ID: nht92-2.10

DATE: November 23, 1992

FROM: T. Kouchi -- Director & General Manager, Automotive Equipment, Development & Administration Department, Stanley Electric Co., Ltd.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 12/30/92 from Paul J. Rice to T. Kouchi (A40; Std. 108)

TEXT:

We are investigating the development of automotive tail & stop lamps using light emitting diodes (LEDs) as light sources.

We have already asked you about Center High-Mounted Stop Lamp (CHMSL) using LEDs and have received your letter of January 9, 1986, in which you answered that such type of CHMSL would be acceptable when it complies with the photometric requirements and provides replaceability of light sources (S4.1.41(e)) specified in FMVSS No. 108.

From your answer, we consider that LEDs can be used in tail & stop lamps.

Now we would like to ask you additional questions as follows:

(1) Is it possible for us to group LED tail & stop lamps into three categories in terms of the number of lighted sections to determine applicable photometric requirements, as specified in paragraph 4.1.5.1 of SAE J1389 JUN83?

(2) Where the above view is acceptable, could we consider the number of lighted section as "one" in case of a lamp which contains three LED arrays arranged as shown in the attached drawing, if the circumferenc of three projected luminous areas does not exceed 150mm both in horizontal and vertical dimensions?

(3) Where the number of lighted section is determined as "one" in the above, can we locate "the geometric center of the illuminated area" at the point marked in the attached drawing, according to paragraph 2.6 of SAE J1389 JUN83?

We would be very pleased if you kindly inform us of your points of view for the above(1)-(3).

(Drawing omitted.)

ID: nht89-2.9

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/89

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: H. HASEGAWA -- AUTOMOTIVE LIGHTING ENGINEERING CONTROL SECTION STANLEY ELECTRIC CO. LTD.

TITLE: NONE

ATTACHMT: LETTER DATED 05/22/89 FROM H. HASEGAWA TO RICHARD L. VANIDERSTINE, RE REVISION OF FMVSS NO 108 [DOCKET NO 85-15 NOTICE 8

TEXT: Dear Mr. Hasegawa:

This is in reply to your FAX letter of May 22, 1989, to Richard Van Iderstine of this agency.

You have two questions with respect to the amendment to Standard No. 108 published on May 9, 1989 (Docket No. 85-15; Notice 8).

Your first question is the effective date of paragraph S7.7.5.1.(a), which you point out was not previously a requirement of Standard No. 108. You suggest the need for a delayed effective date (but give no reason why one may be needed).

Paragraph S7.7.5.1(a) will be effective June 8, 1989. Although the requirement is a new one (the restriction on motion of a headlamp when an external aiming device is applied to it), it was proposed as part of the December 29, 1987 NPRM, and no comments received indicated a need for a delayed effective date. Your supposition is correct; S7.5.5.1 will apply to all headlamps with an external aiming system, including those incorporating replaceable bulbs.

Your second question relates to paragraph S7.7.5.1(b), and you ask "whether the requirement of '0.1 in. max.' will be determined, either during the test or after the test". In pertinent part, subsection (b) states "nor shall the lamp recede more than 0. 1 in. (2.5 mm) after being subjected to an inward force...." This means that the measurement is determined after the test.

Sincerely,

ID: nht89-3.45

TYPE: INTERPRETATION-NHTSA

DATE: 11/27/89

FROM: SCOTT K. HILLER -- CE WHITE COMPANY

TO: NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 01/12/90 FROM STEPHEN P. WOOD -- NHTSA TO SCOTT K. HILLER -- CE WHITE COMPANY; REDBOOK A35; STANDARD 210

TEXT: Dear N.H.T.S.A.:

I request a written, legal interpretation of the Federal Motor Vehicle Safety Standard No. 210 with regard to test procedures involving multi-passenger, passenger seats for school buses under 10,000 GVWR.

The situation is as follows:

1. The seat belts are mounted to the frame itself via a 1 1/4" angle bar running the width of the seat. (See photographs)

2. Each seating position has an individual set of seat belt mounting holes punched into the angle iron bar. (See photographs)

My question is does each seating position, when tested per @ 5.1 of FMVSS 210, have to be pulled simultaneously or should they be pulled individually?

I will be looking forward to your letter. Thank you for your help in this matter.

Sincerely,

ENCLOSURES

(Photo Omitted)

Two passenger school bus passenger seat frame with seat belts attached. Front View.

(Photo Omitted)

Back view of a two passenger school bus seat with frame attached seat belts.

(Photo Omitted)

Top view of a 2 passenger school bus seat with seat belt bar mounted on seat frame for frame mounted seat belts. Note two separate sets of holes.

(Photo Omitted) Front view of a two passenger school bus seat with seat belts attached to seat frame.

(Photo Omitted)

Top forward view of a two passenger school bus seat frame which illustrates the seat belt attachment bar as frame mounted.

ID: nht92-8.32

DATE: March 5, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: James G. White -- Head, Crash Avoidance Standards (ASFBE), Road Safety and Motor Vehicle Regulation, Transport Canada

TITLE: None

ATTACHMT: Attached to letter dated 1/29/92 from J. Yoshimoto to James G. White

TEXT:

This responds to your FAX of February 18, 1992, to Richard van Iderstine of this agency, who has asked this office to respond to your question 1.a.

That question is: "Is Koito correct in stating that FMVSS 108 does not require the 'O' point on IHAD (sic) indicators to be marked by the numeral 'O"'? In the letter from Koito that you furnished, Koito had remarked that the requirement in S7.7.5.2(a) (1) and (2) of Standard No. 108 "to have a zero mark" did "not necessarily mean a mark of figure 'O', but may be just a reference mark."

Koito is incorrect. S7.7.5.2 On-vehicle aiming specifies requirements for Vehicle Headlamp Aiming Devices (VHADs). VHADs provide for headlamp aim inspection in both the vertical and horizontal axes. S7.7.5.2(a)(2) Horizontal aim states that "An 'O' mark shall be used to indicate alignment of the headlamps relative to the longitudinal axis of the vehicle." This clearly establishes the requirement for use of the figure "O" as the mark, and not use of a reference mark. You will note that S7.7.5.2(b) references setting the VHAD "at 'O' vertical and 'O' horizontal." This means at the "O" mark.

Both S7.7.5.2(a)(1) Vertical aim and (a)(2) reference the necessity to provide "an equal number of graduations from the 'O' position representing angular changes in the axis." These graduations are not required to be marked. The presence of the "O" mark will assist the person aiming the headlamp to ensure that the VHAD is set at the junction of the horizontal and vertical axes, rather than at one of adjacent, unmarked graduations.

ID: nht92-8.4

DATE: April 3, 1992

FROM: Frank J. Sonzala -- Senior Vice President, International Transquip Industries, Inc.

TO: Phil Gramm -- United States Senate

COPYEE: J.F. Haasbeek -- President; Gerald Flowers -- Past President

TITLE: None

ATTACHMT: Attached to letter dated 5/20/92 from Frederick H. Grubbe to Phil Gramm (A39; Std. 121); Also attached to letter dated 6/1/92 from Paul J. Rice to Frank J. Sonzala (A39; Std. 121); Also attached to letter dated 4/3/92 from Frank J. Sonzala to Paul J. Rice (OCC 7172)

TEXT:

In May of 1990 our company's former President, Gerald Flowers, asked you to intercede with NHTSA's rule-making powers as it related to our product, and our Texas-based company's future existence. Your help in this matter, I am sure, certainly influenced NHTSA to rule favorably concerning our product and its advanced technology for the transportation industry.

Once again we appeal for your assistance with the NHTSA. The attached letter was sent to Paul Jackson Rice requesting an interpretation of a test procedure mandated by FMVSS 121 regulation. Because of the ambiguity of the test procedure parmeters, our company's growth has been stifled. Our request of your office is to call upon the Chief Counsel for NHTSA and express your concern that this matter be tended to promptly and positively.

I have enclosed a copy of our company's video for your review. I realize you are very busy with government affairs, but you may be interested in knowing how a Texas-based company is leading the transportation industry in air brake technology. A positive response from NHTSA will go a long way in aiding our company to grow, add more jobs and ultimately improve the safety of the air brake equipped heavy truck, trailer and bus industry in the United States.

We thank you for your effective pursuit of this matter on our behalf.

ID: nht93-5.6

TYPE: Interpretation-NHTSA

DATE: July 2, 1993

FROM: Dave Beidleman -- Arizona Department of Transportation, Equipment Services

TO: Taylor Vinson -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 7/29/93 from John Womack to Dave Beidleman (A41; Std. 108)

TEXT:

ADOT is in the process of having ten (10) dump trucks built for use within the Highways Division. We have encountered a problem with the placement of the rear identification lamps which, we hope, you can help solve. When the dump body on these units is raised, the rear cross sill comes in contact with the pintle hitch. The pintle hitch must remain positioned as is to properly mate with trailers in the fleet. The contractor has pre-punched holes for the identification lights in the rear cross sill of the dump body. We want to raise the center light of the 3-light identification light group by approximately 1-1/2 inches, and include a cut-out in the rear cross sill to provide necessary clearance at the pintle hitch when the dump body is raised. The outer lights of the 3-light identification light group cannot he raised due to the positioning of underbody tailgate release mechanism.

CFR 49 - 571.108(S5.3.1.1) states "...if motor vehicle equipment (e.g., mirrors, now plows, wrecker booms, hackhoes, and winches) prevents compliance with this paragraph by any required lamp or reflective devices, an auxiliary lamp or device meeting the requirements of this paragraph shall be provided." Can we proceed with this modification on this basis, without violating the requirements for identification lights established in FMVSS 108? (See attached drawing)

Drawing omitted. (Shows dump body - rear elect.)

ID: nht94-3.74

TYPE: INTERPRETATION-NHTSA

DATE: July 19, 1994

FROM: P. Binder -- ITT Automotive Europe GmbH

TO: John Womack -- Office of Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: Attached to letter dated 8/2/94 from John Womack to P. Binder (Std. 108)

TEXT: Dear Mr. Womack,

Thank you for your reply of June 21, 1994.

To my regret I was forced to realize that I had made a mistake. My fax of April 28, 1994 should be referred to tail lamps.

Lighting System:

[ILLUSTRATION OMITTED - SEE ORIGINAL SOURCE]

1. With regard to the tail lamps I interpret FMVSS 108 and SAE J 585e, Sept. 77 as follows:

- This Lighting System is a multiple lamp arrangement, therefore the combination of taillamp 1 and taillamp 2 has to be used to meet the photometric requirements for 2 lighted sections (SAE J 585e; 3.1 and Table 1).

2

- Visibility will be judged with tailgate closed. Only taillamp 2 mounted on the tailgate will meet the requirements for an unobstructed projected illuminated area of 12,5 cm' measured at 45 deg inboard. This is in accordance with SAE J 585e; Par. 4.

Is my interpretation o.k.?

2. Some general questions:

- Are there regulations, which lamps has to be mounted on the body and which lamps are allowed on the tailgate?

Is there a regulation to take an approval test in an authorized test laboratory (e.g. ETL)?

- Which US-Authority has to be informed about this test?

- How long is this test valid?

- After which period has this test to be repeated?

Excuse my thoughtlessness. Please reply as soon as possible by fax (Fax-No.: Germany - 7142 - 73 28 95). Thank you very much in advance.

ID: nht94-3.8

TYPE: INTERPRETATION-NHTSA

DATE: May 26, 1994

FROM: Eric T. Stewart -- Engineering Manager

TO: Office of Chief Counsel -- NHTSA

TITLE: NONE

ATTACHMT: Attached to a letter dated 7/14/94 from John Womack to Eric T. Stewart (A42; STD 217)

TEXT: REFERENCE: Notice of proposed rule making, response to petition for reconsideration published in the Federal Register December 1, 1992 (Docket 88-21 notice No. 7) and Final rule; technical amendment to FMVSS 571.217 published in the Federal Register Dece mber 2, 1992 (Docket 88-21 notice No. 5)

The background to docket 88-21 notice no 7, Federal register page number 63324, states that "the agency believes that ALL existing exits should be subtracted before determining if additional exits will be required. The agency also notes that the front s ervice door of a non school bus can be counted as an emergency exit if it complies with the performance requirements in standard No. 217."

The above comment by NHTSA raises a question in the minds of the engineering personnel at Mid Bus, because we are currently in the process of designing a unique bus for the school and commercial bus market. This bus could have a capacity of 48 children or 40 adults. The chassis will use the chassis manufacturers cab that has an existing left hand drivers door. Can the daylight opening of this existing door to the left of the drivers seat be used in the calculations of required emergency exit area if it meets the performance requirements of standard No. 217?

I am requesting written clarification indicating how NHTSA interprets standard No. 217 with regard to this existing left hand exit. If you have any questions, please call me at (419) 221-2525.

ID: nht93-9.11

DATE: December 13, 1993

FROM: Lawrence P. White -- Acting Director, Bureau of Motor Vehicles, Commonwealth of Pennsylvania, Dept. of Transportation

TO: Mary Versie -- NHTSA, School Bus Regulations

TITLE: None

ATTACHMT: Attached to letter dated 3/21/94 from John Womack to Lawrence P. White (A42; Redbook; Std. 217)

TEXT:

I am writing concerning the new school bus emergency exit requirements in the FMVSS 217.

My office has received numerous inquiries from Pennsylvania's law enforcement agencies, school bus sales representatives and school bus contractors, concerning the new school bus exit requirements. These questions are:

1. The effective date - is it the chassis manufacturer's date of completion, the final stage manufacturer's date of completion, or somewhere in between?

2. Based on the formula for emergency exit space, is the area of the front entrance door to be included? Does this mean on a vehicle of 60 to 77 passengers, the only additional requirements beyond the front and rear doors is a left side exit door?

3. The "clear aisle space" required for exit to the proposed side emergency door, according to federal specifications, can be met with a flip- up type seat or a clear opening of 12", as measured from the back of the door forward. Are there any specifications, definitions, or descriptions provided as to what would be considered a "flip seat"?

4. Also, there is concern regarding school buses that are equipped with the "flip seat" by the emergency door opening and the possibility of school children, either intentionally or accidentally, unlatching the door latch mechanism. Are the door latch mechanisms to be equipped to help prevent this from occurring?

In the interest of maintaining the integrity of school buses, I am inquiring as to the correct responses to these questions and concerns.

Thank you for your assistance on this matter.

ID: nht78-1.1

DATE: 12/12/78

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

TO: Thomas Built Buses, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. James Tydings Thomas Built Buses, Inc. P.O. Box 2450 High Point, NC 27261

Dear Mr. Tydings:

This responds to your November 7, 1978, question whether the National Highway Traffic Safety Administration's (NHTSA's) October 13, 1978, interpretation of the Ninth Circuit air brake ruling has revoked the exclusion of school buses from the "no lockup" requirements of Standard No. 121, Air Brake Systems. You also ask if a bus which is designed identically to a school bus qualifies for the exclusion from "no lockup" requirements if it is purchased and used for a purpose other than as a school bus.

The answer to the first question is no. The exclusion of school buses from the stopping distance requirements of Standard No. 121 (S5.3.1) remains in effect and was not altered by the October 13, 1978, interpretation.

The answer to the second question is also no. The exclusion from service brake stopping distance requirements (including the "no lockup" requirement) is limited to school buses, which are defined at 49 CFR S 571.3 as follows:

"School bus" means a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation.

The buses you describe would not qualify as "sold ... for purposes that include carrying students to and from school or related events." Therefore, they would not qualify for the school bus exclusion.

Sincerely,

Original Signed By

Joseph J. Levin, Jr. Chief Counsel