ID: nht94-7.23

DATE: March 25, 1994

FROM: Tilman Spingler -- Robert Bosch GMBH

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: FMVSS 108, S4.Definitions, Integral Beam Headlamp Request for Interpretation

ATTACHMT: Attached to letter dated 5/5/94 from John Womack to Tilman Spingler (A42; Std. 108)

TEXT:

In this paragraph an integral beam headlamp is defined to be an indivisible optical assembly of lightsource, reflector and lens. In the case of High Intensity Discharge Headlamps where the lightsource is comprised of a bulb and associated electronic modules, it may in some cases not be feasible to integrate the ignition module and the control module in the headlamp housing because of space limitations. In the letter to TOYOTA of March 1991 these modules were permitted to be separately located, but permanently attached by cable at the time of assembly. When the ignition module is installed inside and the control module outside the headlamp housing they will be connected by a 4-core cable in one design. Are there requirements for this cable concerning indivisibility and integration, for example, may it be of the following? - soft cable, resistant to abrasion? - hard cable, resistant to cutting and abrasion? - armored cable? Maximum voltage on 2 cores will be 130 V AC in the on-mode of the headlamp, on the 2 other cores 400 V AC for 700 msec during ignition of the light source. These voltages are much lower than voltages on ignition cables for motor vehicle engines.

ID: nht93-3.46

DATE: May 17, 1993

FROM: Ray Kesler -- Kesler Research Enterprises, Ltd.

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7/2/93 from John Womack to Ray Kesler (A41; Std. 111)

TEXT:

Mr. Hufstedler and I would like to thank you for your letter of April 27, 1993. It clarified many things for us which heretofore we had been unsure of, however, there is still one area which is not clear to us.

The enclosure you included in your letter was the Federal Register (in part) of September 2, 1982, which addresses FMVSS 111 rear-view mirrors. Section s571.111 states that a deviation of 12.5 percent, plus or minus, from the average radius of curvature, is allowable.

Although a method of calculating the radius of curvature is specified in section s12.1 - s12.8, it is not clear how the average radius of curvature is arrived at.

We would greatly appreciate it if your office could tell us the maximum amount of deviation we would be a owed from the bottom end of the standard (i.e.: 35" ROC), as well as perhaps explain the method by which the average radius of curvature is arrived at.

This information would be of great help to us in our continuing effort to save lives and property damage through the installation and use of our mirror.

ID: nht93-3.48

DATE: May 17, 1993

FROM: Ray Kesler -- Kesler Research Enterprises, Ltd.

TO: John Womack -- Acting Chief Counsel, NHTSA

COPYEE: Lawrence Hufstedler

TITLE: None

ATTACHMT: Attached to letter dated 7/2/93 from John Womack to Ray Kesler (A41; Std. 111)

TEXT:

Mr. Hufstedler and I would like to thank you for your letter of April 27, 1993. It clarified many things for us which heretofore we had been unsure of, however, there is still one area which is not clear to us.

The enclosure you included in your letter was the Federal Register (in part) of September 2, 1982, which addresses FMVSS 111 rear-view mirrors. Section s571.111 states that a deviation of 12.5 percent, plus or minus, from the average radius of curvature, is allowable.

Although a method of calculating the radius of curvature is specified in section s12.1 - s12.8, it is not clear how the average radius of curvature is arrived at.

We would greatly appreciate it if your office could tell us the maximum amount of deviation we would be a owed from the bottom end of the standard (i.e.: 35" ROC), as well as perhaps explain the method by which the average radius of curvature is arrived at.

This information would be of great help to us in our continuing effort to save lives and property damage through the installation and use of our mirror.

ID: nht78-1.19

DATE: 03/29/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Sheller-Globe Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This confirms the discussion held among you, Mr. Roger Tilton, Mr. Guy Hunter, and Mr. Martin Paliokas on February 14, 1978, concerning the applicability of Standard No. 221, School Bus Body Joint Strength, and Standard No. 113, Hood Latch Systems, to your vehicles.

In your first question, you asked whether the joint connecting a piece of metal that is attached to a body pillar and which is covered by the exterior body panels is a joint regulated by Standard No. 221. The standard regulates a "body panel joint" which is defined as "the area of contact or close proximity between the edges of a body panel and another body component, . . . ." "Body panel" is defined as "a body component. . .used to enclose the bus' occupant space." The piece of metal to which you refer becomes a part of the pillar and serves no purpose in enclosing occupant space. Therefore, the joint connecting these two body members is not a body panel joint and is not subject to the standard.

In your second question, you ask whether a hood latch system can utilize two pin-type latches, one on each side of the hood, to comply with Standard No. 113. The standard specifically permits the use of two hood latch systems. The use of these two distinct pins would appear to comply with the requirements.

ID: nht74-4.13

DATE: 07/10/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: University of Virginia

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 28, 1974, asking whether there are any Federal laws that would have a bearing on the University of Virginia's contemplated decision to purchase a tire grooving machine to regroove tires that will be used on buses operated by the University.

The NHTSA has recently amended Federal "Regrooved Tire" regulations (49 CFR 569, copy enclosed) to prohibit any person from regrooving his own tires (49 CFR @ 569.7). The regulation would apply to the University with respect to the tires you contemplate regrooving for use on university buses, and should certainly bear on your decision to purchase a tire regrooving machine.

The amendment to the regulation resulted from litigation National Association of Motor Bus Owners v. Brinegar, 483 F.2d 1294 (D.C. Cir. 1973) in which the United States Court of Appeals held that under section 204 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1524) Congress authorized this agency to permit only the sale of regrooved tires.

There are presently some efforts being made in the Congress to amend the Safety Act to alter the effect of this court decision. No final action of any kind has been taken, however, and we do not know whether or when such action might be taken.

ENC.

ID: nht73-1.2

DATE: 01/10/73

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Van Doorne's Automobielfabrieken N.V.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 12, 1972, about compliance of DAF cars with Federal Motor Vehicle Safety Standard No. 102.

Your question concerns the interpretation of paragraph S3.1.2. From your description in the letter and the description in the owner's manual, only one forward drive position is provided and engine braking can be achieved by actuating the transmission low ratio control switch. Under the conditions described above, the Variomatic transmission in DAF cars is not in violation with paragraph S3.1.2 of Standard No. 102. However, it appears that you do not comply with certain other paragraphs of the standard. For example, paragraph S3.1.1 requires that "A neutral position shall be located between forward drive and reverse positions. . . ." and paragraph S3.1.3 requires that "The engine starter shall be inoperative when the transmission shift lever is in a forward or reverse drive position."

The DAF 66 owners manual dated September 1972, also indicates non-compliance with other standards; for example, 101, Control Location, Identification and Illumination, 114, Theft Protection, 115, Vehicle Identification Number, etc. It is recommended that all standards and regulations be checked for compliance.

A copy of "Where to Obtain Motor Vehicle Safety Standards and Regulations" is enclosed for your review and information.

ID: nht73-1.25

DATE: DECEMBER 7, 1973

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Reservation Business Enterprise

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 16 concerning a definition of "steady burning" lamps.

Our definition of "steady" is "regular, uniform; not changed, replaced or interrupted; not fluctuating or varying widely." Stop lamps activated by the Pulsating Safety Brakelite would therefore not be "steady burning."

Thank you for your interest in highway safety.

Sincerely,

ATTACH.

November 16, 1973

E.T. Driver, Director -- Office of Operating Systems, Motor vehicle Programs, U.S. Department of Transportation, National Highway Traffic Safety Administration

Dear Mr. Driver;

Over a year ago, I wrote you concerning our "Pulsating safety brakelite". Recently we have developed a legal question concerning our product and Federal Motor Vehicle Safety Stanlanl no. 108. 108 states that the brakelite must be steady burning. Our device does not over turn the bulb out but only changes it's brilliance in a pulsating manner.

Our question is; does "steady burning" mean that the bulb must always be on, and therefore our product falls within that definition or does it require it to burn at a steady intensity which would make our product fall outside the definition.

We are very eager to get this clarified.

Sincerly

Mel Aanerud, Manager -- RESERVATION BUSINESS ENTERPRISE

ID: nht73-2.33

DATE: 04/10/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Independent Tire Dealer

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 26, 1968, to Mr. Robert M. O'Mahoney, Assistant Chief Counsel, concerning clearance lamp mounting on bodies installed on chassis-cabs.

It is required by Federal Motor Vehicle Safety Standard No. 108 that clearance lamps be mounted as near as practicable to the upper left and right extreme edges of the vehicle. The cab mounted clearance lamps shown on your drawing CA1030-40, dated September 24, 1968, being mounted approximately 16 inches inboard of the extreme body width, do not appear to be as near as practicable to the extreme edges of the vehicle. Lamps mounted at the right and left extreme edges of the widest part of the body panel would meet the requirements. The mounting height of these lamps should be as high as practicable without causing objectionable glare in the rear view mirror. Retention of cab mounted clearance lamps is optional.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, comments of this Bureau are for information purposes only and in no way relieve any vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.

ID: 77-4.46

TYPE: INTERPRETATION-NHTSA

DATE: 12/05/77

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Rocky Mountain Bandag

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your October 19, 1977, letter asking whether the National Highway Traffic Safety Administration (NHTSA) has regulations that prohibit the use of retreaded tires on steering axles.

The NHTSA has performance regulations applicable to retreaded passenger car tires. The agency does not regulate the use of retreaded tires that meet those performance requirements. You should note that the Bureau of Motor Carrier Safety has regulations (49 Code of Federal Regulations Part 393.75(d)) that prohibit the use of retreaded tires on the front wheels of buses under their jurisdiction. They do not prohibit the use of such retreaded tires on the steering axle of trucks, however.

SINCERELY,

ROCKY MOUNTAIN bandag

October 19, 1977

Director U. S. Department of Transportation National Highway Traffic Safety Administration

We are in the business of cold process retreading truck tires.

Quite frequently, truck owners tell us there's a D.O.T. regulation that says retreaded tires cannot be used on steering axles. To our knowledge, there is no such regulation. If we're correct, would you please send a letter that says there is no D.O.T. regulation that disallows use of retreads on the steering axle?

William H. Loughran President

ID: nht75-2.15

DATE: 04/21/75

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

TO: Dominion Auto Accessories Limited

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 20, 1975, inquiring as to the permissibility of selling your "Panamirror" in the United States as aftermarket equipment.

Motor Vehicle Safety Standard No. 111, Rearview Mirror, provides minimum performance requirements for rearview mirrors on passenger cars and multipurpose passenger vehicles. According to the standard, the inside rearview mirror must furnish the driver with a specified field of view to the rear of substantially unit magnification. Any vehicle manufactured for sale, sold, or introduced into interstate commerce must be equipped with an inside rearview mirror that meets the designated level of performance. It appears that the "Panamirror" would not satisfy the requirements of the provision, because it is convex in structure and therefore would not provide a view of substantially unit magnification.

If the mirror were installed on a vehicle as aftermarket equipment (after the vehicle's first purchase for purposes other than resale) in such a way as to render inoperative the inside rearview mirror, section 108(a) (2) (A) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563) as amended (Pub. L. 93-492) would apply where the installation was accomplished by a manufacturer, distributor, dealer, or motor vehicle repair business. The section prohibits the named parties from knowingly rendering inoperative a system installed in compliance with an applicable motor vehicle safety standard.