ID: nht75-4.24

DATE: 07/22/75

FROM: AUTHOR UNAVAILABLE; J. C. Schultz; NHTSA

TO: RVIA

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 22, 1975, in which you request an interpretation which excludes roof vent covers in recreational vehicles from the coverage of Motor Vehicle Safety Standard No. 205.

The National Highway Traffic Safety Administration (NHTSA) has received an identical request from Richards, Watson, Dreyfuss & Gershon on behalf of Hehr International, Inc. In response to that request, we have determined that roof vent covers should be included within the scope of Standard No. 205, but also concur that roof vent covers manufactured by the injection molding process are not susceptible to testing under the procedures found in USAS Z26.1. Consequently, we intend to issue in the near future proposed rulemaking which would establish surrogate testing procedures for this type of roof vent cover. Until such time as the new procedure is adopted, it is the intention of the NHTSA to take no action against manufacturers who do not certify that their injection molded roof vent covers meet the requirements of Standard No. 205 which incorporate the requirements of USAS Z26.1.

ID: nht91-6.7

DATE: September 23, 1991

FROM: Gene Byrd -- Manager, Auto/Truck Div., Legris, Incorporated

TO: Vernon Bloom -- Office of Vehicle Safety Standards, NHTSA

TITLE: Re MOTOR VEHICLE SAFETY STANDARD NO. 106 (D.O.T. FMVSS 571-106 REV. 2/1/85); REFERENCE: SECTION S7.3.8 AIR PRESSURE & SECTION S8.7 AIR PRESSURE TEST

ATTACHMT: Attached to letter 12-5-91 from Paul Jackson Rice to Gene Byrd (A38; Std. 106)

TEXT:

WE REQUEST YOU ASSISTANCE IN CLARIFICATION OF THIS SECTION OF THE SPECIFICATION.

SECTION 7.3.8 READS AS FOLLOWS:

AN AIR BRAKE HOSE ASSEMBLY SHALL CONTAIN AIR PRESSURE OF 200 PSI FOR 5 MINUTES WITHOUT LOSS OF MORE THAN 5 PSI.

OUR QUESTION; IS THERE IS A TABLE THAT DEFINES WHAT THE PROPER LENGTH OF THE AIR BRAKE HOSE ASSEMBLY SHOULD BE FOR TEST PURPOSES?

MR. BLOOM, IF WE HAVE SENT THIS INQUIRY TO THE WRONG DEPARTMENT, WE REQUEST THAT YOU PLEASE FORWARD TO THE CORRECT PERSON.

SHOULD YOU HAVE ANY QUESTIONS OR COMMENTS PLEASE GIVE US A CALL.

WE THANK YOU FOR YOUR COOPERATION WITH THIS INQUIRY.

ID: nht95-2.72

TYPE: INTERPRETATION-NHTSA

DATE: May 9, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Lance Tunick -- Vehicle Science Corporation

TITLE: NONE

ATTACHMT: ATTACHED TO 4/19/95 LETTER FROM LANCE TUNICK TO MARY VERSAILLES (OCC 1085)

TEXT: Dear Mr. Tunick:

This responds to your FAX of April 19, 1995, requesting clarification of an April 3, 1995, letter from this office. You asked for verification that the "seat belt anchorages in the following scenario are exempt from the location requirement of Standard No. 210:

A vehicle with 2 front seating positions that is fitted with an air bag and manual three-point seat belt at each position, and such restraint meets the frontal crash protection requirements of S5.1 of Standard No. 208 with the air bags alone and with the belts and air bags together, but the belts alone are not crash tested under FMVSS 208."

Your understanding is correct.

I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: nht67-1.29

DATE: 05/25/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Busby and Rivkin, Counsellors at Law

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 26, 1967, concerning the interpretation of Safety Standard Number 210.

Paragraph (Illegible Word) of Standard Number 208, specificas that the Type 2 seat belt anchorage shall be installed in each outboard passanger seat position that includes the windshield header within the head impact area. Therefore, the rear seat is not included in this area and no Type 2 belt assembly is required. A copy of the Federal Register published February 3, 1967, is enclosed for your information.

With regard to your comments on Standard Number 209 and on the provision of Section 108(b)(3) of the Act, please be advised that we anticipate the promulgation of joint regulations with the Secretary of the Treasury, permitting the incorporation of vehicles upon appropriate assurance that they will be brought into conformity with all applicable Federal standards prior to sale. These regulations or related regulations will prescribe the proper means of certifying such nonconforming vehicles in order to insure their admission through United States Customs.

ID: nht68-1.22

DATE: APRIL 26, 1968

FROM: AUTHOR UNAVAILABLE; William H. Risteen; NHTSA

TO: Halfpenny, Hann and Ryan

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of February 6, 1968, to Mr. Lowell K. Bridwell, has been referred to me for reply.

In regard to your question, "Can a car dealer install equipment for which no standards have been established (such as air conditioning units) on a motor vehicle without violating the National Traffic Motor Vehicle Safety Act of 1966?", we are pleased to provide the following clarification.

The fact that there is not a standard directly applicable to air-conditioners or other items of equipment does not mean the dealer has no responsibility under the Act if he installs these equipment items. Any modification to the vehicle before the first purchase for purposes other than resale, must not alter the existing compliance of the motor vehicle with applicable standards.

In the case of an air-conditioner, if it is installed in the instrument panel or any other part of the interior of a passenger car covered by Standard No. 201, it would have to comply with the requirements of the Standard.

I hope this response clarifies the matter with you.

ID: nht69-1.29

DATE: 03/14/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: The Society of Motor Manufacturers and Traders Limited

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 9, 1969, to the Federal Highway Administrator concerning your 1963 Edition of the S.M.M.T. Tyre and Wheel Engineering Manual.

Federal Motor Vehicle Safety Standard No. 109, within Section S3, lists the "Tyre and Wheel Engineering Data Book dated 1965/1966 of the Society of Motor Manufacturers and Traders Limited (S.M.M.T.)" as one of the references containing acceptable test rims. When Standards No. 109 and No. 110 were developed, the National Highway Safety Bureau accepted the S.M.M.T. 1965/1966 Data Book tire and rim combinations based on established usage. We did not, nor do we at present intend to accept general updating of these referenced publications, either foreign or domestic, as valid reasons for answering Standard No. 109 and No. 110. Consequently, any new tire size designations or alternative rim sizes that you wish to list within Standards No. 109 or No. 110 will have to comply, on an individual basis, with the abbreviated guidelines as outlined in the October 5, 1968 Federal Register.

ID: nht69-1.8

DATE: 02/03/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Utility Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 8, 1969, to Mr. Andrew K. Ness, National Highway Safety Bureau, concerning your request for an interpretation relative to the mounting of clearance lamps.

It is required by Federal Motor Vehicle Safety Standard No. 108 that clearance lamps be mounted as near as practicable to the upper right and left extreme edges of the vehicle. Lamps mounted at the right and left extreme edges of the widest part of the body panel shown in your sketch would meet the requirements. The mounting height of these lamps should be as high as practicable without causing objectionable glare in the rearview mirror. Retention of cab mounted clearance lamps is optional.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, comments of this Bureau are for information purposes only and in no way relieve any vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.

ID: nht69-2.15

DATE: 12/16/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Fiat Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 20, 1969, to Mr. Francis Armstrong, concerning your proposed windshield wiper system.

We assume your new windshield wiping system will meet the requirements of S4.1.1.3 of Motor Vehicle Safety Standard No. 104, based upon your description of its operation. Note that S4.1.1.3 states "the highest and one lower frequency" -- the fact that you have even a lower frequency, to cycles per minute, does not conflict with this requirement. The main thing is you do offer a frequency differential of at least 15 cycles per minute measured from a low frequency of at least 20 cycles per minute.

With respect to the requirements of Standard No. 104, I must point out that this Bureau does not issue approvals of windshield wiper systems or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

ID: nht69-2.21

DATE: 06/05/69

FROM: H.A. HEFFRON -- CHIEF COUNSEL, NHTSA; CONCURRENCE OF TENNEY JOHNSON -- MVSPS

TO: G. M. Hilgendorf, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Frank Coy, Special Assistant to the Under Secretary of Transportation, has asked that I respond to your letter of April 16, 1969, in which you ask whether a station wagon purchased in March of 1968, equipped with two ply tires, violates Federal Motor Vehicle Safety Standard No. 109.

The vehicle you purchased was apparently manufactured prior to April 1, 1968, and therefore, it was not required to be equipped with tires conforming to Standard No. 109. However, even if the standards were applicable, because a tire is labeled "2-ply" it is not necessarily a non-conforming tire. Standard No. 109 does not specifically require tires to have a given number of plies. It does require that irrespective of any ply rating tires pass minimum performance tests. As to passenger cars, Standard No. 110 requires that passenger cars manufactured after April 1, 1968, (1) must be equipped with tires that comply with Standard No. 109; and (2) the vehicle must not place a load on any of the tires greater than the load capacity of the tire specified in Standard No. 109.

ID: nht69-2.34

DATE: 10/09/69

FROM: AUTHOR UNAVAILABLE; R. A. Diaz for R. Brenner; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 10, 1969, concerning lamp bulbs to be used in photometric tests.

In answer to your first question, photometric testing of lamps using 1034 and 1157 bulbs should be conducted with the minor filament operating at four mean spherical candlepower to determine conformance to SAE J573b. Bulbs utilizing three candlepower minor filaments would not be in conformance with SAE J573b; however, as provided by the enclosed interpretation issued August 12, 1968, on bulbs and bulb sockets, such bulbs may be used in lamp assemblies conforming to Federal Motor Vehicle Safety Standard No. 108. In accordance with the interpretation, such bulbs should be treated as special bulbs and should be tested at the three candlepower rating.

In answer to your second question, if photometric tests are conducted with a bulb operated at either three or four mean spherical candlepower ratings, it is not acceptable to interpolate (or extrapolate) the data to determine acceptability of the lamp in the other bulb rating.