ID: nht68-3.41

DATE: 07/22/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Lodal, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 17, 1968, to the National Highway Safety Bureau, attention of Mr. Joseph R. O'Gorman, concerning the requirements for rear identification lamps and rear clearance lamps on your EVO Refuse Packer.

Since no mounting height restrictions are specified for rear identification lamps in Motor Vehicle Safety Standard No. 108, these lamps may be mounted on or below the cross member between the rear wheels. Shielding may be necessary to protect the lamps.

No clearance lamp may be combined optically with any tail lamp or identification lamps. Combination rear clearance and side marker lamps may be used providing the requirements for each are met.

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, 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 Standard No. 108.

ID: nht68-3.49

DATE: 08/05/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 1, 1968, to Mr. George C. Nield, concerning a clarification of paragraph S 3.4.3 of Federal Motor Vehicle Safety Standard No. 108.

Paragraph S 3.4.3 specifies that, as a minimum, the taillamps shall be illuminated when the headlamps are illuminated, except when the headlamps are being flashed. The phrase "except when the headlamps are being flashed", permits the vehicle manufacturer to use a separate switch or flasher for illuminating the headlamps only when it would not be appropriate or in the interest of safety to simultaneously illuminate the taillamps and headlamps. In addition to the examples cited in your letter, such devices could also be used for flashing the headlamps on public transit vehicles to indicate an emergency situation.

Since the subject matter of S 3.4.3 is taillamps and since Federal Standard No. 108 is otherwise silent as to headlamp flashing, this matter appears to be within the purview of the California vehicle code.

Thank you for your continued interest in the motor vehicle safety standards.

ID: nht68-4.1

DATE: 08/15/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Toyota Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 23, 1968, to Mr. George C. Nield, Acting Director, Motor Vehicle Safety Performance Service, concerning the requirements for turn signal and hazard warning signal flashers as specified by Motor Vehicle Safety Standard No. 108.

With certain exceptions, paragraph S3.3 of Standard No. 108 permits the use of combination lamps, reflective devices and items of associated equipment, provided the requirements for each lamp, reflective device and item of associated equipment are met. Therefore, a combination turn signal and hazard warning signal flasher may be used, provided the requirements for each signal (turn and hazard warning) are met.

You are correct in your understanding that Standard No. 108 and basically referenced SAE Standards J590 and J945 do not require operation of the flasher unit with only one signal bulb in the test circuit. The standard test circuit shown in Figure I of SAE Standard J823 indicates a minimum of two signal lamps and one pilot indicator lamp as the lamp load.

Thank you for writing.

ID: nht71-1.19

DATE: 04/01/71 EST

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Leasor & Leasor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 26, 1971, concerning regulations pertaining to automobile windshields.

Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses, a copy of which is enclosed, specifies the requirements of automotive glazing materials manufactured on or after January 1, 1963. ANSI Standard Z26.1-1966, incorporated by reference, can be obtained from the American National Standards Institute, 1430 Broadway, New York, New York 10013, at a cost of $ 4.00.

The marking of the windshield that you depict in your letter of March 26 is not sufficient to identify its manufacturer. However, based on the "63" in the marking and the fact that the windshield shape fit the 1969 Plymouth, it can be hypothesized that the material in question is a laminated windshield of the improved design that has been used in 1966 and later models of U.S. automobiles.

There is not a requirement that windshields of this type completely shatter leaving no jagged fragments upon collison.

Sincerely,

ID: nht71-1.48

DATE: 01/20/71

FROM: R.A. DIAZ -- NHTSA; SIGNATURE BY HAROLD M. JACKLIN

TO: Bus and Truck Supply Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 30, 1970, requesting an interpretation of Motor Vehicle Safety Standard No. 205, "Glazing Materials," as it applies to the forward-facing window above the windshield of a particular bus, a picture of which you enclosed.

Because the window in question is a forward-facing window, we cannot conclude that it is an "opening in the roof" under the standard. We apologize for the inconvenience caused by any implication to the contrary that you may have been given on your visit here.

Based upon the picture submitted, and your statement that the window "is not adjacent to passenger seating," we conclude that this location is one that is not specifically designated by the standard. As such, the use of AS2 glazing, which you indicated you plan to use, or alternatively AS1, AS3, AS10, or AS11 glazing, would be appropriate.

If you have further questions, we will be happy to answer them for you.

ID: nht71-2.13

DATE: 03/10/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Bolt Beranek and Newman, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: During your visit which Michael Peskoe on March 4, 1971, you indicated that you were desirous of having a reply to the question that you posed in your letter of December 14, 1970, concerning S4.6 of Standard No. 213, without delaying that answer until the response to the entire letter had been prepared.

Your question concerning S4.6, which states in part, " . . . [Each] forward-facing child seating system shall have a seat back. The height of the seat back shall be . . .," is whether an adjustable head restraint can be used to meet this requirement provided "(a) it meets the height requirement measured at the lateral center of the head restraint, and (b) it is accompanied, in the instruction sheet, by instructions for adjustment to fit the child."

It was intended by paragraph S4.6 that a head restraint could be used to meet the above height requirement, proviced that it meets the other requirements of the standard, such as the head impact protection requirements of S4.10, as well as those you described.

ID: nht72-1.21

DATE: 12/15/72

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

TO: The General Tire & Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 8, 1972, inquiring whether new casings, to which tread is later added, are considered to be "tires" under the National Traffic and Motor Vehicle Safety Act. The NHTSA has taken the position that such casings are not tires until after the tread has been added, and the casings are not required to be certified as conforming to applicable standards until that occurs. Consequently, such casings may be imported without prior certification.

You also ask how best to inform Customs of our position, to avoid possible importation problems. We suggest you write to Mr. P. K. McCarthy, Chief, Restrictive Merchandise Branch, U. S. Bureau of Customs, Room 704C, 1145 19th Street, N.W., Washington, D. C. 20226, advising him of our opinion, and ask him to acknowledge this interpretation. You might also take steps to ensure that this information is relayed to the local customs officials at those ports of entry where the casings will be imported. If you need further assistance in this matter, please let me know.

ID: nht72-1.22

DATE: 09/27/72

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

TO: Goodyear Tire & Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 24, 1972, requesting an opinion as to the applicability of Motor Vehicle Safety Standard No. 109 (49 CFA 471.109) and proposed Standard No. 110 (37 F.R. 13491, July 8, 1972) to tires inflated with "Permafoam" cellular foam rubber.

Although these tires contain other material in addition to air, we have decided that they should be considered "pneumatic tires" for the purpose of the application of Standard No. 109. The reasons for this decision are the fact that their Foam filling contains a substantial proportion of air under pressure, and their general similarity to conventional tires in regard to appearance, use, and load-deflection characteristics.

The NHTSA has also concluded, however, that these tires have desirable performance capabilities and should be available to the public, subject to conditions to assure their safe use, for the special purposes for which they are designed. Accordingly we have decided to initiate rulemaking to establish special requirements for these and similar tires. We plan to issue the appropriate notices in the near future.

ID: nht72-1.29

DATE: 06/23/72

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

TO: Torino

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 15, 1972, inquiring whether the State of Maryland may require tires to be labeled with a "VI" marking. @ection 103(d) of the National Traffic and Motor Vehicle Safety Act. 15 U.S.C 1992(d), provides in pertinent part:

"Whenever a Federal motor vehicle safety standard established under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard."

This provision, considered with Federal Motor Vehicle Safety Standard No. 109, prohibits the State of Maryland or any State from imposing any safety labeling requirements, for passenger car tires other than these contained in that Federal standard. Any differing safety labeling requirements, including the "VI" you mentioned, are thus (Illegible Word) and void.

ID: nht72-1.33

DATE: 06/27/72

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

TO: Checker Motors Sales Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 25, 1972, asking whether you, as a selling dealer, may install steel-belted radial ply tires on an 8-passenger Checker taxicab. You state that the vehicle is normally delivered to you with tires having the "D" load range.

Federal Motor Vehicle Safety Standard No. 110 (49 CFR 571.110, copy enclosed) requires each passenger car to be equipped at the time of sale to a first purchaser with tires of certain minimum load carrying capacity, based on the weight of the vehicle. Any steel-belted radial ply tire that meets these load carrying requirements with respect to your vehicles may be installed by a selling dealer.

Radial tires of similar or related sizes, but of different manufacture, however, may have different load ratings. We suggest, therefore, that you contact Checker Motor Corporation for their recommendations as to which radial ply tires may be installed on these vehicles without adversely affecting the vehicle's conformity with Motor Vehicle Safety Standard No. 110.