ID: nht69-2.39

DATE: 09/12/69

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

TO: The Flexible Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 21, 1969, to Mr. George C. Nield, Acting Assistant Director, Motor Vehicle Safety Performance Service, concerning the requirements of Federal Motor Vehicle Safety Standard No. 108 with respect to activation of stop lamps when the emergency brakes are applied.

Paragraph S3.4.4 of Standard No. 108 specifies that "Except as provided in S3.4.4.1 through S3.4.4.3 stop lamps shall be actuated upon application of any service or emergency broken." The emergency-parking brakes as described in the 2nd paragraph of your letter are not considered "emergency" brakes within the weaning of paragraph S3.4.4 of Standard No. 108. Therefore, actuation of stop lamps need not be provided upon application of such brakes. I should point out, however, that the Bureau now has under development a proposed standard for brakes which will be applicable to trucks. If under this proposed standard, the emergency-parking brakes as used on your vehicles are defined as "emergency" brakes, then the requirement of paragraph S3.4.4 of Standard No. 108 will be applicable.

ID: nht70-1.15

DATE: 10/01/70

FROM: C. A. Baker for R. H. Compton; NHTSA

TO: Barrington Homes of Florida, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 14, 1970, to Mr. Rodolfo A. Diaz, Acting Associate Director for Motor Vehicle Programs, National Highway Safety Bureau concerning clearance lights on mobile homes.

A mobile home moved on its own wheels is a "motor vehicle" under the National Traffic and Motor Vehicle Safety Act, and is categorized as a "trailer".

Federal Motor Vehicle Safety Standard No. 108 requires clearance lamps to be installed on trailers 80 or more inches in overall width. In transit a mobile home towed on its own wheels must therefore be equipped with clearance lamps; however, these lamps may be temporarily installed and removed when the mobile home has reached its destination.

We would appreciate your providing us, if possible, with the names of manufacturers of mobile homes whom you believe to be towing these vehicles without equipping them with lighting devices meeting Standard No. 108. This will assist us in our efforts to insure that all manufacturers meet their obligations under the Act.

ID: nht70-1.17

DATE: 03/17/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: The Auto Sun Products Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of February 13 indicates that your understanding of the regulatory situation is correct. There is no prohibition in the motor vehicle safety standards against the sale of a non-conforming attachment bolt as a separate item. All that Standard No. 209 requires is that the seat belt assemblies which your firm supplies must be accompanied by conforming attachment bolts.

Before you act on your understanding, however, you should give special consideration to the consequences of any widespread use of attachment bolts which do not conform to the strength and other requirements of the standard. If, for example, we found that vehicle owners were being induced to secure their aftermarket seat belts to anchorages by the use of attachment bolts that do not provide adequate strength in crash situations, we would be compelled to consider whether the public interest would require rulemaking action aimed at preventing the marketing of such understrength bolts. We appreciate your desire not to evade the regulations or take advantage of what may be considered a loophole in them.

Sincerely,

ID: nht70-1.3

DATE: 09/17/70

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

TO: Univeral Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT: The Office of Trade Regulation Rules of the Federal Trade Commission has forwarded your letter of July 30, 1970, concerning tires marked "Radial" that have casing cord angles that vary as much as 15 degrees from 90 degrees.

Paragraph 33 of Federal Motor Vehicle Safety Standard No. 109 -- New Pneumatic Tires, Passenger Cars -- defines a radial ply tire as a "pneumatic tire in which the ply cords which extend to the bends are laid at substantially 90 degrees to the centerline of the trend".

The Bureau does not consider cords laid at 75 degrees to the centerline of the trend as "Radial" tires and tires marked as much would not be in compliance with the tire standard.

Persons importing tires that do not comply with the standard would be violating section 108(a) (1) of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1397).

For your information enclosed is a copy of the Passenger Car Tire Standard and the National Traffic and Motor Vehicle Safety Act.

ID: nht70-1.8

DATE: 05/13/70

FROM: AUTHOR UNAVAILABLE; G. C. Nield for Rodolfo A. Diaz; NHTSA

TO: K. L. Rosenberger

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 18, 1970, concerning the use of tires designed for racing purposes for street use.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) prohibits the sale of motor vehicle equipment that does not comply with applicable Federal Motor Vehicle Safety Standards. Therefore, it would be a violation of the Act if someone manufactured or sold a passenger tire that did not meet Standard No. 109. However, the Act does not apply to the use of non-conforming tires so that it would be the sale of such tires for street purposes, not the use, that would be a violation of the Act.

With regard to your comments that the California Highway Patrol considers these tires "OK" for street use, we understand that the restriction in the California regulations is presently limited to the prohibition of the sale of racing tires for street use but that legislation has been introduced which would prohibit the use of such tires for street purposes.

ID: nht68-2.13

DATE: 05/27/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Truck Trailer Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 7, 1968, to Dr. William Haddon, Jr., concerning the location of intermediate side marker lamps and intermediate side reflex reflectors on narrow frame container chassis.

The location requirements for these devices, as specified in Motor Vehicle Safety Standard No. 108, may be met by mounting them on the main frame of narrow frame container chassis, provided they are mounted in accordance with the enclosure to your referenced letter and are located at or near the midpoint between the front and rear side marker lamps and side reflex reflectors.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment 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.

Thank you for writing.

ID: nht68-2.29

DATE: 11/14/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Timmons Metal Products Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 7, 1968, to Dr. William Haddon, Jr., Director, National Highway Safety Bureau, concerning additional side marker lights on tilt cab chassis.

In order to meet the requirements of Federal Motor Vehicle Safety Standard No. 108, an amber side marker lamp should be counted on each side of the chasis cab as far forward as practicable. Additional amber side market lamps are not required on the truck body, providing the overall length of the vehicle is less than 30 feet. This is a general clarification only, since we are not sure of the exact configuration of the vehicles in question. A picture or drawing with the necessary overall dimensions would be needed for specific comments.

This Burenu does not issue approval on items of lighting equipment of 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 lacks the requirements of standard No. 108.

ID: nht68-2.44

DATE: 12/17/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Perley A. Thomas Car Works, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 19, 1968, to Mr. E. Leysath of this Bureau, concerning a clarification of the requirements of paragraph S3.4.3 of Federal Motor Vehicle Safety Standard No. 108.

As you indicated, paragraph S3.4.3 of initial Standard No. 108, which was published in the Federal Register on February 3, 1967, required that tail lamps, license plate lamps, and side marker lamps be illuminated when the headlamps are illuminated. The effective date of the initial standard was January 1, 1968. However, on December 16, 1967, an amendment to the initial standard was published in the Federal Register. This amendment delayed the effective date of paragraph S3.4.3 until May 1, 1968, and in addition revised that paragraph to require, as a minimum, that the fail lamps be illuminated when the headlamps are illuminated. Therefore, the requirements of paragraph S3.4.3 were not applicable to vehicles manufactured during the period of January 1, 1963 through April 30, 1968. During that period, selection of the lamp switching arrangement was at the option of the vehicle manufacturer.

Thank you for writing.

ID: nht68-3.34

DATE: 05/14/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 1, 1968, to Mr. Edwin L. Slagle, requesting a clarification of the location requirements for identification lamps on real trailers.

The brochures attached to your letter describe two types of reel trailers as manufactured by the Standard Trailer Company and designated as the "Reelmaster" and "Cable Winder/Stringer." These trailers are completely open in the rear with no permanently attached crossbar for mounting rear identification lamps. On these trailers, identification lamps mounted on permanently attached swinging arms which are located near the wheels of the trailers would appear to conform to the requirements of Motor Vehicle Safety Standard No. 108.

With respect to the requirements of Standard No. 108. I must point out that this Bureau does not issue approvals on items of lighting equipment 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.

Thank you for writing.

ID: nht68-3.4

DATE: 10/03/68

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

TO: Deputy Chief Experimental

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 23, 1965, to Dr. William Haddon, Jr., concerning windshield washers.

Based upon the information you provided, your annually operated windshield washer system appears to meet the requirements of Motor Vehicle Safety Standard No. 104, Windshield Wiping and Washing Systems. You state your washer system will deliver the required 15 cc of fluid to windshiell (as specified in paragraph 2.11 of SAB Recommended Practice J942, November 1965) within a period of 3 seconds or less (as specified in paragraph 4.4.2(b) of J942). You also state your manual system will meet the washer system capability requirements of paragraph 3.1 and the durability requirements of paragraph 3.4 of J942.

Apparently your concern is that your annually operated system will not deliver 15 cc of fluid per stroke. However, if you can provide the required 15 cc of fluid by using additional strokes within a 3 second period and if this type of operation will clear 75% of the effective wipe pattern within 10 cycles, you meet the performance requirements we consider necessary for highway safety.