ID: nht74-1.6

DATE: 09/11/74

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

TO: International Harvester

TITLE: FMVSS INTERPRETATION

TEXT:

SEP 11 1974

Mr. K. W. Berner Manager Component Design & Development International Harvester Truck Division Engineering 2911 Meyer Road Fort Wayne, Indiana 46803

Dear Mr. Berner:

This is in reply to your letter of August 13, 1974, to Dr. Gregory asking for confirmation of your interpretation of S5.3.1(b) of Motor Vehicle Safety Standard No. 105.

Paragraph S5.3.1(b) states that an indicator lamp shall be ?????? whenever there is "A drop in the level of brake fluid in a master cylinder reservoir to less than . . . one-fourth of the fluid reservoir capacity in any reservoir compartment ...." This will confirm that the lamp must activate whenever the fluid in any compartment is less than one-fourth the capacity of that compartment, rather than one-fourth the total capacity of the reservoir regardless of the number of compartments.

Yours truly,

Richard B. Dyson Acting Chief Counsel

ID: nht74-1.9

DATE: 03/15/74

FROM: AUTHOR UNAVAILABLE; J. B. Gregory; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of November 19, 1974, petitioning the NHTSA to amend Part 567, Certification (@ 567.4(f)), to allow the use of certification labels on which the lettering is embossed or engraved without regard to whether it contrasts with its background.

The NHTSA has decided that your petition should be denied. Our experience has been that certain types of engraving, those that are stencil-typed or stamped, are difficult to read without color contrast. The NHTSA considers it essential that certification labels be readable under all lighting conditions, and has not found embossing or engraving to produce by themselves sufficiently readable lettering for these labels. Of course, there is no prohibition against embossing or engraving if the finished lettering contrasts with its background.

We appreciate your point that Standard No. 105a accepts embossed or engraved lettering on the master cylinder reservoir label without requiring a color contrast. We are presently considering amending Standard No. 105a to eliminate this discrepancy.

ID: nht78-2.24

DATE: 07/27/78

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: Niles Parts Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: We refer to your letter of March 15, 1978, concerning the testing of hazard warning and turn signal operating units (switches) in accordance with Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

The purpose of requiring 3-inch wire leads on any operating unit during testing is to permit the measurement of any voltage drop across a connector in the circuit. Since the connector is an integral part of your type of operating unit with its "terminal-direct" connection system, the wire leads are not necessary. We, therefore, interpret the society of Automotive Engineers Standards J589 and J910, covering Hazard Warning and Turn Signal Operating Units respectively, to require 3-inch wire test leads only on those units that are supplied with integral wire leads. During the prescribed tests, voltage measurements on units such as those that you provide shall be made at the electrical contacts on the units.

ID: nht78-2.50

DATE: 01/20/78

FROM: AUTHOR UNAVAILABLE; F. Berndt for J. J. Levin, Jr.; NHTSA

TO: The Bendix Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Bendix Corporation's November 9, 1977, request for confirmation that S5.6.4 of Standard No. 121, Air Brake Systems, does not prohibit the use of a two-valve sequential means to release the parking brakes on a towed vehicle.

I have enclosed for your information two interpretations that address this question, stating that a two-valve sequential release is permissible under S5.6.4. I have also enclosed a copy of an outstanding rulemaking proposal that would standardize the parking brake control as specified in the Society of Automotive Engineers Recommended Practice J680b. I am unable to advise you whether the National Highway Traffic Safety Administration intends to make final this proposal.

I would also like to remind you of the requirement in S5.6.4 that "[the] control shall be identified in a manner that specifies the method of control operation." So long as different control arrangements are used, it is critical that the means of operation be clearly marked.

ID: nht78-4.18

DATE: 03/20/78

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

TO: Nebraska Dept. of Motor Vehicles

COPYEE: R. TILTON; ARMSTRONG; HITCHCOCK

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your January 16, 1978, letter asking several questions about the applicability of the school bus regulations to school buses manufactured after April 1, 1977, transporting 10 or more students to or from school or related events.

You first ask whether these buses must be painted yellow and have school bus lighting and markings. The answer to your question is yes. Any vehicle that transports 10 or more students to or from school or related events is a school bus and must have the painting, marking, and lighting of a school bus.

Your second question is whether smaller school buses (vans) are permitted to have van-type seats or must comply with the requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection. A vehicle that transports 10 or more students must comply with all of the Federal school bus regulations, including the seating standard.

ID: nht92-1.47

DATE: 12/01/92

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: CHESTER I. NIELSEN, III -- VICE PRESIDENT SALES, WESBAR CORPORATION

ATTACHMT: ATTACHED TO LETTER DATED 10-21-92 FROM CHESTER I. NIELSEN, III TO WALTER B. MCCORMICK, JR. (OCC 7912)

TEXT: This responds to your letter of October 21, 1992, to Walter B. McCormick, Jr. (the General Counsel of this Department). You have written for "further explanation of S5.3.1.1.1 in FMVSS 108."

You have heard that there is an additional interpretation with respect to the location of clearance lamps on boat trailers whose overall width is 80 inches or more, which would allow mounting of these lamps in accordance with a sketch that you enclosed, and you ask for confirmation of this interpretation.

We are unaware of any interpretation of this nature. The requirements for the provision and location of clearance lamps on wide boat trailers remain those set forth in Tables I and II of Standard No. 108, with the exceptions set forth in paragraphs S5.1.1.9, S5.3.1.1.1, and S5.3.1.4.

ID: nht94-3.5

TYPE: INTERPRETATION-NHTSA

DATE: May 24, 1994

FROM: Carmen Colet -- Vice President, John Russo Industrial, Inc.

TO: Dorothy Nakama, NHTSA

TITLE: NONE

ATTACHMT: Attached to letter dated 7/11/94 from John Womack to Carmen Colet (A42; VSA 102(3))

TEXT: WE ARE CONSTRUCTING AN AIRCRAFT RESCUE AND FIRE-FIGHTING VEHICLE TO SATISFY PROPOSED U.S.A.F. AND D.O.D. SPECS. FOR NEW TYPE YF AND YZ AIRCRAFT.

1. WE UNDERSTAND THAT FMVSS DOES NOT COVER THIS VEHICLE WHICH IS NOT PRIMARILY INTENDED FOR PUBLIC HIGHWAY USE. IT IS MADE TO OPERATE ON AIR FIELDS. ITS TIRES ARE 54" HIGH AND OVER 2 FT. WIDE AND MADE TO RUN FOR 20 MINUTES AR 65 MPH AS A GUIDELINE. T HE SMALL VEHICLE WEIGHS 20 TONS FULL OF WATER AND FOAM. BUMPERS ARE SPECIFIED AT 5 FT. HIGH. COCKPIT IS SIMILAR TO 117A STEALTH FIGHTER. IT CARRIES A POWER WATER TURRET ON TOP. ENCLOSED IS A CONFIDENTIAL PICTURE.

2. DO WE NEED TO USE THE 17 DIGIT FORMULA?

3. DO WE HAVE TO NOTIFY NHTSA SINCE THE VEHICLE IS NOT COVERED?

ID: nht93-5.7

TYPE: Interpretation-NHTSA

DATE: July 2, 1993

FROM: Ron Marion -- Sales Engineer, Thomas Built Buses, Inc.

TO: Marvin Shaw -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/16/93 from John Womack to Ron Marion (A41; Std. 131)

TEXT:

We at Thomas Built Buses, Inc. have been asked to provide school buses for a customer in the U.S. Virgin Islands.

Since in this location they drive on the left side of the road, these buses will be built as right hand drive vehicles with the entrance door located on the left side.

The customer would like to have only one stop arm, to be located on the vehicles right side.

I would like to obtain an interpretation of FMVSS 131, School Bus Pedestrian Safety Devices. Would it be acceptable to place only one stop Arm on the school bus and locate it on the right side for this U.S. holding?

Thank you for your consideration in this matter.

ID: nht76-3.8

DATE: 08/30/76

FROM: AUTHOR UNAVAILABLE; Mark Schwimmer; NHTSA

TO: Interpretations File

TITLE: FMVSS INTERPRETATION

TEXT: SUBJECT: TELEPHONE CALL FROM MR. DAVE HUNT, NADA

On August 26, 1976, I spoke with Mr. Dave Hunt of the National Automobile Dealers Association (821-7030). He referred to a letter sent by General Motors Corporation to some of its dealers, concerning the relation between dealer installations of trailer hitches and Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity. Because neither of us had actually seen the letter, we discussed that relationship in general terms. I explained that the installation of a trailer hitch on a used vehcle would be subject to the "knowingly render inoperative" provision -- Section 108(a)(2)(A) -- of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, and referred to Mr. Hunt to our May 18, 1976, letter on this subject to Mr. Larry Henneberger. I explained further that the most relevant portion of that statute concerning the installation of a trailer hitch on a vehicle before its first purchase in good faith for purposes other than resale would be Section 108(a)(1)(A).

ID: nht74-3.5

DATE: 07/09/74

FROM: P.K. KAMATH -- OSHKOSH TRUCK CORPORATION

TO: RICHARD DYSON -- U.S. DEPT. OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMIN.

TITLE: 49 CFR PART 571, FMVSS 101 - CONTROL LOCATION, IDENTIFICATION AND ILLUMINATION

ATTACHMT: ATTACHED TO LETTER DATED 07/30/74 TO P.K. KAMATH FROM RICHARD DYSON -- NHTSA; N40-30 [ZTV]; OPINION FILE REDBOOK (-); STANDARD 101

TEXT: Dear Mr. Dyson:

Oshkosh Truck Corporation, in many vehicles, incorporates two controls to stop the engine. One control designated as engine stop (electrical) is operated in normal use to shut off the engine, the other control designated as the emergency engine stop (mechanical cable) is used only in emergency to shut off the engine, should the normal engine stop fail.

It is our understanding that the standard 101 applies to the control for normal engine stop and not to the emergency engine stop control.

Please confirm our understanding and if you disagree, please clarify how the control is to be identified and illuminated.

Very truly yours,