ID: nht68-4.4

DATE: 08/20/68

FROM: AUTHOR UNAVAILABLE; John A. McLaine; NHTSA

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 9, 1968, containing literature on "Super-Lite" which will be an optional lighting device on the 1969 Dodge Polara and Monaco Models.

According to the literature, "Super-Lite" is an auxillary or supplemental light to be used in conjunction with the low beams of the regular headlamps.

For many years, all lighting devices used on motor vehicles registered in New Jersey have been required to be approved by the New Jersey Division of Motor Vehicles. Lighting devices are added to our approved list after a sample has been submitted along with a report from an independent testing laboratory showing that the device meets the standards of the Society of Automotive Engineers. We will also add a motor vehicle lighting device to our approved list after we receive an Approval Certificate from the American Association of Motor Vehicle Administrators showing that the device meets the SAE Standards.

Electric Supplementary Lamps, such as the "Super-Lite" are covered by SAE Standard No. J582. Perhaps you have submitted a sample light and the necessary test report to the AAMVA, but as yet, we have not received a copy of the Approval Certificate.

In case you desire to have us approve the "Super-Lite" on the basis of New Jersey alone. Please send us a sample and test report, as mentioned above.

Unless the "Super-Lite" is on our approved list at the time motor vehicles equipped with the lighting device are going through our inspection stations, the vehicles will have to be rejected.

New Jersey R S. 39:3-51 concerns the mounting and aiming of auxiliary driving lights. A copy of this section is enclosed for your information.

ID: nht69-1.15

DATE: 03/04/69

FROM: DEAN F. NIEDERNHOFER FOR CLUE D. FERGUSON -- NHTSA

TO: P.O.B. Manufacturing Company

COPYEE: R. O'MAHONEY

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 21, 1960, concerning glazing materials.

I am enclosing a copy of Federal Motor Vehicle Safety Standard No. 205 and, since you manufacture and distribute sealing compounds, a copy of Federal Motor Vehicle Safety Standard No. 212.

ASA Standard Z26.1-1966, incorporated by reference in Standard No. 205, can be obtained at a cost of $ 3.50 from the United States of America Standards Institute, 10 East 40th Street: New York 10016.

SAR Recommended Practice J673A, August 1967, incorporated by reference in Standard No. 205, can be obtained from the Society of Automotive Engineers, Inc., Two Pennsylvania Plaza, New York, New York, 10001.

We are in the process of changing paragraph S.3.2 of Standard No. 205. You may want to keep up with future amendments to these and other standards, therefore, I am enclosing a copy of form HS-13, Mailing List Questionnaire and subscription information for the Federal Register. Either or both of these will enable you to receive information in your areas of interest in all future motor vehicle safety rulemaking actions.

Sincerely,

February 21, 1969

Federal Highway Administration

Dept. of Transportation

Attention: Standards Dept.

Gentlemen:

We are manufacturers and distributors of sealing and glazing compounds for the transportation industry.

In view of this we would appreciate receiving a copy of Standard 205 (glazing materials) or information as to where and how we may obtain some.

Thank you for your courtesies and cooperation.

Sincerely, Jack Flyn--

P.O.B. Manufacturing Company

ID: nht70-2.45

DATE: 12/30/70

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: The Grote Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 5, 1970, to Mr. Julian E. Ieysath of this office concerning mounting of clearance lamps and testing combination lamps.

The wording for the mounting requirements of clearance lamps was amended in Standard No. 103 (35 F.R. 16040) to provide clarification; there was no intent to change the actual requirements. S4.3.1.7 permits clearance lamps in Standard No. 103 (35 F.R. 16840) to provide clarification; there was no intent to change the actual requirements. S4.3.1.7 permits clearance lamps to be mounted on the cab of a truck tractor, which in many cases may not indicate the overall width of the vehicle.

Section L of SAE J575, as modified by S4.2.1 of the amended standard, states, "The device shall be operating in the test in the same manner as it will be operated in service." Combination lamps have therefore been tested for less warpage with the steady burning tail or parking lamp operating continously and with the turn signal flashing. Now that the lens warpage test will also apply to the stop and backup lamps, this Bureau will test a combination lamp under the most severe possible operating condition. Since it is possible to have the tail, stop and backup lamps on simultaneously, these functions will be operating during the test for the stop and backup lamp lenses. A second test with the tail, turn signal and backup lamps operating will also be conducted.

Petitions for reconsideration have been received in Docket 69-18 requesting that the 10 minute cycling test be changed to 5 minutes on and 5 minutes off or that the effective date for the stop and backup lamp lens warpage requirement be extended beyond the July 1, 1971, effective date. Our decisions on these petitions will be published in the Federal Register in the near future.

ID: nht70-2.47

DATE: 10/19/70

FROM: L. R. Schneider, NHTSA

TO: American Honda Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Douglas W. Toms has asked me to reply to your letter of September 8 which requests confirmation "that a transmission gear ratio other than the highest ratio is not required to be available at all speeds below 25 miles per hour".

We cannot confirm this interpretation of S3.1.2 of Motor Vehicle Safety Standard No. 102 (Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect). The phrase "at vehicle speeds below 25 miles per hour" in that section is inclusive; it means at all speeds below 25 miles per hour, and not at a speed.

Douglas W. Toms Director National Highway Safety Bureau

We would appreciate receiving an interpretation to clarify the meaning of Paragraph S3.1.2 of Federal Motor Vehicle Safety Standard 102.

It is our understanding that a transmission gear ratio other than the highest ratio is not required to be available at all speeds below 25 miles per hour. For example, in the case of a vehicle equipped with a three speed automatic transmission, if second gear became available only when selected at speeds below 15 miles per hour, the vehicle would conform to the requirements of Paragraph S3.1.2 provided that within the speed range when second gear was available, the vehicle deceleration was greater than if the highest gear ratio were engaged.

We believe that rewording Paragraph S3.1.2 of M.V.S.S. 102 as follows would clarify this matter:

"S3.1.2 Transmission Braking Effect. In vehicles having more than one forward transmission gear ratio, one forward drive position shall provide a greater degree of vehicle deceleration than the highest speed transmission ratio when tested below 25 miles per hour and within the speed range at which the lower gear ratio is available."

We would greatly appreciate an early reply.

C. L. Hale Staff Engineer

ID: nht70-2.53

DATE: 07/10/70

FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 26, 1970, to Mr. Douglas W. Toms, Director, National Highway Safety Bureau, concerning plastic materials for reflex reflectors.

The contents of your letter, including the technical data and information enclosed therewith, have been carefully reviewed by interested members of this Bureau. As a result of this review and evaluation, and also considering the nature and intent of the requirements in question, we concur, basically, with your interpretation of the requirements of SAE J576b, as subreferenced in Federal Motor Vehicle Safety Standard No. 108. Your interpretation of the requirements of paragraphs 3.4 and 4.2 of SAE J576b, as quoted from your letter, is as follows:

"A plastic material used in a lamp or reflector assembly so that it is covered by other material and is not directly exposed to sunlight meets the requirements of SAE J576b if, when so covered, it satisfies the requirements of paragraphs 3.4 and 4.2."

We would fully concur with this interpretation if it is rephrased to read as follows:

"A plastic material used in a lamp or reflector assembly so that it is covered by other material and is not directly exposed to sunlight meets the requirements of paragraphs 3.4 and 4.2 of SAE J576b if, when so covered, it satisfies the requirements of those paragraphs."

To test for compliance, using this interpretation, the test sample discs, as specified in SAE 576b, would be exposed to the outdoor exposure test (paragraph 3.4) while covered with the actual lens material used in production lamp assemblies. In your particular case, the discs would be the polycarbonate ("Loxan") material and the "covering material" would be the red taillamp lens molded for production use.

ID: nht71-1.23

DATE: 12/20/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mechanism Division

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of November 4, 1971, concerning the compliance of two dual rear door locking systems with Standard 206, has been forwarded to this office for reply.

Both systems consist of

. . . a primary locking system which when engaged renders the outside rear door handle and the inside rear door handle inoperative and a special locking device accessible from the door shut face, which when engaged renders the inside door handle imperative but does not affect the outside door handle.

The systems differ is that engagement of the special locking device in the first system prevents the engagement of the primary locking system, while engagement of the special device in the second system does not have this effect.

As stated in the preamble to the April 27, 1968 amendment (33 F.R. 6465) to the standard, S4.1.3 does not preclude the installation of a special locking mechanism in addition to the required locking mechanism. However, the required locking mechanism must be engageable or disengageable regardless of whether any additional locking mechanism is engaged or disengaged. If the special locking mechanism does not interfere with the operation of the required locking mechanism, it will not constitute a failure to comply with the standard.

Under these criteria, the first dual system would not comply with the standard since engagement of the special locking mechanism would interfere with the operation of the primary locking mechanism.

The second dual system would comply if engagement of the special locking mechanism would prevent neither the engagement nor the disengagement of the primary locking mechanism.

Please write if I can be of any further assistance.

ID: nht71-1.28

DATE: 04/14/71

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: Mrs. Barbara G. Rothschild

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 29, 1971 in which you inquired whether a particular safety belt system, described in a patent application, would qualify as a "passive restraint" within the meaning of the Occupant Crash Protection standard. We have delayed an answer to your inquiry, pending issuance of amendments to that standard that were made on March 10, 1971 (36 F.R. 4600), in response to petitions for reconsideration.

You describe your system as one in which "you have to manually pivot the belt in order to take your seat in the car". From that point on, however, everything is automatic . . ." The issue, then, is whether such a system is a "means that require[s] no action by vehicle occupants," in the words of the standard.

Our position is that such a system would not meet the above requirement of the standard, since it is a system that does require action by the occupant,i.e., pivoting the belt. By "no action" is meant just that -- no action by occupants other that would be required if the protective system were not present in the vehicle. We recognize that in some cases, the action that is required may be ralatively slight. In terms of regulatory categories, however, we consider it important to distinguish "no-action" systems from "forced-action" systems, of which the most commonly discussed example is the seat belt with an ignition interlock. Your system appears clearly to come within the forced-action category.

Please note that although we are glad to provide interpretations in response to specific questions such as yours, the National Highway Traffic Safety Administration generally does not issue overall "approvals" of any vehicle or motor vehicle equipment, with respect to conformity with the standards.

ID: nht71-1.41

DATE: 12/29/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson, Assistant Chief Counsel; NHTSA

TO: L. E. Needham

TITLE: FMVSS Interpretation

TEXT: Your letter of November 4, 1971, concerning the compliance of two dual rear door locking system with Standard 206, has been forwarded to this office for reply.

Both systems consist of

". . . a primary locking system which when engaged renders the outside rear door handle and the inside rear door handle inoperative and a special locking device accessible from the door shut face, which when engaged renders the inside door handle inoperative but does not affect the outside door handle."

The systems differ is that engagement of the special locking device in the first system prevents the engagement of the primary locking systems, while engagement of the special device in the second system does not have this effect.

As stated in the preamble to the April 27, 1968 amendment (33 F.R. 6465) to the standard. S4.1.3 does not preclude the installation of a special locking mechanism in addition to the required locking mechanism. However, the required locking mechanism must be engageable or disengageable regardless of whether any additional locking mechanism is engaged or disengaged. If the special locking mechanism does not interfere with the operation of the required locking mechanism, it will not constitute a failure to comply with the standard.

Under these criteria, the first dual system would not comply with the standard since engagement of the special locking mechanism would interfere with the operation of the primary locking mechanism.

The second dual system would comply if engagement of the special locking mechanism would prevent neither the engagement nor the disengagement of the primary locking mechanism.

Please write if I can be of any further assistance.

ID: nht71-1.49

DATE: 01/22/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Bolt Beranek and Newman, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters, both dated December 16, 1970, concerning Motor Vehicle Safety Standard No. 213, "Child Seating Systems." One of these letters enclosed a request for clarification of two provisions of Standard No. 213. This request is presently under review and you should be hearing from the agency concerning it in the near future. You also enclosed in this letter a copy of a page from the 1970 Sears, Roebuck & Co. catalogue showing a child harness that is advertised as "not a safety harness," and ask whether this type of harness is exempt from the requirements of Motor Vehicle Safety Standard No. 209. The agency considers these types of harnesses to fall within the purview of Standard No. 209 and they are required to comply with the requirements for Type 3 seat belt assemblies as specified in S4. of that standard. Enforcement procedures are currently in progress in this area to eliminate those child harnesses that do not comply with the standard.

Your second letter requests that a study conducted by the University of Michigan Highway Safety Research Institute (Contract No. FR-11-6962), entitled "Integrated Seat - Restraint and Child Systems," be placed in the public docket, and further request that the "data films of the dynamic sled test be made available through the Docket." The report to which you apparently refer has been placed in the general reference section of Docket 2-15. It is entitled "Child Seat and Restraint Systems Test Program" but bears the same contract number as the one you request. With reference to your request for data films, these films are presently available for examination by the public through the agency's Research Institute, and information to this effect has been placed in the Docket.

ID: nht71-5.9

DATE: 12/01/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Penn-Ohio Chapter

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of November 23, 1971, you asked how your members could make sure that the seat belts they install in their trucks conform to the applicable motor vehicle safety standards. As far as the belts themselves are concerned, each belt made after the seat belt standard (No. 209) became effective in 1967 is required to marked with the year of manufacture. So long as the belt bears a date after 1967, it will have had to conform to the seat belt standard and your members should use the date as a guide in purchasing belts.

The provision of anchorages for the belts is a somewhat more complex problem. A new truck - manufactured after July 1, 1971 is required to have anchorages for lap belts at all seating positions (and, in some cases, anchorages for shoulder belts). Although older trucks were sometimes provided with anchorages, many were not, and for these you will have to follow the location and instructions of Standard No. 210 in order to comply with the Motor Carrier Safety Regulations. Although the Motor Carrier Safety Regulations do not establish strength requirements for anchorages, their strength should be of concern to you and in this area you may have to rely on the manufacturer, rather than the dealer, for advice on reinforcement of the vehicle structure.

Our legal staff is centralized in Washington and there are no field representatives of the agency who could assist you in matters relating to the standards. As much as we would like to send someone to address your group, the workload of the upcoming

months prevents such a trip. However, we have found that many questions can be satisfactorily answered by letter. If your group could assemble a detailed list of questions, we will try to answer them as fully as possible.