ID: nht74-5.29

DATE: 03/14/74

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

TO: L and R Enterprises

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 15, 1974, letter asking whether your installation of spotlights through the left A-pillar of passenger cars is subject to Standards 201 and 216.

Standard 201 does not apply to the instrument panel area on the driver's side from the left door to a longitudinal plane 3-1/4 inches to the right of the steering wheel. The left A pillar is within this excluded area.

Your drilling operation may affect roof strength and I have enclosed a copy of Standard 216, our standard on roof crush resistance. Under the National Traffic and Motor Vehicle Safety Act of 1966, it is the responsibility of the person who manufacturers or alters a vehicle to determine whether his vehicle meets the requirements.

Your business is subject to these requirements, however, only if you qualify as an alterer of motor vehicles under 49 CFR 567.7, which is enclosed. The mounting of a spotlight by drilling the A-pillar is a "non-readily attachable" alteration. Such an alteration would be subject to the @ 567.7 requirement only if you mount it "before the first purchase of the vehicle in good faith for purposes other than resale."

2 ENCLS.

CC: HONORABLE JOHN TOWER HONORABLE LLOYD BENTSEN

ID: nht94-6.34

DATE: April 13, 1994

FROM: Richard Kreutziger -- Executive Director, New York State Bus Distributors Ass'n.

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/25/94 from John Womack to Richard Kreutziger (A42; Std. 108)

TEXT:

I VERY MUCH APPRECIATE YOUR RESPONSE TO MY QUESTIONS FAXED TO YOU ON 1/12/94 AND 2/14/94. THE "APPENDIX" PROVIDED HAS AND I AM SURE WILL PROVIDE MUCH MORE BENEFIT IN TIME.

I AM FACED, NOW, WITH A NEW QUANDARY. I CERTAINLY DO NOT MEAN TO IMPOSE ADDED WORK LOAD, AND I ASSURE YOU THAT I HAVE READ AND REREAD FMVSS 571.108 - LAMPS, REFLECTIVE DEVICES, AND ASSOCIATED EQUIPMENT, FOR MY ANSWER.

IN 571.108 SECTION S5.5.7 - REFERENCE TO VEHICLES INCLUDING BUSES, OF LESS THAN 80 INCHES OVERALL WIDTH - HAVE VERY DEFINITE WIRING PROGRAMS INCLUDED, PART (a) AND (b) - IN BOTH SUB-SECTIONS THE "MAKER LIGHTS" ARE REFERRED TO - WHICH HAVE TO BE ACTIVATED WHEN THE PARKING OR HEADLIGHT SWITCH IS ACTIVATED.

MY "QUANDARY" IS - I CAN FIND NO LIKE OR SIMILAR SECTION REQUIRING THE ACTIVATION OF SPECIFIC LIGHTS ON VEHICLES OF MORE THAN 80 INCHES IN OVERALL WIDTH.

ANY HELP AND/OR KNOWLEDGE OF A SIMILAR POSITION/FACTOR ON VEHICLES OF MORE THAN 80 INCHES IN WIDTH AS THOSE OF 80 INCHES OR LESS WILL BE GREATLY APPRECIATED.

ID: nht69-1.27

DATE: 06/06/69

FROM: AUTHOR UNAVAILABLE; H. M. Jacklin, Jr.; NHTSA

TO: Rubber Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of May 14, 1969, to the National Highway Safety Bureau requesting the addition of the 6JJ alternative rim size for the E78-14 tire size designation to Table I of Appendix A of Federal Motor Vehicle Safety Standard No. 110.

On the basis of the data submitted indicating compliance with the requirements of Federal Motor Vehicle Safety Standards No. 109 and No. 110 and other information submitted in accordance with the procedural guidelines set forth in the Federal Register, Volume 33, No. 195, page 14964, dated October 5, 1968, the 6JJ alternative rim size for the E78-14 tire size designation will be listed within Table I of Appendix A of Standard No. 110. This change will be published in the Federal Register in the near future.

The addition of new alternative rim size designations to the table is accomplished through an abbreviated procedure consisting of the publication in the Federal Register of petitioned alternative rim size. If no comments are received, the amendment becomes effective 30 days from the date of publication. If comments objecting to amendments are received, additional rule making pursuant to Part 216 of the Procedural Rules for Motor Vehicle Safety Standards will be considered.

ID: nht69-1.32

DATE: 04/04/69

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

TO: Carlisle Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Your December 27, 1968, request for a code number in accordance with Subsection S4.3 of the Federal Motor Vehicle Safety Standard No. 109 and the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1421 (1)) has been reviewed. Subsection S4.3 of the Federal Motor Vehicle Safety Standard No. 109 applies to passenger car tires; accordingly, the National Highway Safety Bureau has restricted the issuance of code numbers to manufacturers of those tires.

Since Carlisle Tire and Rubber Division does not engage in the manufacture of passanger car tires, and since the code number was requested in anticipation of future tire rule making, the issuance of a code number to the Carlisle Tire and Rubber Division would be premature and not in keeping with the intent of the regulation.

We have enclosed a Mailing List Questionnaire as promised. To assure a flow of specialized mailings which may be of great importance to your particular organization, please complete both sides with the correct information and return it to the Federal Highway Administration, National Highway Safety Bureau, Motor Vehicle Safety Performance Service, Washington, D. C. 20591, Attention: MVSPS List Questionnaire. If you require more than one form or have any inquiries concerning the form, please direct your correspondence to the same address.

ID: nht69-1.4

DATE: 09/02/69

FROM: C. A. Baker; NHTSA

TO: Garis, Trezza, Ithurburn and Keely

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of August 6, 1969, to the National Commission on Products Liability has been referred to the National Highway Safety Bureau for reply.

Vehicle skidding is a function of many parameters within the tire-pavement interface. The most adverse tire-pavement interactions occur when pavement is covered with water. Under certain wet pavement conditions, complete loss of traction or hydroplaning occurs. The two possible hydroplaning phenomena which may occur are viscous hydroplaning or dynamic hydroplaning. Both of these conditions of hydroplaning to a degree may be controlled by the proper selection of pavement texture and tread-depth of tires.

The detection of hydroplaning as the causation of accidents is most difficult to establish and although we have many accident studies in progress, I would seriously doubt that hydroplaning can be successfully isolated from the common form of skidding.

The tire manufacturers recognize hydroplaning and they do provide adequate water escape passages as well as tread depth to copy with this problem. However, the tire is only a subsystem within the tire-pavement system of hydroplaning.

For further information on this subject, I suggest that you contact the National Aeronautics and Space Administration who's research history on hydroplaning dates to 1958.

ID: nht69-2.1

DATE: 03/28/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: The Hail Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 24, 1969, to the Office of Standards Preparation, concerning the proposed lighting equipment on your dump trailers.

The lamps and reflectors shown on your drawing 701b1907 dated February 20, 1969, appear to be in conformance with the requirements of Standard No. 108 with the following exceptions:

1. The required license plate lamp is not shown.

2. The minimum mounting height for reflectors is 15 inches.

3. With respect to maximum mounting zones for lamps and reflectors, the limiting dimensions of 16, 30, and 24 inches indicated on your drawing appear to be too liberal for a trailer with essentially square corners.

With reference to Notes 2 and 3 on your drawing, certain restrictions as specified in paragraph S3.3 of Standard No. 108 are applicable for combination lamps.

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 (Illegible Word) responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.

ID: nht69-2.2

DATE: 05/02/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Reliance Trailer and Truck Company Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 12, 1969, to the Director of the National Highway Safety Bureau concerning your questions on mounting of clearance and identification lamps on your open top bulk commodity trailers. In response to your question no. 1, identification lamps mounted below the bottom edge of the tarp as shown on your attached marked print no. 2 appear to be in compliance with Standard No. 108. With the identification lamps to mounted the rear clearance lamps may be mounted at the extreme edge of the rear lower structure as shown on print no. 2.

The answer to question numbers 2 and 3 is that the front clearance lamps should be mounted as high as practicable to clear the bottom edge of the tarp as shown on your attached marked print no. 2.

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.

ID: nht69-2.6

DATE: 01/16/69

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA

TO: Rolls-Royce Limited Motor Car Division

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 8, 1968, requesting a clarification of the 30g horizontal inertia load direction specified in Standard No. 201, as published in the Federal Register on October 25, 1968.

In section S3.3.1(c), "Subject the interior compartment door latch system to a horizontal inertia load of 30g in a longitudinal direction....." means both forward and rearward directions. In addition, the loads specified in S3.3.1(a) are applied in both the inboard and outboard and the up and down directions. This is consistent with similar type requirements in Standard No. 206.

You state that a forward and rearward 30g inertia load requirement is more stringent than the alternative procedure of S3.3.1(b), the barrier test. The Bureau believes, and one large manufacturer so stated in his comments, that the most meaningful test of the ability of an interior compartment door to remain closed is one which considers the distortion and deformation loads that occur in a collision. A barrier or equivalent dynamic test is the best way of realistically evaluating the ability of these doors to remain closed. The Bureau, therefore, believes that the barrier test is as stringent a requirement as S3.3.1(c).

ID: nht70-1.44

DATE: 03/10/70

FROM: D. W. TOMS -- DIR., NHTSA; SIGNATURE BY ROBERT BRENNER

TO: Recreational Vehicle Institute, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 13, 1970 to the Administrator, in which you requested an interpretation of Standard 206, Door Locks and Door Retention Components, as applied to motor homes and chassis-mount campers. Specifically, you asked whether door components must conform to the requirements of the standard when the door is located across the width of the vehicle from a seating position.

The relevant language is in paragraph S4. of the standard:

"Side door components referred to herein shall conform to this standard if any portion of a 90-percentile two-dimensional manikin as described in SAE Practice J826, when positioned at any seating reference point, projects into the door opening area on the side elevation or profile view."

This language clearly covers, and was intended to cover, the situation that you describe. The phrase "projects into the door opening area on the side elevation or profile view" eliminates, in respect to the standard's application, any consideration of the lateral distance of the seating position from the door opening. The door components of vehicles you described in your letter must therefore conform to the standard.

We are pleased to be of assistance.

ID: nht70-1.48

DATE: 03/25/70

FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA

TO: The Society of Motor Manufacturers and Traders Limited

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 2, 1970, to the Federal Highway Administration, transmitting the August 1969, edition of the S.M.M.T. Tyre and Wheel Engineering Manual.

Your letter also expressed your intention of having the 1969 manual supercede the 1965/66 data book as referenced in Section 83 of Standard No. 109. As we stated in our letter of March 14, 1969, to Mr. Woodbridge, Chief Engineer of S.M.M.T., "Federal Motor Vehicle Safety Standard No. 109, within Section 83, lists the Tyre and Wheel Engineering Data Book dated 1965/66 of the Society of Motor Manufacturers and Traders Limited (S.M.M.T.), "as one of the references containing acceptable test rims. When Standards No. 109 and 110 were developed, the National Highway Safety Bureau accepted the S.M.M.T. 1965/66 Data Book tire and rim combinations based on established usage. We did not, nor do we at present intend to accept general updating of these referenced publications, either foreign or domestic, as valid reasons for amending Standards No. 109 and 110. Consequently, any new tire size designations or alternative rim sizes that you wish to list within Standards No. 109 and 110 will have to comply, on an individual basis, with the abbreviated guidelines as outlined in the October 5, 1968, Federal Register.