ID: nht75-4.35

DATE: 10/29/75

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

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Volkswagen of America's August 27, 1975, request for confirmation that a seat belt warning system that activates a 4- to 8-second warning light when the vehicle ignition is turned complies with the requirements of S4.5.3.3 of Standard No. 208, Occupant Crash Protection, although the warning system also activates the same warning light continuously when a separate circuit senses that the front seat belts are not fastened.

Volkswagen's understanding of S4.5.3.3 is correct. As we understand your description, the Volkswagen warning system does provide the automatic 4- to 8-second activation of a warning light called for in S4.5.3.3. This provision prohibits the use of an activation longer than the limits set forth in the standard.

The Volkswagen system provides a different and additional activation of the warning light when the seat belts are not fastened, using a separate circuit to monitor a set of conditions separate from those specified in the requirements of S4.5.3.3. The National Highway Traffic Safety Administration does not consider this activation (which can be longer than 8 seconds) to violate the limit on activation of the automatic reminder specified by the standard.

ID: nht75-3.45

DATE: 06/06/75

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

TO: TTMA

TITLE: FMVSS INTERPRETATION

TEXT: This responds to the Truck Trailer Manufacturers Association's May 1, 1975, request for a determination of what speed the National Highway Traffic Safety Administration (NHTSA) considers as "highway speeds" in establishing gross vehicle weight ratings (GVWR) and gross axle weight ratings (GAWR) under the requirements of 49 CFR @ 567.4 (g)(3) and (4).

For purposes of GVWR-GAWR calculations, NHTSA will consider "highway speeds" to be the 60 mph value used by the United States Tire and Rim Association in assigning unqualified ratings to their tires. Therefore, trailers which are capable of speeds of 60 mph or more should be assigned ratings which reflect vehicle capabilities at 60 mph.

SINCERELY,

May 1, 1975

James C. Schultz Chief Counsel National Highway Traffic Safety Administration

In regard to your letter of March 5, 1975, you state that "A vehicle capable of highway speeds and reasonably expected to be operated at such speeds is subject to Standard No. 121 - Air Brake Systems at weight ratings specified for highway speeds".

Advice would be greatly appreciated as to the numerical value NHTSA has assigned to the term "highway speeds".

Don W. Wieriman Staff Engineer-Tank Vehicles

ID: nht94-1.86

TYPE: Interpretation-NHTSA

DATE: March 17, 1994

FROM: Eric T. Stewart -- Engineering Manager, Mid Bus

TO: Office of Chief Counsel, NHTSA

TITLE: Reference: Amendment to FMVSS 571.217 published in the Federal Register November 11, 1992 (Docket 88-21 notice No. 3)

ATTACHMT: Attached to letter dated 4/1/94 from John Womack to Eric T. Stewart (A42; Std. 217); Also attached to letter dated 7/7/93 from John Womack to Thomas D. Turner

TEXT:

The background to this amendment indicates that the "final rule requires a minimum of 1 inch wide retro-reflective tape ...." (page 49421). The actual amendment reads that the retro-reflective tape is to be "a minimum 3 centimeters wide". (page 49425) (CFR571.217 S 5.53(c)). These two dimensions are not the same since 1.00 inch is equal to 2.54 centimeters.

I believe that the intent of this rule making was to make the retro-reflective tape 1.00 inch wide and an error has taken place in converting the dimension to metric units. I am requesting written clarification indicating how wide NHTSA wants the retro- reflective tape around the outside perimeter of a school bus emergency door.

If you have any questions, please call me at (419) 221-2525.

ID: nht94-1.98

TYPE: Interpretation-NHTSA

DATE: March 25, 1994

FROM: Roger W. Bruett -- Chief; Signed by Carol I. Morton -- Administrative Assistant, Equipment and Standards Review Unit, Washington State Patrol

TO: Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/14/94 from John Womack to Carol I. Morton (A42; Std. 108)

TEXT:

It has come to our attention, new headlamps are being installed on BMWs, 750 models. These lamps are called XENON and are "Hella SSB 352 (lower beam) and Hella SSB 328 (upper beam) with replaceable bulb headlamp with glass lens and plastic reflector.

This office received a complaint from a BMW Dealership indicating an owner of one of these vehicles is being continually stopped by law enforcement because of these headlamps. The reason for concern from the officers, is the intensity of the light beam from these lamps is much whiter and appears to be stronger.

We would like to know if these headlamps are legal for use on motor vehicles. A report was sent to us stating they meet all the requirements of the FMVSS 108. This report was generated by ETL Testing Laboratory in New York.

I would appreciate your response on this subject as soon as possible.

ID: 8992

Mr. Dennis G. Moore
President
Sierra Products, Inc.
1113 Greenville Road
Livermore, CA 94550

Dear Mr. Moore:

We have received your letter of August 12, 1993, "requesting a legal clarification detailing where FMVSS 108 requires a Clearance Light to be mounted." It is clear from your letter that it is the lateral spacing of clearance lamps that concerns you as you believe that it is not uncommon to see them mounted as much as 6 to 8 inches "'inside' the side extremities of huge vehicles."

With respect to lateral spacing, Table II of Standard No. 108 requires clearance lamps to be mounted "to indicate the overall width of the vehicle . . . ." The standard does not require the lamps to be mounted at the widest point of the vehicle, nor does it require them to be mounted as far apart as practicable. We believe that manufacturers generally try to mount clearance lamps to "indicate" the overall width of the vehicle, but we recognize that there may be certain circumstances and/or configurations that require mounting of the lamps at something less than the widest point.

Sincerely,

John Womack Acting Chief Counsel

ref:108 d:11/16/93

ID: nht67-1.27

DATE: 06/13/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Texas Department of Public Safety

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Arnold Wise has asked that I answer your letter of April 14, 1967, concerning a clarification of several requirements of Motor Vehicle Safety Standards 207, 208, and 209.

I am enclosing copies of the Federal Register of August 31, 1966, and February 3, 1967, which provide all of the information which you require. You will note that Standard No. 207 is concerned with the anchorage of the seats - not seat belts. Standard No. 208 requires seat belts in all passenger cars manufactured after January 1, 1968. In a regular size, four door, sedan-type vehicle with regular undivided seats, six lap belts would be required and, in addition, upper torso restraints would be required in the front outboard seats if the windshield header is in the head impact area.

The installation of seat belts in other than passenger cars is not required by the initial standards. However, any seat belts that are manufactured after March 1, 1967, must conform to the requirements of Motor Vehicle Safety Standard No. 209.

Your interest in the traffic safety program of this Bureau is appreciated.

ID: nht69-1.34

DATE: 03/12/69

FROM: AUTHOR UNAVAILABLE; R. M. O'Mahoney; NHTSA

TO: Hector J. Rosso, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 14, 1969, in which you seek information concerning possible overloading of Seiberling 8.25-20 ten ply rating truck tires manufactured in approximately 1963.

The Federal Highway Administration has issued a Federal motor vehicle safety standard for passenger car tires manufactured after January 1, 1968 requiring them to meet certain tests when loaded to prescribed weights. (49 C.F.R. @ 371.21 Standard 109). Performance requirements for truck tires are presently under consideration. Comments have been received in response to an Advance Notice of Proposed Rule Making on this matter but regulations have not as yet been issued.

The Bureau of Motor Carrier Safety regulates the safety and operation of interstate motor carriers. Its regulation regarding tires (49 C.F.R. @ 393.75) is not relevant to your inquiry.

One fruitful source of information may be the Tire and Rim Association Yearbook. This publication provides data on tires and suggests standards for tire load limits. It is published by the Tire and Rim Association, Inc., Comend Building, 34 H. Hawkins Avenue, Akron, Ohio 44313.

I hope this information will be of value to you.

ID: nht70-1.13

DATE: 04/30/70

FROM: AUTHOR UNAVAILABLE; Frances Armstrong; NHTSA

TO: Clements, McClellan and Hawley

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 3, 1970, to the Director, National Highway Safety Bureau, that has been referred to this office.

The type of information requested under items 1 and 2 of your letter can be extracted, within the limitations of the tests conducted, from the enclosed test result summaries. However, it should be recognized that the scope of the Bureau's testing program is such that valid statistical inferences relating to industry-wide rates or tire defects or failures are not possible with the limited data available.

Prior to the adoption of the labeling requirement in Federal Motor Vehicle Safety Standard No. 109, tires could be identified by manufacturer. This was an industry practice, involving the use of serial number systems and was not required by Government regulation nor was the coding used readily available to the general public.

We trust this and the enclosed publications will answer your questions. We will be pleased to answer any additional questions.

Thank you for your interest in the programs of the National Highway Safety Bureau.

ID: nht70-1.28

DATE: 02/11/70

FROM: CLUE. D. FERGUSON -- OFFICE OF VEHICLE STRUCTURES, MOTOR VEH. PROGRAMS, NHTSA; SIGNATURE BY F.C. KOCH

TO: Mr. Eddie E. Barnes

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your recent letter concerning the number of safety belts in your 1969 Chevrolet nine-passenger station wagon.

The present Federal Motor Vehicle Safety Standard No. 208 requires that seat belt assemblies be installed in each forward-facing designated seating position in passenger cars. The standard does not apply to side-facing or rear-facing seats. The manufacturer is not required to install safety belts for such seats: however, in the interest of safety, most manufacturers usually install lap belts for the seating positions most commonly used.

A Notice of Proposed Rule Making was issued on September 15, 1969, which would extend the applicability of Standard No. 208 to apply also to side-facing and rear-facing seats. The comments of those who responded to the Notice have been analysed and the final rule is now being developed.

I am enclosing a copy of our present Standard No. 208 and a copy of the Notice of Proposed Rule Making for your reference.

Thank you for your interest in motor vehicle safety.

ID: nht70-1.5

DATE: 02/12/70

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

TO: Oesterreichisch-Amerikanische

TITLE: FMVSS INTERPRETATION

TEXT: Re: Farm Use Only Tires and Request for Interpretation of Standard No. 109

Thank you for your reply to our letter of December 11, 1969 concerning tires marked with the legend "Farm Use Only Tires".

Concerning the questions you raise in your letter relating to the DOT symbol, Standard No. 109 requires that the symbol be between the maximum section width and the bend to protect the lettering from obliteration during use. Therefore, placing the DOT symbol at the widest place on the side wall rib as illustrated in your enclosed drawing would not be permitted.

With regard to your question asking if the approved symbol and the manufacturer's code mark is necessary, the approved symbol signifies that the manufacturer certifies that the tire complies with the Standard and is, therefore, necessary. Tires exported to this country without the symbol would be in violation of the National Traffic and Motor Vehicle Safety Act of 1966. The code number is only required if your company manufactures a tire with a brand name other than its own. The purpose of the code number is to identify the manufacturer of the tire.