ID: nht75-4.4

DATE: 05/28/75

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

TO: Dairy Equipment Co.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Dairy Equipment's April 3, 1975 request for a discussion of what constitutes the manufacture of a trailer in cases where used components from an existing vehicle are involved.

In response to a similar request from the Truck Trailer Manufacturers Association, the National Highway Traffic Safety Administration recently prepared a comprehensive discussion of this subject, a copy of which is enclosed for your information.

YOURS TRULY,

April 3, 1975

David E. Wells, Chief Counsel Federal Highway Administration Department of Transportation

Confirming the phone conversation on March 31, 1975 between Mr. Kazmierazack of the D.O.T. and Mr. Ehinger of our company regarding the rebuilding of used trailers, Mr. Kazmierzack stated that we can obtain an official ruling by writing to your office.

We have customers who want to replace the tank of an existing semi-trailer tank motor vehicle utilizing the under carriage frame, suspension, axles, wheels, and tires from the old semi-trailer. Can you confirm to us in writing Mr. Kazmierzack's verbal approval to Mr. Ehinger that this type of repair does not incur any obligation to comply with current motor vehicle safety standards? We intend to retain the vehicle identification number, make, and model year.

Thank you for your consideration.

DAIRY EQUIPMENT COMPANY

Jim Koester Product Engineer

ID: nht95-1.81

TYPE: INTERPRETATION-NHTSA

DATE: February 28, 1995

FROM: Chong D. Lee -- President, TMR International, Inc.

TO: Mr. Philip Recht -- Office of the Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 4/10/95 LETTER FROM PHILIP RECHT TO CHONG D. LEE (A43; STD. 208)

TEXT: Dear Mr. Recht:

The purpose of this letter is to request the opinion and advice of the National Highway Traffic Safety Administration on the legality and potential legal risks of an automotive product intended to increase occupant safety.

Our company, TMR International, Inc., plans to import, for North American sale, an aftermarket driver's side airbag. The intent is to offer this product as a safety improvement for customers whose cars and trucks were manufactured without an airbag as o riginal equipment. The airbag comes in assembly with a steering wheel and is intended for installation as a unit in replacement of the vehicle's OEM steering wheel.

We are requesting the opinion of NHTSA as to; a) Whether such a product as described is legal for U.S. sale; b) Legal procedures, testing or submissions required to certify the product for U.S. sale; c) Applicable Federal law (e.g., FMVSS 208) d) Actions or registrations required to reduce legal risks; e) Any other information of which we should be aware.

Thank you for prompt attention. We look forward to bringing to market, as soon as possible, this important safety improvement product.

ID: nht94-1.99

TYPE: Interpretation-NHTSA

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 mod ules, 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 per manently 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: nht94-2.37

TYPE: Interpretation-NHTSA

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: nht69-1.50

DATE: 04/29/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Hueck and Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 22, 1969, requesting a clarification of the location requirements for license plate lamps as specified in Federal Motor Vehicle Safety Standard No. 108.

As you indicated, Standard No. 108 currently references SAE Standard J587B and also permits the location of license plate lamps at the top, side or bottom of the license plate. The latest revision of SAE Standard J587 (J587c) is no way changes the location provision of Standard No. 108. Therefore, a license plate lamp assembly may be tested according to SAE Standard J587b and Standard No. 108 when the license plate is illuminated from the bottom.

Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 states: "Whenever a Federal motor vehicle safety standard established under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect, with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard." Therefore, any State regulations on the location of license plate lamps should be identical to the requirements of Standard No. 108 on and after the effective date of the standard.

ID: nht69-2.48

DATE: 10/16/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Seagrove Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 29, 1969, to Mr. Julien B. Leysath concerning the mounting location of lamps and reflectors on fire trucks.

The lamps and reflectors shown on your print of drawing number 2207 B 43.3 dated September 29, 1969, appear to meet the requirements of MVSS No. 108 with the following exception:

1. Front side marker lamps are not indicated on either the "F" or "S" cab. The front clearance lamps on the "F" cab may be combination clearance and side marker lamps, but are not so labeled.

2. The rear reflex reflectors on the 4 wheel aerial truck and the trailer do not appear to be located as far apart as practicable.

3. Backup lamps are not required on trailers.

Since no dimensions are specified on your drawing, we can only assume that the locations are otherwise as specified in MVSS No. 108.

With respect to the requirements of MVSS 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 consants 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: nht70-1.11

DATE: 12/17/70

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Northeast Kentucky Area Development Council, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 28, 1970, to Mr. Lowell K. Bridwall, Administrator, Federal Highway Administration, asking for a definition of "blemished," "second," and "form use only," which has been referred to this office for reply.

Tire manufacturers are required to certify that their product complies with the Federal Motor Vehicle Safety Standard No. 109, and do so by labeling each tire 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.

Sometime 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 required to remove the DOT symbol.

We do not have a definition for "blemished."

We have enclosed a copy of an amendment to the passenger car tire standard (No. 109) that contains the definition for "non-highway use tires" which is applicable to "farm use only," and "tire identification and recordkeeping" which is applicable to "manufacturer's marks on tires."

Thank you for your interest in the Motor Vehicle Safety Program.

ID: nht70-1.9

DATE: 10/26/70

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

TO: Long Mile Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of October 12, 1970, requesting clarification of the required testing for retreaded passenger car tires has been received.

The notice of proposed rule making for Retreaded Pneumatic Tires - Passenger Car was published in the Federal Register (35 FR 4136) on March 5, 1970. Within the proposed standard is states: "S3.2 Retreaded tire requirements: Retreaded tires shall conform to the size, construction, performance and tread wear indicator requirements set forth in paragraphs S4.1 and S4.2 of Federal Motor Vehicle Safety Standard No. 109, no tire may be retreaded by a process which includes the removal of a ply or belt from the casing."

Within S4.2 of Standard No. 109, paragraph S4.2.2.5 specifies the laboratory (dynamometer) test for tire endurance and paragraph S4.2.2.5 specifies the laboratory (dynamometer) test for high speed performance. For your information, I have enclosed a copy of Federal Motor Vehicle Safety Standards No. 109 and No. 110 with amendments.

It was intended that the phrase "through testing" mean testing to Standard No. 109 and it was not intended that the phrase be construed to mean any form of testing.

I hope the above clarifies your question concerning retreaded tires performing to the(Illegible Word) dynamometer tests for tire endurance and high speed performances(Illegible Word)

Sincerely,

ID: nht70-2.1

DATE: 04/01/70

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

TO: Baker Equipment Engineering Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter to the Director, U. S. Department of Transportation dated February 19, 1970, concerning the mounting of identification lamps on your reel type trailers has been referred to this office for reply. A thorough review of our correspondence files indicates no record of our receipt of your letter of January 12, 1968, on this matter.

Federal Motor Vehicle Safety Standard No. 108 requires that all trailers (except pole trailers and trailer converter dollies), which are 80 or more inches in overall width, be equipped with rear identification lamps in accordance with Tables I and II of the standard. The standard contains no provision for exemption of specially designed trailers such as your reel type models and we have to authority to provide relief for individual manufacturers.

Identification lamps mounted on the axle of your trailer would appear to meet the mounting location requirements of Standard No. 108.

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 comment is for your information only and in no way relieves the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.

ID: nht68-1.5

DATE: 11/25/68

FROM: H. M. JACKLIN; CONCURRENCE BY R. M. O'MAHONEY -- NHTSA

TO: Firestone Tire and Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letters of July 12, 1968, October 10, 1968, and October 31, 1968, to the National Highway Safety Bureau requesting the addition of three 50 Series Centilevered Sidewall tire size designations to Federal Motor Vehicle Safety Standard No. 109.

On the basis of the data submitted indicating compliance with the requirements of Federal Motor Vehicle Safety Standards Nos. 109 and 110 and other information submitted in accordance with the procedural guidelines set forth in Federal Register Volume 33, No. 195, page 14964, dated October 5, 1968, the E50C-16, F50C-16 and H50C-17 tire size designations will be listed within a new table to be established in Appendix A of Standard No. 109 and the 3 1/2 inch rim size will be listed within Table I of the Appendix to Standard No. 110. These changes will be published in the Federal Register in the near future.

The addition of new tire size designations to the tables is accomplished through an abbreviated procedure consisting of the publication in the Federal Register of the petitioned tire sizes or tables. If no comments are received, the amendment becomes effective after 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.