ID: nht70-2.10

DATE: 05/15/70

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

TO: Fleet Cap'n Trailers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 29, 1970, to Mr. Rodolfo A. Diaz, Acting Associate Director, Motor Vehicle Programs, concerning the location of rear lamps on various models of your trailers.

From a review of the sketch attached to your letter, it appears that the tail, stop and turn signal lamps mounted on the trailer frame rearward of the fenders will meet the location requirements specified in Table IV of Federal Motor Vehicle Safety Standard No. 108. However, Standard No. 108, by reference to SAE Standard J588d, also re-requires that "--- visibility of the front turn signal to the front and the rear signal to the rear shall not be obstructed by any part of the vehicle throughout the photometric test angles for the lamps." The photometric test angles for turn signal lamps are specified in Table 2 of SAE Standard J575c. From your sketch it appears that the required visibility of the turn signal lamps, when mounted in the proposed location, would be partially blocked by the framework of the trailer. Mounting the lamps on the rear crossmember may therefore be necessary to provide the required unobstructed visibility.

For your information I am enclosing copies of Standard No. 108, SAE Standard J588d and SAE Standard J575c.

ID: nht70-2.13

DATE: 06/18/70

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

TO: Capitol Tire Distributors

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 6, 1970, asking if you are violating the National Traffic and Motor Vehicle Safety Act, or, regulations issued pursuant to it, if you distribute tires marked seconds.

Neither the Act nor the regulations prohibit the sale of tires marked seconds. Manufacturers are required to certify that their product complies with Federal motor vehicle safety standards and do so by labeling each tire they they certify with the symbol "DOT". Tires that are certified by the manufacturer and marked "seconds" are not necessarily unsafe, as the "second" may be due to a cosmetic defect not affecting the tire's performance. In such cases, the distributor of the tire would not be in violation of the Act.

Sometimes a tire manufacturer will make a tire that he believes is defective in a way that affects the safety of the tire. Often, that manufacturer will mark the tire "farm use only" or "non-highway use" and then sell it. In such instances, he is supposed to remove the DOT symbol. Enclosed is a copy of a notice of proposed rulemaking dealing with this problem which may be of interest to you or your members.

Thank you for your interest in the motor vehicle safety program.

ID: nht68-2.2

DATE: 06/24/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Toyota Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 31, 1968, to Mr. George C. Hield, concerning your combination stop, tail, and turn signal lamp.

You are correct in your interpretation with respect to the combination lamp (A,B,C) fulfilling the requirement of paragraph S3.3 (a) of Motor Vehicle Safety Standard No. 108. However, the additional tail lamp (C) must also conform to the requirement of paragraph S3.1.2 which specifies that no additional lamp, reflective device, or associated equipment shall be installed if it impairs the effectiveness of the required equipment. If the intensity of tail lamp (C) is extremely high, the lamp could impair the effectiveness of lamp combination (A,B) when the combination is used as a stop or turn signal lamp. As you noted, the intensity of the tail lamps may be reduced by inserting resistance in the tail lamp circuit as provided by SAE Standard J585c.

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: nht68-3.40

DATE: 07/12/68

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

TO: Western Body and Hoist Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 9, 1968, to the Federal Highway Administration, in which you requested clarification of the requirements for amber side marker lamps and amber side reflectors.

A copy of presently applicable standards, and some proposed standards are enclosed. Note that Federal Motor Vehicle Safety Standard No. 108, effective January 1, 1969, requires amber front side marker lamps, and amber front side reflectors for vehicles of less than 30 feet overall length, and 80 or more inches in overall width. When the overall vehicle length is less than 30 feet and the front side marker lamps and front side reflectors have been mounted on the cab by the chassis-cab manufacturer, an additional set of the foregoing lamps and reflectors is not required on the body when it is installed.

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.

I trust this answers your questions.

ID: nht68-4.13

DATE: 08/27/68

FROM: AUTHOR UNAVAILABLE; E. B. Laskin; NHTSA

TO: Cleveland Public Schools

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of July 3, 1968, addressed to Mr. George C. Nield, of the National Highway Safety Bureau has been forwarded to my office for reply.

The installation of dual controls on driver education cars is not per se in violation of the Federal motor vehicle safety standards. However, the secondary equipment must meet the same safety standards established for the primary controls. The secondary steering column must fulfill the same requirements made for the primary column as set forth in Federal Motor Vehicle Safety Standards Nos. 203 and 204. The installation of an additional foot brake must not affect compliance with Standard No. 105. However, duplicate compliance with the control location and identification requirements of Standard No. 101 is not required since the "driver" of such a vehicle remain the person seated behind the primary controls. For the same reason the "driver" mirror requirements of Standard No. 111 apply only with respect to the person seated at the primary controls.

Changes may be made to original equipment when necessary for installation of secondary controls but none of the standards requirements specified may be eliminated or adversely affected by the alteration.

You may make available copies of this letter to dealers and interested parties.

ID: nht69-1.1

DATE: 01/27/69

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

TO: American Honda Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of November 18, 1968, and your subsequent telephone conversation of December 4, 1968, with a member of the Tire Branch, requesting the addition to Federal Motor Vehicle Safety Standard No. 110 of the 3.50B alternative rim size for use with the 145-10 redial tire size designation.

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 14969, dated October 5, 1968, the 3.503 alternative rim size for the 145-10 tire size designation will be listed within Table I of Appendix A to Standard No. 110.

The addition of this alternative rim size to the table in accomplished through an abbreviated procedure consisting of the publication in the Federal Register of the petitioned alternative rim size. If no comments are received, the amendment becomes effective 30 days after 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: nht71-1.4

DATE: 01/01/71 EST.

FROM: Robert L. Carter; NHTSA

TO: JEEP Corporation

TITLE: FMVSS INTERPRETATION

TEXT: On June 16, 1971, you and Mr. William Fleming of American Motors met with representatives of NHTSA and pointed out that the March 4, 1971, revisions of Standard No. 210 (36 F.R. 4291) had created a situation where seat belt anchorages for side-facing seats of multipurpose passenger vehicles would have to meet strength requirements only for the six-month period from July 1, 1971, to January 1, 1972. This occurred because the March 4 notice, which basically extended the existing standard for passenger cars to other types of vehicles as of July 1, 1972, did not have the exemption for side-facing seat belt anchorages that is contained in the revised standard that goes into effect on January 1, 1972.

The failure to exempt side-facing seats from the anchorage test requirements for the six-month period ending January 1, 1972, was inadvertent. A Federal Register notice will be issued shortly amending Standard No. 210 to correct this discrepancy. I am sending you this letter, which will be placed in the public files, in advance of the notice as an extraordinary procedure in light of the time period involved, to confirm that your vehicles need not meet the strength requirements for seat belt anchorages for side-facing seats apparently contained in Standard No. 210.

ID: nht71-2.1

DATE: 02/02/71

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Department of Public Utilities and Transportation

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of December 14, 1970, concerning taxicab driver security.

It is our opinion that the facts presented do not warrant rule making action in the form of safety performance standards applicable to new vehicle manufacture.

There are available, however, manufacturing options that may be procured to satisfy operational requirements. Bullet resistant glass between the cab driver and holdup men is one that quickly comes to mind. Further, we have issued a notice of proposed rule making (on December 31, 1970, which proposes amendment to the glazing Standard No. 205, (36 PR 326), a copy of which is enclosed. This(Illegible Word), if carried to a rule, would allow high strength plastics such as cellulose acetate butyrate and polycarbonate in areas not necessary for driving visibility. Cellulose acetate butyrate and polycarbonate do not meet requirements of the glazing standard as presently written.

(Illegible Word) share your concern for the security of cab drivers who seem to be under constant threat of robbery. However, we feel that the matter is one of satisfying operational needs rather than safety performance requirements as dictated in the National Traffic and Motor Vehicle Safety Act of 1966.

Enclosure

ID: nht71-2.34

DATE: 04/29/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Busby, Rivkin, Sherman and Levy

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of April 20, 1971, in which you enclosed a request for clarification, on behalf of Rolls-Royce, Ltd., of the requirements of Standard No. 208, Occupant Crash Protection. Essentially, the question was whether a "European type combined lap and diagonal strap seat belt assembly with retractor" could be furnished instead of the "Type 1 seatbelt assembly" specified in the second protection option on passenger cars manufactured from August 15, 1973, to August 14, 1975.

Standard No. 208 does not permit this substitution. The key feature of the second option in the August 1973- August 1975 period is that the manufacturer must design his vehicles so that the front seat occupants are protected from injury when restrained with lap belts only, and provide lap belts for all occupants that may, at least, be separately usable as such. A detachable upper torso belt may be provided at the manufacturer's option. The basis for this requirement is the well-documented finding that a much larger percentage of the American public will fasten lap belts than will use upper torso belts, whether the latter are of the detachable or the combination type.

We are pleased to be of assistance.

ID: nht71-5.65

DATE: 12/17/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: FWD Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 18, 1971, requesting for twenty-six of your trucks a temporary exemption from Standard No. 206. You reported that these trucks represent the final units to be produced in two soon-to-be-discontinued cab styles.

We regret that we are unable to consider your request, since our authority under section 123 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1410) to grant such exemptions expired in April of this year.

Beginning January 1, 1972, the manufacture of any truck not in compliance with the standard will be prohibited. Section 108(a) of the Act provides that

"(no) person shall manufacture for sale . . . any motor vehicle . . . manufactured on or after the date any applicable . . . standard takes effect . . . unless it is in conformity with such standard . . ." (15 U.S.C. 1397)

The prohibition is enforceable by civil penalties under section 109 (15 U.S.C. 1398) and injunction under section 110 (15 U.S.C. 1349). In addition, in the event that a noncompliance were determined to be a safety-related defect, notification of the defect would have to be furnished under section 113 (15 U.S.C. 1402) to purchaser of the vehicle.

LET US KNOW IF WE MAY BE OF FURTHER ASSISTANCE.