ID: nht72-6.22

DATE: 02/15/72

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

TO: Wells Manufacturing Corp.

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of February 2 you refer to paragraph S4.5.1 of Motor Vehicle Safety Standard No. 108 and its reference to SAE Recommended Practice J564a, Headlamp Beam Switching, April 1964. You ask "whether there is anything in your Docket related to Rule #108 to bring it up to either J564b or J564c."

Perhaps you misread S4.5.1, but it does allow conformance with J564b as an alternative to J564a. No proposal has been issued requiring or allowing conformance with J564c.

ID: nht73-3.25

DATE: 02/14/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 23, 1973, concerning the sequence of manual switch operation under S7.4.4 of Motor Vehicle Safety Standard No. 208. Your question is whether S7.4.4 requires the manual switch and ignition switch to be operated in a specific order.

S7.4.4 does not require any specific sequence. After the ignition has been turned off, it can be made operable either by turning the ignition switch on, then operating the manual switch, or by operating the manual switch and then turning the ignition on.

ID: nht73-3.32

DATE: 02/20/73

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

TO: Truck Body and Equipment Assoc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 8, 1973, concerning the application of Standard No. 124, "Accelerator Control Systems", to auxiliary throttles mounted inside or outside of the cab and used exclusively while the vehicle is in a stationary position to insure proper engine speed for the operation of pumps, elevating platforms, and similar equipment. Since the definition of "idle position" was amended to provide for the use of throttle positioners in 37 F.R. 20035 (September 23, 1972), the auxiliary throttles described are not subject to the requirements of the standard.

ID: nht73-4.24

DATE: 06/01/73

FROM: AUTHOR UNAVAILABLE; J. E. Wilson; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 11, 1973, asking for confirmation of your interpretation of paragraph S7.9 of Standard No. 105a in terms of General Motors' air vacuum power brake.

Your interpretation is correct. Your system with its "two separate and independent energy sources in the power head . . . is equivalent to two entirely duplicate systems", and disconnection of one source at a time would be the correct test procedure under S7.9, provided the requirements of S5.1.3 are satisfactorily met under both conditions.

ID: aiam3981

Dear Mr. Turner: This responds to your two letters to the National Highway Traffi Safety Administration (NHTSA) regarding Federal Motor Vehicle Safety Standard No. 217, *Bus Window Retention and Release*. We apologize for the delay in responding to your letters.; Your December 6, 1984 letter asked about paragraph S5.4.1 of Standar No. 217 and the ellipsoid used to measure the unobstructed opening of a pushout window or other emergency exit. To simplify matters, I will refer to the illustration you attached with your letter. You asked whether you may rotate the ellipsoid in such a way that axis C-D may be horizontal instead of axis A-B.; By way of background information, I would like to explain that NHTS does not pass approval on the compliance of any vehicle or equipment with a safety standard before the actual events that underlie certification. Under the National Traffic and Motor Vehicle Safety Act, the manufacturer is required to determine whether its vehicles and equipment comply with all applicable safety standards and regulations, and to certify its products in accordance with that determination. Therefore, the following statements only represent the agency's opinion based on the information provided in your letters.; Paragraph S5.4.1 of Standard No. 217 states that: >>>After the release mechanism has been operated, each push-out windo or other emergency exit not required by S5.2.3 shall...be manually extendable by a single occupant to a position that provides an opening large enough to admit unobstructed passage, keeping a major axis horizontal at all times, of an ellipsoid generated by rotating about its minor axis an ellipse having a major axis of 20 inches and a minor axis of 13 inches.<<<; Since the language of section S5.4.1 requires only that '*a* majo axis' of the ellipsoid to be horizontal when the ellipsoid is passed through the emergency exit, you are not prohibited from positioning the ellipsoid with only a single major axis, such as C-D, horizontal. If there is unobstructed access of the ellipsoid through the opening, with major axis C-D horizontal, then the emergency exit meets the requirement of S5.4.1 as that section is written.; Even if the design of the exit would not violate S5.4.1, however, w urge you to ensure that the design would not complicate efforts of the passengers to use the emergency exit. It appears that the intent of the agency was for the *plane* generated by the major axes to be horizontal when the ellipsoid is passed through the exit. Otherwise, since *a* major axis of the ellipsoid will at all times be horizontal, no matter how the ellipsoid is passed, the benefit of such a requirement would be reduced. Further, the opening to the emergency exit could be significantly reduced when the only horizontal major axis is C-D.; The agency issued an opinion in April 1977, stating that S5.4.1 an S5.2.1 of Standard No. 217 require the long side of a rectangular roof exit to be parallel to the center line or the side wall of a bus. That opinion interpreted S5.4.1 as requiring the ellipsoid to be passed through the exit with more than one of its major axes horizontal. That interpretation relied on the intent of the standard, but not the language of S5.4.1. This letter reconsiders the 1977 opinion and holds that the language of S5.4.1 requires only one major axis of the ellipsoid to be horizontal.; The two questions in your December 13, 1984 letter dealt with a outside release mechanism for pushout rear emergency windows. In a telephone call to this office on February 5, 1985, you said that the rear emergency pushout windows would be on school buses and buses other than school buses. You also asked whether an outside release mechanism may be installed on rear emergency doors on buses other than school buses.; Your first question was whether the following interpretation wa correct:; >>>FMVSS 217 does not require emergency exits to have outside releas mechanisms, except for school bus emergency doors. Therefore, if we provide an outside handle to operate a pushout rear emergency window, it does not have to meet any force level or type of motion requirements.<<<; You are correct that Standard No. 217 does not require emergency exit on school buses to have outside release mechanisms, with the exception in S5.3.3 for school bus emergency doors. We assume that there are release mechanisms for the pushout rear emergency windows located within the bus which meet all applicable requirements of Standard No. 217. If the emergency exit meets all applicable requirements of the standard, an outside release mechanism for a pushout rear emergency window that is provided in addition to the release mechanisms required by the standard need not meet any force application and type of motion requirements.; Your second question was whether the outside handle on the pushout rea emergency window could be equipped with a key operated mechanism that disengages the handle from outside the bus for security purposes. The handle, even when locked from the outside, does not ever prevent operation of the window's release mechanisms from inside the bus. The answer to your question is yes. Standard No. 217 does not prohibit the type of handle you described when all applicable requirements of the standard can be met.; Our answers given above apply to outside release mechanisms on pushou rear emergency windows on school buses and buses other than school buses.; An outside release mechanism on rear emergency doors on buses othe than school buses would likewise not have to meet any force application and type of motion requirements, if the emergency door meets all applicable requirements of Standard No. 217. The outside release mechanism can be equipped with the locking device you described, provided that Standard No. 217's requirements are met.; Sincerely, Jeffrey R. Miller, Chief Counsel

ID: nht88-2.80

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: C. DIANNE BLACK -- ENGINEERING MANAGER, JAGUAR CARS, INC.

TITLE: NONE

ATTACHMT: MEMO DATED 4-14-88, TO ERIKA Z. JONES, FROM C. DIANNE BLACK -- JAGUAR, REF: FMVSS 108, HEADLAMP LEVELLING SYSTEM

TEXT: Thank you for your letter of April 14, 1988, providing further information about the Jaguar headlamp levelling system discussed in your letters of June and October 1987 to which I responded on February 1, 1988.

We support your efforts to call the driver's attention to the fact that the system does not automatically return to the "zero" position from either of the two adjustment positions when those loading conditions no longer exist.

ID: nht94-2.69

TYPE: INTERPRETATION-NHTSA

DATE: May 5, 1994

FROM: J. L. Steffy -- Triumph Designs Ltd.

TO: Taylor Vinson -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 5/31/94 From John Womack To J.L. Steffy (A42; Std. 108)

TEXT: Dear Taylor

An additional concern for another unit with respect to FMVSS 108:

This is a self contained seal unit that would allow for symetric design & lighting. It comprises a headlight with high and low beams and 2 symetrically flanking front auxillary lamps possessing low beam that augment the headlight. Can you please comment on this as it affects our immediately plans for U.S. importation.

Thank you for your assistance

ID: nht74-3.30

DATE: 08/15/74

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

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: We confirm your interpretation of S5.3.2 of Motor Vehicle Safety Standard No. 105-75, expressed in your letter of August 2, 1974, to Dr. Gregory, that the engine "start" position may be used as a check position for indicator lamp function.

The phrase in S5.3.2 "when the ignition (start) switch is in a position between 'on' ('run') and 'start'" is intended to include both "on" and "start" as well as any position between.

Application of the parking brake as an indicator check will no longer be permitted for vehicles manufactured after the effective date of Standard 105-75.

ID: nht73-1.20

DATE: 03/01/73

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

TO: Nashville Glass Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 14, 1973, requesting information concerning Federal Motor Vehicle Safety Standard No. 212 and replacement of motor vehicle windshields.

Federal Motor Vehicle Safety Standard No. 212 applies only up to the point where a vehicle is first sold to a user. The National Highway Traffic Safety Administration currently has no standards that apply to vehicles in use. A program for the development of standards that would apply to vehicles other than new vehicles is being considered by the Administration for implementation in the future.

Thank you for your inquiry.

ID: nht94-6.2

DATE: May 5, 1994

FROM: J. L. Steffy -- Triumph Designs Ltd.

TO: Taylor Vinson -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 5/31/94 From John Womack To J.L. Steffy (A42; Std. 108)

TEXT: Dear Taylor

An additional concern for another unit with respect to FMVSS 108:

This is a self contained seal unit that would allow for symetric design & lighting. It comprises a headlight with high and low beams and 2 symetrically flanking front auxillary lamps possessing low beam that augment the headlight. Can you please comment on this as it affects our immediately plans for U.S. importation.

Thank you for your assistance