ID: nht68-2.50

DATE: 04/16/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Hercules Galion Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 15, 1968, to the Director, National Highway Safety Bureau, concerning your interpretation of the requirements of Motor Vehicle Safety Standard No. 108.

The lamps and reflectors shown on your drawing(Illegible Words) dated March 8, 1968 appear to be in conference with the requirements of Initial Standard No. 108; however, since no dimensions are specified on your drawing, we can only assume that the locations are as specified in the standard.

The certification requirements for complete vehicles incorporating chassis and bodies manufactured prior to and after January 1, 1968, are correctly stated in the information bulletin attached to your referenced letter and dated March 15, 1968.

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 Standard No. 108.

ID: nht68-3.21

DATE: 04/04/68

FROM: AUTHOR UNAVAILABLE; John R. Jamieson; NHTSA

TO: The Firestone Tire & Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: Your petition of March 7, 1968, requesting a reduction in the high speed performance test (Section S5.5) of the Federal Motor Vehicle Safety Standard No. 109 (23 CFR, Part 255) for special heavy gauge troad taxi tires is denied.

While we agree that some taxis are used for low speed intercity operation, many taxis now use high speed freeways for sustained periods of time. With the continuous expansion of freeways in metropolitan areas, the average service speed for taxi tires is certain to increase. In view of this, and because it is impossible to limit the use of taxi type tires to speeds lower than those presently permitted for other passenger vehicles, an amendment to Standard No. 109 exempting the heavy gauge tread tires from the high speed performance requirements, would not be in the interest of safety.

For your future reference enclosed is a copy of Rule Making Procedures: Motor Vehicle Safety Standards as published in the Federal Register (32 F.R. 15816 - 15820). Your attention is directed to S210.31 which sets forth the procedural regulations for petitions for rule making.

ID: nht68-3.25

DATE: 04/22/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Badger Auto Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your cooperation and response to the Federal Highway Administration request regarding the "Certification Requirements."

The information you have provided will be very useful to us; however, in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with information as to where your tag will be located on your vehicles and also the serial identification system as requested in order that vehicles manufactured (complete) after January 1, 1968, can be identified.

In regard to your question as to whether there is an exception to the law regarding the placement of the three light markers at the rear of your vehicle because of the limited space on your rear frame, the answer is there is no exception and adherence is required. One possible solution to your problem might be to mount an additional bracket to mount the cluster of lights. This is only a suggestion and you may be able to arrive at a more practical arrangement.

Trusting this information answers your questions.

ID: nht68-3.50

DATE: 08/05/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Kawasaki Motorcycle Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 21, 1968, to Mr. George C. Nield, Acting Director, Motor Vehicle Safety Performance Service, concerning the mounting of the front side reflex reflector on motorcycles.

Mounting the front side reflex reflectors just below or immediately ahead of the front of the fuel tank, as shown in the brochures on your models C2TR. and F3, appears to satisfactorily meet the requirements of Federal Motor Vehicle Safety Standard No. 108. The front side reflex reflectors shown in the brochure on your model W2TT do not appear to be located as for forward as practicable. A location corresponding to that shown for models C2TR and F3 also appears practicable for the model W2TT.

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 the way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

ID: nht68-4.12

DATE: 09/10/68

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

TO: National Highway Users Conference

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 23, to Mr. George Nield, concerning the compliance of crane carriers and fire engines with Federal Motor Vehicle Safety Standards 103 and 104.

The crane carrier you have described is a "motor vehicle" subject to the provisions of the National Traffic and Motor Vehicle Safety Act of 1966. For purposes of the Federal Motor Vehicle Safety Standards the described crane carrier is classified as a "truck." Although currently Federal Standards 103 and 104 do not apply to trucks both standards, by amendment, issued April 24, 1968, (33 F.R. 6466-69), will be applicable to trucks manufactured on or after January 1, 1969.

Similarly, a fire truck is a "motor vehicle" and a "truck" and subject to all Federal Motor Vehicle Safety Standards applicable to this category of vehicle, including Standards 103 and 104. However, the open cabs found on many fire trucks may make full compliance with Standard 103 impossible. A public docket, Docket No. 24, has been established to receive comments pertaining to the possible classification of fire fighting equipment as a separate vehicle category which might be exempt from certain standards.

ID: nht70-2.25

DATE: 09/11/70

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

TO: Tanaka and Walders

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of July 27, 1970 to the National Highway Safety Bureau requesting an interpretation of Federal Motor Vehicle Safety Standard No. 110.

You are correct in your statement that no formal petition for rule making action is necessary for tire and rim combination cited within the references of S3 of Standard No. 109.

Concerning your question on "approval equivalent rim", we offer the following. The policy of the Bureau in 1967 at the time of the promulgation of Standards No. 109 and No. 110 was to give a "blanket" approval of all rims cited within the references. From that time on however, all new tire and rim combinations had to be approved by the Bureau. After the tire and rim combination was approved then it was listed within Table I, Appendix A of Standard No. 110.

Standards No. 109 and No. 110 do not have requirements for rim contours. Our standards only specify the flange letter-code and width for a particular rim designation. Therefore, any request to change a rim dimension of an existing rim does not require a formal action by this Bureau.

ID: nht70-2.35

DATE: 11/12/70

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 21, 1970, to the National Highway Safety Bureau, concerning environmental tests for sealed beam headlamps used on motocycles and motor-driven cycles.

Federal Motor Vehicle Safety Standard No. 108 requires that motorcycle and motor-driven cycle headlamps conform to SAE Standard J584. This SAE Standard, in turn, permits optional use of "one 7-in. sealed beam unit or one 5 3/4-in. Type 1 and one 5 3/4-in. Type 2 sealed beau units meeting the requirements of SAE J579".

Therefore, unsealed motorcycle and motor-driven cycle headlamps must conform to the vibration, moisture, dust and corrosion test requirements of SAE J584. Glass sealed beau motocycle and motor-driven cycle headlamps, which are designed specifically to conform to the requirements of SAE J584 (including photometric values), and which are not intended for use on other vehicles, must conform to the vibration, moisture and corrosion test requirement of SAE J584. Such test requirements would not, however, be applicable if a manufacturer elected to provide optional headlamps meeting the requirements of SAE J579a.

ID: nht71-1.22

DATE: 05/01/71 EST

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Mr. Harvey R. Rosen, Attorney at Law

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 2, 1971, to Mr. Douglas Toms, in which you inquired about Federal requirements governing the interaction of passenger car door locking mechanisms and door opening capability.

I am enclosing a copy of Federal Motor Vehicle Safety Standard No. 206, entitled Door Locks and Door Retention Components, which applies to the area you have discussed. Please further note that paragraph 54.1.3.1 is applicable to the point in question, and requires that only the outside latch release control become inoperative on front doors when the locking mechanism is engaged. In the case of rear doors, addressed by paragraph 54.1.3.2, both inside and outside release mechanisms are affected. For your clarification, this standard was issued pursuant to the National Traffic and Motor Vehicle Safety Act of 1966 (Public Law 89-563).

As you point out, certain manufacturers have included the inside and outside feature on front as well as rear doors; however, the inside application to front doors was not required by the standard.

Thank you for your interest in motor vehicle safety.

ID: nht71-2.22

DATE: 03/29/71

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

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: RE: PETITION TO AMEND STANDARD NO. 103

This is in response to your petition of February 24 to Douglas Toms for a amendment of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment (35 F.R. 16640).

You petitioned for an amendment of S4.6(b) that would allow use of a non-automatic means for flashing headlamps. Standard No. 103 does not contain requirements for, or prohibitions against, flashing headlamps non-automatically, and therefore installation of such devices is at the option of the manufacturer.

You commented that S4.6(b) appears to require simultaneous flashing of headlamps and side marker lamps if an automatic means of flashing is provided. Your interpretation is incorrect; either headlamps or side marker lamps, or both, may be flashed by automatic means.

You also petitioned for an amendment of S4.1.1.6 and S4.1.1.7 on the basis of a conflict in the dates of applicability of the effective date of the sections. Your petition on this point is moot; this ambiquity was resolved is an amendment to Standard No. 108 published on February 3, 1971 (36 F.R. 1896). I enclose a copy for your information.

ID: nht71-3.10

DATE: 05/27/71

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

TO: Ideal Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of May 4, 1971, to Francis Armstrong you request permission to conduct testing of turn signal and hazard warning signal flashers pursuant to SAE Standard J823b, "Flasher Test Equipment," April 1963.

Federal Motor Vehicle Safety Standard No. 108 incorporates by reference SAE Standard J590b, "Automotive Turn Signal Flashers," October 1965, and SAE Recommended Practice J945, "Vehicular Hazard Warning Signal Flasher," February 1966, both of which specify test circuitry and equipment according to "SAE J823." It is my understanding that the major difference between J823 and J823b, which becomes the appropriate sub-referenced standard on January 1, 1972, is the specification in the latter that "The required voltage tests [for variable-load flashers] with maximum bulb load shall be conducted without readjusting each corresponding power supply voltage, previously set with minimum bulb load." It appears that J823 was written before variable load flashers were in general use and that this is the reason for omission of this specification from J823. Since J823b includes all the requirements of the presently referenced SAE standard, you may proceed to implement it immediately.