ID: nht72-3.27

DATE: 01/01/72 EST.

FROM: Richard B. Dyson; NHTSA

TO: Brockway Motor Trucks

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 12, 1972, regarding the application of S4.3 of Standard No. 207, Seating Systems, to an auxiliary folding seat installed in Brockway trucks.

As shown in your drawings and photographs, the seat faces forward and has a hinge at the rear of the lower cushion. An upward force at the front of the lower cushion will move the cushion upward and rearward until it presses against the seat back.

The intent of S4.3 is to reduce the forces acting on an occupant in an accident by preventing the seat or seat back from folding onto him. It does not appear from the material you have submitted that any motion of the lower seat cushion will impose such additional forces on an occupant. The folding action is therefore not of the type contemplated by the standard and no restaining device would be required for this seat.

ID: nht72-3.30

DATE: 09/08/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Auto Top, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 25, 1972, concerning the application of section S4.3 of Motor Vehicle Safety Standard No. 207 to a folding dinette seat manufactured by your company for use in recreational vehicles.

The seat you describe has a back that folds flat to make a bed. A seat back that travels through such a large arc does not fall within the limited exceptions provided in S4.3 for a "back that is adjustable only for the comfort of its occupants," and it must therefore be equipped with a restraining device conforming to S4.3. The quoted language applies to the type of seat whose back is adjustable through a few degrees of arc to provide a variety of riding positions for persons of different sizes and postures. A seat back that folds to the point where it no longer restrains the longitudinal motion of the occupant is required to have a device that prevents it from assuming that position accidentally.

ID: nht72-3.42

DATE: 11/13/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 14, 1972, on the subject of the test dummy specifications of Standard No. 208. I apologize for our delay in replying.

The alignment procedures of S8.1.11 of the standard cause the head to be aligned so that its vertical axis is almost in the same plane as the dummy's back. The necks on most commercial dummies are made of rubber and are installed at such an angle that, as you have noted, the specified head alignment cannot be maintained. To correct this misalignment, the necks must be adjusted by shims or other means so that the correct alignment can be maintained.

The center of gravity of the upper thorax is approximated by dimensions C and D in Table I and Figure 1 of SAE Recommended Practice J963. The precise location may vary slightly from one dummy model to another due to variances in the distribution of mass in the thoracic area.

ID: nht71-3.48

DATE: 07/22/71

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: S. Jackson-Smith

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your recent letter inquiring about the mounting of a spare tire between headlights of a Volkswagen Camper.

There is no Federal regulation that prohibits the mounting of the spare tire on the front of a vehicle. Federal motor vehicle safety standards apply to new vehicles and regulate manufacturers so as to assure compliance with applicable requirements. The standards do not regulate the vehicle purchaser and owner.

However, in the importation of vehicles into the United States, certain requirements must be met. These requirements are described in the enclosed pamphlet dated October 1969. If your vehicle has been manufactured more recently, up-to-date requirements may be obtained from your Volkswagen dealer.

It is recommended that inquiry be made of the State in which the vehicle will be licensed or driven for applicable laws and regulations in this area.

We appreciate your concern for motor vehicle safety.

ENC.

ID: nht71-3.7

DATE: 05/24/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 7, 1971, requesting clarification of S4.9 of Motor Vehicle Safety Standard No. 213, "Child Seating Systems." Your letter asks whether the release mechanism requirements of S4.9 apply to either a Type 1 or Type 2 seat belt assembly that is used to restrain the child seating system pursuant to S4.4(b) of the standard. Your letter also raises by implication the question whether a Type 1 or Type 2 seat belt assembly that pursuant to S4.9, is used to directly restrain the child must also meet the release mechanism requirements of S4.9.

The answer to both questions is no. The release mechnism requirements that each Type 1 or Type 2 seat belt assembly is required to meet are those specified in Motor Vehicle Safety Standard No. 209. The requirements for the release mechanism specified in S4.9 of Standard No. 213 apply to those components, other than a Type 1 or Type 2 seat belt assembly, that directly restrain the child.

ID: nht71-4.10

DATE: 09/13/71

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

TO: Ray. C. Ellsworth Ranches

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 2 inquiring whether your braking system hydraulic valve "is in conformity with the Federal Dual Braking Regulations now in effect."

Federal Motor Vehicle Safety Standard No. 105, Hydraulic Service Brake, Emergency Brake, and Parking Brake Systems, applies to passenger cars, and not to individual items of motor vehicle equipment incorporated in a hydraulic brake system. Thus, there is no Federal Standard to which your valve must conform. If the valve is installed as original equipment in a passenger car, it is the vehicle that would be required to conform to the performance requirements of Standard No. 105.

I have noted your comment that the valve is to be tested on braking systems for military vehicles. You may be interested to know that Federal Motor Vehicle Safety Standards, including No. 105, do not apply to vehicles manufactured for and sold to the Armed Forces of the United States.

ID: nht71-4.23

DATE: 10/18/71

FROM: AUTHOR UNAVAILABLE; D. W. Toms; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Secretary Volpe has asked me to reply to your letter of October 18, 1971, concerning the applicability of the National Traffic and Motor Vehicle Safety Act of 1966 in the territories and possessions of the United States.

The Act and the Federal motor vehicle safety standards issued thereunder apply in Puerto Rico, the Virgin Islands, the Canal Zone, Guam, and American Samoa. Motor vehicles, including buses, manufactured for sale and imported into those areas must meet all applicable Federal motor vehicle safety standards. Only one standard applicable to buses, No. 103, Windshield Defrosting and Defogging Systems, specifically does not apply to buses manufactured for sale outside the Continental United States. There are no Federal standards applicable to school bus bodies, so that the wooden bodied buses in American Samoa, of which you spoke, are not prohited by the Act. School buses manufactured for sale in Puerto Rico are required, however, to have a warning light system.

I HOPE THIS CLARIFIES THE MATTER FOR YOU.

ID: nht71-4.3

DATE: 08/11/71

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Long Trailer Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 30, 1971, to Mr. Ed. Leysath of this office concerning the mounting location of side marker and taillights on your boat trailers.

The mounting requirements for lamps and reflectors are specified in Federal Motor Vehicle Safety Standard No. 108 (copy enclosed). It appears as if devices mounted as indicated on your drawing would meet the requirements. If, however, severe problems would be encountered in mounting the devices as indicated or the devices would be subjected to damage during normal use, other mountings may be appropriate and still meet the "as far apart as practicable" or "as far to the rear as practicable" or "as far to the front as practicable" requirements.

If water damage is the only problem when lamps and reflectors are mounted in the indicated positions, special waterproof devices are available and could be used.

ENC.

ID: nht71-4.49

DATE: 11/16/71

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

TO: The Flxible Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 22 asking whether the "hoodlum warning system" requested by the city of Boston (MBTA) would conform to Federal Motor Vehicle Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

Paragraph S3.5 of Standard No. 108 permits "normally steadily-burning lights [to] be capable of being individually flashed for signalling purposes" on motor vehicles manufactured before January 1, 1972. Therefore the hoodlum warning system is currently permissible under Standard No. 108.

However, a new requirement effective January 1, 1972, would prohibit the installation of this system on vehicles manufactured on or after this date. Paragraph S4.6 of Standard No. 108 states:

"Where activated

(a) Turn signal lamps, hazard warning signal lamps, and school bus warning lamps shall flash;

(b) All other lamps shall be steady-burning except that means may be provided to flash headlamps and side marker lamps for signalling purposes." (emphasis added)

ID: nht71-5.2

DATE: 11/17/71

FROM: AUTHOR UNAVAILABLE; J. W. Carson for E. T. Driver; NHTSA

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 4, 1971, to Mr. J. E. Leysath of this Office, concerning the maximum candlepower for taillamps as specified in Federal Motor Vehicle Safety Standard No. 108.

Paragraph S5.1 of Standard No. 108 (35 FR, 16840, October 31, 1970) is quoted as follows:

"S5.1 SAE Standards and Recommended Practices subreferenced by the SAE Standards and Recommended Practices included in Tables I and III and paragraphs S4.1.4 and S4.5.1 are those published in the 1970 edition of the SAE Handbook."

Subreferenced SAE Standard J575, as published in the 1970 edition of the SAE Handbook, is the "d" revision (SAE J575d, August 1967). SAE Standard J575d specifies a maximum of 15 candlepower for a single compartment taillamp, 20 candlepower for a 2-compartment taillamp, and 25 candlepower for a 3-compartment taillamp. These maximum candlepower values are, therefore, applicable requirements under Standard No. 108 (35 FR, 16840, October 31, 1970).