ID: nht72-1.12

DATE: 04/25/72

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

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 5 to Mr. Schneider asking for an interpretation of Standard No. 106.

You ask whether it is permissible to use a rubber protector on a brake nose which masks in part the identification marking required by Standard No. 106. SAE Standard J40b, Automotive brake Hoses, incorporated by reference in Standard No. 106, requires hose working to be permanent in nature. Therefore, use of this protector is permissible, provided that its rubbing effect, if any, does not oblitorate in time the required marking.

You have also asked whether you may conduct the whip test with the rubber protector removed. We have no objection to this method of conducting the whip test. Standard No. 106 is silent as to how the test may be conducted. Paragraph 57.1.4 of our proposal to amend Standard No. 106 (Docket No. 1-5; Notice 7, 36 F.R. 5855, March 30, 1971) represents our view that "protective armor" should be removed for the fatigue test, and you may interpret this as including the rubber protectors also.

YOURS TRULY,

NISSAN MOTOR CO., LTD.

April 5, 1972

Lawrence Schneider National Highway Traffic Safety Administration

SUBJECT: Interpretation of MVSS 106.

We would like to have your interpretation regarding MVSS 106-Hydraulic Brake Hoses, (1) whether or not we may use the rubber protector which would hide the marking on brake hose in part. (Protector itself is not glued, but envelopes the hose tightly so it could be movable when relatively strong force is applied.) (2) whether or not we may conduct the whip test with the rubber protector removed.

Your assistance in this matter would be greatly appreciated.

Satoshi Nishibori Engineering Representative Liaison Office in U. S. A.

ID: nht72-1.41

DATE: 07/11/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 21, 1972, in which you requested our interpretation of the phrase in S4.3.1.3 of Motor Vehicle Safety Standard No. 210 which states that the angle of the belt is to be measured from the seating reference point to the "nearest contact point of the belt with the hardware attaching it to the anchorage".

The language in question was adopted in response to petitions for reconsideration of the amended rule as published in 1970 (35 F. R. 15298, 35 F. R. 18116). Several petitioners had stated that measuring the angle from the seating reference point to the anchorage, as the standard then specified, would not accurately reflect the true angle of the belt because of the intervention of rigid attachment hardware between the anchorage and the webbing. The section was therefore amended to refe to the point at which the belt touched such attachment hardware.

In the diagram which you provide of a seat belt system in which the buckle is attached to the seat by means of a rigid bracket, we would consider the buckle itself to be a part of the attaching hardware. The contact point would therefore lie on the interface between the tongue and the (Illegible Word) at the point nearest the seating reference point.

It does not appear from Figures 2 and 3 of your letter that any of the designated angles correspond exactly to the angle that should be measured under S4.3.1.3. In both figures the angle would be determined by the line between the reference point and the nearest point to it on the forward end of the buckle.

Please advise us if you have further questions on this point.

ID: nht72-1.43

DATE: 06/01/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Hamilton Cosco, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 4, 1972, posing certain questions concerning paragraph S4.10 of Motor Vehicle Safety Standard No. 213, "Child Seating Systems." You ask "what criteria are to be used to determine whether an area is a contactable area under S4.10."

The components that would be considered contactable by the head under S4.10.1, or by the torso under S4.10.2, are any components which a child within the weight and height range for which the seat is recommended might contact in a 30 m.p.h. barrier crash, as represented by the test procedure specified in S5.1 and S5.2.

You also ask for clarification of the meaning of "rigid side" as that phrase is used in S4.10.3. As we indicated to you in our letter of February 23, 1972, manufacturers should rely on generally available definitions of "rigid" in determining whether or not components are within the term. The reference to "side" includes components placed both to the right and left, and forward of and behind the child occupant. Consequently, both an arm rest and a head rest (either separate from the back of a child seat or part of a one piece back of a child seat) could fall within the exemption of S4.10.3. The reference to "back or side" in the proposed amendment to S4.10 published September 23, 1970 (35 F.R. 14786), is intended purely as a clarification of the existing language; the main thrust of the proposed revision would be, as stated in its preamble, to eliminate the exemption in the head-contact area.

With reference to the status of the September 23 proposal, a final rule based on this notice is still under consideration and we cannot presently provide an indication as to when it may become effective.

ID: nht72-1.49

DATE: 02/28/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Cosco Household Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 8, 1972, requesting information pertaining to reclining type child seating systems. You describe these seats in your letter as those which allow the child to ride in a semi-recumbent posture by moving the seating surface forward while maintaining the upper back in a more or less fixed location. You state the hip of the child moves forward as a result, while the head remains in roughly the same place.

The questions you asked regarding this type of child seat are repeated below, followed by our responses.

1. Is NHTSA now testing, or does it intend to test, reclining car seats in both the upright and reclining configurations?

Paragraph S4.11.1(b) of Standard No. 213 requires that each child seating system in which the attitude of the child is adjustable meet the performance requirements of the standard when placed in each designed adjustment position. Consequently, reclining child seats must meet these requirements in both reclining and upright positions.

2. Is the allowed twelve-inch excursion to be measured from the reference point of the semi-recumbent dummy, or from the location of this point were the seat assumed to be upright?

The allowable forward movement of the dummy reference point is to be measured using the reference point of the semi-recumbent dummy, and the forward movement must not exceed 12 inches when measured from that point.

3. Does the NHTSA intend to make a specific statement on the requirements of reclining car seats . . .?

We believe the language of paragraph S4.11.1 of the standard to be sufficiently explicit regarding this requirement.

ID: nht72-2.11

DATE: 11/21/72

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

TO: Mobile Aerial Towers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to the questions you asked in your letter of October 24, 1972, to Mr. Wells of the Federal Highway Administration concerning compliance with Standard No. 108 of trucks to which mobile aerial towers are mounted.

"1. The aerial tower is considered a load rather than part of the vehicle to be included in determining the overall length. Correct?"

Correct.

"2. Are amber intermediate side marker lights and/or reflectors required on the body?"

If the overall length of the vehicle is 30 feet or more, intermediate side marker lamps and reflectors are required, and they must be located at or near the midpoint between the front and rear side marker lamps and reflectors.

"3. Are amber side marker lights and/or reflectors required on the body?"

Front amber side marker lamps and reflectors are required to be mounted as far to the front as practicable on a vehicle. Generally, this is somewhere on the front fender, though in some configurations a manufacturer might determine that a location on the truck body is as far to the front as practicable.

"4. Are amber clearance lights and/or reflectors required on the front of the body?"

Yes. Front clearance lamps are required to indicate the overall width of the vehicle and to be mounted "as close to the top [of the vehicle, exclusive of load] as practicable."

"5. If a unit is over 30 ft. long, will amber side marker lights and reflectors suffice also as amber intermediate side marker lights and reflectors?"

No, they will not. As the above answers indicate, the location requirements are different for front and intermediate side markers.

ID: nht72-2.22

DATE: 02/18/72

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

TO: FMC Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to the questions you ask in your letter of January 7 concerning the Federal Motor Vehicle Safety Standards.

In your first question you ask whether a vehicular hazard warning signal operating unit must conform to SAE Recommended Practice J910 specified in Table 1 of Standard No. 106, or to the newer SAE J910s. The answer is J910; the revision J910a cannot become a requirement of Standard No. 103 without ruleasking action by this agency. As of (Illegible Words) has issued no proposal that (Illegible Word) be adopted. You also ask whether hazard lamps at both ends of the vehicle must flash simultaneously. The operating unit is defined in (Illegible Word) as a device "which causes all turn signal lamps to flash simultaneously . . ." This means that all turn signal lamps must flash on the same cycle, and that separate cycles for froat and rear turn signal lamps are not permissible.

In answer to your second question, Standard No. 108 does not yet specify requirements for side turn signal lamps, and thus does not prohibit their use on your motor home. As indicated in our "Program Plan for Motor Vehicle Safety Standards," October 1971, this agency intends to issue a notice in the near future proposing to incorporate requirements for side turn signal lamps in Standard No. 108

Finally you ask whether Standard No. 101 requires illumination (Illegible Words) handlamp switch with park ponition to operate clearance, I.D., and the marker lamps. Standard No. 101 does not require illumination of the headlamp switch, even if the switch does (Illegible Word) is the operation of other lamps whose controls, if separate, would have to be illuminated.

ID: nht72-3.20

DATE: 12/01/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Trailer Coach Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of August 17, 1972. We indicated in a letter to you of September 8, 1972, that we would respond to your letter when action on petitions for reconsideration of the June 21, 1972, amendment to Standard No. 205 had been completed. Notice of our action has now been published 137 F.R. 24035, November 11, 1972) and a copy is enclosed.

Based upon the November 11, 1972, notice, your conclusions regarding the requirements for certification and marketing by prime glazing material manufacturers (paragraph 3.2 of your letter) are for the most part correct. These manufacturers must mark glazing materials in accordance with Section 6 of ANS (Illegible Word). They must also certify. The certification must be made by the addition of the symbol DOT and assigned code number only when the glazing is designed as a component of any specific motor vehicle or camper. In other cases certification may be accomplished by any method meeting the requirements of section 114 of the National Traffic and Motor Vehicle Safety Act (13 U.S.C. 1403). It may not be accomplished, however, by affixing the DOT and code number.

Your conclusions regarding certification and marking requirements for persons who cut glazing material from larger sheets (paragraph 3.1 of your letter) are not entirely correct. It is true that such persons must also certify, and that the method for certification may be any that satisfies the requirements of section 114 of the Act. Affixing a label to the material is one such method. You are incorrect, however, in your conclusion that the material need not contain the markings of the prime manufacturer. Section 6 of ANS %26 requires glazing cut from larger pieces to contain the markings of the manufacturer of the larger piece. As clarified in the notice of November 11, 1972, this requirement is still applicable.

ID: nht72-3.4

DATE: 02/16/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Alabama Tire Dealers and Retreaders Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your three letters, dated December 1, 1971, December 27, 1971, and January 11, 1972, concerning Motor Vehicle Safety Standard No. 117.

In your letter of December 1, 1971, you enclose a booklet that you have recently made available which contains your interpretation of Standard No. 117, and ask us to review it. As your letter was written before the amendment of December 23, 1971 (36 F.R. 24814), and the suit in Chicago, it does not, and our reply will not, deal with the changes made by that amendment or the "stay" ordered by the Court of Appeals. We believe your summary of the standard is correct, but we would recommend that you include in the requirements of paragraph S5.1.1 of Standard No. 117 the treadwear indicator requirements found in S4.2.1(d) of Standard No. 109. This fact is apparently being overlooked by some retreaders, and you may wish to point it out more clearly.

Your letter of December 27 asks whether exposure of cord that has occurred on casings because of "chipping" would prevent the casing from being retreaded under S5.2.1. As presently written, S5.2.1 would preclude the retreading of such a casing if what is exposed is ply cord. However, if it is actually "chafer" fabric, which is a special fabric placed only around the bead, then exposure is permitted.

Finally, with regard to your letter of January 11, I regret that, as you have been told, Mike will not be able to attend the Missalaga Conference. He has told me that your organization has done a very responsible job with regard to not only Standard No. 117 but other areas of tire safety as well, and we appreciate your efforts.

ID: nht71-3.45

DATE: 07/21/71

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

TO: Rueck and Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 7, 1971, to the National Highway Safety Bureau (now the National Highway Traffic Safety Administration) concerning the requirements for sealed beam headlamp units.

The answers to your specific questions are as follows:

1. Sealed beam units must meet the photometric specifications in SAE J579 at the design voltage at or below the maximum amperes specified in SAE J573.

2. Tolerances are as follows:

Electrical power - the maximum electrical power is the product, in watts, of the design voltage multiplied by the maximum amperes at design volts. There is no specified minimum electrical power.

Maximum amperes - There is no tolerance. Maximum amperes is the maximum specified in SAE J573.

Design watts - There is no tolerance. There is, however, a tolerance on the actual watts or electrical power as described above.

3.4.4. The filament types and positions are illustrative of current practice only. Any type or position may be used to meet the specification of J579 and J573.

5. All glass sealed beam units are not mandatory. There are no restriction in Federal Motor Vehicle Safety Standard No. 108 or the SAE Standards on the number of pieces or the materials which are used to complete the assembled sealed beam unit as long as the specifications, including those in SAE J571, are met. Caution should be used, however, to ensure that a good and durable seal is obtained between the metal back, if used, and the other parts to optimize the useful service life of the sealed beam unit.

ID: nht71-4.2

DATE: 08/10/71

FROM: AUTHOR UNAVAILABLE; Charles H. Hartman; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: In the conference that was held on July 23, 1971, between Ford representatives and National Highway Traffic Safety Administration personnel concerning Standard No. 208, Occupant Crash Protection (memorandum dated July 29, 1971, filed in Docket 69-7), your legal counsel raised a question concerning the National Highway Traffic Safety Administration's position with respect to enforcement of the standard.

The question raised was whether this agency would consider a motor vehicle not to conform to the standard if the National Highway Traffic Safety Administration tests showed noncompliance, but the manufacturer's analogous tests showed compliance, and the difference in results were due to the use of slightly different anthropomorphic test devices, with both sets of tests assumed to be run in accordance with the prescribed conditions and procedures of the standard. We agree that the question is an important one and that it may arise, because the complexity of the physical variables in crash testing with anthropomorphic devices makes it difficult if not impossible to refine the standard's specifications to the point where all relevant conditions are specified and all permissible variations eliminated.

In a case where tests conducted by the NHTSA show noncompliance with a standard, and the manufacturer's tests, valid on their face, appear to give complying results, the NHTSA conducts an inquiry to determine the reason for the differing results. If, after completing such an inquiry, the NHTSA were to conclude that the difference in results was entirely due to differences in the

test devices used by each, and further that the manufacturer's tests, including his test devices, were in complete conformity with the standard, then the agency would not consider that particular series of tests to be the basis for a finding of noncompliance against the manufacturer.

I hope that this clarifies the matter for you.