ID: nht74-4.8

DATE: 07/03/74

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

TO: Continental Hydraulic Hose Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 16, 1974, request for approval of Continental's banding technique to meet the requirements of Standard No. 106 Brake hoses, for labeling brake hose assemblies, and for use of the letter "C" to identify Continental as an assembly manufacturer.

The NHTSA interpretes a band as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. From this discussion, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of specific design.

The letter "C" has already been recorded with the Office of Standards Enforcement as the manufacturer designation for Continental Gummi-Werke A. G. of Germany. Please submit another choice to: Office of Standards Enforcement, "Brake Hose Identification", National Highway Traffic Safety Administration, 400 Seventh St. S.W., Washington, D.C. 20590.

Continental Hydraulic Hose Corp.

National Highway Traffic Safety Administration

Attention: Mr. Herlehy

Subject: MVSS-106 Docket 10

Dear Sir:

Continental Hydraulic Hose manufacture hydraulic brake hose assemblies. We also make the end fittings but purchase the hose. The fittings are permanently crimped in place.

Reference is made to paragraph S5.2.4 of Docket 10 which relates to labeling by the hose assembler. We propose:

1) That our designation be the letter "C".

2) That the band be a strip of adhesive backed vinyl tape wrapped securely around the skirt of one end fitting. The tape would be preprinted in 1/8" letters with:

DOT

C (our code) Month and year.

Please advise if the above is acceptable.

Sincerely,

James W. Long

ID: nht74-5.15

DATE: 02/28/74

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

TO: Mercedes-Benz of No. America

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 11, 1973, asking whether each of the following tire labeling formats used by the Michelin Tire Corporation complies with Motor Vehicle Safety Standard No. 109:

1. "2 steel tread plies/2 rayon body plies";

2. "max load 1,310 lbs at 36 psi max press."

We find that the first label format fails to conform to the standard. Paragraph S4.3(a) requires the tire to be labeled with, "the actual number of plies in the sidewall, and the actual number of plies in the tread area, if different." The labeling format used by Michelin creates the impression, contrary to the stated requirements, that the number of plies in the sidewall and the tread area is the same, viz. "2". We consider the body plies, running from bead to bead and lying under the plies in the tread area, to be counted also as plies in the tread area. Thus, the number of plies in the tread area is "4", 2 steel and 2 rayon. Moreover, while we understand the words "body plies" to be essentially synonymous with "sidewall plies", we feel there is little justification for departing from the words of the standard, which uses the word "sidewall" in referring to plies.

We find the second labeling format, that dealing with maximum permissible inflation pressure and maximum load rating, to conform to Standard No. 109. The words "permissible," "inflation," and "rating" are not essential to conformity as long as the appropriate values, clearly identified, are provided.

For your information, I point out that NHTSA test laboratories are without authority to interpret Federal motor vehicle safety standards or provide such interpretations to companies whose

products they test. Only interpretations issued in the form of correspondence signed by authorized NHTSA personnel or by notice published in the Federal Register are considered by this agency to be binding.

ID: nht74-5.45

DATE: 08/01/74

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

TO: Bayerische Motoren Werke AG

TITLE: FMVSS INTERPRETATION

TEXT: This responds to BMW's June 20, 1974, question whether 7/16-inch vacuum tubing may be manufactured and sold although it does not appear in Table V of Standard No. 106-74, and if so, what Table V values would be used in testing it.

Table V establishes test values for vacuum hose but does not limit the vacuum hose sizes which may be manufactured and sold in conformity with the standard. You are free to utilize 7/16-inch vacuum hose, and the Table V test values for 15/32-inch hose should be used to test 7/16-inch hose.

We are considering the addition of an entry in Table V to cover 7/16-inch hose in the near future.

YOURS TRULY,

Bayerische Motoren Werke KTIENGESELLSCHAFT

AIR MAIL

Docket Section

National Highway Traffic Safety Administration

June 20, 1974

Betreff: Standard 109; Vacuum Brake Hose Tests

With reference to Table V (38 FR 31308) of the subject standard, BMW would like to forward the comments and requests contained below.

Table V lists various values relating to vacuum brake hoses of different inside diameters. We are presently contemplating the use of such a hose whose I.D. is 11.1 mm, or 7/16 of an inch, which is not included in the table.

There is concern here that it may have been omitted if, for some reason, this size is not approved.

If use of the 7/16 inch size is permitted, we would like to have written statement to that effect - since it is not part of the present table - and would further request that, in the interest of completeness, this size be included in future tables.

Accordingly, we await your reply.

ppa. i.v.

(Kraft) (Fellerer)

ID: nht74-5.56

DATE: 06/06/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Hellstar Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 13, 1974, requesting information concerning the existence of any Federal Motor Vehicle Safety Standards applicable to auxiliary fuel tanks.

The National Highway Traffic Safety Administration has promulgated no motor vehicle safety standard relating to auxiliary fuel tanks. There is, however, a safety standard which imposes performance requirements upon motor vehicles with regard to their fuel systems. Thus, if installation of the auxiliary tank is accomplished prior to the first purchase of the vehicle for purposes other than resale causing the vehicle's fuel system not to be in compliance with the applicable safety standard, the person installing the tank or offering the vehicle for sale would be in violation of @ 108(a)(1) of the National Traffic and Motor Vehicle Safety Act. That would make the installer or seller subject to civil penalties of up to $ 1,000 for each violation.

The National Traffic and Motor Vehicle Safety Act authorizes the Secretary of Transportation to make a determination as to whether or not an item of motor vehicle equipment contains a defect which relates to motor vehicle safety. If he finds that a safety-related defect exists, he may compel the manufacturer to notify purchasers of the hazard. Therefore, even though auxiliary fuel tanks are not the subject of a standard, they still must be safely designed.

For your information, I have enclosed a copy of the Federal Safety Standard relating to motor vehicle fuel systems.

Enc.

HELLSTAR CORPORATION

May 13, 1974

U. S. Department of Transportation National Highway Traffic Administration

Hellstar is making auxilary gas tanks for pickups, which is added to the pickup after manufactured from original manufacturer.

What are the regulations and what standards do we have to meet? Is there any test requirement necessary?

Merle O. Roberts Controller

ID: nht75-1.11

DATE: 08/25/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: American Honda Motor Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: I am writing to confirm your telephone conversation of August 4, 1975, with Mark Schwimmer concerning the applicability of Federal Motor Vehicle Safety Standard No. 101, Control Location, Identification and Illumination, to an intermittent-operation windshield wiper switch.

Your letter of June 4, 1975, described such an intermittent operation switch which is distinct from the normal windshield wiper switch. As Mr. Schwimmer explained, Standard No. 101 requires neither illumination nor any particular location for this intermittent switch, because the normal switch is already subject to all of the standard's requirements.

SINCERELY,

June 4, 1975

Richard B. Dyson NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

This is to request your official interpretation as to the applicability of Federal Motor Vehicle Safety Standards in the case of an 'intermittent-operation' windshield wiper switch. The switch would be offered as a dealer installed option and is intended for use when driving in light rain.

I am enclosing photographs showing the recommended switch positions, photo A shows placement on vehicles fitted with air conditioning, photo B is without airconditioning. The location of the standard wiper switch is shown in both photos.

The optional switch has a non-illuminated control knob identified by a windshield wiper symbol and the letters 'INT'.

The switch will cause the wipers to operate intermittently, one stroke across the windshield and back to the parked position, at intervals ranging from 2 to 10 seconds depending upon the degree of rotation of the control from the 'ON' position. The intermittent operation switch will operate the wipers when the standard wiper switch is in the 'OFF' position; switching ON the standard switch will over-ride the intermittent operation.

I would appreciate your early response on this matter. Please contact me if you need further information.

AMERICAN HONDA MOTOR CO., INC.

Brian Gill Assistant Manager Safety & Environmental Activities (Graphics omitted)

ID: nht75-4.42

DATE: 05/14/75

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

TO: Massachusetts Department of Public Health

TITLE: FMVSS INTERPRETATION

TEXT: In response to your request of April 4, 1975, I am enclosing a copy of Federal Motor Vehicle Safety Standard No. 208, several Federal Register notices which have modified the basic standard, and the Motor Vehicle and Schoolbus Safety Amendments of 1974. Also enclosed is a circular explaining how all the safety standards and regulations of the National Highway Traffic Safety Administration (NHTSA) may be obtained.

Until October 29, 1974, section S4.1.2 of the standard required recognition interlock on 1974- and 1975-model passenger cars. As noted in the enclosed amendment (Docket 74-39, Notice 1), recent legislation mandated the deletion of this requirement, which was accomplished by NHTSA on October 29, 1974.

Manufacturers may now meet Standard No. 208 by providing (1) lap and shoulder belts at front outboard positions and lap belts at other positions, and (2) a continuous or flashing remainder light that operates only during the 4- to 8-second period after the ignition is operated and a continuous or intermittent audible warning signal which operates only during the 4- to 8-second period after the ignition is operated if the driver's lap belt is not in use. They may also provide certain types of "passive restraint" devices in place of the seat belt assemblies. Although the seat-belt interlock system is not prohibited, it is no longer a means of complying with the standard.

YOURS TRULY,

The Commonwealth of Massachusetts

Department of Public Health

April 4, 1975

National Highway Traffic Safety Administration

Please send to me a copy of your motor vehicle safety standard requiring ignition interlock for new cars. I would appreciate your sending, also, a copy of the Motor Vehicle and School Bus Safety Amendments of 1974.

Thank you for your help.

Benjamin Sachs, M.D., M.P.H. Associate Director Division of Local Health Services

ID: nht91-4.6

DATE: May 28, 1991

FROM: Roddy Williams -- Container Enterprise

TO: Paul J. Rice -- Chief Counsel, NHTSA

TITLE: Reference: FMVSS No. 115 Vehicle Identification

ATTACHMT: Attached to letter dated 7-12-91 from Paul Jackson Rice to Roddy Williams (A38; Std. 115; Part 571.7(f); VSA 108(a)(2)(A))

TEXT:

Container Enterprise is a chassis manufacturer in New Orleans, La. and is registered with S.A.E. to apply VIN numbers. We are presently converting container chassis from their original 23' length to a new length of 27' which will enable them to conform to the new Federal Bridge Formula.

Leasing companies have contracted us to modify these older chassis carrying a five digit VIN number. According to S.A.E., current regulations require a seventeen digit VIN number on any new and remanufactured productions. Any length change would also constitute a VIN number change.

Explanation of Modification:

The original chassis is 23' long. We remove the axles and half of the cross members on the original frame. We manufacture a 12' subframe and reinstall axles to the subframe. The subframe upon completion will extend the chassis length to 27'. The conversion will allow the chassis to slide open or closed.

Upon completion of modification, Container Enterprise will issue a new manufacturer plate with a new VIN number and date of remanufacture. A remanufacture certificate of orgin is sent to the leasing company and the leasing company registers the chassis.

It is our understanding after a telephone conversation with D. Nacoma with N.H.T.S.A. that the original manufacturer is no longer responsible after remanufacturing is completed. It is also our understanding that the remanufacturer assumes responsibility of the chassis meeting all of N.H.T.S.A. standards.

According to the Department of the Treasury Publication 510, Excise Taxes, Page 10, Heavy Trucks, Trailers, & Tractor: F.E.T. is not taxable on remanufactured equipment.

We feel that these procedures comply with all requirements and regulations. We would appreciate your review of these procedures and responding with any comments or opinions.

Should you require additional information or clarification, please contact me at your convenience.

ID: nht95-3.50

TYPE: INTERPRETATION-NHTSA

DATE: July 21, 1995

FROM: Heather Paul -- Executive Director, National Safe Kids Campaign

TO: Patricia Breslin, Ph.D. -- Director, Office of Vehicle Safety Standards, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 9/5/95 LETTER FROM JOHN WOMACK TO ANGELA MICKALIDE (REDBOOK 2; STD. 213; A43)

TEXT: Dear Dr. Breslin:

As you know, the National SAFE KIDS Campaign and its partners, the National Safety Council, the International Association of Chiefs of Police, and the State and Territorial Injury Prevention Directors Association, will be distributing approximately 38,00 0 child safety seats to families in need over the next few months.

This presents an ideal opportunity for research on the effectiveness of the child safety seat distribution process. The Campaign is submitting a written request to the National Highway Traffic Safety Administration for an interpretation of the Federal M otor Vehicle Safety Standard (FMVqSS) 213. Specifically, the Campaign is interested in modifying the uniform child restraint registration card to collect information about recipient families' sociodemographic profile, the type of cars in which the child safety seats would typically be installed in order to address incompatibility issues, and the comprehensiveness of the educational outreach at the distribution sites (see enclosed draft).

The Campaign would require the distribution site coordinators to complete the modified child [Illegible Word] registration card with the recipient family prior to distributing the child safety seat. This would yield almost a 100% child safety seat regis tration response rate which would allow NHTSA and the manufacturer to more readily notify families about recalls. Distribution site coordinators would mail the cards directly to the manufacturer, who would then tabulate the data for the Campaign's evalu ation research purposes.

Please call me or Dr. Angela Mickalide, Program Director, as soon as possible in order to resolve this important child safety matter. Thank you in advance for your timely response to the Campaign's request for an interpretation of FMVSS 213.

(Enclosure omitted.)

ID: nht95-5.29

TYPE: INTERPRETATION-NHTSA

DATE: July 21, 1995

FROM: Heather Paul -- Executive Director, National Safe Kids Campaign

TO: Patricia Breslin, Ph.D. -- Director, Office of Vehicle Safety Standards, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 9/5/95 LETTER FROM JOHN WOMACK TO ANGELA MICKALIDE (REDBOOK 2; STD. 213; A43)

TEXT: Dear Dr. Breslin:

As you know, the National SAFE KIDS Campaign and its partners, the National Safety Council, the International Association of Chiefs of Police, and the State and Territorial Injury Prevention Directors Association, will be distributing approximately 38,000 child safety seats to families in need over the next few months.

This presents an ideal opportunity for research on the effectiveness of the child safety seat distribution process. The Campaign is submitting a written request to the National Highway Traffic Safety Administration for an interpretation of the Federal Motor Vehicle Safety Standard (FMVqSS) 213. Specifically, the Campaign is interested in modifying the uniform child restraint registration card to collect information about recipient families' sociodemographic profile, the type of cars in which the child safety seats would typically be installed in order to address incompatibility issues, and the comprehensiveness of the educational outreach at the distribution sites (see enclosed draft).

The Campaign would require the distribution site coordinators to complete the modified child [Illegible Word] registration card with the recipient family prior to distributing the child safety seat. This would yield almost a 100% child safety seat registration response rate which would allow NHTSA and the manufacturer to more readily notify families about recalls. Distribution site coordinators would mail the cards directly to the manufacturer, who would then tabulate the data for the Campaign's evaluation research purposes.

Please call me or Dr. Angela Mickalide, Program Director, as soon as possible in order to resolve this important child safety matter. Thank you in advance for your timely response to the Campaign's request for an interpretation of FMVSS 213.

(Enclosure omitted.)

ID: nht67-1.18

DATE: 06/16/67

FROM: AUTHOR UNAVAILABLE: Robert M. O'Mahoney; NHTSA

TO: Peugeot, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: In answer to your letter of May 26, concerning Federal Motor Vehicle Safety Standards Nos. 208 and 210, your interpretation is correct: a four-passenger automobile (such an the Peugeot 404) must have two Type 2 seat belt assemblies for the front seat passengers if the windshield header is within the head impact area, two Type 1 or Type 2 sent belt assemblies for the front seat passengers if the windshied hender is not within the hand impact area, and two Type 1 seat belt assemblies for the rear seat passengers. However anchorages for Type 2 seat belt assemblies are required in the rear to enable the owner to install Type 2 seat belt assemblies should he desire to afford his rear seat passengers this means of protection.

May 26, 1967

Mr. O'Mahoney National Traffic Safety Agency United States Dept. of Commerce

Regarding our telephone conversation of May 26, I am in need of legal interpretation concerning Standards 208 and 210.

According to Standard 208, paragraph S3.1.1, Type 2 seat belt assembly should be installed in each outboard passenger car in the front seat position, including the windshield, within the impact area, which, in my mind includes the front seats only. Thus, the rear seats should have only Type 1 (lap belt).

From Standard 210, table 1, it seems to clearly indicate that we must have seal belt anchorages for a Type 2 seat belt in outboard seats in the rear, but it does not expressly state that the Type 2 seat belts should be installed in the outboard seats in the rear.

Would you kindly let me know if my interpretation is correct: on a 4-passenger car, we should have Type 2 seat belts in the front, Type 1 seat belts in the rear, but anchorages in the rear for Type 2 and Type 1 seat belts.

Thank you very much in advance for your reply.

Henri B. Combe Executive Vice President