ID: nht95-6.38

TYPE: INTERPRETATION-NHTSA

DATE: September 6, 1995

FROM: Earl Eisenhart -- Vice President, National Private Truck Council; Larry W. Strawhorn -- Vice President - Engineering, American Trucking Associations

TO: John G. Womack -- Acting Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 11/17/95 LETTER FROM Samuel J. Dubbin to Larry W. Strawhorn (A43; Std. 121)

TEXT: Dear Mr. Womack:

This letter is a request for an interpretation of the phrase "separate electrical circuit" in Section 5.1.6.3 Antilock Power Circuit for Towed Vehicles of Federal Motor Vehicle Safety Standard (FMVSS) 121, Air Brake Systems, which states:

"Each truck tractor manufactured on or after March 1, 1997 and each single unit vehicle manufactured on or after March 1, 1998 that is equipped to tow another air-braked vehicle shall be equipped with one or more separate electrical circuits, specifically provided to power the antilock system on the towed vehicle(s). Such a circuit shall be adequate to enable the antilock system on each towed vehicle to be fully operable."

Our interpretation is that the phrase "separate electrical circuit" allows the continued use of the single SAE J560 connector if one of the seven pins provides full-time power for the ABS. It is also our interpretation that the ABS malfunction signal can be multiplexed on the power circuit or any other circuit of the SAE J560 connector and that the other trailer devices can be powered off the circuit as long as the performance required by the last sentence of Section 5.1.6....3 is achieved, i.e., the circuit is adequate to enable the antilock system on each towed vehicle to be fully operable.

The bases for our interpretation are:

We interpret separate to mean full-time power is supplied to the ABS. The preamble appears to use terms continuous, dedicated, full-time and separate interchangeably but fails to define these terms. In contrast, we interpret shared to mean that the power is supplied only when switched ON by some means, e.g., turn signal switch, light switch, brake pedal, etc. The preamble (FR60-47, p13250) states that "The agency further notes that requiring that trailer ABSs receive "full-time power will not prohibit multiplexing." Therefore, we interpret that the ABS malfunction signal could be multiplexed on the power circuit. We further interpret that other trailer devices could also be powered through this circuit if they were automatically switched OFF if the trailer is equipped with an ABS, except when the vehicle is stationary. This would require that the trailer be capable of signalling the tractor that it has an ABS. The tractor would

have to be capable of receiving that signal and automatically deactivating the power to other trailer-mounted devices that now recieve power through the auxiliary pin. This solution would protect these devices from being continually powered if the trailer was equipped with an ABS, yet would still allow for the provision of power when the combination was not moving. The majority of today's applications for powering trailer equipment through the auxiliary pin, only require power when the vehicle is stationary.

Our interpretation of the word circuit as used in FMVSS 121 is that it refers to a single conductor between the towing and towed vehicle(s). This interpretation is consistent with preamble statements and SAE's commone use of the term. For examples, Notice 3 of Docket 88-18 (FR57-134, p30911) states, "The stop lamp circuit is powered through one of the pins on a seven-pin connector" and in SAE Standard J560, Seven Conductor Electrical Connector for Truck-Trailer Jumper Cable, in Sectino 6.4 defines the function and color code each of the seven pins, each of which is defined as a circuit. With the understanding that a circuit refers to one conductor between towing and towed vehicle, one can comply with Section 5.1.6.3 without having to provide a separate ground return fro the circuit to provide full-time power to towed vehicle ABS.

Utilizing a single ground on vehicles is considered to be good engineering practice since multiple grounds can cause EMI problems and ground loops which have in the past resulted on severe damage to vehicle electrical systems and even caused numerous fires. Without the need to provide a separate ground circuit, vehicle/antilock suppliers have the flexibility needed to provide the desired level of trailer antilock power in the most efficient method.

Because of the need to finalize design decisions, especially for truck-tractor manufacturers who must meet the requirements of the final rule on March 1, 1997, we would appreciate an early answer to this request.

Please contact us if there is a need for further information.

Sincerely

ID: nht95-4.16

TYPE: INTERPRETATION-NHTSA

DATE: September 6, 1995

FROM: Earl Eisenhart -- Vice President, National Private Truck Council; Larry W. Strawhorn -- Vice President - Engineering, American Trucking Associations

TO: John G. Womack -- Acting Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 11/17/95 LETTER FROM Samuel J. Dubbin to Larry W. Strawhorn (A43; Std. 121)

TEXT: Dear Mr. Womack:

This letter is a request for an interpretation of the phrase "separate electrical circuit" in Section 5.1.6.3 Antilock Power Circuit for Towed Vehicles of Federal Motor Vehicle Safety Standard (FMVSS) 121, Air Brake Systems, which states:

"Each truck tractor manufactured on or after March 1, 1997 and each single unit vehicle manufactured on or after March 1, 1998 that is equipped to tow another air-braked vehicle shall be equipped with one or more separate electrical circuits, specific ally provided to power the antilock system on the towed vehicle(s). Such a circuit shall be adequate to enable the antilock system on each towed vehicle to be fully operable."

Our interpretation is that the phrase "separate electrical circuit" allows the continued use of the single SAE J560 connector if one of the seven pins provides full-time power for the ABS. It is also our interpretation that the ABS malfunction signal ca n be multiplexed on the power circuit or any other circuit of the SAE J560 connector and that the other trailer devices can be powered off the circuit as long as the performance required by the last sentence of Section 5.1.6....3 is achieved, i.e., the c ircuit is adequate to enable the antilock system on each towed vehicle to be fully operable.

The bases for our interpretation are:

We interpret separate to mean full-time power is supplied to the ABS. The preamble appears to use terms continuous, dedicated, full-time and separate interchangeably but fails to define these terms. In contrast, we interpret shared to mean that the pow er is supplied only when switched ON by some means, e.g., turn signal switch, light switch, brake pedal, etc. The preamble (FR60-47, p13250) states that "The agency further notes that requiring that trailer ABSs receive "full-time power will not prohibi t multiplexing." Therefore, we interpret that the ABS malfunction signal could be multiplexed on the power circuit. We further interpret that other trailer devices could also be powered through this circuit if they were automatically switched OFF if the trailer is equipped with an ABS, except when the vehicle is stationary. This would require that the trailer be capable of signalling the tractor that it has an ABS. The tractor would

have to be capable of receiving that signal and automatically deactivating the power to other trailer-mounted devices that now recieve power through the auxiliary pin. This solution would protect these devices from being continually powered if the trail er was equipped with an ABS, yet would still allow for the provision of power when the combination was not moving. The majority of today's applications for powering trailer equipment through the auxiliary pin, only require power when the vehicle is stat ionary.

Our interpretation of the word circuit as used in FMVSS 121 is that it refers to a single conductor between the towing and towed vehicle(s). This interpretation is consistent with preamble statements and SAE's commone use of the term. For examples, Not ice 3 of Docket 88-18 (FR57-134, p30911) states, "The stop lamp circuit is powered through one of the pins on a seven-pin connector" and in SAE Standard J560, Seven Conductor Electrical Connector for Truck-Trailer Jumper Cable, in Sectino 6.4 defines the function and color code each of the seven pins, each of which is defined as a circuit. With the understanding that a circuit refers to one conductor between towing and towed vehicle, one can comply with Section 5.1.6.3 without having to provide a separ ate ground return fro the circuit to provide full-time power to towed vehicle ABS.

Utilizing a single ground on vehicles is considered to be good engineering practice since multiple grounds can cause EMI problems and ground loops which have in the past resulted on severe damage to vehicle electrical systems and even caused numerous fir es. Without the need to provide a separate ground circuit, vehicle/antilock suppliers have the flexibility needed to provide the desired level of trailer antilock power in the most efficient method.

Because of the need to finalize design decisions, especially for truck-tractor manufacturers who must meet the requirements of the final rule on March 1, 1997, we would appreciate an early answer to this request.

Please contact us if there is a need for further information.

Sincerely

ID: 86-5.30

TYPE: INTERPRETATION-NHTSA

DATE: 10/16/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Alan Cranston

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter on behalf of Mr. Raymond Kesler. He asked for this agency's response to a letter from Mr. Robert R. Phillips concerning the bi-focal mirror developed by Mr. Kesler. In his letter, Mr. Phillips asked whether an outside rearview mirror, which has both a planar surface of unit magnification and a convex surface, complies with Standard No. 111, Rearview Mirrors. I regret the delay in responding to this letter.

As we understand the information supplied by Mr. Phillips, the bi-focal mirror would be installed on the driver's side of motor vehicles to give the driver a wider field of view by combining a convex mirror and a planar mirror as the outside rearview mirror on the driver's side. The convex portion would abut the planar portion and be located to the left of the planar portion. Thus, both normal and wide-angle vision would be provided at the same horizontal viewing level.

By way of background information, this agency does not give approvals of vehicles or their equipment. The National Traffic and Motor Vehicle Safety Act of 1966, as amended (the Act), places the responsibility on the manufacturer to ensure that items of motor vehicle equipment, such as rearview mirrors, comply with any applicable requirements. A manufacturer certifies that its equipment complies with all applicable safety standards.

Mr. Phillips asked this agency to confirm his interpretation that this bi-focal mirror meets the requirements of Standard No. 111 if its planar or unit magnification surface has an area of at least 19.5 square inches, regardless of the existence of the convex portion. The 19.5 square inch requirement is one applicable to multipurpose passenger vehicles, trucks, and buses (other than schoolbuses) with a GVWR of 10,000 pounds or less. Those types of vehicles are required by S6.1 of the standard either to have a set of inside and outside rearview mirrors that comply with the requirements applicable to passenger cars or to have outside mirrors of unit magnification, each with not less than 19.5 square inches of reflective surface, on both sides of the vehicle. If Mr. Phillips' mirror meets that size requirement, is located on a vehicle so as to provide the required view and is adjustable in the required manner, it complies with S6.1.

There are no minimum size requirements for unit magnification outside rearview mirrors on passenger cars. Mr. Phillips' mirror can be installed on the driver's side of passenger cars if the mirror's unit magnification portion, independently of the convex portion, meets the field of view and mounting requirements specified in S5.2.

In one drawing accompanying Mr. Phillips' letter, there appears to be a warning on the planar portion of his bi-focal mirror stating "Objects Appear Within Markers: Caution." There is no requirement in Standard No. 111 for such a warning. The agency is concerned that the message conveyed by this warning is unclear and could confuse motorists. The warning ("CAUTION When Vehicle Appears Here") in Mr. Phillips' other drawing seems more easily understood. He might consider providing purchasers with written instructions explaining that the purpose of the message is to warn drivers that the appearance of a vehicle in the convex portion of the mirror means that the vehicle is so close that a lane change would be unsafe.

Unit magnification and convex mirrors on other types of vehicles must meet the specific performance and location requirements for those types of vehicles, as set out in the standard. Again, please note that a vehicle manufacturer installing a bi-focal mirror on different types of vehicles must ensure that the unit magnification portion of the mirror meets any applicable requirements of the standard independently of the convex portion.

If Mr. Phillips' mirror meets the requirements of Standard No. 111 for a particular vehicle type, then it may be installed on new vehicles of that type. It may also be installed on used vehicles of that type. Conversely, if the mirror does not meet those requirements, then it may not be installed on new vehicles. Further, manufacturers, distributors, dealers and repair businesses would be prohibited from installing it on used vehicles. However, the Act does not establish any limitations on an individual vehicle owner's ability to alter his or her own used vehicle.

Under Federal law, individual vehicle owners can themselves install any product they want on their used vehicles, regardless of whether that product would render inoperative the compliance of the vehicle's rearview mirrors with the performance or location requirements of Standard No. 111.

I hope this information is helpful to you.

SINCERELY

United States Senate

August 19, 1986

To: Congressional Laision Department of Transportation National Highway Traffic Safety Administration

Enclosure From:

Mr. Ray Kesler

Re: Mr. Kesler would appreciate a letter confirming his bifocal safety mirror conforms to federal safety standards. Is this possible?

I forward the attached for your consideration.

Your report, in duplicate, along with the return of the enclosure will be appreciated.

Alan Cranston

Please address envelope to:

Senator Alan Cranston

August 6, 1986

Dear Senator Cranston,

I am seeking a letter to confirm, yes it does provide the plane flat mirror (unit of manification) on the required amount because it is comformity of the standards. I would expect they would simply state it back to us so I can present it to the S.A,E, (society of automotive engineers) and the automotive industry that they have no question, it does meet the federal safety standards, but that has not happened and would appreciate a answer on this soon. This has held up this project for many monthes. I believe we can start saving lives with the new mirror concept in safety vision soon. I know you will give federal support on this matter. You have been so helpful before and I sincerely thank you.

Ray Kesler

enclosure. Drawings (2)

Instructions on viewing bifocal safety mirror

July 25, 1980

The Honorable Alan Cranston UNITED STATE SENATE

Dear Senator Cranston:

Your concern for public safety is well known to us, and because of your reputation as a strong-willed combatant for causes you believe in, we are soliciting your advice and support for our project.

My client, Mr. Raymond Kesler, has recently developed a bifocal safety mirror for automobiles that has the potential to make a major contribution to the cause or automotive safety. You have previously been kind enough to lend support to Mr. Kesler on this project (i.e. your letter to Diane Steed at NHTSA on Feb. 5, 1985), and we are once again in need of someone to help break what appears to be a bureaucratic logjam.

The enclosed letter was written to Brika Jones, Chief Counsel at NHTSA upon the advice of Dr. Carl Clark, Investor Contact Code NRD-12 in the Office of Vehicle Research. As the letter indicates, we are simply seeking interpretation of the code of federal regulations governing automotive mirrors. Our question is, we believe, specific and clear, yet to date no response from Ms. Jones was received.

If you could assist us in getting some official interpretation as to how the federal regulations affect this bi-focal mirror, we would be most grateful.

Robert R. Phillips Project Manager enclosure: Erika Jones Letter (March 27, 1986)

P.S. We are also enclosing a copy of an article on the mirror that recently appeared in Automotive News.

March 27, 1980

Erika Jones Chief Counsel NATIONAL HIGHWAY TRAFFIC AND SAFETY ADMIN.

Dear Ms. Jones:

At the suggestion of Dr. Carl Clark in the Office of Vehicle Research, we are seeking from you some interpretation of existing federal regulations regarding outside rear-view mirrors for automobiles.

In particular, we are concerned about a mirror that was recently developed by Mr. Raymond Kesler, a California inventor. The enclosed article in Automotive News plus the other material provides information on the mirror, but our inquiry is, I believe, specific and clear.

It is our interpretation or the NHTSA regulations that this bi-focal mirror (i.e. a planar surface abutted to a convex mirror of fixed radius) does meet the requirements if its planar (unit magnification) surface has an area of at least 19.5 square inches, regardless of the existence of the convex portion.

We would greatly appreciate your comments on this interpretation prior to final approval of the mirror's specific dimensions.

Thank you for your assistance.

Robert R. Phillips

Automotive News

March 24, 1986

engineering

Mirror wipes out blind spot

An inventor in West Hollywood, Calif., believes car mirrors have been overlooked for too long. He has taken what he calls a revolutionary approach to the subject and has eliminated the pesky -- and dangerous -- passing-car blind spot.

The first auto mirror, patterned after one seen on a carriage in Chicago, was used on the winning car in the first Indianapolis 500 race in 1911. Driver Ray Harroun installed the 8-inch-by-3-inch mirror to avoid using the riding mechanic who usually kept one eye rearward in races of the era.

It would appear that little change has taken place over the years, and 47-year-old inventor Raymond Kesler said his latest work will refocus attention of safety authorities on the mirror.

Others say that attention is overdue. They contend that because the U.S. population is aging, the left-side blind spot is growing as a danger point. (Illegible Word) one's peripheral vision diminishes with age.

Kesler said he has combined the positive characteristics of two different optics -- a planar, or flat, surface connected to a curved surface of fixed radius.

"This achieves a remarkably effective enhancement of the field of view without the distortion associated with variable-curvature convex mirrors," he said.

"The Kesler approach uses the flat surface for 70 percent of the mirror with the remaining 30 percent devoted to the convex portion for wide-angle vision."

On the convex surface, there are what Kesler calls "reflective caution arrows" which warn the driver of traffic approaching from the rear and act as a distance finder for position and size of objects.

"The overall unit is rectangular to fit most 1985/86 original equipment mirror housings," Kesler said, "It also it well-suited for the aftermarket manufacturers who utilize the new rectangular design for their mirrors."

A patent is pending, Kesler said.

The inventor has been interested in automotive accessories and automotive phenomena for many years, said Robert R. Phillips, of the Woodland Hills (Calif.) consulting firm that bears his name. Phillips is handling inquiries about Kesler's device.

In most other attempts at bifocal mirrors, distortion has been the major problem, and NHTSA regulations have kept them off the road. Hopes of other inventors have been shattered by NHTSA investigations.

Small, convex anti-blind-spot mirrors that adhere to flat mirrors are sold by parts stores and are not installed as original equipment. Therefore, their distortion escapes the regulatory eye of NHTSA. Also, such mirrors stand out physically from the flat mirror and it is not likely a driver would confus, images seen in them with images in the flat mirror.

A mirror manufacturer in Michigan said some drivers become nauseated from multiple radius mirrors. The eyes see differing images simultaneously, and the brain becomes confused.

Several mirror makers have petitioned NHTSA for regulation changes. European regulations are reported to be similarly rigid, but Saab in 1982 introduced in Europe a mirror it says eliminates the blind spot.

The Saab mirror, as does Kesler's, shows two fields of view at the same time.

The mirror glass has two surfaces. One is a large plane surface closest to the driver. It is separated from the second, a narrow convex surface, by an etched line.

Together, the two surfaces enable the driver to follow a passing vehicle until it becomes visible in the driver's direct vision, even in the blind spot, Saab said.

Saab said European legislation is very strict regarding the design of side mirrors and requires that the division between the two fields be clearly marked. In Saab's case, this is achieved by the etched line, the company said.

Kesler said the Kesler Bi-Focal Safety Mirror meets federal safety standards. He also said there are no other similarly qualified mirrors that have normal and wide-angle vision at the same horizontal viewing level.

The Kesler Bi-focal Wide Angle Automotive Safety Mirror

(Meets Federal Motor Vehicle Safety Standard No. 111.) D.O.T.

REFLECTIVE CAUTION ARROWS RNS DRIVER OF APPROACHING TRAFFIC

(ACTS AS A DISTANCE FINDER FOR POSITION AND SIZE OF OBJECTS)

PLANAR MIRROR (NORMAL VISION OF STANDARDS) D.O.T.

ABUTTED JUNCTURE TANGENT TO PLANE KESLER PATENT PENDING

(C) 1986 KESLER RESEARCH ENTERPRISES

PICTORIAL CONCEPT OF WIDE ANGLE OPTIC

(Graphics omitted)

Traffic in "BLIND SPOT" Appears Here

CAUTION When Vehicle Appears Here

Traffic Leaves View of Planar Mirror Here

Anti-Blind Spot Mirror

(Graphics omitted)

KESLER RESEARCH ENTERPRISES

"Avoid an Accident at a Glance"

SAFETY ADVANTAGES OF VIEWING BIFOCAL REARVIEW SAFETY MIRROR

1. Plane section of mirror is for normal viewing of traffic with no depth perception loss. This section complies with FMVSS III D.O.T. standards.

2. The constant radius convex section of the mirror provides an extra margin of safety with uniform vision on a horizontal level, allowing extra vision for better view of the far lane, pulling away from curbs, and backing out of driveways.

3. A conventional mirror out of adjustment can cause an accident. The fact is that a convex section of the bi-focal safety mirror provides the extra vision, even when out of adjustment.

4. The reflective caution safety markers on the convex section aid the user for judging distance, position, and size or objects.

5. Both plane and convex mirrors can be viewed to cut glance duration time to a minimum when objects (traffic) appear in the safety markers.

6. Both separate sections can be viewed as one (integrated) mirror when objects meet the transition.

Copyright, 1986 KESLER RESEARCH

ID: Evans_10-005739_108

ID: nht92-2.18

DATE: 11/19/92

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: PAUL GOULD -- SENIOR ENGINEER - FRICTION MATERIALS, LUCAS HEAVY DUTY BRAKING SYSTEMS

ATTACHMT: ATTACHED TO LETTER FROM PAUL GOULD TO PAUL RICE DATED 9-1-92 (EST.) (OCC 7792)

TEXT: This responds to your letter asking about the dynamometer requirements of Federal Motor Vehicle Safety Standard No. 121, Air Brake Systems (49 CFR 571.121). You requested clarification of the term "average deceleration rate" and its tolerance, particularly with respect to the brake power test (S5.4.2). You stated that you view the specified deceleration rate as "only a target" in order to fade the linings, and believe that it is acceptable to conduct tests at five percent below the specified rate. I am pleased to have this opportunity to explain our regulations to you.

Some background information on Federal motor vehicle safety laws and regulations may be helpful. The National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1381 et seq., Safety Act) authorizes this agency to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

Manufacturers must have some independent basis for their certification that a product complies with all applicable safety standards. This does not necessarily mean that a manufacturer must conduct the specific tests set forth in an applicable standard. Certifications may be based on, among other things, engineering analyses, actual testing, and computer simulations. Whatever the basis for certification, however, the manufacturer must certify that the product complies with a standard as it is written, i.e., that the vehicle will pass all applicable requirements if it is tested exactly according to the standard's test conditions and other specifications.

Standard No. 121's dynamometer test requirements are set forth in section S5.4. That section specifies that brake assemblies must meet the requirements of S5.4.1 (brake retardation force -- relevant only to towed vehicles), S5.4.2 (brake power), and S5.4.3 (brake recovery), under the conditions of S6.2. The purpose of the dynamometer test requirements is to help ensure that brakes retain adequate stopping capacity during and after exposure to conditions caused by prolonged or severe use, such as long, downhill driving.

With respect to your question about the meaning of "average deceleration rate," that term is used in both S5.4.2 and S5.4.3. Section S5.4.2 specifies, for example, that each brake shall be capable of making 10 consecutive decelerations at an average rate of 9 f.p.s.p.s. from 50 mph to 15 mph, and shall be capable of decelerating to a stop from 20 mph at an average deceleration rate of 14 f.p.s.p.s. after the 10th deceleration. In S5.4, the meaning of average deceleration rate is explained as follows: For purposes of the requirements of S5.4.2 and S5.4.3, an average deceleration rate is the change in velocity divided by the decleration time measured from the onset of deceleration.

We do not agree with your suggestion that the deceleration rates specified in Standard No. 121 are "only a target" in order to fade the linings. As indicated above, manufacturers must certify that each vehicle complies with a standard as it is written, i.e., that the vehicle will pass all applicable requirements if it is tested exactly according to the standard's test conditions and other specifications. Thus, if a vehicle was unable to pass Standard No. 121's test requirements at the specified deceleration rates, it would not comply with the standard, notwithstanding the fact that it might be able to pass the standard's requirements at slightly lower deceleration rates.

We recognize, however, that it may be difficult to achieve any exact deceleration rate in conducting a brake test. For this reason, the agency's Office of Vehicle Safety Compliance (OVSC) specifies tolerances in its Laboratory Test Procedures developed for use by contractors in conducting compliance tests for the agency. For the brake power and brake recovery tests (S5.4.2 and S5.4.3), the agency's current Laboratory Test Procedure specifies the following tolerances on deceleration rates: +0 to -1 ft/s/s, except for 12 ft/s/s: +/-0.5 ft/s/s.

Enclosed for your information is a copy of the agency's Laboratory Test Procedure for Standard No. 121's dynamometer tests. On the issue of tolerances, I call your attention to the following statement at the beginning of the Laboratory Test Procedure:

The OVSC Laboratory Test Procedures, prepared for use by independent laboratories under contract to conduct compliance tests for the OVSC, are not intended to limit the requirements of the applicable FMVSS(s). In some cases, the OVSC Laboratory Test Procedures do not include all of the various FMVSS minimum performance requirements. Sometimes, recognizing applicable test tolerances, the Test Procedures specify test conditions which are less severe than the minimum requirements of the standards themselves. Therefore, compliance of a vehicle or item of motor vehicle equipment is not necessarily guaranteed if the manufacturer limits certification tests to those described in the OVSC Laboratory Test Procedures.

If you have any further questions, please feel free to call Mr. Marvin Shaw of my staff at (202) 366-2992.

ID: nht76-1.48

DATE: 02/24/76

FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA

TO: file

TITLE: FMVSS INTERPRETATION

ID: nht76-4.37

DATE: 03/19/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Werner Incorporated

TITLE: FMVSS INTERPRETATION

ID: nht75-2.17

DATE: 12/04/75

FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA

TO: FILE

TITLE: FMVSS INTERPRETATION

ID: nht72-3.8

DATE: 05/10/72

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Dockets

TITLE: FMVSS INTERPRETATION

ID: nht74-1.48

DATE: 05/23/74

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: The Flxible Company

TITLE: FMVSS INTERPRETATION