ID: nht71-4.24

DATE: 10/14/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: FWD Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of September 15, 1971, requesting our interpretation of certain motor vehicle safety standards and regulations:

1. Federal Motor Vehicle Safety Standard No. 208, "Occupant Crash Protection," as amended at 36 F.R. 4600 (March 10, 1971). If trucks over 10,000 pounds CV-R are equipped with a seat belt system as in paragraph S4.3.2, the vehicles need not meet the requirements of paragraphs S5 and S6, which apply only when the complete passive protection system option of paragraph S4.3.1 is adopted. Of course, the seat belt system must conform to the seat belt assembly requirements of Federal Motor Vehicle Safety Standard No. 209, "Seat Belt Assemblies."

2. Federal Motor Vehicle Safety Standard No. 206, "Door Locks and Door Retention Components." Your interpretation of the standard's coverage is correct: there are no requirements in the standard for the installation of the latches and hinges.

3. Part 573, "Defect Reports," S6 F.R. 3064 (February 17, 1971). The National Traffic and Motor Vehicle Safety Act and our regulations do not require manufacturers to repair defective motor vehicles. Manufacturers are therefore free to make whatever arrangements for repair of defects they wish. Of course, we hope that in making such arrangements the manufacturers will assume the responsibility of assuring that the repairs are made properly.

ID: nht71-4.47

DATE: 11/13/71

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

TO: The Commonwealth of Massachusetts

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 17, 1971, asking if present Federal regulations would preempt the Massachusetts requirement that certain outside rearview mirrors be provided with reflective material over the rear surface.

Section 103(d) of the National Traffic and Motor Vehicle Safety Act, 15 U.S.C. 1392(d), states in pertinent part:

"Whenever A Federal motor vehicle safety standard . . . is in effect, no State . . . shall have any authority . . . to establish . . . with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable tot he same aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard."

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, establishes requirements for reflective materials used on motor vehicles. The NHTSA considers this standard to include within its scope all reflective materials required to be used on motor vehicles to which it applies. Any State requirements that have the effect of regulating such reflective materials must therefore be identical to the relevant provisions of Standard No. 108. The Massachusetts statute that you have brought to our attention is not identical to the Federal standards relating

to that aspect of performance, and must therefore be considered to be invalidated by the operation of the National Traffic and Motor Vehicle Safety Act.

ID: nht71-5.23

DATE: 12/14/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: FWD Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of September 15, 1971, requesting our interpretation of certain motor vehicle safety standards and regulations:

1. Federal Motor Vehicle Safety Standard No. 206, "Occupant Crash Protection," as amended at 36 F.R. 4600 (March 10, 1971). If trucks over 10,000 pounds(Illegible Word) are equipped with a seat belt system(Illegible Word) in paragraph S4.3.2, the vehicles need not meet the requirements of paragraphs S5 and S6, which apply only when the complete passive protection system option of paragraph S4.3.1 is adopted. Of course, the seat belt system must conform to the seat belt assembly requirements of Federal Motor Vehicle Safety Standard No. 209, "Seat Belt Assemblies."

2. Federal Motor Vehicle Safety Standard No. 206, "Door Locks and Door Retention Components." Your interpretation of the standard's coverage is correct: there are no requirements in the standard for the installation of the latches and hinges.

3. Part 573, "Defect Reports," 36 F.R. 3064 (February 17, 1971). The National Traffic and Motor Vehicle Safety Act and our regulations do not require manufacturers to repair defective motor vehicles. Manufacturers are therefore free to make whatever arrangements for repair of defects they wish. Of course, we hope that in making such arrangements the manufacturers will assume the responsibility of assuring that the repairs are made properly.

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.

ID: nht73-5.12

DATE: 09/25/73

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

TO: Crown Coach Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 28, 1973, concerning the effective date of Motor Vehicle Safety Standard No. 121. Your direct question is whether the effective date is the starting or completion date for the vehicle's components or the starting date for the vehicle.

Standard No. 121 applies to the vehicle and its effective date therefore relates to the vehicle, rather than to any of its components. A vehicle completed after the effective date will have to meet the standard, even though it is equipped with a foundation brake system that was manufactured before the effective date.

The vehicle's completion date, rather than its starting date, is the date that determines whether it must conform to the standard. If your company manufactures its vehicles from the ground up, rather than installing a body on a vehicle built by another manufacturer, the relevant completion date is the date you complete your manufacturing operation. However, if you buy an incomplete vehicle, as defined in our regulation on vehicles manufactured in two or more stages (49 CFR Part 568), and complete that vehicle, you may choose as the completion date for purposes of Standard No. 121 the date on which the manufacturer of the incomplete vehicle finished his work, the date on which you completed the vehicle or any date in between.

ENC.

ID: nht73-5.16

DATE: 04/12/73

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

TO: District Director of Customs

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 15, 1973, to Mr. Armstrong asking "whether a hub cap with a wing type attachment is subject to Standard 211."

Standard No. 211 prohibits wheel discs, wheel nuts, and hub caps that incorporate winged projections. The item that you enclosed appears to be a wheel spinner which, when attached to a wheel disc or hub cap would create an assembly incorporating a winged projection in violation of Standard No. 211. The item itself is not literally prohibited by the standard, but it evidently has no function apart from this end use. I am therefore of the opinion, if the same source is separately shipping spinners and wheel discs/hub caps to which the spinner may be attached, that these items may be refused entry into the United States.

THE DEPARTMENT OF THE TREASURY

BUREAU OF CUSTOMS LOS ANGELES, CALIF.

MAR 15 1973

Francis Armstrong, Director Office of Standards Enforcement Motor Vehicle Programs National Highway Traffic Safety Administration

A question has arisen as to whether a hub cap with a wing type attachment is subject to Standard 211 of the National Traffic Motor Vehicle Safety Act.

A sample of the subject hub cap is forwarded for your inspection and decision.

C. A. MCGONIGLE Senior Import Specialist

Encl.

ID: nht73-5.19

DATE: 03/09/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 8, 1973, concerning the use of a "comfort clip" on the shoulder belt portion of GM's 1974 seat belt system.

In response to questions from other manufacturers concerning the use of high friction buckles in continuous loop belt systems, we have indicated that the requirement of Standard 208 that the belts adjust to fit specified occupants precludes the use of such buckles. In the case of systems with separate lap and shoulder belt retractors, however, the shoulder belt does not affect the tension in the lap belt and therefore does not present the risk of submarining that exists with the single loop systems. Accordingly, we are of the opinion that a comfort clip would be acceptable under S7.1.1 of the standard, so long as the shoulder belt is otherwise capable of adjustment as required by S7.1.1.

At a meeting with you on this subject on January 24, 1973, the NHTSA expressed its concern about possible reductions in shoulder belt effectiveness due to excessive belt slack. On the whole, we find that this possibility is more than offset by the prospects of greater usage due to the added convenience of the system with the clip. However, we strongly support your proposal to include instructions for the use of the clip both on the clip itself and in the owner's manual.

ID: nht73-5.30

DATE: 10/26/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 25, 1973, asking whether the fuel spillage measurement specified in Standard No. 301 is an average rate of one onunce per minute (your Item A) or an actual rate. (Your Item B)

Your item B is correct. Fuel spillage shall not exceed one ounce per minute in any one of the fifteen minutes of the observed period.

YOURS TRULY,

NISSAN MOTOR CO., LTD.

September 25, 1973

Lawrence Schneider Chief Council National Highway Traffic Safety Administration

This is to ask your interpretation regarding the test procedures of MVSS 301 Fuel System Integrity published in Federal Register, Vol. 38, No. 160 (Docket No. 70-20) on August 20, 1973.

We feel that the fuel spillage requirement following cessation of vehicle motion of S.5.4 has the following two meanings:

A) The calculated fuel spillage rate.

Total amount of fuel spillage (oz.)

B) The measured fuel spillage rate every minute. All of the collected fifteen one-minute timed samples shall not exceed one ounce per minute.

We would like to know which definition is correct understanding. Your prompt reply would be greatly appreciated.

Very Truly Yours,

Tatsuo Kato

ID: nht91-1.38

DATE: February 11, 1991

FROM: Delbert N. Pier -- Legislation and Compliance Coordinator, Hyundai America Technical Center, Inc.

TO: Paul Jackson Rice -- Chief Council, NHTSA

TITLE: Re FMVSS Number 108, Lamps, Reflective Devices, and Associated Equipment

ATTACHMT: Attached to letter dated 3-14-91 from Paul Jackson Rice to Delbert N. Pier (A37; Std. 108)

TEXT:

Hyundai requests assistance with an interpretation regarding Federal Motor Vehicle Safety Standard, Number 108 (lamps, reflective devices, and associated equipment).

In regards to the interchangeability of headlamp bulbs, the procedure (571.108) requires that the terminals must be perpendicular to the base and parallel within plus or minus 1.5 degrees.

Hyundai would like an interpretation on whether the bulb fixture can be rotated approximately 11 degrees, as shown in the attachment, view X. This will not change the terminal logistics by the rotation of the bulb fixture. This rotation will not change the constants, (attachment, view Y, from 49 CFR) or the relationship of the terminals to the constants.

Hyundai is requesting an interpretation for a future production vehicle and needs a prompt answer. Thank you for your assistance in this matter. Should further clarification be required, feel free to contact me at the telephone number listed above.

Attachment 1

S571.108 49 CFR Ch. V (10-1-89) Interchangeability Drawing Headlamp Bulb Assembly (Text and graphics omitted)

ID: nht91-3.2

DATE: March 28, 1991

FROM: Takeo Wakamatsu -- Executive Vice President, General Manager, Mitsubishi Motors America, Inc.

TO: Scott Shadle -- Supervisor, Vehicle Certification, NHTSA

TITLE: Re Derating of Trucks

ATTACHMT: Attached to letter dated 4-29-91 from Paul Jackson Rice to Takeo Wakamatsu (A37; Part 567)

TEXT:

Mitsubishi Fuso Truck of America, Inc. (MFTA), is the importer and distributor of trucks as incomplete vehicles manufactured by Mitsubishi Motors Corporation (MMC) in Japan. MMC Japan has asked Mitsubishi Motors America, Inc. (MMA), the liaison between MFTA and MMC Japan, to make the following request on their behalf.

MMC is considering derating the GVW of the trucks imported for the purpose of marketing strategy.

In this case, the brake system will not be modified and the vehicle should be in compliance with FMVSS 105 requirements. MMC would supply the new VIN plates with the derated GVW and have MFTA replace the old ones with the new ones.

We expect this kind of modification is such an implementation that has to meet with official approval. At this time, we are asking you for your approval of this modification.

If there are any additional questions you have regarding the above, please do not hesitate to contact me at (609)467-4664.

Your anticipated cooperation in this matter is greatly appreciated.