ID: nht67-1.20

DATE: 10/02/67

FROM: AUTHOR UNAVAILABLE; George C. Neild; NHTSA

TO: Patton, Blew, Verrill, Krand and Boggs

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of August 10, 1967, you requested clarification of the application of Motor Vehicle Safety Standard No.(Illegible Word) to boat trailers.

Although a boat trailer does in some respect resemble a "pole trailer," it does not completely conform to the definition of a "pole trailer," as stated in Section 235.3 of the Initial Federal Motor Vehicle Safety Standards. This section states in part that a "pole trailer" is for transporting long or irregularly shaped loads such as poles, pipes, or structural members capable generally of sustaining themselves as(Illegible Word) between the supporting connections. The single load (a boat) on the boat trailer does not appear to meet these stated provisions of the definition.

The primary purpose of clearance and identification lights is to identify a vehicle that is 80 or more inches in overall width, regardless of the height of the vehicle. It should be noted, in this respect, that a "height-above-road-surface"(Illegible Word) for location of the lights is not specified in Standard No.(Illegible Word). Nevertheless, we have initiated a study to further determine the applicability of identification lights to best trailers.

With regard to your several questions on the use and location of side marker lights, it appears that each trailer model must be considered individually, particularly with respect to the front side marker lights. As you suggested, the extreme rear of the transverse marker provides a possible location for the rear side marker light. On those trailer models having a long transverse marker, it appears possible to locate the front side marker light on the extreme front side of the transverse marker. For those models having an extremely short transverse marker, it appears that a location as far forward as possible, exclusive of the trailer tongue, would meet the requirements of the standard.

Thank you for your interest in the motor vehicle safety standards.

ID: nht67-1.3

DATE: 08/17/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Fire Apparatus Manufacturers Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter addressed to Dr. Haddon, dated June 19, 1967, which has been referred to me for reply to your inquiry concerning the effect of Motor Vehicle Safety Standards on fire trucks.

The purpose of Standard No. 107 is to reduce the likelihood that unacceptable glare from reflecting surfaces in the driver's field of view will hinder the safe and normal operation of the motor vehicle. At present, paragraph S4, "Requirements," only covers windshield wiper arms and blades, inside windshield mouldings, horn ring and hub of the steering wheel, and inside rearview mirror frame and mounting bracket.

The initial Federal Motor Vehicle Safety Standards contain no mandatory requirement for seat belt installations or seat belt anchorages in trucks. However, if seat belts are installed in trucks they must conform to Motor Vehicle Safety Standard No. 209, effective March 1, 1967.

Sincerely,

FIRE APPARATUS MANUFACTURERS ASSOCIATION, INC.

June 19, 1967

William Haddon, Jr. Administrator National Traffic Safety Agency

Dear Dr. Haddon:

Our concern is about Motor Vehicle Safety Standard No. 107. In it view, glare, brightness, and reflection is set forth. Is the use of chrome prohibited because of its reflective qualities either inside the vehicle or on the outside of the vehicle? As you are aware, fire trucks have a considerable amount of chrome in their make-up.

One further question would be as to the seat belt assembly requirements. It is our understanding that only the anchoring point is necessary to be installed in the equipment as of March 1, 1967. The actual installation of the seat belt itself is an optional piece of equipment.

May we hear from you?

Very truly yours,

E.L. Koepenick Secretary-Treasurer

ID: nht68-1.1

DATE: 05/29/68

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

TO: Royal Brass, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 26, 1968, concerning certification of brake hoses. Hydraulic brake hose for use in passenger cars and multipurpose passenger vehicles manufactured after January 1 1968 must comply with Federal Motor Vehicle Safety Standard No. 106. Hydraulic Brake Hoses - Passenger Cars and Mutipurpose Passenger Vehicles.

At the time of delivery of the completed brake hose assembly to a distributor or dealer the manufacturer of the completed brake hose assembly must certify that it complies with the applicable standard. In the case of equipment such as the brake hose assembly the certification may be in the form of a label or tag on the completed brake hose assembly or on the outside of the container in which the brake hose assembly is delivered.

For your information I have enclosed a copy of the Federal Motor Vehicle Safety Standards, the notice published in the Federal Register concerning certification and a copy of the National Traffic and Motor Vehicle Safety Act of 1966. Particular attention should be paid to sections 108 and 114 of the Act.

I hope this letter and the enclosures are adequately responsive to your questions.

Sincerely,

April 26, 1968

U.S. Department of Transportation Federal Highway Administration

Attn: Robert M. O'Mahoney

Gentlemen:

We are manufacturer and distributor of automotive brass fittings, steel hydraulic fittings, hydraulic brake fittings, hydraulic brake hose assemblies, and make equipment for the assembly of hydraulic hoses and hydraulic brake hoses. The bulk brake hose is purchased from Inland Rubber Division of General Motors. All of our fittings are made to SAE specifications as shown in the SAE Handbook. What type of certification must we give to our customers? We sell to original equipment manufacturers, trucking companies, jobbers, and garages.

An early reply will be appreciated.

Very truly yours,

ROYAL BRASS, INC. -- R. R. McLain

Sales Manager

ID: nht69-1.45

DATE: 09/11/69

FROM: AUTHOR UNAVAILABLE; H. M. Jackin for W. M. Jacklin, Jr.; NHTSA

TO: Hon. W. Proxmire - U.S. Senate

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 27, 1969, to the Director, Legislative Liaison, Department of Transportation, concerning Mr. Eugene J. Shermeister's comments on headlamps for motor vehicles.

Enclosed for Mr. Shermeister's information is a copy of Federal Motor Vehicle Safety Standard No. 108 on lighting requirements for the vehicles specified in the standard. Standard No. 108 is applicable to new vehicles manufactured on or after the effective date of January 1, 1969. In accordance with the National Traffic and Motor Vehicle Safety Act of 1966, the initial safety standards were based on existing standards. Headlighting requirements, as specified in Standard No. 108, were therefore based on existing Bureau of Motor Carrier Safety Regulations, certain State regulations and the Society of Automotive Engineers (SAE) Standards. On this basis, Standard No. 108 specifies that headlamps for all vehicles except motorcycles conform to SAE Standards J579a and J580a, entitled, respectively, "Sealed Beam Headlamp Units for Motor Vehicles" and "Sealed Beam Headlamp." To provide protection from blinding effects to oncoming drivers, SAE Standard J579a specifies a maximum lamp output of 37,500 candlepower. This candlepower value is considerably less than the candlepower output of quartz iodine type headlamps.

As indicated in paragraph S2 of Standard No. 108, the standard is applicable to lighting on new vehicles and not to replacement lighting equipment. Except for vehicles subject to the Bureau of Motor Carrier Safety Regulations, the requirements for replacement lighting equipment, as well as lighting requirements for vehicles in use, are those requirements as set by the regulatory agencies of the individual states.

The National Highway Safety Bureau is sponsoring a research contract on improved forward lighting for motor vehicles. Results of this contract will not only provide us with well-founded data for use in amending the standard, but will also assist us in evaluating the relative merits of sealed beam, quartz iodine and other types of headlamps.

ENCLOSURE

ID: nht69-1.5

DATE: 05/01/69 EST

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Concorde Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 2, 1969, requesting a Department of Transportation (DOT) code number be assigned the Concorde Rubber Company. According to your letter, Concorde has tires manufactured for it by (Illegible Word) Tire and Rubber Company of Hadera, Israel, and by Lee Tire and Rubber Company of Conehehocken, Pennsylvania, which are labeled with Concorde's brand name and the manufacturer's code number (alliance Tire and Rubber Company uses approved code number DOT 187 and Lee Tire and Rubber Company uses approved code number 152).

Pursuant to Motor Vehicle Safety Standard No. 109, DOT numbers to be molded onto new tires, where a brand name is used rather than the manufacturer's own name, are assigned to tire manufacturers so the seller of the tire may identify the manufacturer to a purchaser upon request.

The legislative history of section 201 of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 4121) e.g., see 112 Cong. Rec. 18792 (daily ed. August 17, 1966), and the plain meaning of section 201 of the Act demonstrates that Congress intended to have tires made for sale under the private brand of a merchandiser bear the name or code mark of the concern that actually produces the tire, not merely an identification of the merchandiser distributing and selling the tires to the public.

The Act provides that tire labeling shall include "suitable identification of the manufacturer . . . unless the tire contains a brand name other than the name of the manufacturer in which case it shall also contain a code mark which would permit the seller of such tire to identify the manufacturer thereof to the purchaser upon his request." Accordingly, your request for the Concorde Rubber Company's own code number, so that tires manufactured for Concorde by different tire producers can have the same code number, must be denied.

ID: nht69-2.23

DATE: 09/08/69

FROM: AUTHOR UNAVAILABLE; C. D. Ferguson; NHTSA

TO: Caroline Nigro

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 30, 1969, concerning head restraints on your 1969 Pontiac Catalina.

Before Federal Motor Vehicle Safety Standard No. 202, which requires passenger cars manufactured on or after January 1, 1969, to be equipped with head restraints was issued, the issue you raise, that of the possibility of decreased visibility, was carefully considered. It was felt, however, that the possibility of a slight decrease in visibility, which may occur in certain passenger cars, was far cutweighed by the benefits to safety provided by head restraints.

In a study published by the Society of Automotive Engineers, and conducted by members of the Institute of Transportation and Traffic Engineers, U.C.L.A., it was concluded that (1) "Rear-end collisions are one of the most common types of accidents, and can cause crippling injuries even at low speed," and (2) "head restraints are as important to the motorist involved in rear-end collisions as the safety belt is to the motorist involved in front-end impact."

Furthermore, in the recent case of Sterling Products versus Boyd, in which the Federal Highway Administrator's iasuance of the head restraint standard was challenged and upheld, Judge McGovern of the Circuit Court of Appeals for the District of Columbia concludeds;

"In any event, we find substantial support in the record for conclusion that the contribution of head restriants to consumer safety is such as to warrant their inclusion in all newly manufactured motor cars. There can be no question but that the Administrater, on the besis of the submissions made to him, could reasonably determine that the benefits from mandatory head restraints for outweighed any disadvantage from such restraints due to decreased visibility, or other possible adverse effects upon safety."

Federal law does not prohibit you from removing head restraints. However, I strongly urge that you retain these safety devices in your vehicle for your own safety and protection.

ID: nht68-2.4

DATE: 05/16/68

FROM: ROGER H. COMPTON -- NHTSA; SIGNATURE BY DAVID A. FAY

TO: White Trucks, Division of White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 20, 1968, to Mr. Lowell Z. Bridwell, requesting clarification of paragraph S3.4.3 of Federal Motor Vehicle Safety Standard No. 109.

In your referenced letter you have asked two questions as follows:

"1. While we provide as standard on all tractor models built on or after January 1, 1968, a 7-wire trailer connection and cable, is it satisfactory to furnish the 3-wire cable and connector being requested by many customer? Would we still be considered as conforming to Standard No. 103 with such a cable and contector?

2. Upon customer request, will we still be considered as conforming to the requirements of Standard No. 103 if, in addition to providing the standard double pole double throw switch which would actuate the brown circuit for the tail, clearance and certain marker lights on the trailer, we also furnish a separate switch for the black circuit on the trailer which would illeminate the remainder of the running lights, provided the trailer was wired in accordance with SAE Recommended Practice J560A."

In answer to question No. 1, either the 7-wire or 6-wire trailer connection and cable may be used on truck-tractors, provided the wiring is such that trailer tail lamps will be illuminated when the truck-tractor headlamps are illuminated. It is also to be noted that Standard No. 105 does not specify the number of wires to be used in the trailer connector and cable.

In answer to question No. 2, on trailers wired in accordance with SAE Recommended Practice J560a, a seperate switch for the black circuit on the trailer is permitted under the provisions of Standard No. 103. Again, the wiring and switching for the brown circuit must provide illumination of the tail lamps when the headlamps are illuminated.

The above answer also appear to be responsive to the questions raised in your letter of March 14, 1963.

Thank you for writing.

ID: nht68-2.8

DATE: 05/15/68

FROM: JOSEPH R. O'GORMAN -- NHTSA SIGNATURE BY ANDREW K. NESS

TO: Cheetah Coaches

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 19, 1967, to the National Highway Safety Bureau, in which you request information governing vehicle width and safety glass installation requirements on the vehicles you manufacture.

Regarding your question on vehicle width, Safety Standard No. 108 relative to lamps, reflectors and associated equipment, for specified vehicles 80 or more inches wide overall, defines the term "overall width" as the nominal design dimension of the widest part of the vehicle, exclusive of signal lamps, marker lamps, outside rear view mirrors, flexible fender extensions and mud flaps, determined with doors and windows closed and the wheels in the straight ahead position. Therefore, if your vehicle measures less than the Safety Standard No. 108 requires, compliance is not required.

Your question regarding installation of safety glass as specified by Safety Standard No. 205, relative to Glazing Materials, can be answered by directing your attention to Standard No. 205. It specifies adherence by a multi-purpose Passenger Vehicle, a category into which your pick-up campers fall. A copy of the Federal Register, Volume 32, No. 23 and amendment to this regulation, Volume 32, No. 131, is enclosed for your information.

The application of Safety Standard No. 205 to pick-ups, is covered by the enclosed Federal Register, Volume 33, No. 59.

Thank you for your cooperation and response to the Federal Highway Administration request regarding the certification requirement.

The label sample and information as to its location that you have provided will be very useful to us, however, in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with the serial indentification system in order that vehicles manufactured (completed) after January 1, 1968, can be identified.

Your interest in the safety program of the Bureau is appreciated.

ID: nht68-3.12

DATE: 01/26/68

FROM: AUTHOR UNAVAILABLE; Roger H. Compton: NHTSA

TO: Fire Department, Lynn, Massachusetts

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 12, 1967, you questioned several requirements of Initial Motor Vehicle Safety Standard No. 108 as applied to fire trucks.

Paragraph S3.1.1.3, which permits the installation of additional equipment if it does not impair the effectiveness of the required equipment, will not prohibit the installation of rotary flashing lights on fire trucks. Therefore, a waiver of this clause is not necessary for fire trucks.

Paragraph S3.5 a revised by the latest amendment to Standard No. 108, and issued December 11, 1967, (copy enclosed), permits the flashing of steady-burning lamps for signalling purposes. Therefore, the flashing of side marker and clearance lamps on fire trucks to signify an emergency vehicle will not be prohibited by the requirements of this paragraph.

Standard No. 108 does not require that front identification lamps be located on the roof of the vehicle cab, but only that they be "as near as practicable to(Illegible Word) vertical centerlines." If, however, they are mounted on the upper body structure, "no part of the lamps or mountings may extend below the top of the vehicle's windshield." This mounting flexibility will permit a selective location of identification lamps and rotary warning lamps which will not cause the rotary lamps to blot out the identification lamps. Also to be considered is the effectiveness of the identification lamps when the vehicle is operated on the highway and without illumination of the rotary lamps. Therefore, fire trucks need not be excepted from the requirement for front identification lamps.

Rear identification lamps mounted on the edge of or under the rear step of a fire truck will meet the location requirements as specified in Standard No. 108. Adequate guards or protective shields are available and commonly used on lamps located in these positions. Therefore, fire trucks need not be excepted from the requirement for rear identification lamps.

If you have any further comments or questions on the requirements of Standard No. 108, I hope you will let us know.

ID: nht68-3.19

DATE: 03/25/68

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

TO: Renault

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 1, 1967, concerning tests made on the Renault 10 model for compliance with Federal Motor Vehicle Safety Standard No. 203.

We recognise the validity of a system which takes advantage of the energy absorbing characteristics of the surrounding vehicle structure as on alternative to the more conventional approach of employing on energy absorbing column and/or wheel. As you mentioned, SAE J944 was not written with that type of energy absorbing system in mind. The structure which you intend to employ to provide the energy absorbing requirements specified in Federal Motor Vehicle Safety Standard No. 203 might in reality first be severely stressed and deformed in a crash eltuation. Therefore any laboratory test used to evaluate such a system should recognize this detrimental influence. In the event that you would wish to submit a proposed alternative test procedure which incorporates a barrier test is specified in Standard No. 204 prior to testing for compliance with Standard No. 203, we would be pleased to consider such a request.

Your second point concerns the need for a more explicit definition of translational motion. SAE J944 states that the body-block contacts the wheel in translational motion. It does not say that this motion must continue after impacting the wheel. Your magnetic release mechanism appears to impart approximately translational motion to the body-block at impact and is a satisfactory procedure. The fact that the body-block is free to rotate forward after impact is a stimulation of an actual crash situation and the body-block was not intended by SAE J944 to be restrained in translational motion after impact. Since the body motion in on actual crash situation will very somewhat the Bureau feels that a more explicity definition of translational motion is unnecessary.

The third series of tests as described in Report No. 287.397 using a right test fixture and the free flying body-block are compatible with the SAE J944 test procedure.

Your interest in motor vehicle safety is appreciated.