ID: nht76-1.14

DATE: 10/26/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Toyoda Gosei Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in belated response to your April 9, 1976, letter concerning the application of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, to certain combination hydraulic brake hose assemblies.

Figure 3 of your letter depicts two typical brake hose assemblies that are connected end-to-end. Figure 4 depicts the intended installation of such a pair of assemblies, with the joined fittings meeting at a bracket that is attached to a shock absorber. Figures 1 and 2 show two designs to simplify the structure at this juncture.

Treating these figures in reverse order, the "B type" design shown in Figure 2 is similar to the pair of assemblies shown in Figure 3, except that the pair of joined end fittings is replaced with a single center fitting. The National Highway Traffic Safety Administration (NHTSA) considers such a construction to be two distinct brake hose assemblies, which would be tested separately for compliance with Standard No. 106-74. The center fitting would simply be considered an end fitting for each of these assemblies.

The "A type" design shown in Figure 1 would be treated differently, however. In this design, the two separate pieces of hose are replaced by a single piece that runs the full length between the outermost end fittings. In place of joined fittings as in Figure 3 or a center fitting as in Figure 2, this hose would be surrounded by molded rubber and a metal ring. The ring would be mounted in the bracket that is attached to the shock absorber. The NHTSA considers this construction to be a single brake hose assembly, and testing for compliance with Standard No. 106-74 would be conducted accordingly. For example, the tensile strength test would be performed by pulling, at the outermost fittings, on the full length of the hose. However, this interpretation would not require the assembly to be capable of meeting the whip resistance requirement of S5.3.3 with the full length subject to flex. The NHTSA considers such a brake hose assembly to have two distinct "free lengths" -- one on either side of the center metal ring. Therefore, the whip resistance test would be performed separately on each of these portions. In other words, the metal ring would be treated as an "end fitting," for the purposes of the whip resistance test described in S6.3.

Sincerely,

ATTACH.

TOYODA GOSEI CO., LTD.

April 9, 1975

Richard B. Dyson -- Acting Chief Counsel, National Highway Traffic Safety Administration Dear Mr. Dyson

We want to obtain an approval for the two types of hydrauric brake hose assemblies as shown in the attached Fig. 1 and Fig. 2. Please tell us how to obtain the approval.

Sometimes we have to fix an intermediate point of hose assembly to prevent it from being in touch with any part of motor vehicle as shown in Fig. 4. Currently, in this case, we joint No. 1 hose assembly with No. 2 hose assembly as shown in Fig. 3 and use the joined hose, which we call "joint hose assembly". For example, its jointed fitting is fixed on the frange of a shock absorber as shown in Fig. 4.

We obtain the approval for each No. 1 hose assembly and No. 2 hose assembly when they are used as joint hose assembly. When we use A type and B type hose assemblies which are shown in Fig. 1 and Fig. 2 respectively, how can we obtain their approvals.

1. Explanation of A and B type hose assembly

a) A type hose assembly

This hose assembly has the part which is constructed with insert metal ring and molded rubber as shown in Fig

b) B type hose assembly

This hose assembly has the integrated "center fitting" as shown in Fig. 3.

2. Questions

Please answer the following questions.

a) About A type hose assembly

Can we use A type hose assembly from which the metal ring and molded rubber are taken off when we estimate its performance?

b) About B type hose assembly

1) Should we regard that this is composed of two hose assemblies and estimate their performances separately?

2) Or should we test it as one hose assembly?

In the latter case, how should we practice the following performance tests?

1; Constriction

* Can we test the constriction of the center fitting by using a long gauge plug as shown in Fig. 5?

2; Free length * Should we regard the sum of free length of the two parts as that of the B-type hose assembly? (That is, L[1] + L[2] in Fig. 2)

3; Whip test

* Should we test it using a special jig as shown in Fig. 6?

* Should we test B type hose assembly in the same method as usual hose assembly is tested as shown in Fig. 7? In this case we can not proof the required whip performance for this type hose.

* Or can we regard the whip performance of usual hose assembly, whose free length is equal to L in Fig. 2 as that of B type hose assembly? (cf. Fig. 8)

4; Tensile test

* Should we determine the tensile strength of the two parts separately as shown in Fig. 9?

* Or can we test it as the usual hose assembly with only two end fittings as shown in Fig. 10?

Your kind reply will be appriciated

Very truely yours,

Katsuhiko Yokoi -- Chief staff Ist. Product Development Sect

[Graphics omitted]

ID: aiam0534

Dear Mr. Scully: This is in reply to your letter of October 18, 1972, to Mr. Schneide asking for an interpretation of paragraph S4.3.1.3 of Motor Vehicle Safety Standard No. 108. You have enclosed photographs of boat trailers marked to show your understanding of the language 'as far forward as practicable' and ask for our views.; Table II and Table IV of Standard No. 108 require that front sid reflex reflectors and lamps on trailers, including boat trailers, be located as far to the front as practicable. Recognizing that a literal interpretation of the standard would require that these devices be installed on the trailer tongue and that in many instances it would be impracticable to do so, the NHTSA added paragraph S4.3.1.3 to allow a location as far forward as practicable exclusive of the trailer tongue.' The intent of the regulation is that the device be mounted as far to the front of the vehicle as the manufacturer determines is practicable, and a definition of 'trailer tongue' is immaterial for this purpose. If the angled portion of the frame is deemed 'practicable', and the device is located there, it must be mounted, as you suggested, in a position such that it meets the photometric requirements at the specified angles with respect to the vehicle.; Sincerely, Richard B. Dyson, Assistant Chief Counsel

ID: 86-4.4

TYPE: INTERPRETATION-NHTSA

DATE: 06/30/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Robert E. Mileham

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 18, 1985, regarding the trailer-mounted aerial personnel lift or "cherry picker" which your company manufactures. I regret the delay in responding to your letter.

You ask whether a vehicle identification number (VIN) is required on these trailers. You state that the sole purpose of the trailer is to take the aerial lift to and from a job site and estimate that the trailer will not spend more than 10% to 15% of its time traveling on the highway.

The National Traffic and Motor Vehicle Safety Act provides that vehicles which fall within the statutory definition of the term "motor vehicle" must comply with applicable safety standards. That definition includes vehicles "manufactured primarily for use on the public streets, roads, and highways." (15 U.S.C. 1391(3)). The agency has taken the position that this definition does not encompass mobile constructior equipment which uses the highways only to move between job sites, whose job sites are normally located off the public roads, and which typically spend extended periods of time at a single job site. In such cases, the on-highway use of the vehicle is merely incidental, not the primary purpose for which the vehicle is manufactured.

The information in the brochure enclosed with your letter indicates that the job site of your cherry picker is typically in the streets, not off the road. Based on that information, it appears that your cherry picker may spend virtually its entire operating life on public roads. When a vehicle frequently uses the highway going to and from job sites, and its job site is frequently on the road, the agency's position is that the vehicle is a "motor vehicle." Therefore, these trailers are required to comply with Standard No. 115, Vehicle Identification Number -- Basic Requirements, and other standards applicable to trailers.

You also ask in your letter if these trailers could be considered the same as mobile air compressors, mobile cement mixers, or mobile generators, which the state of Iowa apparently licenses as "Special Mobile Equipment," not requiring a VIN. Whether a state requires a VIN on your trailer lifts, for purposes of licensing or registration, is not determinative of Federal regulatory questions. This agency has taken the position that mobile cement mixers, for example, are motor vehicles because of their use of the public roadways in traveling from job site to job site and their typically short time at any particular site. Therefore, they must comply with Standard No. 115 as well as other Federal motor vehicle safety standards.

I hope this information is helpful to you.

Sincerely,

ATTACH.

DURNELL ENGINEERING, INC.

September 18, 1985

Jeffrey R. Miller, Chief Council -- National Highway Traffic Safety Administration, U.S. Department of Transportation

Dear Sir:

We are a manufacturer of truck and van mounted aerial personnel lifts. They are sometime referred to as cherry pickers.

We are establishing a trailer mounted series, to compliment the truck and van models. The sole purpose of the trailer components is to take the aerial lift to and from a job site. There is no additional carrying capacity on this unit for anything. We estimate the unit will not spend more than 10% to 15% of its time, in a transport mode, on the highway.

While the lift is in operation at the job site, the trailer components, consisting of axle, wheels, tongue, and tongue wheel, do not contribute to the stability of the lift. For the lift to be stable and operate, it is necessary for the manually operated outriggers to be extended, lift the rear wheels and tongue wheel completely off the ground.

The question has been asked if these units require V.I.N.'s. Our thinking and understanding was, that one of these units could be considered the same as a mobile air compressor, mobile cement mixer, mobile generator, or related piece of equipment. In Iowa the above can be licensed as Special Mobile Equipment. The purpose of this letter is to obtain your opinion on whether or not V.I.N.'s are needed on these units.

I have enclosed a brochure for your study and reference. If I can supply any further information, please contact me.

Yours truly,

Robert E. Mileham -- Operations Manager

Enclosure: 1

(Graphics omitted)

(Illegible Table)

STANDARD FEATURES:

* Full control in bucket with manual override inside trailer * (Illegible Word) bucket capacity 300 lbs (136 kg). * (Illegible Word) tie down strap. * (Illegible Word) color white. * Fully enclosed direct worm drive rotation 360 degrees non-continuous * Stability achieved with four manual outriggers.

* Maximum operating pressure 1800 PSI (127 kpa). * Built-in battery charger inside trailer. * Generator start/stop on engine generator models. * Upper boom limit switch on articulated models. * Control System Choices: 12v D C Electric-Hydraulic with single or dual pumps and motors (Batteries included) Single, two-speed or variable speed engine generator (generator not included). * Bucket Choices: Square fiberglass with steel frame, square all fiberglass, steel work platform.

OPTIONS AVAILABLE:

* 115v weatherproof outlet at bucket on non-insulated models. * 12v D.C. back-up for engine generator models. * Battery pack for engine generator models. * Hydraulic self-leveling (telescopic only). * Special paint. * Bucketoptions: Cover, cable TV test compartment, access ladder, scuff pad, e-z step.

SAFETY FEATURES:

* Limit switch on each outrigger and axle of trailer to insure fully extended and completely supporting trailer. * Electric rotation limit switch included. * Holding valves mounted on each cylinder and lock in event of line failure. * Worm drive rotation to prevent free wheeling in event of line failure. * (Illegible Word) insulated models rated up to 69 kv * Over-ride switch located inside trailer. * Safety belt shipped with all units. * Stability test load, horizontally extended:

On level ground -- 450 lbs. (205 kg).

On 5 degrees slope -- 400 lbs. (182 kg) * Meets or exceeds ANSI A92.5.

[Illustration Omitted]

DURNELL engineering, inc. Highway 4 South (Illegible Word) Iowa 50636 - Phone 712-852-2611

Distributed by:

ID: nht76-1.16

DATE: 10/08/76

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

TO: Alfred Teves GMBH

TITLE: FMVSS INTERPRETATION

TEXT: This responds to the Alfred Teves GMBH (Teves) petition of April 9, 1976, for amendment of S5.2.1 of Standard No. 106-74, Brake Hoses, to eliminate the striping requirement in the case of hose used in assemblies that have "keyed" end fittings at both ends. We interprete "keyed" fittings to mean those that can be installed in only one (or possibly several) orientation(s) to the vehicle.

This is to advise you that the National Highway Traffic Safety Administration has determined to grant Teves' petition with regard to hose that is assembled into an assembly whose fittings permit their installation into the vehicle in only one orientation. Detailed reasons for the limitations expressed in this letter will accompany any notice that proposes this change.

You should understand that our commencement of a rulemaking proceeding does not signify that the rule in question will be issued. A decision as to the issuance of the rule is made on the basis of all available information in accordance with statutory criteria.

Your letter incorrectly characterized the amendment of S5.2.2 that was proposed in Notice 19 of docket 1-5 (40 FR 55365, November 28, 1975) and made final in Notice 21 (41 FR 28505, July 12, 1976). The amendment only stated that the labeling required on hose need not be present after the hose has become part of a brake hose assembly or after it has been installed in a motor vehicle. The conclusion in the second paragraph of your letter that ". . . brake hose does not require labelling according to S5.2.2. . ." is therefore incorrect.

With regard to your comments on Standard No. 116, Brake Fluids, I assume that you were referring to the agency's proposed definition of "brake fluid" published on December 5, 1975 (40 FR 56928). I also assume that the phrase "polychloroprene (CR) brake hose inner tube stock" in the proposed definition led you to conclude that only polychloroprene inner tube stock would be allowed for brake hose construction. This is incorrect. All of the materials specified in the definition, including SBR, EPR, CR, and NR, are considered suitable for use in brake hoses.

Sincerely,

ATTACH.

ALFRED TEVES GMBH

Welfred M. Redler, P. E. -- Office of Crash Avoidance

April 9, 1976 PETITION

Ref.: Amendment to Standards FMVSS 106 49 CFR Part 571, Docket No. 1-5, Notice 19

In notice 19 DOT has proposed that S.5.2.2 should be altered, in that, the labeling information could be eliminated as soon as the brake hose becomes a brake hose assembly. According to S.5.2.1 the hose manufacturer was given the option to interrupt the 2 stripes by information according to S.5.2.2 and additional information.

We understand this DOT recommendation to mean that in future permanent brake assemblies do not require labelling information so long as the manufacturer documents all hoses before assembly. i.e the brake hose does not require labelling according to S.5.2.2 because the hoses are documented and can thereby always be identified

Notice 19 indicates that our interpretation in assuming the above is correct. Provided that our interpretation is correct then, we are in agreement with the proposed amendment and endorse it.

Although the deleting of S.5.2.2 for brake hoses used in permanent brake hose assemblies is apparent, the requirement S.5.2.1 which states: "each hydraulic brake hose shall have at least two clearly identifiable stripes" is still required for brake hoses not part of a brake hose assembly.

The stripes are a visible indication of hose twisting during assembly. We are convinced that the brake hose marking would be unnecessary if the brake hose assembly could, by mechanical means, be prevented from twisting during and after installation. This mechanical means would eliminate the necessity of having two marking stripes.

Taking into account the foregoing we petition that S.5.2.1. should be amended to require the two marking stripes only when this mechanical means is not a part of the brake hose assembly in both ends.

We propose that FMVSS 106 should be amended as follows:

S.5.2.1 Each hydraulic brake hose, with the exception of those brake hose assemblies which have keyed ends (preventing twisting during and after instalation), shall have at least two clearly identifiable stripes of at least one-sixteenth of an inch in width, placed on opp. . . .

This amendment would prevent the unnecessary duplication of safety requirements thereby keeping costs to a minimum.

Ref.: FMVSS 116 49 CFR 571 116 Docket No. 71-13

The formulation of the definition S.4. suggests that brake hose inner tube stock must be of polychloroprene (CR). We have been using SBR for our inner tubes for years with excellent results. Naturally they meet the USA Standard FMVSS 106 and also have US approval through AAMVA based on a certificate from the independent test laboratory "ETL".

As the US standards FMVSS 106 has never objected to our brake hose material with regards to its properties and suitability for use in its designed environment we fail to understand why SBR together with the other materials EPR, EPDM, buthyl etc. are not considered suitable for use as brake hose inner tube.

May we suggest therefore that the definition S4 be formulated in such a way that this point is more clearly defined. In our opinion this should be changed to cover all materials which have a stable resistance to brake fluid.

Yours faithfully -- ALFRED TEVES GMBH

ID: aiam4140

Dear Mr. Maeda: Thank you for your letter of April 11, 1986, requesting a interpretation of the comfort and convenience requirements of Standard No. 208, *Occupant Crash Protection*. Your specific question is whether the retraction requirements of S7.4.5 of the standard apply only to the front outboard seating positions. As explained below, the answer is yes.; The April 12, 1985 notice proposed changes to the comfort an convenience requirements in response to petitions for reconsideration. In the case of the retraction requirements, the proposed language of S7.4.5 said that the requirement would only apply to a safety belt system installed at the 'front outboard designated seating position.' In the November 6, 1985 final rule adopting the retraction requirement, the agency dropped the reference to the 'front outboard seating position.' However, S7.4.5 still referred to conducting a compliance test on a test dummy which has been positioned 'in accordance with S10.' S10, in turn, references the test dummy positioning requirements of S8.1.11. S8.1.11.1 and S8.1.11.2 provide for positioning test dummies in the front outboard seating positions. Thus, the minor change in the language of the requirements did not change the applicability of the requirement. However, to eliminate any possible ambiguity about the application of the retraction requirement, the agency is planning to amend S7.4.5 to provide explicitly that it only applies to the front outboard designated seating positions.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel

ID: Cyr.1

Mr. Leo M. Cyr
Vice President, NGA Auto Glass Division
National Glass Association
8200 Greensboro Drive, Suite 302
McLean, VA 22102-3881

Dear Mr. Cyr:

This responds to your letter to Dr. Jeffrey Runge, Administrator of the National Highway Traffic Safety Administration (NHTSA), in which you asked a number of questions regarding NHTSAs regulations and other issues of concern to the automotive glass industry. Your letter was referred to my office for reply. In order to simplify our reply, we repeat each of the questions presented in your letter below, followed by our response.

(1) We understand the Federal Motor Vehicle Safety Standards (FMVSS) do apply to factory installation of auto glass on vehicles destined for sale in interstate commerce. Do these same FMVSS regulations (specifically FMVSS 212, 216 and [219]) apply:

a.)  Once the new vehicle is purchased by a consumer?
b.)  When auto glass is damaged in the aftermarket?
c.)  To the individual states being required to enforce the FMVSS and, if so, how are the regulations enforced?

Response:

By way of background, we note that NHTSA has authority under 49 U.S.C. Chapter 301 to promulgate Federal motor vehicle safety standards that apply to new motor vehicles and motor vehicle equipment. Most safety standards issued by the agency apply only to new vehicles. However, certain "equipment standards" apply to new parts and equipment, whether they are installed in new vehicles or sold in the aftermarket. A manufacturer must certify that its motor vehicle or motor vehicle equipment meets the requirements of all applicable FMVSS before being sold to a consumer for the first time.

The primary standard related to automotive glass is FMVSS No. 205, Glazing Materials. As an equipment standard, a manufacturer of glazing intended for use in a motor vehicle must certify that its products meet the requirements of FMVSS No. 205. However, as your question suggests, other FMVSS also relate to glazing materials, including FMVSS No. 212, Windshield Mounting, FMVSS No. 216, Roof Crush Resistance, and FMVSS No. 219, Windshield Zone Intrusion, which are vehicle standards.

To address the first part of your question, the Federal motor vehicle safety standards do not apply to vehicles and motor vehicle equipment after their first sale to a consumer. However, once a vehicle or item of motor vehicle equipment has been sold to a first purchaser for purposes other than resale, a manufacturer, distributor, dealer, or motor vehicle repair business may not "knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard."49 U.S.C. 30122(b). In general, this "make inoperative" prohibition requires businesses that modify motor vehicles to ensure that they do not remove, disconnect, or degrade the performance of safety features installed in compliance with applicable standards.

In those cases where an item of glazing is damaged and replaced, the replacement glazing must meet the requirements of Standard No. 205. This is because all replacement glazing must meet, and be certified by its manufacturer as meeting, the requirements of FMVSS No. 205, which is an equipment standard. Failure of a repair business to install replacement glazing that complies with this standard would be a violation of the prohibition on selling motor vehicle equipment that does not comply with applicable FMVSSs (see 49 U.S.C. 30112).

However, the vehicle with the new replacement glazing would not have to comply with the vehicle standard requirements of FMVSS Nos. 212, 216, or 219. A manufacturer is not required to assure that a vehicle remains in compliance after it has been sold for purposes other than resale. Moreover, a repair business that replaced the damaged glazing would not violate the "make inoperative" prohibition, because the object or event that damaged the windshield in the first place had already rendered the glazing "inoperative" with respect to these standards. Repair businesses are not required to restore a damaged vehicle to its original level of performance.

Finally, responsibility for enforcing the federal motor vehicle safety standards resides with this agency. NHTSA randomly purchases products and tests them in accordance with our regulations. A test failure may lead to an investigation and a recall of noncompliant equipment. States may only enact provisions relating to the same aspect of performance covered by a federal motor vehicle safety standard if the provision is identical to the federal standard.

(2) What is NHTSAs specific position, if any, on the repair (as opposed to replacement) of rock chip damaged windshields? If such a position exists, does it include or, in some way limit, the repair of long cracks?

Response:

NHTSA is responsible for the promulgation and enforcement of performance standards to ensure the safety of motor vehicles and items of motor vehicle equipment. We do not specify when or how repairs are conducted on a vehicle.

(3) Has the NHTSA reviewed the auto glass industrys voluntary Auto Glass Replacement Standard (www.AGRSS.com) and, if so, does the NHTSA have a position on that standard?

Response:

We are aware of the automotive glass industrys voluntary Auto Glass Replacement Standard, which provides detailed procedures for the proper installation of glazing. By invitation of the National Glass Association, NHTSA participated as an observer in a related Industry Code Practices/Standard meeting on September 18, 1998. However, we have not taken a position with regard to that standard, because as discussed above, we do not specify when or how repairs are conducted on a vehicle.

(4) Can the NHTSA provide a citation for their internal study that stated 82 people per day were injured or killed as a result of being ejected from their motor vehicles during crashes, and, if data available through your office that quantifies the number of individuals who were ejected through the windshield; through a side glass; or, through a door that opened during the crash? And, further, can your office advise (if such detail is not available in the current study) whether such detail is being considered for future studies?

Response:

We are not aware of the "internal study" to which this question refers. However, the statistics cited appear to approximate the number of serious injuries and fatalities that result from rollover crashes (not necessarily due to ejection). Using 1995-1999 data from the National Automotive Sampling System (NASS), we estimate that, on average, 253,000 light vehicles were involved in a tow-away, rollover crash each year, and that 27,000 occupants of these vehicles were seriously injured, equating to about 74 serious injuries per day (see Federal Register notice on Consumer Information Regulations; Rollover Resistance, 66 FR 3388 (Jan. 12, 2001) (Docket No. NHTSA-2000-8298)).

Focusing more specifically on the issue of ejection, in August of 2001, NHTSA published a final report entitled, "Ejection Mitigation Using Advanced Glazing," which presented research conducted by the agency. That report again studied crashes in the 1995-1999 NASS database. The report estimated that approximately 7,800 people are killed and 7,100 people are seriously injured each year because of partial or complete occupant ejections through glazing. This document can be found on NHTSAs website at: http://www-nrd.nhtsa.dot.gov/PDF/nrd-11/glazingreport.pdf. Specifically, Table 1.3 of the report provides statistics for ejection routes. NHTSA will continue to consider and update this information as part of our door lock and ejection mitigation research programs.

(5) Does the Bush Administration have plans to encourage states that have repealed all or part of their periodic motor vehicle inspection (PMVI) programs to reinstate PMVI?

a.)  During the 1970s and 1980s, anti-PMVI forces argued effectively that no one could prove PMVI saved lives. Has the NHTSA conducted any studies that compare accident or personal injury rates before and after PMVIs repeal?

Response:

While we recognize the importance of owners maintaining the safety systems in their vehicles, NHTSA currently has no plans to encourage States to implement PMVI programs, as the data do not indicate that PMVI should be an agency priority. The agencys current priorities include:impaired driving, safety belts, rollover, crash compatibility, and traffic records and data. NHTSA has not conducted, nor are there plans to conduct, research on the effectiveness of PMVI programs.

(6)Does NHTSA have any plans to revise the FMVSS regulations to more clearly reflect the materials and designs used in todays vehicles?

Response:

NHTSA periodically reviews our Federal motor vehicle safety standards on a 7-year cycle. As part of that review, we consider advancements in materials and designs used in current vehicles. FMVSS No. 205 is part of this periodic reassessment process.

The following provides one recent example of our efforts to improve the safety of glazing used in motor vehicles. On July 25, 2003, NHTSA published a final rule amending FMVSS No. 205 to incorporate the 1996 American National Standards Institute standard that deals with the safety performance of safety glass and safety glazing.

(7) Does the NHTSA receive and compile consumer requests for improved auto glass performance?If so, would that information be available to the National Glass Association?

Response:

On occasion, NHTSA receives petitions for rulemaking to improve automotive glass performance. These petitions are made available to the public through the Department of Transportations Docket Management System (DMS), which can be accessed at http://dms.dot.gov. For example, all petitions submitted to the agency in calendar year 2004 are posted in Docket No. NHTSA-2004-16856 for public review. However, NHTSA has not received any glazing-related petitions to date in 2004.

NHTSA also sometimes receives information related to automotive glass performance through consumer complaints submitted to NHTSAs Office of Defects Investigation (ODI). Such information is compiled in ODIs complaint database, which includes reports concerning glazing materials. These reports can be obtained from NHTSAs website at http://www.nhtsa.dot.gov/cars/problems/ by entering relevant search terms.

Enclosed is a copy of a reference document entitled, "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment," which you may find useful. If you have any further questions, please contact Eric Stas of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosure
ref:205
d.7/7/04

ID: nht91-1.5

DATE: January 3, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Tom Wiatrak -- Century Products Co.

TITLE: None

ATTACHMT: Attached to letter dated 10-19-90 from Tom Wiatrak to Deidre Fujita (OCC 5360)

TEXT:

This responds to your October 19, 1990 letter asking about the application of the labeling requirements of Safety Standard 213, Child Restraint Systems, to a seat pad you plan to produce for new child safety seats. You state that the pad would cover information that Standard 213 requires to be labeled on a child safety seat. You ask whether the labeling requirements of the standard could be met by directly labeling the seat and by permanently labeling a durable tag (made of "tyvek" material) that would be sewn to the pad.

The answer is yes. Paragraph S5.5 of Standard 213 required each add-on child restraint system to be permanently labeled with specified information. Paragraph S5.5.3 requires a portion of the required information to be located on the add-on child restraint system so that it is visible when the system is installed..." Your suggested tag would satisfy paragraph S5.5.3 if it bears the required information and if that information is visible when the seat is installed in the vehicle.

You should be aware that paragraph S5.7 of standard 213 requires "each material used in a child restraint system" to conform to the flammability resistance requirements of Standard 302, Flammability of Interior Materials. Since the tag would be affixed to the child restraint, the tag would have to comply with 302.

I hope this information is helpful.

ID: nht88-2.34

TYPE: INTERPRETATION-NHTSA

DATE: 05/27/88

FROM: TEVES, ALFRED -- TEVES TECHNICAL SERVICE

TO: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TITLE: BRAKE FLUID RESERVOIR DESIGN ACCORDING TO FMVSS 105 REQUEST FOR INTERPRETATION

ATTACHMT: OCTOBER 9, 1981 LETTER FROM BERNDT TO KAWANO, OCTOBER 3, 1988 LETTER FROM JONES TO BURKARD, EBNER, AND TEVES, FEBRUARY 3, 1981 LETTER FROM KAWANO TO BERNDT, JULY 10, 1974 LETTER FROM DYSON TO NAKAJIMA, AND MAY 24, 1988 LETTER FROM TEVES TO GREG ORY

TEXT: during his visit at NHTSA on May 17th, 1988 Mr. Ebner presented our new brake system to your experts.

We request an interpretation of S 5.4.2 (reservoir capacity) and S 5.3.1/b (Fluid level indicator) of FMVSS 105, with respect to the proposed brake fluid reservoir shown in the attachment.

Essential is the existence of an ancillary brake unit in this new brake system. This ancillary brake unit serves the brake circuits 1 and 2 directly.

Compared with a conventional reservoir the proposed brake fluid reservoir's distinctive feature is the exit for the ancillary unit.

This ancillary unit serves the brake circuits 1 and 2. When the brake pedal is released, the used brake fluid will flow back to the reservoir. This unit does not cause any additional fluid volume.

Teves interprets standard 105 S 5.4.2 and S 5.3.1/b) as follows:

1. The total minimum capacity of a reservoir shall be equivalent to the fluid displacement resulting when all the wheel cylinder or caliper pistons serviced by the reservoir move from a new lining, fully retracted position to a fully worn, fully applied position.

2. Reservoir systems utilizing a portion of the reservoir for a common supply to two or more subsystems, individual partial compartments shall each have a minimum volume of fluid equal to at least the volume displaced by the master cylinder piston servi cing the subsystem, during a full stroke of the piston.

3. The total amount of the fluid shall be solely available for the brakes.

4. The ancillary unit shall not use brake fluid for other purposes than for the brake circuits.

5. A drop in the level of brake fluid in any master cylinder reservoir compartment to less then the recommended safe level specified by the manufacturer ot to one-fourth of the fluid capacity of that reservoir compartment, which ever is greater.

The ancillary unit does not diminish the built in safety features of the reservoir. In case of a circuit failure, volume 1 resp. volume 2 remains still available for the brakes and the fluid level indicator lamp gives a warning to the driver.

In case of a fluid leakage in the ancillary unit, the unit is switched off. The fluid level indicator lamp and additional a separate warning lamp gives a warning to the driver. The fluid volumes 1 and 2 remain in the reservoir and are fully usable fo r applying the brakes with the master cylinder.

Accordingly, we believe that the proposed brake fluid reservoir described in this letter and presented to your experts fulfils the requirements S 5.4.2 and S 5.3.1 (b) of FMVSS 105.

We ask that you confirm our interpretation at your earliest convenience.

FMVSS 105, S 5.4.2: V = V[1] + V[2] + V[3] + V[4] V: GREATER OR EQUIVALENT TO FLUID DISPLACEMENT RESULTING WHEN ALL W/C MOVE FROM A NEW LINING POSITION TO A FULLY WORN LINING POSITION. MAX V[4] FLI V[3] V[1] V[2] BRAKE BRAKE ANCILLARY UNIT CIRCUIT 1 CIRCUIT 2 SERVICING BRAKE CIRCUIT 1+2

FMVSS 105, S 5.3.lb V[1] + V[3] >/- 0.25 (V[1] + V[3] + V[4]) V[2] + V[3] >/- 0.25 (V[2] + V[3] + V[4])

V[1] VOL. DISPLACEMENT EQUIVALENT TO A V[2] >/- FULL STROKE OF THE RELATED M/C-PISTON. TEVES MASTER CYLINDER RESERVOIR DESIGN ACCORDING TO FMVSS 105 3-34513-07

ID: nht89-3.22

TYPE: Interpretation-NHTSA

DATE: October 23, 1989

FROM: Richard J. Sullivan -- Attorney at Law

TO: Deirdre Fujita -- NHTSA

TITLE: Re Child Riding, Inc. Hideaway Safety Seat

ATTACHMT: Attached to letter dated 10-7-88 from G.T. Miller to E. Jones (OCC 2652); Also attached to letter dated 9-13-90 from P.J. Rice to R.J. Sullivan (A36; Std. 213)

TEXT:

Enclosed please find a videotape which details the installation of Child Riding, Inc.'s Hideaway Safety Seat.

As we discussed, the corporation has been waiting for a letter of interpretation from NHTSA for over a year clarifying the provisions of Section 4 of CFR571.213 as applied to this product and more specifically the definition of "Specific Vehicle Shell" c ontained therein by which it appears that the built-in seat must be tested in each model of each vehicle in which it is installed.

Several members of the corporations management team met with Mr. Gilkey, Ms. Tillman and various other individuals in your office in or about February, 1989 to demonstrate one of the installed prototypes and to discuss the certification procedure.

As management indicated at that meeting, Child Riding, Inc. is a small business concern with limited funds. An interpretation of the Regulation 213 that would require testing in each and every model of each and every vehicle in which it is installed wou ld, for all intents and purposes, put the company out of business before it could begin operation because of the prohibitive cost of testing (estimated at $10,000 per test by the University of Michigan).

It was managment's distinct impression following the February meeting that NHTSA had failed to take into consideration the possibility that a small business concern might market a built-in seat when it drafted Regulation 213 for built-in child restraint systems and that a review of the regulation would be promptly made consistent with the goals of the Regulatory Flexibility Act (P.L. 96-354) to encourage the development of innovative products by small business concerns.

A follow-up call was made to Ms. Tillman by this office in June of this year and she indicated that an initial draft of a letter of interpretation had been completed.

The corporation expects to have its product available for compliance testing in the very near future and would very much appreciate your efforts in securing an early determination of this matter.

If you require any additional information concerning Child Riding, Inc. and or the "Hideaway Seat" please do not hesitate to contact the undersigned.

ID: nht73-3.26

DATE: 02/14/73

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: Commonwealth of Pennsylvania

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 27, 1972, concerning the absence from Motor Vehicle Safety Standard No. 208 of requirements for seat belts after the passive restraint requirements become effective.

Our aim in the last three years has been to improve the protective capabilities of the autombile so that it will automatically protect its occupants from serious injury and death. We do not intend in the least to disparage seat belts -- to the contrary, we are making every effort to encourage their use. However, as passive restraints are installed, the marginal benefits to be gained from belts do not appear to be great enough to justify keeping them as required equipment.

The impacts that particularly concern you -- those occurring between 90 degrees and 270 degrees -- are partially covered by the lateral impact test of Standard 208. Impacts in which the force is more nearly rearward are the subject of continuing investigation by our Research Institute, with a view toward possible improvements in the rear-end structure. If standards are proposed concerning rear impact protection, they will probably focus on improved seat structure or on rear-end modifications rather than on seat belts.

We think the course we are following will result in significantly increased protection for the motoring public.