time interval for the load back-off?

(3) Same questions re Para. 571.222 S5.1.3 thru S5.1.3.4 - Seat Performance Forward.

Thank you for your prompt assistance in answering these questions.

Malcolm B. Mathieson Engineering Manager

ID: nht88-2.58

TYPE: INTERPRETATION-NHTSA

DATE: 06/28/88

FROM: KARL H. MAYER -- DR ING H. C F PORSCHE AG RULES AND REGULATIONS PORSCHE

TO: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TITLE: REQUEST FOR INTERPRETATION/CLARIFICATION FMVSS 101 AND FMVSS 102

ATTACHMT: ATTACHED TO LETTER DATED 04/03/89 FROM ERIKA Z. JONES -- NHTSA TO KARL H. MAYER, REDBOOK A33 (4), STANDARD 101, STANDARD 102; LETTER DATED 06/28/88 FROM KARL H. MAYER TO ERIKA Z. JONES -- NHTSA, REQUEST FOR CONFIDENTIAL TREATMENT; LETTER DATED 08/25/88 FROM DEAN HANSELL TO KATHLEEN DEMETER -- NHTSA, RE PORSCHE'S JUNE 28 REQUEST FOR REGULATORY INTERPRETATION FMVSS 101 AND 102

TEXT:

Dear Ms. Jones,

In connection with the development of a new vehicle transmission we would like to request your opinion concerning regulatory questions raised by this transmission and its related gear shift mechanism, taking into account Federal Motor Vehicle Safety Stan dards 101 and 102.

We understand that the National Highway Traffic Safety Administration ("NHTSA") does not grant approvals of motor vehicles or motor vehicle equipment. We also realize that, under the National Traffic Motor Vehicles Safety Act, it is the responsibility o f the manufacturer to assure that its vehicles and equipment comply with the applicable standards.

Nevertheless, in our opinion it can at times be helpful and desirable for both the NHTSA and a motor vehicle manufacturer if a candid dialogue can be brought about regarding new technological developments and related regulatory questions. It is the inten t of this letter to create such a dialogue, as needed, in connection with the questions we are presenting.

I. Descriptions of the transmission, its functions and the operation of the gear shift lever

The above mentioned motor vehicle transmission is characterized by two functions -- i.e., a manuel gear shift and an automatic gear shift -- combined in a single unit. The transmission will thus let the driver decide at any time if he wishes to shift manually or transfer that task to the automatic portion of the transmission.

A motor vehicle equipped with such a unit does not have a clutch pedal. Regardless of which of the dual functions is chosen, its operation depends entirely on the position selected for the gear shift lever.

As is customary, the gear shift lever is located in the middle console, where it can be moved along either of two slots which are located essentially parallel to the longitudinal axis of the vehicle. The movement between the two slots corresponds to the change-over from the automatic to the manual function or vice versa. Movement of the lever between the slots can be accomplished while driving the vehicle forward or also while the vehicle is standing still, entirely at the option of the driver.

To accomplish the change from one slot (or function) to the other one, the driver only needs to move the shift lever to the other side across a tranverse connecting slot. As attached drawing 1 shows, this change can only be made from the "D" position on the automatic side to the "M" (manual shift) function on the other side, or vice versa.

When the slot exchange takes place from the automatic to the manual function, at first there is no actual gear shift change; i.e., the vehicle remains in the gear it was in on the automatic side. Only after a further "shift order" is given by the dri ver (by tapping on the shift lever) is the desired gear shift change achieved; i.e., either by shifting up (+) or by shifting down (-). (Shifting on the manual side has a "rocker" characteristic similar to that found with a computer video control, which always returns the gear shift lever to the "M" position after being tapped).

When changing from the manual to the automatic function, at first the gear selected on the automatic side is "taken along" from the one selected by the driver in the manual mode. However, immediately thereafter the automatic speed adaption of the aut omatic function takes over. This adaption, as usual, depends upon the load factor and the engine revolutions as well as the vehicular speed, and corresponds to the conventional functioning of existing automatic transmission units.

II. Questions resulting from the new transmission and Standards 101 and 102

1. We are of the opinion that th s new type of transmission with a dual function is basically permissible under the FMVSS, provided certain requirements are met as per FMVSS 101 and 102. We would like to know whether the NHTSA agrees with this inter pretation of the regulations.

The requirements we have taken into consideration in reaching our conclusion are, among others:

The shift lever can be reached by the driver. FMVSS 101. S5.1. hand operated controls, item (j) of the list.

The shift pattern manufactured as per drawing 1, is continually visible to the driver on the middle console during daylight, FMVSS 101, S5.1 displays, item (c) of the list.

The shift pattern, as per drawing 2, shown in the speedometer, is continually visible to the driver and provided with illumination, which is in accordance with the requirement contained in FMVSS 101, S5.3.1.

If a gauge is listed in column 1 of Table 2, and accompanied by the word "yes" in column 5, then the gauge and its identification required by S5.2.3 shall be illuminated whenever the ignition switch and/or the headlamps are activated. Controls, gauge s, and their identifications need not be illuminated when the headlamps are being flashed.

The above mentioned illumination of the shift pattern is adjustable, in accordance with FMVSS 101, S5.3.3.

In the automatic mode the gear position can be set selectively to P, R, N, D, 3, 2, or 1, clearly readable on the guide display plate of the gear shift on the middle console, as well as clearly marked for the driver by illuminating the corresponding a rrows (arrow) on the shift display in the speedometer.

The engine can only be started if the shift lever is in the P or N position as per FMVSS 102. S3.1.3.

[FOLLOWING PAGE MISSING]

4. The display shown in drawing 3 differs from the mode depicted in drawing 2 only by including the letter "M" on the manual side. The corresponding arrow would be illuminated during use of the manual mode. Additionally the arrow of the selected sh ift position would light up.

Please advise us if the display mode shown in drawing 3 is permissible.

Note: The speedometer depicted in drawings 2 and 3 will have a scale reading in MPH in the version manufactured for the USA instead of a scale in KM.

We are prepared to provide you with any further information that you would need to consider this inquiry, whether by telephone or in writing, or, if you would prefer, in a face-to-face meeting. We have developed a working model of the dual function shif t lever which we are prepared to demonstrate for you, if that would be helpful to you in evaluating these questions.

Your early favorable consideration of these requests would be greatly appreciated so that we can move this technology toward production as soon as possible.

A confidential treatment of this inquiry in accordance with 49 CFR Part 512 ist requested. (See enclosed declaration.)

Very truly yours,

Enclosure

(FIGURE 1-3 OMITTED)

ID: 18433.nhf

Mr. Daniel J. Selke
Mercedes-Benz of North America, Inc.
One Mercedes Drive, P.O. Box 350
Montvale, NJ 07645-0350

Dear Mr. Selke:

This responds to your letter asking whether the National Highway Traffic Safety Administration (NHTSA) will exercise its discretion not to institute enforcement proceedings with respect to special seat belt installations in a 1985 300 TD Mercedes-Benz and a 1991 300SE Mercedes-Benz. In a telephone conversation with Nicole Fradette of my staff you explained that the extra-long belt assemblies are needed to accommodate two severely obese drivers and a passenger. You explain that the drivers in both cases are extremely obese and cannot use the driver-side seat belt because of their large body size and that your special order 12-inch longer belt is still too short to fit them. You explain that you also need to install an extra-long belt assembly in the 1985 300 TD Mercedes-Benz to accommodate a severely obese passenger. You indicated that your factory has supplied longer seat belts, but that the extra-long belt assembly will not comply with the following aspects of Standard No. 209:

• the seat belt will not completely roll up into the B-pillar due to excessive webbing on the spool;
• the seat belt has not been tested for retraction spring durability and therefore may not pass the retractor cycle test;
• no certification label is attached.

As explained below, our answer is that the extra-long seat belt assemblies may be installed. The National Highway Traffic Safety Administration (NHTSA) will not institute enforcement proceedings against a dealer that installs the longer seat belt assembly to accommodate the condition you described. A more detailed answer to your letter is provided below.

As you are aware, our agency is authorized to issue Federal motor vehicle safety standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. Manufacturers are required to certify that their products conform to our safety standards before they can be offered for sale. After the first sale of the vehicle, manufacturers, distributors, dealers, and repair businesses are prohibited from "knowingly making inoperative" any device or element of design installed on or in a motor vehicle in compliance with an applicable standard. In general, the "make inoperative" prohibition (49 U.S.C. 30122) requires businesses which modify motor vehicles to ensure that they do not remove, disconnect, or degrade the performance of safety equipment installed in compliance with an applicable standard. Violations of this prohibition are punishable by civil penalties of up to $1,100 per violation.

There is no procedure by which businesses petition for and are granted permission from NHTSA to modify a motor vehicle. Businesses are permitted to modify vehicles without obtaining permission from NHTSA to do so, but are subject to the make inoperative provision of 49 U.S.C. 30122. In certain limited situations, we have exercised our discretion in enforcing our requirements to provide some allowances to a business which cannot conform to our requirements when making modifications to accommodate the special needs of persons with disabilities.

As you noted in your letter, removing the original seat belt assemblies and replacing them with the longer seat belt assemblies would affect the vehicles' compliance with Standard No. 209, Seat belt assemblies. In situations such as yours where a vehicle must be modified to accommodate the needs of a particular disability, we have been willing to consider violations of the "make inoperative" prohibition to be justified by public need. As I have already noted above, NHTSA will not institute enforcement proceedings against a business that modifies the seat belt assembly to accommodate the condition you describe as we equate the special needs of a severely obese individual with the needs associated with a disability.

We caution, however, that only necessary modifications should be made. Further, if the vehicle is sold, we urge the owner to advise the purchaser that the vehicle has been modified and consider reinstalling the removed safety seat belt assemblies.

If you have other questions or need some additional information, please contact Nicole Fradette of my staff at this address or by phone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:209#VSA
d.2/11/99

ID: 19797-1.pja

Mr. Yaichi Oishi
General Manager
Vehicle Safety Regulation
Toyota Technical Center, USA, Inc.
1850 M Street, NW
Washington, DC 20036

Dear Mr. Oishi:

This responds to your letter asking for an interpretation of how Federal Motor Vehicle Safety Standard No. 103, Windshield Defrosting and Defogging Systems, would apply to the Prius, a hybrid electric vehicle Toyota produces. I apologize for the delay in our response. According to your letter, the vehicle utilizes both an electric motor and gasoline engine to provide motive power. The wheels and the powertrain cannot be mechanically disconnected. For this reason, the engine cannot be "raced" when the transmission shift lever is in the "neutral" position, as it can with most vehicles.

Your concern is with S4.3(b)(2)(i) of Standard No. 103, which states that "The engine speed shall not exceed 1,500 r.p.m. in neutral gear." You believe that the purpose of this provision is to allow testing to be conducted on a stationary vehicle with the engine racing up to 1,500 r.p.m. You state that, since conventional engines can be raced while stationary in either "park" or "neutral," that we should interpret the term "in neutral gear" as meaning any shift position in which motive power is not transmitted to the wheels, including "park."

We agree that the purpose of the provision at issue is to allow testing of a vehicle's defrosting/defogging system to be conducted with the vehicle stationary but with its engine at a speed up to 1,500 r.p.m. This, in essence, gets and keeps the engine up to its ordinary operating temperature during the test. Since, because of the new technology used in your vehicle, the engine speed cannot be maintained at 1,500 r.p.m. when the shift position is in "neutral" but can be when the shift position is in "park," we would interpret the standard to permit the shift position to be in "park" for purposes of S4.3(b)(2)(i) of Standard No. 103. Please note that this interpretation reflects consideration of the purposes underlying Standard No. 103 generally and S4.3(b)(2)(i) in particular and should not be considered to have any broader application. We also note that S4.3(b)(2)(ii) provides another option which allows for testing in a forward drive position.

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

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:103
d.3/10/2000

ID: aiam4466

Dear Mr. Wilson: This is in response to your letter of December 9 1987, to Ms. Brenda Brown, Office of Congressional Affairs, Department of Transportation, which has been forwarded to this Office for reply. Unfortunately, the Department has no record of receiving your previous letter of August 19, 1987. You have written on behalf of your constituent Mr. W. P. Brandon of Palestine who has designed a 'Wide Right Turn' signal for installation on the rear of trailers. The device consists of the words 'Wide Right Turn' and an arrow, in black on a 'caution yellow' background. The device is attached to the lower right rear of a trailer, and flashes when the turn indicator is positioned for a right turn. Mr. Brandon asks three questions with respect to his device, which I shall answer shortly. Preliminarily let me note that the applicable Federal law and regulation are, respectively, the National Traffic and Motor Vehicle Safety Act of l966, and Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices, and Associated Equipment. Standard No. 108 permits a supplementary lighting device such as Mr. Brandon's as original trailer equipment if it does not impair the effectiveness of the lighting equipment that Standard No. 108 requires, such as the standard turn signal system. The Vehicle Safety Act permits it as aftermarket trailer equipment if its installation by a person other than the trailer owner does not render inoperative, wholly or in part, equipment installed on the trailer pursuant to Standard No. 108 or any other safety standard. With these general remarks in mind, we reach the three questions that Mr. Brandon asked. 'l. Is there any rule regarding the placement of a flashing 'Wide Right Turn' signal on the lower right rear of a trailer?' The answer is no, as long as there is no impairment of the effectiveness of the other rear lamps (i.e., the standard turn signal must continue to operate when the lever is in the position indicating a right turn, but the wide turn signal should not operate when the hazard warning signals (which operate through the turn signal lamps) are on). '2. Can the signal be black letters on a safety yellow background or should it be another color'? The agency does not prescribe the color of supplementary lighting devices, and color is subject only to the 'impairment' restriction. Required lighting equipment on the rear of trailers may be white (back up lamps), amber (turn signals), or red (the alternative color for turn signals, and the required color for taillamps and stop lamps). I am unsure what 'safety yellow' is, but it would not appear to impair the effectiveness of the red, amber, or white lamps on the trailer's rear. '3. Are there any restrictions on manufacturing of the signal insofar as materials or construction are concerned?' There are no Federal restrictions or requirements. However, supplementary lighting devices such as Mr. Brandon's are subject to regulation in all their aspects by the States in which they will be sold and used. We are not conversant with State regulations on this subject, and suggest that, for further advice, Mr. Brandon contact the American Association of Motor Vehicle Administrators, 120l Connecticut Ave., N.W., Washington, D.C. 20036. We appreciate Mr. Brandon's interest in safety, and your writing us with respect to his 'Wide Turn Signal' device. Sincerely, Erika Z. Jones Chief Counsel;

ID: nht69-2.4

DATE: 02/12/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Scientific Brake & Equipment Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of November 11, 1968, to Mr. Barkley Sweet, Truck Body and Equipment Association, concerning lighting for trucks equipped with snow plow blades, has been hand-carried by him to this Bureau for consideration and reply.

Federal Motor Vehicle Safety Standard No. 108 requires that all trucks be equipped with headlamps mounted at a height above the road surface not more than 54 inches. To effectively illuminate the road when its snow plow is in use, a truck often runt be equipped with additional headlamps at a height greater than 54 inches, and you are correct in installing these lights for dealers and purchasers.

With respect to the several specific questions listed on page 2 of your letter, I would point out that local and State regulations should be reviewed for possible requirements relating to the additional lamps used on trucks operating as snow-plowing vehicles.