ID: nht95-2.74

TYPE: INTERPRETATION-NHTSA

DATE: May 9, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Takashi Adachi -- Manager, Ichikoh Industries, Ltd.

TITLE: NONE

ATTACHMT: ATTACHED TO 3/14/95 LETTER FROM TAKASHI ADACHI TO RICHARD L. VAN IDERSTIN (OCC 10857)

TEXT: Dear Mr. Adachi:

This is in reply to your letter of March 14, 1995, to Richard Van Iderstine of this agency, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it applies to a reflex reflector design that you attached. This design shows a single re flector 2 inches in height mounted behind a clear outer lens which is bisected horizontally by an opaque strip 6mm (.25 in.) wide, giving the impression from the exterior of two reflectors, one .75 in. high above the divider, and one that is 1.00 in. in height, below the divider.

You have asked whether the "structure of the reflex reflector conforms to FMVSS 108," and whether photometric conformance is judged with respect to the single reflector crossed by the opaque strip, or whether both the upper and lower portions of the bise cted reflector must meet the photometric specification.

Standard No. 108 is a performance standard, not a design standard. The standard does not specify any requirements concerning the structure of reflectors. The applicable requirements for reflex reflectors are those of SAE Standard J594f. Reflex Reflecto rs January 1977, which Standard No. 108 incorporates by reference. Your reflector should be tested as a single reflector according to the procedures set forth in J594f. If the reflector does not meet the photometric performance requirements of that sta ndard, you may add sufficient reflective elements to the reflector design until conformance is achieved. There is no need to test the upper and lower portions as separate reflectors.

If you have any further questions, you may refer them to Taylor Vinson (202) 366-5263 of this Office.

ID: nht95-3.30

TYPE: INTERPRETATION-NHTSA

DATE: June 29, 1995

FROM: Isaias Rios -- Product Engineering Dpt., Rines De Acero K-H, S.A. De C.V.

TO: Marvin Shaw -- NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 08/11/95 LETTER FROM JOHN WOMACK TO ISAIAS RIOS (A43; PART 566; STD. 110; STD. 120)

TEXT: DEAR MR. SHAW:

CURRENTLY RINES DE ACERO K-H. S.A. DE C.V. IS THE PRINCIPAL SUPPLIER OF PASSENGER CAR STEEL WHEELS FOR THE MAJOROTY OF THE AUTOMAKERS THAT ARE ASSEMBLING VEHICLES IN MEXICO (FORD MOTOR Co., GENERAL MOTORS, VOLKSWAGEN, NISSAN AND CHRYSLER).

TO EXPORT PASSENGER CAR STEEL WHEELS FROM MEXICO TO U.S.A., [Illegible Words] IS REQUIRING A CERTIFICATE WHICH DEMONSTRATES TOTAL COMPLIANCE WITH THE APPLICABLE REQUIREMENTS OF THE FEDERAL MOTOR VEHICLE SAFETY STANDARD No. 110 No. 120 OR OTHER FMVSS S TANDARDS OF INTERNATIONAL MOTOR VEHICLE SAFETY ACT. OF 1966.

THE PURPOSE OF THIS LETTER IS TO REQUEST THE [Illegible Words] INFORMATION AND PROCEDURE NECESSARY FOR US TO [Illegible Words] CERTIFICATION, AND ENABLE US TO SHIP WHEELS TO NISSAN FOR [Illegible Words] TO THE U.S.

IF A FORM IS NECESSARY, PLEASE FORWARD A COPY OF [Illegible Words] FORM OR A LIST OF THE DATA REQUIRED. PLEASE ALSO [Illegible Words] OTHER AGENCIES OR GOVERNMENT DEPARTMENTS [Illegible Words] INCLUDING CONTACT PERSON AND THE NAME AND [Illegible Word s] THE APPLICABLE STANDARD FOR WHEELS (BOTH STEEL AND ALUMINUM).

IF WE NEED TO HAVE WHEELS TESTED BY APPROVED LABS IN THE U.S. COULD YOU ALSO PROVIDE US WITH A LIST OF SUCH LABS, NAME, ADDRESS, AND CONTACT PERSON. OUR FAX NUMBER IS 011-525-572-74-70, AND THE PRODUCT ENGINEERING TELEPHONE NUMBER IS 011-625-562-73-0 0.

I WOULD REALLY APPRECIATE YOUR HELP ON THIS MATTER. PLEASE CALL ME IF YOU REQUIRE ADDITIONAL INFORMATION OR EXPLANATION.

ID: nht95-3.32

TYPE: INTERPRETATION-NHTSA

DATE: June 29, 1995

FROM: Isaias Rios -- Product Engineering Dept., Rines De Acero K-H, S.A. DE C.V.

TO: Marvin Shaw -- NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 8/14/95 LETTER FROM JOHN WOMACK TO ISAIAS RIOS (REDBOOK 6; A43; STD. 110; STD. 120; PART 566)

TEXT: DEAR MR. SHAW:

CURRENTLY RINES DE ACERO K-H, S.A.DE C.V. IS THE PRINCIPAL SUPPLIER OF PASSENGER CAR STEEL WHEELS FOR THE MAJOROTY OF THE AUTOMAKERS THAT ARE ASSEMBLING VEHICLES IN MEXICO (FORD MOTOR Co., GENERAL MOTORS, VOLKSWAGEN, NISSAN AND CHRYSLER).

TO EXPORT PASSENGER CAR STEEL WHEELS FROM MEXICO TO U.S.A., NISSAN MEXICANA IS REQUIRING A CERTIFICATE WHICH DEMONSTRATES TOTAL COMPLIANCE WITH THE APPLICABLE REQUIREMENTS OF THE FEDERAL MOTOR VEHICLE SAFETY STANDARD No. 110 No. 120 OR OTHER FMVSS STA NDARD OF THE NATIONAL MOTOR VEHICLE SAFETY ACT OF 1966.

THE PURPOSE OF THIS LETTER IS TO REQUEST THE REQUIRED INFORMATION AND PROCEDURE NECESSARY FOR US TO OBTAIN SUCH A CERTIFICATION, AND ENABLE US TO SHIP WHEELS TO NISSAN FOR SUBSEQUENT SHIPMENT TO THE U.S.

IF A FORM IS NECESSARY, PLEASE FORWARD A COPY OF THE REQUIRED FORM OR A LIST OF THE DATA REQUIRED. PLEASE ALSO ADVISE US OF THE OTHER AGENCIES OR GOVERNMENT DEPARTMENTS OR STANDARDS ORGANIZATIONS INCLUDING CONTACT PERSON AND THE NAME AND NUMBER OF TH E APPLICABLE STANDARD FOR WHEELS (BOTH STEEL AND ALUMINUM).

IF WE NEED TO HAVE WHEELS TESTED BY APPROVED LABS IN THE U.S., COULD YOU ALSO PROVIDE US WITH A LIST OF SUCH LABS, NAME, ADDRESS, AND CONTACT PERSON. OUR FAX NUMBER IS 011-525-572-74-70, AND THE PRODUCT ENGINEERING TELEPHONE NUMBER IS 011-525-562-73- 00.

I WOULD REALLY APPRECIATE YOUR HELP ON THIS MATTER. PLEASE CALL ME IF YOU REQUIRE ADDITIONAL INFORMATION OR EXPLANATION.

ID: nht67-1.10

DATE: 08/01/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Sears, Roebuck & Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 20, 1967, concerning restraining straps for children.

Initial Federal Motor Vehicle Safety No. 209 provides that seat belt assemblies shall meet the requirements of Department of Commerce, National Bureau of Standards, Standards for Seat Belts for Use in Motor Vehicles (15 CFR 9) (31 F.N. 11528). For your convenience a copy of the Federal Register containing the seat belt standard is enclosed.

The standard affects any seat belt manufactured for sale after February 23, 1967, including Type 3 belts which are designed for children between 8 months and 6 years of age. The problem you discuss in your letter, that of manufactures who consider their devices something less than seat belts, and so label them, is under review to determine if there is any violation of the National Traffic and Motor Vehicle Safety Act of 1965.

Sincerely,

June 20, 1967

Department of Transportation Washington, D.C.

Attention: Dr. Haddon

Dear Dr. Haddon

Sears Automotive Department carries only a child's harness that meets your new federal safety standard, but many competitors are carrying inexpensive restraining straps which obviously do not meet the standard. We would like to know the position that the federal government will take regarding them. If inexpensive restraining straps state on the package clearly that "this is not a safety harness but only a child's restraining strap" or words to that effect, will they be legal since the federal standard does not apply to them? A statement regarding this form you will be greatly appreciated.

Very truly yours,

C.M. HATTERSLEY, Buyer -- Auto Parts and Accessories, Department 628,SEARS, ROEBUCK AND CO.

ID: nht68-1.18

DATE: 07/27/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Blaw-Knox Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your May 6, 1968, letter to the Director of the National Highway Safety Bureau concerning lighting and certification requirements on your concrete mixers.

Providing the combination rear clearance and side narear lamps meet the requirements for both as specified in SAE Standard J992b, April 1964 the lamps and reflectors shown on your drawing C-8450-911 dated April 3, 1968, and Service Bulletin 533 dated April 10, 1968, appear to be in fonformance with the requirements of Standard No. 103. With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments 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. 103.

Bules regarding classic-cabs and certification requirements which have been published in the Federal Register are enclosed for your reference. Please note that in order to comply with the certification requirements, we need the following additional information from you:

1. The locating on the vehicle at which the certification label or tag will be placed.

2. An actual sample certification label or tag.

3. The means by which the certification label or tag will be attached, e.g., wole, rivet, serev, or achoaive.

This information should is sent to the U.S. Department of Transportation, Federal Highway Administration, National Highway Safety Dureon, Washington, D.C. 23591 to the attention of Mr. Joseph R. O'Corman, Acting Director, Office of Performance Analysis, Motor Vehicle Safety Performance Service.

ID: nht69-2.22

DATE: 10/03/69

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

TO: Donald J. Norris

TITLE: FMVSS INTERPRETATION

TEXT: This reply is in reference to your letter to Mrs. Knauer concerning Federal tire codes and tire tests, and a minimum service guarantee on tires.

The list of tire manufacturer's approved code marks is periodically updated wherever new number are requereted or other chop as are necessary. The latest revision, a copy of which is enclosed, was printed on July 2, 1969. in the Federal Register. The tire code mumber, you realise, is placed on the tire to enable the consumer to identify the actual manufacturer of a tire. With respect to the minimum performance standards for passenger care times it is our intent to revise there standard and up-grade as necessary to protect the motoring public.

It has been the policy of the National Highway Safety Bureau to retest tires when individual failures are found and to request the manufacturer of these tires to provide information concerning their basis of certifying compliance with Federal Motor Vehicle Safety Standard No. 109. When upon retesting a significant number of tires of a certain brand and line of tires are found to be defective, indicating that failures are not of the "isolated-instance type", this information has been released to the public and recall campains have been initiated. The Bureau has taken the position that an isolated instance of failure is not necessarily representative of the tires being manufactured and further verification is needed by retesting. We feel that the release of information on isolated failures would be confusing and serve no useful purpose to the consumer.

The National Highway Safety Bureau has the responsibility of establishing safety standards for motor vehicles to reduce accidents.(Illegible Words) injuries in(Illegible Word) accidents.(Illegible Words) into relationships between the consumer and the caller of tires in cases involving(Illegible Word) service(Illegible Word).

ID: nht70-1.36

DATE: 01/22/70

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

TO: Pacer Performance Products

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 31, 1969 requesting information about the Federal Motor Vehicle Safety Standards and their applicability to wheels manufactured by Pacer. We have enclosed a copy of the April, 1969, edition of the Federal Motor Vehicle Safety Standards, along with amendments relevant to your inquiry.

You have requested information as to how you can comply with Standards No. 109 and 110. These Standards, as you will notice, are applicable to new passenger car tires add to wheels and tires mounted on new passenger cars, so that if a wheel manufactured by Pacer is placed on a passenger car before the car is sold to the first purchaser, the wheel and the tire must conform to the requirements of Standards No. 109 and 110. To comply the tire and rim must meet the performance requirements of Standard 109, and the rim must be able to retain a deflated tire during a stop from 60 miles per hour, as required by paragraph S4.4.1(b) of Standard No. 110. There are no other requirements applicable to wheels and rims as such.

The National Highway Safety Bureau issues no certificate of compliance, although it maintains surveillance over product safely through its own testing program. The Gregon manufacturer to whom you refer may have requested the Bureau's opinion as to whether a particular wheel design would violate Standard No. 211, a standard applicable to wheel nuts, wheel discs and hub caps as items of motor vehicle equipment which prohibits certain tyres of hazardous projections on wheels. In response to such requests, the Bureau has occasionally issued interpretations of Standard No. 211, but these are in no way equivalent to a certificate of compliance.

I trust this information will be helpful to you. Should you have additional questions, please advise us and we will try to provide further clarification.

ID: nht68-2.39

DATE: 09/20/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: White Trucks, Division of White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 22, 1963, to Mr. David A. Fay, concerning a clarification of the requirements of paragraph S3.4.3 of Motor Vehicle Safety Standard No. 108.

As a truck-tracter manufacturer, your responsibility with respect to the requirements of paragraph S3.4.3 may be set by installing on your truck-tractors the switches, wiring and trailer electrical connectors that will, when properly mated with the wiring and electrical plugs on the trailern that are designed to be used with your particular electrical circuitry, cause the trailer tail lamps and the truck-tractor tail lamps to be illuminated when the truck-tractor headlamps are illuminated. If your truck-tractors are subsequently used to tow trailers that are not equipped with properly mated electrical plugs, connectors or circuitry, then you are not burdened with the responsibility of providing, for the resulting tractor-trailer combination, electrical circuitry that will cause the trailer tail lamps to be illuminated then the tractor headlamps are illuminated.

The trailer electrical connector that is installed on the tractor may be the 7-wire connector conforming to SAE 3560a, a 6-wire connector, or a special connector as specified by your customers. In this respect, we agree that your cannot ascertain at the time you build your truck-tractor the type of wiring system or electrical plugs that will be used on the trailer or trailer combinations that might, in the future, be tored by the truck-tractors.

Thank you for writing.

ID: nht68-3.43

DATE: 07/25/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 2, 1968, to Mr. George C. Nield, Acting Director, Motor Vehicle Safety Performance Service, concerning requirements for combination clearance and side marker lamps.

Paragraph S3.3 of Motor Vehicle Safety Standard No. 108 permits the combination of two or more lamps providing the requirements for each are met. Table 1 in SAE Standard J592b gives the photometric requirements for both the clearance and side marker lamps, and Section J of the Standard permits their combination providing the combination complies with both clearance and side marker minimum candlepower requirements. Section J also defines the H-V axis of the combination as parallel with the longitudinal axis of the vehicle when checking clearance lamp test points, and normal to this vehicle axis when checking side marker test points.

Your table of minimum candlepower requirements for the Type 2 combination lamp meets J592b and therefore Standard No. 108 providing you define the H-V axis as that of the side marker lamp. The requirements for the Type 1 combination as specified in your table will not meet J592b or Standard No. 108 unless you change H-10, -20, -30, -45, -60, -80 and -90, both 1, and R to H-15, -25, -35, -45, -55, -65, -75 and -90, both L and R, and define the H-V axis as a line through the center of the lamp at a 45 degree angle to the longitudinal axis of the vehicle.

Your mounting instructions are considerably more restrictive than those implied in J592b and Standard No. 108. Actually, no additional mounting instructions are necessary, because any mounting which meets the minimum candlepower requirements of Table 1 in J592 and your table with the suggested revisions would meet the requirements of Standard No. 108.

ID: nht68-3.48

DATE: 08/05/68

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA

TO: Luis M. Neco

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 25, 1968, concerning the motor vehicle safety requirement for head restraints and your proposed specification for the installation of transparent partitions separating the front and rear compartments of taxicabs.

A head restraint will be required on all passenger cars manufactured after December 31, 1968. Our findings based on passenger vehicle collision research clearly indicate the use of head restraints to be one of the most effective safety measures that can be provided for the driver and front seat passenger. For your information, I am enclosing a copy of a news release on this subject and a report entitled "Backrest and Head Support Design for Rear-End Collision Protection" published by the SAE, January 10, 1968.

I appreciate the problem of driver assault. However, we do not believe the deletion of a proven safety device is an appropriate way to resolve the problem. A positive approach, and one that is practical, would be to develop a suitable partition, and we know of no reason why this can not be accomplished practically, with head restraints and shoulder belts installed. The partition design should provide the current level of safety for(Illegible Word) occupants. I refer here to the use of laminated safety glass with energy absorbing characteristics of today's windshields in a frame that would retain the glass during a collison and that is not hazardous to head impact.

Giving consideration to all the factors involved, we are convinced that head restraints offer significant benefits in reduced "whiplash" injuries, and are certain that you can resolve the partition problem to accomplish both your objective of protecting the driver from others, and of reducing his chances of injury in a crash.