ID: 77-2.1

TYPE: INTERPRETATION-NHTSA

DATE: 03/25/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Wayne Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your oral request of February 17, 1977, for an interpretation of the requirements of Standard No. 210, Seat Belt Assembly Anchorages, as they apply to Standard No. 222, School Bus Passenger Seating and Crash Protection. In particular, you ask how much force must be used when testing school bus seat belt anchorages for compliance with the standards.

As you may know, the National Highway Traffic Safety Administration, initially proposed that seat belt anchorages be installed in all school buses. At that time, we also proposed that each seat belt assembly be tested under a force of 1,500 pounds. A seat containing three seating positions would have had the three seat belt assemblies tested simultaneously with a possible resulting load upon the seat of 4,500 pounds. The requirement of seat belt anchorages in larger buses was dropped from the proposal based upon comments from school bus operators and as a result of our compartmentalization approach to passenger seating safety in school buses.

The present Standard No. 222 requires seat belts and anchorages in small buses and mandates testing of the anchorages as outlined in Standard No. 210. Standard No. 210 requires in S4.2.1 that each seat belt assembly sustain a force application of 5,000 pounds. Where two adjacent seating positions have a common seat belt anchorage mounted on a seat frame, the two seat belt assemblies must simultaneously sustain a 5,000 pound force for a maximum load on the seat of 10,000 pounds.

Standard No. 207, Seating Systems, requires the simultaneous testing of all seat-mounted seat belt assemblies, whether or not they have common anchorages. However, Standard No. 207 is not applicable to school bus seats constructed in accordance with Standard No. 222, and it is not necessary to test simultaneously all seat belt assemblies attached to anchorages mounted on a school bus seat frame.

ID: 77-2.28

TYPE: INTERPRETATION-NHTSA

DATE: 05/04/77

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

TO: Hon. J. W. Wydler

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 21, 1977, requesting information concerning Federal regulations regarding school bus safety on behalf of your constituent, Mrs. Peter Peugeot of Rockville Centre, New York.

I have enclosed a document, "Summary Description of Motor Vehicle Safety Standards Applicable to Buses," which should be helpful to Mrs. Peugeot. I have also enclosed an information summary, "Where to Obtain Motor Vehicle Safety Standards and Regulations," along with a set of forms from our Technical Reference Branch indicating how specific information may be retrieved through computer assisted literature searches along with an outline of fees for this service.

In addition to the above material, I have enclosed an order form for the entire set of Federal motor vehicle safety standards and regulations, in case Mrs. Peugeot desires this specific volume. I would call her attention to the fact that although this document is relatively expensive, it is furnished in loose-leaf form and is updated periodically for an indefinite period with the latest amendments and changes at no additional cost.

I trust this information and material will be of value to Mrs. Peugeot. If I can be of further assistance, please do not hesitate to contact me.

SINCERELY,

Congress of the United States House of Representatives

April 21, 1977

Office of Congressional Liaison National Highway Traffic Safety Administration Department of Transportation

I have received a request from one of my constituents, Mrs. Peter Peugeot of Rockville Centre, New York, for a copy of the federal regulations regarding safety for school buses.

I would appreciate receiving the relevant regulations, and would also appreciate receiving any additional comments on this subject that you feel might be helpful or informative to Mrs. Peugeot.

Thanking you for your cooperation, and with every good wish, I am.

John W. Wydler Member of Congress

ID: 77-3.36

TYPE: INTERPRETATION-NHTSA

DATE: 07/29/77

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

TO: Cox Trailers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 7, 1977, informing us of your wish to relocate combination stop, tail, turn signal and side marker lamps "to the upper rear fender" of the boat trailers that you manufacture. You have asked whether this location complies with the requirements of Standard No. 108.

I am sorry that we cannot give you the interpretation you seek. Standard No. 108 requires that rear side marker lamps be mounted "as far to the rear as practicable," and stop, tail, and turn signal lamps must be mounted "on the rear." Even though, in your opinion, at your planned fender location "the lights will pass all of the required photometric and visibility requirements", when the trailer is carrying a boat the lamps are more likely to be visible "on the rear," as the standard requires.

SINCERELY,

July 7, 1977

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

With reference to Motor Vehicle Standard 108, we intend to relocate some of the combination stop, tail, turn and side marker lamps to the upper rear fender of our boat trailers. At this location the lights will pass all of the required photometric and visibility requirements.

We need from you an interpretation of the statement that "these lights must be mounted on the rear of the trailer". Could we use this mounting as long as these lights meet the other requirements and can be considered mounted as far to the rear as practicable. The distance from the rear would normally not exceed four (4) feet.

Our reasons for deviating from the rear most position on the trailer is due to trailer construction which makes rear mounting highly impractical.

Your prompt attention to this matter will be greatly appreciated.

COX TRAILERS, INC

William F. Cox President

ID: 1984-1.33

TYPE: INTERPRETATION-NHTSA

DATE: 04/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Wesbar Corporation -- C.I. Nielsen, III, Vice President, Marketing

TITLE: FMVSS INTERPRETATION

ATTACHMT: 10/28/70 letter from Roger H. Compton to E.W. Bernitt (L.W. Kermitt), Jeep Corporation

TEXT:

Mr. C. I. Nielsen III Vice President - Marketing Wesbar Corporation Box 577 West Bend, Wisconsin 53095

In response to your letter of February 16, 1984, I enclose a copy of the letter of October 28, 1970, to AMC that you requested. The interpretation remains valid. There is no charge for the letter.

Sincerely,

Frank Berndt Chief Counsel

Enclosure 10/28/70 letter from Roger H. Compton to E.W. Bernitt omitted here.

February 16, 1984

Gentlemen:

We are writing to you at this time to request a copy of a "letter of intent" regarding compliance with DOT-108 para S4.1.1.6 and S4.1.1.7.

It has been suggested we get a copy of this letter from you before proceeding on the design on a multi-function tail light.

The "letter of intent" we are referring to is Mr. Roger Compton's October 23, 1970 letter to AMC-Jeep regarding what area is considered "measurable" to meet the requirements.

If there is a charge for this requested copy, and it is under $25.00 please send the letter with the invoice and we will pay it promptly. If the charges are in excess of $25.00, please advise same before proceeding any further.

Thank you in advance for your prompt response to our request.

Sincerely,

WESBAR CORPORATION

C. I. Nielsen III Vice President -Marketing

CIN:mk

ID: 1983-3.34

TYPE: INTERPRETATION-NHTSA

DATE: 12/20/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Bertman; Johnson and Sahli

TITLE: FMVSS INTERPRETATION

TEXT:

John Bertman, Esq. Bertman, Johnson and Sahli 401 Twelfth Street (Route #54) P.O. BoX 440 Hammonton, New Jersey 08037-0440

Dear Mr. Bertman:

This responds to your recent letter to this office, seeking information on retreaded passenger car tires. You asked for the name of the retreader of a tire with the code letters "BJE" marked on the sidewall. That retreader is Trio Tire Service, Inc. of Clementon, New Jersey. You also asked if there were any regulations applicable to the retread of radial tires. All retreaded passenger car tires (whether bias or radial) must be certified by the retreader as complying with the requirements of Federal Motor Vehicle Safety Standard No. 117 (49 CFR S 571.117). I have enclosed a copy of the standard for your information.

Should you have any further questions or need further information in this area, please contact Mr. Stephen Kratzke of my staff at this address and at (202) 426-2992.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

October 10, 1983

Office of Chief Council National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 Re: Retread Radial Tire Bearing Markings: DOT R BJE R33 481 Our file no. 9479-1B

Gentlemen:

Will you please advise me of the manufacturer or the retread manufacturer of the tire bearing the above markings.

Please also advise me whether or not there are rules, regulations or standards regarding the retread of radial tires and forward a copy to me. If there is any charge, please advise.

Very truly yours,

John Bertman

ID: nht79-2.21

DATE: 08/31/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Halliburton Services

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Ron Bechtel Halliburton Services Drawer 1431 Duncan, Oklahoma 73533

Dear Mr. Bechtel:

This is in response to your letter of May 1, 1979, requesting an interpretation of the definition of "incomplete vehicle" contained in Federal Motor Vehicle Safety Standard No. 115, and in confirmation of your subsequent telephone conversations with Mr. Schwartz of my office.

The term "incomplete vehicle" is defined in S3 of the standard to mean "an assemblage consisting, as a minimum, of frame and chassis structure, power train, steering system, suspension system, and braking system, to the extent that those systems are to be part of the completed vehicle, that requires further manufacturing operations, other than the addition of readily attachable components, such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, to become a completed trailer."

You are correct in saying that most of the components listed in the definition are not meant to be part of a trailer. Consequently, an incomplete trailer would consist of only those components, such as a frame, listed in the definition which are meant to be part of the completed trailer. The outfitting of an incomplete trailer for a specific purpose would not be sufficient to make Halliburton Services responsible for assigning the vehicle identification number.

Sincerely,

Frank Berndt Chief Counsel

(405) 251-3565 May 1, 1979 RB-90-79

Office of Chief Council National Highway Traffic Safety Administration 400 7th Street, S.W. Washington, D.C. 20590

Dear Sir:

VIN Standards

I would like to request an interpretation as to the definition of an "incomplete vehicle" in regard to trailers. The definition as contained in S571.115(s)(3) is only applicable to powered vehicles as the stated minimum requirements are not relative to trailers.

Very truly yours,

Ron Bechtel

RB:im

ID: nht79-2.44

DATE: 03/27/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: L. B. Leiby

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 7, 1979, to the Department asking about the legality of wiring the rear hazard warning signals so that they automatically flash when the gear shift lever is placed in reverse.

We are able to give you guidance about applicable Federal law only. The Federal requirements for new motor vehicles are set forth in Federal Motor Vehicle Safety Standard No. 108 (49 Code of Federal Regulations 571.108). As you probably know, the hazard warning system and the turn signal system typically use the same lights. There is no provision in the standard which prohibits a manufacturer from wiring the rear hazard signals/turn lights so that they flash when the vehicle gear shift is in reverse. Please note, however, that the standard (S4.6(b)) requires the separate rear tail lamps to be steady burning. Thus, those lamps may not be wired so that they flash.

As for modification of used vehicles, contact the State in which the modified vehicle would be licensed and operated to determine if it has any applicable vehicle-in-use laws.

We appreciate your interest in motor vehicle safety.

SINCERELY,

7 February 1979

Dear Sir,

I am working on a concept which if legal and feasible, will, I believe, reduce accidents in parking areas.

The concept concerns the utilization of blinker lights normally used for highway emergency purposes to be wired to the backup lights circuit so that when the gear shift lever is placed in reverse, the red tail lights will automatically blink thus providing extra warning to oncoming drivers in parking areas.

Can you provide information as to the legality of the above concept, and please include any related factors.

Thank you.

Lawrence B. Leiby

ID: nht79-3.16

DATE: 11/14/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Performance Plus Products, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to the questions that you raised on October 23, 1979, with Ms. Debra Weiner of my office concerning the legal and technical issues arising from the manufacture of auxiliary fuel tanks for use in pickup trucks. You noted that you are going into the business of manufacturing auxiliary fuel tanks, that you will not be involved in the installation of such tanks, and that you would like any advice that we might be able to provide as to the construction standards that should be followed in manufacturing such tanks.

I have enclosed a copy of a letter which was sent to a company that planned to manufacture auxiliary fuel tanks for passenger cars and to do some installation. The legal principles enunciated in that letter are applicable to auxiliary fuel tanks intended for use in all types of motor vehicles except motor carriers in interstate commerce. Although your company is not planning to install auxiliary tanks, I think that you might find that the discussion of the legal issues that arise with respect to installation may be helpful in determining what safety margins should be built into these types of tanks.

As Ms. Weiner noted on the phone, this agency has not issued any standards applicable to the construction of auxiliary fuel tanks. However, the Federal Highway Administration, Bureau of Motor Carrier Safety has issued standards relevant to the construction of auxiliary fuel tanks for use in motor vehicles which are engaged in interstate commerce. I have enclosed a copy of these standards in hope that they will provide you with some suggestions as to what would constitute safe construction of an auxiliary fuel tank. In addition, the Society of Automotive Engineers has published standards pertinent to some aspects of the construction of fuel tanks. I have also enclosed copies of these.

I hope that you will find the enclosed material helpful. If you have any further questions, please feel free to contact Ms. Weiner for further information.

ID: nht81-2.36

DATE: 06/19/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bajaj Auto Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 25, 1981 with regard to turn signal pilot indicators on motorcycles.

You noted that the front turn signal lamps are directly in front of the operator and are fully visible. You therefore believe that a separate pilot indicator is unnecessary. You are correct. Pursuant to SAE Standard J588e Turn Signal Lamps, September 1970, incorporated by reference into Standard No. 108, no separate pilot indicator is required for Turn Signal Lamps that are "readily visible to the driver."

You have also pointed out that the motorcycle controls and displays standard, No. 123, "does not indicate the provisions and location of the Turn Signal Pilot Indicator." That is correct. Standard No. 108 and J588e establish the requirements for this item of vehicle equipment. I enclose a copy for your information.

ENC.

Date May 25, 1981

To

The Administrator National Highway Traffic Safety Administration 400, Seventh Street, S. W.,

Dear Sir,

We are manufacturing scooters which fall under the catagory of Class I Motorcycles. The scooters are provided with Turn Signal Lamps both at the front and rear. The front turn signal lamps are directly in front of the rider and are fully visible to the rider. In view of the fact that the front turn signal lamps are visible to the rider, we feel the same lamps can serve as a pilot indicator and provision of seperate pilot indicator is not necessary. Please let us know whether our contention is proper from the standards point of view.

In this connection we would like to bring to your kind attention that Standard No. 123 - Motorcycle Controls & Displays as well as the statement of compliance does not indicate the provision and location of the turn signal pilot indicator.

We are enclosing herewith the pamplet which shows the photograph of the vehicle. Thanking you

For BAJAJ AUTO LIMITED (M. S. KESHAV) MANAGER (R&D)

ID: nht81-2.8

DATE: 03/24/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: International Traders

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 17, 1981, letter in which you requested information from this agency concerning "the grading standards applicable to truck tires." We have issued Uniform Tire Quality Grading Standards (49 Code of Federal Regulations @ 575.104) for passenger car tires which specify labeling information concerning the tire's treadwear, traction and heat resistance. However, these grading standards apply only to passenger car tires and, therefore, would not be applicable to the truck tires you purchase.

There are, however, performance requirements applicable to truck tires, set forth in Federal Motor Vehicle Safety Standard No. 119 (49 Code of Federal Regulations @ 571.119), a copy of which is enclosed. The manufacturer of the truck tire must certify that the imported tire complies with the requirements of this standard by labeling the symbol "DOT" on the sidewall of the tire, according to the requirement of section S6.5(a) of the enclosed standard. This information may not be especially helpful to your company in comparing the price quotations, since every tire must have this certification to be legally imported into the United States.

Should you need any further information concerning the requirements applicable to truck tires, please feel free to contact Mr. Stephen Kratzke of my staff at (202) 426-2992.

Sincerely,

ATTACH.

INTERNATIONAL TRADERS

February 17, 1981

National Highway Traffic Safety Administration -- Chief Counsel

Dear Sir:

We are in the process of gathering quotations for the import of truck tires for resale to heavy hauling trucking companies in the United States. We would appreciate receiving from you the grading standards for these tires.

If you have any forms that are necessary for us to complete for you, please send these as well.

Thank you.

Very truly yours, Rusty D. Hitch