ID: nht73-1.2

DATE: 01/10/73

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

TO: Van Doorne's Automobielfabrieken N.V.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 12, 1972, about compliance of DAF cars with Federal Motor Vehicle Safety Standard No. 102.

Your question concerns the interpretation of paragraph S3.1.2. From your description in the letter and the description in the owner's manual, only one forward drive position is provided and engine braking can be achieved by actuating the transmission low ratio control switch. Under the conditions described above, the Variomatic transmission in DAF cars is not in violation with paragraph S3.1.2 of Standard No. 102. However, it appears that you do not comply with certain other paragraphs of the standard. For example, paragraph S3.1.1 requires that "A neutral position shall be located between forward drive and reverse positions. . . ." and paragraph S3.1.3 requires that "The engine starter shall be inoperative when the transmission shift lever is in a forward or reverse drive position."

The DAF 66 owners manual dated September 1972, also indicates non-compliance with other standards; for example, 101, Control Location, Identification and Illumination, 114, Theft Protection, 115, Vehicle Identification Number, etc. It is recommended that all standards and regulations be checked for compliance.

A copy of "Where to Obtain Motor Vehicle Safety Standards and Regulations" is enclosed for your review and information.

ID: aiam2110

Dear Mr. Gill: This is in response to your letter of October 14, 1975, in which yo request an interpretation of Standard No. 301 as it applies to a vehicle with an electric fuel pump that operates only when the ignition switch is in the 'ON' position and the engine oil pressure is within the normal operating range.; You indicate in you letter that, in effect, the fuel pump can onl operate when the vehicle's engine is running. Paragraph S7.1.3 of Standard No. 301 requires that an electrically driven fuel pump be operating at the time of the crash tests if the pump 'normally runs when the vehicle's electrical system is activated.' It appears from your letter that activation of the electrical system by switching the ignition to 'ON' will not by itself activate the fuel pump. As a result, the pump need not be operating at the time of the crash tests.; Sincerely, Frank A Berndt, Acting Chief Counsel

ID: nht95-3.51

TYPE: INTERPRETATION-NHTSA

DATE: July 24, 1995

FROM: Doug Burnett -- (Office Of Chuck Chvala)

TO: Dorothy Nakama -- DOT

TITLE: Re: School bus definition language

ATTACHMT: ATTACHED TO 8/4/95 LETTER FROM JOHN WOMACK TO CHUCK CHVALA (REDBOOK 2; PART 571)

TEXT: The budget language is reproduced below. The plus marks indicate new language and the minus marks indicate deleted language. Our current definition is not statutory, and I was mistaken when I told you that it is in Administrative Rule. Our only referen ces to the definition of a school bus are modified in the language below.

I have also attached a copy of the motion which was included in the budget, including a brief analysis of it by the Legislature's budget office. There is also a 1993 memo from our state DOT which discusses some of the issues involved here.

Thanks for your help on this and give me a call if you have any questions.

347.40 (2) No person shall operate on a highway any school bus having a passenger-carrying capacity of [- 10 -] [+ 16 +] or more persons [- including -] [+ in addition to +] the operator unless such bus is equipped with at least one mirror which is 7 inches in diameter so located as to enable the operator to see a reflection of the road from the entire front bumper forward to a point where direct observation is possible.

121.555 (2) (a) Insurance. If the vehicle is owned or leased by a school or a school bus contractor, or is a vehicle authorized under sub. (1) (b), it shall comply with s. 121.53. If the vehicle is transporting [- 9 -] [+ 15 +] or less persons in ad dition to the operator and is not owned or leased by a school or by a school bus contractor, it shall be insured by a policy providing property damage coverage with a limit of not less than $ 10,000 and bodily injury liability coverage with limits of not less than $ 25,000 for each person, and, subject to the limit for each person, a total limit of not less than $ 50,000 for each accident.

PUBLIC INSTRUCTION

Definition of School Bus

Motion:

Move to modify the current definition of school bus as follows:

1. Define a school bus as a motor vehicle which carries 16 or more passengers (in addition to the operator).

2. Provide that a school district can use, as an alternative method of transportation, a motor vehicle transporting 15 or less passengers (in addition to the operator).

Note:

Under current law, a school bus is defined as a motor vehicle which carries 10 or more passengers (in addition to the operator) for the purpose of transporting private and public school pupils to or from school, curricular or extracurricular activitie s, religious instruction (on days when school is in session). If a school board uses a school bus to transport pupils through a contract or the use of its own motor vehicles, the operation of the bus is subject to certain requirements regarding bus oper ator licensure and physical examinations, vehicle insurance, school bus painting and traffic safety rules. A school board can use, as an alternative, a motor vehicle transporting 9 or less passengers (in addition to the operator): in such cases, the scho ol district is not subject to the same requirements applicable to the operation of a school bus.

[Change to Governor: None]

LETTER

Ricardo Martinez Administrator, NHTSA Department of Transportation

Dear Mr. Martinez,

I have been contacted by Wisconsin State Senator Chuck Chvala regarding a provision recently passed in the Wisconsin Legislature's biennial budget. The language included in the legislation changes the state definition of school buses in a manner that is inconsistent with the definition established by the U.S. Department of Transportation. Senator Chvala has inquired as to whether this change in state law and subsequent state regulations would violate any federal laws or regulations with respect to the definition of school buses.

I would appreciate a prompt reply to Senator Chvala's inquiry. Please direct your response to:

Chuck Chvala Wisconsin State Senator State Capitol P.O. Box 7882 Madison, WI 53707-7882

Russell D. Feingold United States Senator

cc: Ms. Carmen Rivera, Legislative Liaison, NHTSA

ID: nht95-5.30

TYPE: INTERPRETATION-NHTSA

DATE: July 24, 1995

FROM: Doug Burnett -- (Office Of Chuck Chvala)

TO: Dorothy Nakama -- DOT

TITLE: Re: School bus definition language

ATTACHMT: ATTACHED TO 8/4/95 LETTER FROM JOHN WOMACK TO CHUCK CHVALA (REDBOOK 2; PART 571)

TEXT: The budget language is reproduced below. The plus marks indicate new language and the minus marks indicate deleted language. Our current definition is not statutory, and I was mistaken when I told you that it is in Administrative Rule. Our only references to the definition of a school bus are modified in the language below.

I have also attached a copy of the motion which was included in the budget, including a brief analysis of it by the Legislature's budget office. There is also a 1993 memo from our state DOT which discusses some of the issues involved here.

Thanks for your help on this and give me a call if you have any questions.

347.40 (2) No person shall operate on a highway any school bus having a passenger-carrying capacity of [- 10 -] [+ 16 +] or more persons [- including -] [+ in addition to +] the operator unless such bus is equipped with at least one mirror which is 7 inches in diameter so located as to enable the operator to see a reflection of the road from the entire front bumper forward to a point where direct observation is possible.

121.555 (2) (a) Insurance. If the vehicle is owned or leased by a school or a school bus contractor, or is a vehicle authorized under sub. (1) (b), it shall comply with s. 121.53. If the vehicle is transporting [- 9 -] [+ 15 +] or less persons in addition to the operator and is not owned or leased by a school or by a school bus contractor, it shall be insured by a policy providing property damage coverage with a limit of not less than $ 10,000 and bodily injury liability coverage with limits of not less than $ 25,000 for each person, and, subject to the limit for each person, a total limit of not less than $ 50,000 for each accident.

PUBLIC INSTRUCTION

Definition of School Bus

Motion:

Move to modify the current definition of school bus as follows:

1. Define a school bus as a motor vehicle which carries 16 or more passengers (in addition to the operator).

2. Provide that a school district can use, as an alternative method of transportation, a motor vehicle transporting 15 or less passengers (in addition to the operator).

Note:

Under current law, a school bus is defined as a motor vehicle which carries 10 or more passengers (in addition to the operator) for the purpose of transporting private and public school pupils to or from school, curricular or extracurricular activities, religious instruction (on days when school is in session). If a school board uses a school bus to transport pupils through a contract or the use of its own motor vehicles, the operation of the bus is subject to certain requirements regarding bus operator licensure and physical examinations, vehicle insurance, school bus painting and traffic safety rules. A school board can use, as an alternative, a motor vehicle transporting 9 or less passengers (in addition to the operator): in such cases, the school district is not subject to the same requirements applicable to the operation of a school bus.

[Change to Governor: None]

LETTER

Ricardo Martinez Administrator, NHTSA Department of Transportation

Dear Mr. Martinez,

I have been contacted by Wisconsin State Senator Chuck Chvala regarding a provision recently passed in the Wisconsin Legislature's biennial budget. The language included in the legislation changes the state definition of school buses in a manner that is inconsistent with the definition established by the U.S. Department of Transportation. Senator Chvala has inquired as to whether this change in state law and subsequent state regulations would violate any federal laws or regulations with respect to the definition of school buses.

I would appreciate a prompt reply to Senator Chvala's inquiry. Please direct your response to:

Chuck Chvala Wisconsin State Senator State Capitol P.O. Box 7882 Madison, WI 53707-7882

Russell D. Feingold United States Senator

cc: Ms. Carmen Rivera, Legislative Liaison, NHTSA

ID: aiam4261

Dear Mr. Tupper: It has come to our attention that a recent Alabama Supreme Cour decision has led some dealers to question the appropriate certification to make when issuing an odometer disclosure statement. We have received an inquiry about this decision from the Oregon Independent Auto Dealers Association. Furthermore, I have enclosed a copy of an article which appeared in the November 1986 issue of *The California Dealer* and which was provided to us by the maryland Independent Auto Dealers Association. Based on the Alabama decision, the article instructs dealers who doubt the accuracy of the odometer reading to certify that the odometer reading does not reflect the actual mileage and should not be relied upon. The purpose of this letter is to advise you of the National Highway Traffic Safety Administration's position concerning the certifications to be made on odometer disclosure statements.; Congress found that purchasers rely on mileage as an indicator of th value and condition of vehicles and enacted Title IV of the Motor Vehicle Information and Cost Savings Act, 15 U.S.C. S1981 *et seq*. Section 1988(a) of the Act requires the Secretary of Transportation to prescribe rules requiring any transferor to give a written disclosure (1) of the cumulative mileage registered on the odometer or (2) that the actual mileage is unknown, if the odometer reading is know to the transferor to be different from the number of miles the vehicle has actually travelled. To carry out this mandate, Federal regulation 49 C.F.R. Part 580 was promulgated. Furthermore, Section 1988(a) states that no transferor shall violate any rule prescribed under the section or give a false statement to a transferee in making any disclosure required by such rule.; A Senate report interprets Section 1988 as placing duty on auto dealer to alert purchasers of irregularities in odometers when, in the exercise of reasonable care, they would have reason to know the odometer reading is inaccurate. S. Rep. No. 92-413, (92nd Cong., 2nd Sess.), 1972 U.S. Code Cong. & Ad. News 3971-3972. If a purchaser receives an odometer statement in which his transferor certified that the odometer reading does not reflect the actual mileage and should not be relied upon, that purchaser, when selling the vehicle, should certify the same. However, if a purchaser receives an odometer statement in which his transferor certified that to the best of his knowledge the odometer reading reflects the actual mileage the vehicle has been driven, and he has no reasonable suspicion that the reading is inaccurate, when selling the vehicle, he should not certify that the reading is inaccurate. If transferors certify the reading as inaccurate in the latter situation, it is the position of the National Highway Traffic Safety Administration that they violate the regulations prescribed under Section 1988, 49 C.F.R. S580.4.; The Federal regulations provide for the inclusion of two sets o certifications on odometer disclosure statements. If the dealers truly wish to insulate themselves from liability when they have a reasonable suspicion that the mileage on the odometer has been altered, they *should* certify that the reading is not accurate, and check the third statement in the first set of certifications. However, none of the three statements in the second set covers a situation where a transferor suspects that an odometer reading is inaccurate, but the odometer was not altered, set back or disconnected in his possession. The Agency allows a transferor to check the first statement and cross out the lines which read, 'and I have no knowledge of anyone else doing so' provided that though crossed out it can still be read. Alternatively, we have no objection to a transferor writing and checking a fourth statement which would read:; >>>I hereby certify that the odometer of said vehicle was not altered set back, or disconnected while in my possession.; <<

ID: aiam5483

Gentlemen: We have received your letter of January 2, 1995, asking fo a confirmation of the appropriateness of your proposed test procedures for plastic materials, as you wish to 'continue to adhere to the SAE testing protocol as delineated in SAE J576C.' Paragraph S5.1.2 of Standard No. 108 requires, with certain exceptions, that plastic materials used for optical parts such as lenses and reflectors shall conform to SAE J576c. It has been the agency's position over the years that 49 U.S.C. Chapter 301 (formerly the National Traffic and Motor Vehicle Safety Act) does not establish a requirement that a manufacturer actually conduct compliance testing, but requires only that a vehicle or equipment item conform to any applicable Federal motor vehicle safety standard if tested in the manner set forth in the standard. We have advised that a manufacturer may exercise due care in certifying compliance of its product on bases other than the test procedures that are set forth in the Federal motor vehicle safety standards, whether the procedures are incorporated by reference, as with J576c, or directly expressed in the standards themselves, although NHTSA itself will conduct its tests according to the procedures set forth in the standards. For this reason, we have no comment on the merits of your suggested approach. Because the agency has proposed amending Standard No. 108 to substitute SAE J576 JUL91 for J576c, we are filing your letter in Docket No. 94-37 as a comment to be considered in this rulemaking. Enclosed is a copy of the proposal with which you are probably already familiar. Although the comment period closed on January 3, it is the agency's practice to consider late-filed comments to the extent practicable. Sincerely, Philip R. Recht Chief Counsel Enclosure;

ID: nht89-3.28

TYPE: INTERPRETATION-NHTSA

DATE: 11/01/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: SAMUEL KIMMELMAN -- PRODUCT ENGINEERING MANAGER IDEAL DIVISION PARKER HANNAFIN CORPORATION

TITLE: NONE

ATTACHMT: LETTER DATED 03/22/89 FROM SAMUEL KIMMELMAN -- PARKER HANNIFIN TO TAYLOR VINSON -- NHTSA; OCC 3309

TEXT: Dear Mr. Kimmelman:

This is in reply to your letter to Taylor Vinson of this office. I regret the delay in responding. You express your understanding that Standard No. 108 "allows vehicles with combined function rear stop and turn signal/hazard lamps to operate in either of two modes when both the hazard switch and brake switch have been actuated." You have expressed these two modes as follows:

"1. The hazard switch is the major control for operation of the combined rear stop and turn signal/hazard lamps.

a. Actuating the hazard switch some period of time after actuation of the brake switch will cause the rear lamps to change from steady on, stop signal, to flashing, hazard signal.

b. Actuating the brake switch some period of time after actuation of the hazard switch will not change the flashing lamps, hazard signal, to steady on, stop signal.

2. The brake switch is the major control for operation of the combined rear stop and turn signal/hazard lamps.

a. Actuating the brake switch some period of time after actuation of the hazard switch will cause the rear lamps to change from flashing, hazard signal, to steady on, stop signal.

The front flashing hazard lamps will also become steady on.

b. Actuating the hazard switch some period of time after actuation of the brake switch will not change the rear steady on lamps, stop signal, to flashing, hazard, while the front hazard lamps go from off to steady on."

You ask for confirmation of your understanding, and if it is correct, whether NHTSA is presently considering rulemaking "to specify a specific signal from the combined function rear stop and turn signal/hazard lamps when both the hazard and brake switche s are actuated."

Neither of these modes are correct, for the reasons discussed below. Initially we note that systems with combined-function lamps are those that use red lenses for the rear turn signals lamps, and not the amber lenses that Standard No.

108 allows. The second point we wish to make is that you may have confused hazard warning lamps with turn signal lamps. The basic Federal requirements for stop lamps are those of SAE Standard J586c Stop Lamps, August 1970, which is incorporated by refe rence in Standard No. 108. Paragraph 4.2 of J586c states "When a stop signal is optically combined with the turn signal, the circuit shall be such that the stop signal cannot be turned on in the turn signal which is flashing." The identical provision is found in paragraph 4.4 of SAE Standard J588e Turn Signal Lamps, September 1970, which is also incorporated by reference in Standard No. 108. This clearly means that a turn signal cannot be overriden by a stop lamp. In addition, you should note that re gulations of the Federal Highway Administration's Bureau of Motor Carrier Safety forbid the optical combination of a stop lamp with a turn signal lamp unless the stop lamp function is deactivated when the turn signal lamp is activated (49 CFR 393.22(b)(2 ).

Assuming, however, that you meant hazard warning system lamps, there is no provision in Standard No. 108 for hazard warning system operation (those of SAE Recommended Practice J945 Vehicular Hazard Warning Signal Flasher, February 1968, incorporated by r eference in Standard No. 108) specifying priority of operation with respect to the stop lamp system. Because paragraph S5.5.4 of Standard No. 108 requires the stop lamps to be activated upon application of the service brakes, we interpret this as allowi ng the stop lamp system to override the hazard warning system. This opinion, of course, relates only to the rear lamps. The hazard warning system at the front of a vehicle must operate at any time the system is actuated.

In response to your question about the possibility of rulemaking, please note that the agency does not plan any rulemaking on this subject.

Sincerely,

ID: 2108y

Mr. Samuel Kimmelman
Product Engineering Manager
Ideal Division
Parker Hannafin Corporation
3200 Parker Drive
St. Augustine, FL 32084

Dear Mr. Kimmelman:

This is in reply to your letter to Taylor Vinson of this office. I regret the delay in responding. You express your understanding that Standard No. l08 "allows vehicles with combined function rear stop and turn signal/hazard lamps to operate in either of two modes when both the hazard switch and brake switch have been actuated." You have expressed these two modes as follows:

"l. The hazard switch is the major control for operation of the combined rear stop and turn signal/hazard lamps.

a. Actuating the hazard switch some period of time after actuation of the brake switch will cause the rear lamps to change from steady on, stop signal, to flashing, hazard signal.

b. Actuating the brake switch some period of time after actuation of the hazard switch will not change the flashing lamps, hazard signal, to steady on, stop signal.

2. The brake switch is the major control for operation of the combined rear stop and turn signal/hazard lamps.

a. Actuating the brake switch some period of time after actuation of the hazard switch will cause the rear lamps to change from flashing, hazard signal, to steady on, stop signal.

The front flashing hazard lamps will also become steady on.

b. Actuating the hazard switch some period of time after actuation of the brake switch will not change the rear steady on lamps, stop signal, to flashing, hazard, while the front hazard lamps go from off to steady on."

You ask for confirmation of your understanding, and if it is correct, whether NHTSA is presently considering rulemaking "to specify a specific signal from the combined function rear stop and turn signal/hazard lamps when both the hazard and brake switches are actuated."

Neither of these modes are correct, for the reasons discussed below. Initially we note that systems with combined-function lamps are those that use red lenses for the rear turn signals lamps, and not the amber lenses that Standard No. l08 allows. The second point we wish to make is that you may have confused hazard warning lamps with turn signal lamps. The basic Federal requirements for stop lamps are those of SAE Standard J586c Stop Lamps, August l970, which is incorporated by reference in Standard No. l08. Paragraph 4.2 of J586c states "When a stop signal is optically combined with the turn signal, the circuit shall be such that the stop signal cannot be turned on in the turn signal which is flashing." The identical provision is found in paragraph 4.4 of SAE Standard J588e Turn Signal Lamps, September l970, which is also incorporated by reference in Standard No. l08. This clearly means that a turn signal cannot be overriden by a stop lamp. In addition, you should note that regulations of the Federal Highway Administration's Bureau of Motor Carrier Safety forbid the optical combination of a stop lamp with a turn signal lamp unless the stop lamp function is deactivated when the turn signal lamp is activated (49 CFR 393.22(b)(2).

Assuming, however, that you meant hazard warning system lamps, there is no provision in Standard No. l08 for hazard warning system operation (those of SAE Recommended Practice J945 Vehicular Hazard Warning Signal Flasher, February l968, incorporated by reference in Standard No. l08) specifying priority of operation with respect to the stop lamp system. Because paragraph S5.5.4 of Standard No. l08 requires the stop lamps to be activated upon application of the service brakes, we interpret this as allowing the stop lamp system to override the hazard warning system. This opinion, of course, relates only to the rear lamps. The hazard warning system at the front of a vehicle must operate at any time the system is actuated.

In response to your question about the possibility of rulemaking, please note that the agency does not plan any rulemaking on this subject.

Sincerely,

Stephen P. Wood Acting Chief Counsel /ref:108 d:ll/l/89

ID: aiam4322

Dear Mr. Utans: This responds to your letter of April 21, 1987, concerning the Part 58 Bumper Standard. You asked whether a vehicle equipped with a suspension system whose height is adjustable by the driver is tested at the manufacturer's engine- on and engine-off nominal design height.; On May 6, 1986, I responded to a similar request that you made for a interpretation. My letter (copy enclosed) stated that it is our interpretation that a vehicle must be capable of meeting the standard's damage criteria at any height position to which the suspension can be adjusted.; Your current request for an interpretation does not provide ne arguments which indicate that our earlier interpretation was incorrect. Therefore, I must reaffirm that earlier opinion.; As we indicated in the May 6, 1986 letter, we appreciate your concer that the very reason that the adjustable height is provided (increased ground clearance and ramp angle for special operations) is partially negated by requiring bumpers to extend low enough to provide Part 581 protection at the elevated settings. The letter stated, however, that if the agency were to consider establishing special provisions in Part 581 for vehicles with adjustable suspension height control systems, it would need to be done in rulemaking. See section 102(c)(1) of the Motor Vehicle Information and Cost Savings Act.; I would also note that in a meeting in March of this year, a member o my staff advised your representatives that your company could submit a petition for rulemaking requesting an amendment to Part 581. The procedures for submitting a petition for rulemaking are set forth at 49 CFR Part 552. If you should submit a petition, the agency would decide whether to grant it in accordance with statutory criteria.; Sincerely, Erika Z. Jones, Chief Counsel

ID: nht74-2.43

DATE: 05/24/74

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

TO: Dorsey Trailers

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 3, 1974, question concerning the certification responsibility of a manufacturer of trailers that must conform to Standard No. 121, Air brake systems. You ask if the substitution of parts not specified by an axle manufacturer will affect certification if the parts are nearly identical in their specifications and performance to the recommended parts.

In the case of substitution of parts, you must simply satisfy yourself that your vehicles are capable of meeting the requirements of the standard in a test by the NHTSA. If you are satisfied that the supplier's recommended package will meet the requirements, and you determine that a substitution would not adversely affect the vehicle's performance to the point where it no longer would meet the requirements, you are free to make the substitution. It would be advisable to make some record of your calculations of the effect of such substitutions.

Yours truly,

ATTACH.

May 3, 1974

James B. Gregory, Administrator -- National Highway Traffic Safety Administration

Dear Sir:

Dorsey Trailers, Inc. has selected Wagner Electric Corporation and The Berg Manufacturing Company to supply the air actuation and anti-skid equipment for all trailers manufactured by this company. Other companies have been reviewed as suppliers on special customer request but our Engineering and Production techniques are only developed for the above two suppliers at this time. Both of the suppliers have assured us of adequate inventory of the required material to start shipping trailers by September 1, 1974 with the F.M.V.S.S. 121 specifications.

The two major axle suppliers which we use, Kershaw Axle Division of C. & M. Spring Company and Standard Forg and Axle Company, have both promised axles with brakes to meet the 121 specifications by September 1, 1974.

The problem that concerns us is the dynamometer brake rating. We have just been given a new interpretation of the requirements for the dynamometer rating, stating that if any portion of the combinations of components such as air chambers, slack adjusters, brake drums, etc. is changed from the exact specified part number and brand name used in certifying an axle with a given brake lining, the certification is voided and not acceptable. If this is true, then there does not seem to be enough dynamometer time available to meet a deadline even by January 1, 1975 for all combinations of parts available to the trailer industry.

As a smaller manufacturer of trailers we do not enjoy the luxury of telling our customers that certain parts are our standard materials and we won't furnish other components. Our customers usually have their own part specifications to simplify their maintenance.

If we had an axle certified with B-W slack adjusters, 6" long and B-W type 30 spring brake chambers, but our customer specified his axles must have Berg 6" slack adjusters and Berg Type 30 spring brake chambers, would this affect the certified axle? The substitution would be of equal parts and performance but different brand names.

Another example would be an axle certified with a Webb #66518 drum weighing 96 pounds and the customer specifying a Webb #67518 drum which weighs 106 pounds. The addition of the 10 pounds of weight would increase the fade-away characteristics by better heat dissipation but would this change require another dynamometer test?

Some customers specify cast brake shoes while others prefer fabricated brake shoes. With all other components being the same, would the change in brake shoes require a new certification?

If our suppliers meet their commitments, we could offer certain of our options to meet "121" specs on September 1, 1974. To certify all of the options that we are required to furnish, there could possibly not be enough dynamometer time available by January 1, 1975. Please give us an interpretation on varying the components and how this would effect the certifications.

Due to material shortages, the privilege of switching suppliers of certain assemblies is almost prohibitive since allocation of material is very common. This problem will only multiply the above problem of dynamometer testing time. If your regular supplier does not have his own dynamometer, it will be very difficult to secure time on an independent test machine and impossible to get the service of your competitors' equipment.

Yours very truly,

DORSEY TRAILERS; Roy C. Belcer - Vice President -- Manufacturing and Engineering

CC: G. L. Collier