ID: 77-3.25

TYPE: INTERPRETATION-NHTSA

DATE: 07/13/77

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

TO: AM General Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 10, 1977, petitioning for temporary exemption, on behalf of an electric truck, from Federal Motor Vehicle Safety Standards Nos. 102 and 301.

Your petition is inadequate for consideration at this time. A manufacturer may apply for temporary exemption upon only one basis, while AM General's petition is an attempt to apply both on grounds of hardship (49 CFR 555.6(a)) and of low-emissions vehicle development (555.6(c)). On either basis the petition lacks the full complement of information required by Part 555.

In view of the fact that AM General has previously received an exemption (NHTSA Exemption No. 74-4) under 555.6(c) I suggest that you reapply on that basis, using the company's previous petition as a guide. Your present petition is inadequate under 555.6(c) because it does not provide "reasons why the failure to meet the standard does not unreasonably degrade the safety of the vehicle" (555.6(c) (2) (iv)). It also does not supply the results of tests conducted on conforming vehicles to substantiate certification to Standards Nos. 102 and 301-75 (555.6(c) (2) (ii)); you have morely stated that AM General manufactures vehicles that meet these standards.

Under our general requirements for petitions, AM General must also provide its views why the granting of the petition would be in the public interest and consistent with the objectives of the National Traffic and Motor Vehicle Safety Act (555.5(b) (7)).

We shall be pleased to consider your petition further when you have furnished the information requested.

ID: 1984-2.16

TYPE: INTERPRETATION-NHTSA

DATE: 07/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Automobile Importers of America

TITLE: FMVSS INTERPRETATION

TEXT:

Bruce Henderson Automobile Importer of America 1735 Jefferson Davis Highway Suite 1002 Arlington, VA 22202

Dear Mr. Henderson:

This is to follow-up on your phone conversation with Stephen Oesch of my staff concerning Safety Standard No. 201, Occupant protection in interior impact. Your specific question was whether a fuse box cover must comply with the requirements of section 3.3 of the standard. As explained below, a fuse box cover does not have to comply with section 3.3.

Section 3.3 of the standard provides that each "interior compartment door" in certain vehicle locations must remain closed when subjected to the specified performance tests. Section 571.3 defines an interior compartment door as "any door in the interior of the vehicle installed by the manufacturer as a cover for storage space normally used for personal effects." The definition is meant to include such storage areas as the "glovebox" which has a large door which could fly open in a crash, and not a portion of the vehicle's electrical system such as a fuse box, which is not used as storage space.

Although not covered by the standard, we would urge a manufacturer carefully to design the fuse box in such a way as to prevent injuries if it is located in an area which could be struck by an occupant in a crash.

If you have further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

ID: 1983-3.6

TYPE: INTERPRETATION-NHTSA

DATE: 09/15/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Potemkin

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30 Mr. Al Desarro Potemkin 21111 South Dixie Highway Miami, Florida 33189

Dear Mr. Desarro:

This is to follow up on your phone conversation with Stephen Oesch of my staff concerning the type of seat belts that must be used in a 1983 converted van that has a sofa.

Paragraph S4.2.2 of Safety Standard No. 208, Occupant Crash Protection, (copy enclosed) requires trucks and multipurpose passenger vehicles with a gross vehicle weight rating of 10,000 pounds or less to meet the same requirements as passenger cars. This would include the vans in question. Paragraph S4.1.2.3 of the standard specifies that passenger cars must be equipped with a Type 2 seat belt assembly (non-detachable lap and shoulder belt) at each front outboard designated seating position. At all other seating positions, either a Type 1 seat belt assembly (lap belt only) or a Type 2 seat belt assembly must be used. Thus, your vans must have Type 2 belts in the two front seats and either Type 2 or Type 1 belts in the rear seating positions, including the sofa. The agency's position regarding seat belts for sofa/beds used in van conversions is more fully explained in the enclosed interpretation letter of March 29, 1983, to Sherrod Vans, Inc.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

ID: nht80-1.8

DATE: 01/31/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Doug Smith

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your December 6, 1979, letter asking questions about Standard No. 211, Wheel Nuts, Wheel Discs, and Hub Caps. In particular, you ask whether winged projections are permitted in a rim as long as they do not extend beyond the lip of a rim or the sidewall of a tire.

When the standard was issued, the agency concluded that winged projections could catch the clothing of children or pedestrians thereby posing a safety hazard. As a result, the standard prohibits the use of all winged projections regardless of the extent to which they extend from a rim. The standard, however, only prohibits winged projections and does not affect other projections from a rim.

SINCERELY,

December 6, 1979

Roger Tilton Office of Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Tilton:

After talking with you this after noon I'm writing for your ruling on wing projections covered in Motor Vehicle Safety Standard no. 211-S3.

I am of the opinion that if the knock off (winged projection) does not extends beyond the lip of the rim or the sidewall face of the tire mounted on the rim, it will be all right with the knock off in the center.

As I understand the ruling, it is designed to eliminate catching people or objects and dragging them into the wheel. By not extending beyond the lip of the rim or sidewall face the knock off would be safe.

Please return you ruling to me as soon as possible.

Doug Smith

Attachment Omitted.

ID: nht80-2.4

DATE: 04/17/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Sholz Oldsmobile, John Galotti

TITLE: FMVSS INTERPRETATION

ATTACHMT: 8/17/79 letter from Frank Berndt to Mike Champagne

TEXT:

Mr. John B. Galotti Service Manager Sholz Oldsmobile 35 West Post Road White Plains, New York 10606

Dear Mr. Galotti:

This responds to your recent letter requesting information concerning the legal requirements applicable to the installation of fuel separators and auxiliary fuel tanks in motor vehicles. I am enclosing a copy of a letter the agency issued last year which discusses the Federal requirements and implications that would be involved with such activities. That discussion should answer all of your questions. If, however, you require further information, please contact Hugh Oates of my office at 202-426-2992.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

[8/17/79 letter from Frank Berndt to Mike Champagne omitted here.]

March 10, 1980

NHTSA Office of Chief Counsel NOA 30

Re; Installation of Diesel engine fuel and dirt separators and auxiliary Diesel fuel tanks in trunks of passenger cars.

Dear Sir;

We have received many requests and inquires from car owners concerning the installation of Fuel separators and Auxiliary fuel tanks in their vehicles.

Before we oblige them we would like to know officially what difficulties and liabilities we might run into as far as Federal Laws are concerned.

Any assistance you may give us pertaining to this matter will be greatly appreciated.

Thank you.

Sincerely,

John B. Galotti Service Manager

ID: nht73-5.49

DATE: 04/02/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. Ralph L. Finley

COPYEE: WYSZPOLSKI

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 8, 1973, in which you request information regarding safety standards or restrictions pertaining to rumble seat installation. The installation you have made and contemplate merchandising falls into the aftermarket category.

Aftermarket seat assemblies installed in vehicles, after the sale of such vehicles is consummated, are not required to comply with Federal Motor Vehicle Safety Standard No. 207, Seating Systems. However, it is reasonable to expect that those who manufacture, sell, and install aftermarket seats will make them at least as strong as required by the standard, and will install seat belt systems to help prevent ejection and other injuries.

I am enclosing a copy of our Summary Description of Standards and Federal Motor Vehicle Safety Standard No. 207 for your information and retention. I appreciate your interest in motor vehicle safety.

2 ENCLS.

March 8, 1973

National Highway Traffic Safety Administration

Attention: Motor Vehicle Programs

Gentlemen:

I have a 1957 Thunderbird with a rumble seat in it. I am thinking of reproducing this rumble seat and merchandising it to T-Bird members in the United States. I have enclosed a picture for your review.

Are there any safety standards or vehicle restrictions that I would have to comply with? Please let me know.

Sincerely,

Ralph L. Finley 12476 Dover Court Saratoga, California 95070

enc:

(Graphics omitted)

ID: nht73-6.6

DATE: 04/13/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. Thomas B. Mitchell

TITLE: FMVSS INTERPRETATION

TEXT: (Illegible Text)

DIRECTOR DIVISION OF MOTOR CARRIER SAFETY DEPARTMENT OF TRANSPORTATION 400 SEVENTH STREET, S.W. WASHINGTON, D.C. 20590

2 (Illegible Text)

MRCH 27, 1973

The Officer in Charge, Federal Highway Administration,

Dear Sir,

I have been advised by the American Embassy in New Zealand to write to you so that(Illegible Word) may be furnished with certain information concerning the American Federal Motor Vehicle Safety Standards which I believe have been in force in your Country since 1968 to which Motor Vehicle Manufacturers must conform in respect to vehicles for sale or use in the United States.

Whilst I am very much interested in all the Safety Standards and Regulations which are in force in your Country the one which I am most interested in at the moment is the one which I believe specifies certain requirements for the safety of Fuel Tanks etc..

I particularly wish to know if the relevant Safety Standard in force in American requires the fuel tanks to be located outside the main body shell of the vehicles or if it is permissible under this Safety Standard for fuel tanks to be situated in the interior of the vehicles.

Trusting that the amount enclosed will be sufficient to cover the costs of postage etc and thanking you in anticipation.

Yours faithfully,

T. B. MITCHELL 707 EAST QUEEN ST. HASTINGS, NEW ZEALAND

ID: nht74-1.32

DATE: 05/16/74

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

TO: Lt. Commander Robert H. Weldman, Jr.

COPYEE: LARSON; RANADER

TITLE: FMVSS INTERPRETATION

TEXT: This response to your letter of April 17, 1974, to the Department of Transportation requesting information on standards for (Illegible Word) Lighting systems. We have me record of your (Illegible Words)

In answer to your specific questions --

1. "Are there any federal or state regulations which specify sealed beam headlamps?"

Yes, this requirement has been effective either by Federal or State standards for more than three decades.

2. "Are both acceptable?"

A replacable bulb type headlamp is not acceptable.

3. "Is amber a permissible headlight (Illegible Word)

No, headlight must white light.

4. "Is white mandatory for backup lights?"

Yes, white is mandatory.

Sincerely,

ATTACH.

APRIL 17, 1974

U.S. Department of Transportation,

Attn: Federal Standards for Automobiles.

Dear Sirs,

I wrote you on 12 February 1974 to ask for information on Federal and state standards for automobile lighting systems. I have received no reply, so herewith a repeat of my request: are there any federal or state regulations which specify sealed beam headlamps, or are bulbs acceptable? Is amber a permissible headlight color? Is white mandatory for backup lights?

I will appreciate any information you can give me.

Sincerely,

Robert H. Weidman, Jr. -- LCDR USN,

Box 33 B753, FPO NEW YORK 09540

ID: nht74-2.16

DATE: 11/14/74

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

TO: Hall and Myers

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your October 23, 1974, question whether the language of S5.3.1(b) and S5.3.2(b) in Standard No. 121, Air brake systems, exempts all liftable, nonsteerable axles from the "no lockup" requirements of the standard. You specifically ask whether a liftable, nonsteerable "tag" axle and "pusher" axle would be exempt if they were both mounted on a vehicle equipped with a single nonliftable, nonsteerable axle or with tandem nonliftable, nonsteerable axles.

The sections in question permit "lockup of wheels on nonsteerable axles other than the two rearmost nonliftable, nonsteerable axles on a vehicle with more than two nonsteerable axles." This language is limited to vehicles which have more than two nonsteerable axles and therefore a liftable axle on a vehicle with only one other nonsteerable axle would not be exempt. Such combination can be found on some intercity buses.

In both of the examples you described the vehicle has more than two nonsteerable axles, and therefore the language of S5.3.1(b) and S5.3.2(b) would exempt the tag and pusher axles from the "no lockup" requirements of the standard. I would like to emphasize, however, that our language is intended to require "no lockup" performance on not less than two nonsteerable axles of any vehicle with at least two nonsteerable axles. We did not contemplate the unlikely configuration of a single fixed axle and two liftable axles which you cite as an example. If a safety problem arises with this configuration, we would consider an amendment of the standard to require "no lockup" performance of two of these axles.

Yours truly,

ATTACH.

ID: nht80-1.36

DATE: 03/18/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: American Mfg. & Equipment Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Pursuant to the request in your February 13, 1980, letter to this office, I am enclosing an up-to-date copy of Federal Motor Vehicle Safety Standard No. 117 (49 CFR @ 571.117).

You asked about the agency's "current position with respect to Standard No. 117 as to (1) passenger tires and (2) truck tires." The requirements of this standard apply to all retreaded pneumatic passenger car tires sold in the United States. As of this date, however, neither Standard No. 117 nor any other standard applies to retreaded truck tires.

If you have any further questions regarding the requirements of the enclosed standard or any other regulations of this agency, please contact Steve Kratzke of my office (202-426-2992).

SINCERELY,

AMERICAN MFG.

& EQUIPMENT INC.

February 13, 1980

Lawrence R. Schneider Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Admin.

RE: Standard No. 117 (S5.2) MV22117 Federal Retread Standard

Dear Mr. Schneider:

May I inquire as to the Department's current position with respect to the referenced standard as to (1) passenger tires and (2) truck tires.

Would you be kind enough to provide us with a copy of Federal Retread Standards also.

Thanking you in advance for any assistance you can provide.

AMERICAN MFG. & EQUIPMENT INC.

Albert P. Penter President