ID: nht81-2.25

DATE: 05/12/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Gregory Equipment & Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 13, 1981, with respect to placement of identification lamps on the boat trailer you wish to manufacture.

You have informed us that the trailers are not built for transporting boats on the highways and your sales sheet reiterates that point: "These trailers are for in marina use only. Not for over the road use." Under the National Traffic and Motor Vehicle Safety Act, a vehicle that is not manufactured primarily for use on the public roads is not a vehicle subject to our regulations. From your letter and advertising enclosure, it appears that your intent is to build a vehicle that will be used primarily on private property. Therefore, our lighting requirements would not apply to it.

I hope that this answers your question.

SINCERELY,

Gregory Equipment & Manufacturing Co.

April 13, 1981

Chief Consul National Hwy. Traffic Safety Administration

Dear Sir;

I would like a ruling on the 3 cluster light for the rear of trailers. The boat trailer we are starting to manufacture doesn't have a place which such light may be mounted as shown in Picture #1. If lights were placed on the rear they would be jammed into the mud in the bottom of the river as shown in picture #2.

These lights are for the movement of the empty trailers from the plant to the sales designation. These are not built for transporting boats on the highways.

Inclosed is a brouchure. The trailer in this brochure is not equiped with lights because it is our prototype.

If any further information is needed please call me at 319-372-5314.

James E. Gregory

ID: nht74-1.17

DATE: 07/15/74

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

TO: National Campers & Hikers Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 27, 1974, objecting to the use of extension mirrors on automobiles when a trailer is not in tow.

Although we fully appreciate the possible dangers inherent in the use of extension mirrors, this agency has no authority to regulate the use of such equipment. The authority that Congress has conferred upon the National Highway Traffic Safety Administration relates to the safe manufacture of motor vehicles and motor vehicle equipment, and not directly to its use. Therefore, unless some showing can be made that the design of the mirrors is dangerous, we have no authority to deal with the problem you describe.

Your truly,

ATTACH.

June 27, 1974

Lawrence R., Schneider, Chief Counsel -- U.S. Department of Transportation, National Highway Traffic Safety Administration

Dear Mr. Schneider:

As a frequent camper in Michigan's out-of-doors, I am concerned that there are far too many pedestrians being injured and sometimes killed, by the uncontrolled use of extension mirrors on automobiles used for towing travel trailers.

The offending mirrors are the ones which are clamped on the front fenders or doors of automobiles and are easily detached. They extend out to approximately 8 Ft. and are chest high for all adults and head high for children.

These mirrors are not to be confused with permanent standard equipment on trucks and automobiles.

I believe that legislation should be passed that would outlaw extension mirrors on automobiles when a trailer is not being towed.

Sincerely

Lee & Winnie Jones -- District Directors, National Campers & Hikers Assoc.

ID: nht74-1.37

DATE: 06/20/74

FROM: AUTHOR UNAVAILABLE; Lawerence R. Schneider; NHTSA

TO: Western Scooter Distributor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 14, 1974, advising that the State of Virginia refuses to register the Ciao Moped "because there is no high beam."

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, through its incorporation of SAE Standard J584, Motorcycle and Motor Driven Cycle Headlamps, allows motorcycles of 5 horsepower or less to be equipped with either one single beam or one multiple beam headlamp. Section 103(d) of the National Traffic and Motor Vehicle Safety Act of 1966 prohibits a State from having requirements that differ from Federal ones where the same aspect of vehicle performance is concerned. Therefore, a State law or regulation under which a motor driven cycle is barred solely because it is equipped with a single beam headlamp would be preempted and void, by Federal law.

Sincerely,

ATTACH.

June 14, 1974

Chief Counsel -- National Highway Traffic Safety Administration

Dear Sir:

Our firm imports Piaggio motor vehicle products for distribution through the United States. We are currently importing the Vespa Motorscooters and the Ciao Mopeds.

We have recently encountered problems on registration in the State of Virginia concerning the Ciao Moped. The only area in question concerns the headlight. The State of Virginia has refused to register these vehicles because there is no high beam.

It is our interpretation of Standard 108 that "motor driven cycles" do not require a high beam on their headlights.

We request clarification on this matter.

Very truly yours,

R. H. Remensperger -- President, WESTERN SCOOTER DISTRIBUTORS

ID: nht74-1.38

DATE: 01/03/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck-Lite Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 20, 1973, concerning the placement of rear identification lamps on the header of Fruehauf trailers.

I enclose a copy of a recent exchange of correspondence between Fruehauf and this agency on this question which I believe is in point. It is our view that if a lamp is available which may be installed in a narrow header area, the upper location is "practicable" even though the lamps may not be the one specified by the vehicle's purchaser.

Yours truly,

ATTACH.

December 20, 1973

Larry Schneider -- Chief Counsel, National Highway Traffic Safety Administration

Subject: Placement of Rear Identification Lights

Dear Mr. Schneider:

We have a customer at the present time who finds it impractical to mount the three rear red identification light at the high level.

Due to the special high door construction on the dry van, the upper door header does not lend itself to the installation of the standard lights that are now used on his equipment.

These trailers are being manufactured by Fruehauf Corporation, and the present quantity is 400 trailers.

In consideration of the large number of containers that are now on the highways with no upper lights and the hardship involved in endeavoring to place improvised lights at this level, we are requesting an opinion from your office as a guide for our future action.

Thank you very much for your consideration.

Yours very truly,

TRUCK-LITE COMPANY; H. A. Sage, Director -- Research Development

Enclosure

CC: R. V. Tarr; J. J. Vicario

ID: nht74-2.10

DATE: 11/07/74

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

TO: Columbia Body & Equipment Co.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to CBE's October 24, 1974, question whether a trailer equipped with a telescoping drawbar that varies the distance between axles to conform to various State regulations would qualify as a "Heavy hauler trailer" as that term is defined in Standard No. 121, Air brake systems:

"Heavy hauler trailer" means a trailer with one or more of the following characteristics:

(1) Its brake lines are designed to adapt to separation or extension of the vehicle frame; or

(2) Its body consists only of a platform whose primary cargo-carrying surface is not more than 40 inches above the ground in an unloaded condition, except that it may include sides that are designed to be easily removable and a permanent "front-end structure" as that term is used in @ 393.106 of this title.

The answer to your question is no. The extension of the drawbar is not an "extension of the vehicle frame." This characteristic is intended only to describe trailers whose function necessitates a highly specialized configuration that significantly interferes with brake design. In contrast, the telescoping drawbar is not related to the trailer's function, but simply permits the vehicle to conform to State highway regulations.

Yours truly,

ATTACH.

October 24, 1974

Acting Chief Consel -- U.S. Dept. of Transportation

Attn: Richard Dyson

Dear Mr. Dyson;

Does the Pony Trailor on our drawing number T65-497 (enclosed) qualify as a heavy hauler trailer and exempt from the S121 or any other antiskid requirement until Sept. 1, 1976 as Mr. Tadd Herllhy defined in our phone conversation Oct. 23, 1974. Please reply as soon as possible.

Sincerely yours,

COLUMBIA BODY & EQUIPMENT COMPANY

John C. Hansen -- Sales Manager

ID: nht80-1.35

DATE: 03/18/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bertolini Engineering Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 22, 1980, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

You have referenced our letter of May 5, 1977, to Mr. Dennis Moore of Dry Launch. That letter interpreted S4.3.1.1.1 with respect to a rear clearance lamp which indicated overall width though it was not located on the rear of the trailer. In that position it was not required to be visible at 45 degrees inboard. You have asked whether the same inboard visibility requirements may be eliminated for front clearance lamps "for the same reasons".

The answer is yes. If a front clearance lamp that indicates overall width is not located at the front of the trailer, S4.3.1.1.1 relieves it of the requirement that it be visible at 45 degrees inboard.

I hope this answers your question.

SINCERELY,

BERTOLINI ENGINEERING CO., INC.

February 22, 1980

Frank Berndt Acting Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration

Dear Mr. Berndt:

I am in receipt of a letter written to you on April 7, 1977 concerning the elimination of the requirement for inboard visibility of a rear clearance lamp for a truck trailer, and your reply of May 5, 1977 advising that the inboard visibility is not required.

My question is as follows: Can the same inboard visibility requirement for the front clearance light of a truck trailer be eliminated for the same reasons as cited in your letter of May 5, applying the diagram shown in the April 7, 1977 letter, with the exception that the diagram applies to the front of a trailer instead of the rear.

William A. Bertolini President

ID: nht78-3.23

DATE: 02/14/78

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

TO: Collins Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 15, 1977, letter asking several questions concerning Standard No. 217, Bus Window Retention and Release.

In your first question, you paraphrase the requirements of S5.3.3 concerning emergency exit force requirements and release motion and ask whether your understanding of the section is correct. Your interpretations of the standard's requirements are accurate.

Second, you enclosed photographs of a manufacturer's rear emergency door release mechanism and asked whether it complies with the standard's requirements. The force release mechanism shown in the pictures does not comply with the requirements of Standard No. 217. The release mechanism is not located in the high force access region as required by the standard, and the motion required for release of the exit is not upward as required by paragraph S5.3.3

Finally, you asked whether your enclosed copy of Standard No. 217 which includes paragraph S5.2.3.1 is up-to-date. The answer to your question is yes. You have been confused by paragraph S5.2.3.1 because it states that a bus must have, at a minimum, one rear emergency door or a side emergency door and a rear push-out window. The requirement for one rear emergency door does not preclude a schoolbus with a 10,000 pound GVWR or less from using two (double) rear emergency doors. Paragraph S5.4.2.2 states ". . . the opening of the rear emergency door or doors shall be . . ." (Emphasis added). The use of the term "doors" in paragraph S5.4.2.2 indicates that double doors are permitted.

ID: nht78-3.24

DATE: 09/22/78

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

TO: Thomas Built Buses, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 21, 1978, letter asking whether you are permitted under Standard No. 217, to place the emergency exit sign at the bottom of a rear emergency window exit.

The National Highway Traffic Safety Administration has permitted the use of the emergency exit sign to be on the top half of rear emergency doors. This has permitted the sign to be located just below the glass on the rear emergency door. Although your location of the exit sign is not on top of the rear emergency window exit, its location is similar to the location of the exit sign on a rear emergency door. Since the location of the sign is on the emergency window exit and is within the top half of the bus, the agency has determined that this location complies with the requirements.

SINCERELY,

Thomas BUILT BUSES, INC.

August 21, 1978

Office of the Chief U. S. Department of Transportation

Attn: Roger Tilton

Subject: MVSS - 217. Section S5.5.3 - School Bus

Reference is made to our conversation relative to the above.

In that conversation, we discussed the location of the sign "Emergency Exit".

We are enclosing a photo of what we were describing the location of the sign. According to the writer, the location as depicted in the photo is permissable. As we pointed out, this location, in our opinion more closely covers the intent of the section.

On this point, we understand you concurred. We would appreciate confirmation of this concurrance for the record.

James Tydings, Specifications Engineer

(Graphics omitted)

ID: nht78-4.25

DATE: 03/14/78

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

TO: Vespa of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Donald Beyer National Service Manager Vespa of America Corporation 322 East Grand Avenue South San Francisco, California 94080

Dear Mr. Beyer:

This is in reply to your letter of October 24, 1977, requesting an interpretation whether motorcycles with turn signals are required to have turn signal indicators. You noted that Table 2 of Standard No. 123 does not include a turn signal indicator as a motorcycle display, while there appear to be conflicts within Standard No. 108, S4.5.6 requires an indicator but SAE Standard J588c (incorporated by reference in Standard No. 108) requires an indicator only if turn signal lamps are not readily visible to the driver.

Although S4.5.6 does require each vehicle equipped with a turn signal operating unit to have an illuminated pilot indicator, in my view a manufacturer who eliminated them in reliance upon J588c would not fail to comply with the standard if all signal lamps are readily visible to the driver.

However, we interpret "readily visible to the driver" to mean visible to the driver when facing forward in the driving position. Motorcycles are required to have separate turn signal lamps at or near the front, and at or near the rear of the vehicle. If the driver must turn his head to the rear to check the operation of his rear turn signal lamps, then those lamps are not "readily visible to the driver" and a turn signal indicator must be provided. While Standard No. 123 itself in Table 3 does specify requirements for identification of turn signal "control and display identification", it does not provide requirements for illumination ana operation of the display in Table 2, as you noted.

Sincerely, Joseph J. Levin, Jr. Chief Counsel

ID: nht88-1.62

TYPE: INTERPRETATION-NHTSA

DATE: 03/01/88

FROM: DAVE TAYLOR -- REGIONAL MANAGER/FIELD ENGINEERING BRIDGESTONE

TO: JOHN FORTH -- STANISLAUS COUNTY D.A. OFFICE MODESTO, CA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12/09/88 FROM ERIKA Z. JONES -- NHTSA TO DONALD N. STAHL RE MCCOY TIRE SERVICE CENTER D.A. NO CF696 REDBOOK A33, STANDARD 119, PART 574; UNDATED LETTER FROM JOHN T. FORTH AND DONALD N. STAHL TO ERIKA Z. JONES NHTSA RE M CCOY TIRE SERVICE CENTER D.A. NO CF696, OCC 1749; LETTER DATED 07/13/87 FROM ERIKA Z. JONES -- NHTSA TO JACK DENIJS EXHIBIT 2; LETTER DATED 05/19/87 FROM JACK DENIJS TO ERIKA Z. JONES, SUBJECT COVERED DOT NUMBERS ON REMANUFACTURED TRUCK CASINGS; DRAWING OF TIRE DATED 01/14/88, MODESTO CITY SCHOOLS TIRE INFORMATION, EXHIBIT 3

TEXT: Dear Mr. Forth,

Attached is the N.H.T.S.A. letter which I referred to.

The 'E12R22.5 V-Steel Express' is not sold in N. America, however we have confirmed that this tire was specifically designed for rubber tired subway trains in Japan and therefor is not suitable by any means for highway use.

We appreciate the diligence of your office and those people involved in discovering them and removing them from the school bus.

We would definitely like to know the source or importer of these casings, or any other information which would assist us in taking the necessary steps to prevent these casings from being sold & used in N. America.

For your information we do not consider these used tires to be 'grey market' tires. All new truck tires imported to the U.S. must meet the requirements of FMVSS 119 and therefor have D.O.T. markings molded into one sidewall of the tire.

Sincerely yours,