ID: nht76-4.40

DATE: 03/10/76

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

TO: Monsanto Polymers and Petrochemicals Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of December 22, 1975, to Mr. Guy Hunter of my staff, concerning our reasons for prohibiting the use of tempered glass in windshields of motor vehicles.

The use of tempered glass in windshields is prohibited for the following reasons:

1. Tempered glass has little, if any, energy absorbing capability while laminated glass has intrinsic deflective characteristics that provide such capability.

2. When tempered glass breaks, it usually either "crazes" or shatters into many small pieces. If crazing occurs, the driver's vision becomes obscured thus not only endangering himself but others as well. If the glass shatters, the driver and other vehicle occupants are showered with glass pellets which could not only result in loss of control of the vehicle but is also likely to cause eye injuries.

3. When cracked, tempered glass has essentially no retentive capability, thus the likelihood of occupant ejection through the windshield opening is greatly increased in crash situations. Laminated glass, on the other hand, possesses significant retentive capability even after initial cracking of the glass laminate on either side of the plastic interlayer.

If I can be of further help, do not hesitate to contact me.

Sincerely,

MONSANTO POLYMERS & PETROCHEMICALS CO.

December 22, 1975

Guy Hunter -- National Highway Traffic Safety Admin.

Dear Guy:

Our Monsanto Europe associates receive, from time to time, inquiries from a variety of industry and independent sources concerning NHTSA's position on the question of tempered vs. laminated HPR windshields. While I am aware of your position in this matter, would you be willing to document your feelings in a letter which I could distribute to our associates.

Should you agree, it would be appreciated if you could define the reasons for which NHTSA would be opposed to permitting tempered windshield use in the American market, and perhaps include an endorsement of the HPR windshield.

Thank you for your assistance.

Kindest regards,

E. Lacey -- Industry Technical Specialist, Laminated Glass

ID: nht76-5.1

DATE: 01/23/76

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

TO: AB Stil-Industri

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Stil-Industri's December 12, 1975, question whether S5.2(d)(1) of Standard No. 209, Seat Belt Assemblies, specifies, in the case of a push-button release, the location and direction of force application used in testing the release under the requirements of S4.3(d)(1). Section S5.2(d)(1) provides in part:

(1) . . .The buckle release force shall be measured by applying a force on the buckle in a manner and direction typical of those which would be employed by a seatbelt occupant. For pushbutton-release buckles, the force shall be applied at least 0.125 inch from the edge of the push-button access opening of the buckle in a direction that produces maximum releasing effect. . .

The NHTSA interprets these provisions of S5.2(d)(1) to permit the manufacturer to apply force in the direction and location that provides the best possible mechanical advantage relative to the manufacturer's buckle design. The only limitation in the case of a push-button design is that the manufacturer must not apply the force any closer than 0.125 inch from the edge of the push-button access opening.

Yours truly,

ATTACH.

CHIEF COUNSEL -- NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

DECEMBER 12, 1975

GENTLEMEN,

WE ARE A SWEDISH COMPANY PRODUCING SAFETY-BELTS FOR DIFFERENT CARS AND ALL DIFFERENT MARKETS. WE WOULD KINDLY ASK YOU TO HELP US WITH SOME QUESTIONS WE HAVE ABOUT HOW TO INTERPRET SECTION (1) IN S.5.2 (D) ABOUT BUCKLE RELEASE.

FROM THE PASSAGE: "THE BUCKLE RELEASE FORCE SHALL BE. . . . .TO:. .. RELEASING EFFECT". WE WOULD LIKE TO ASK YOU THE FOLLOWING QUESTIONS. WHERE ON THE PUSH BUTTON SHALL WE APPLY THE FORCE? IN A POSITION WHICH IS TYPICAL FOR THE SEAT BELT OCCUPANT? IN THE CENTER? 1/8 INCH FROM WHICH EDGE? IN WHAT DIRECTION? THESE QUESTIONS ARE OF GREAT IMPORTANCE FOR US AND WE AWAIT YOUR REPLY WITH GREAT INTEREST. WE ARE VERY GREATFUL IF YOU COULD ANSWER AS SOON AS POSSIBLE.

SINCERELY YOURS AB STIL-INDUSTRI; HANS SYLVEN -- CHIEF OF CONSTRUCTION

ID: nht74-3.22

DATE: 10/07/74

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

TO: Diamond Reo Trucks, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 13, 1974, question whether building a motor vehicle from a used power train (rear axle, suspension, drive line, and engine) and a new "glider kit" constitutes the manufacture of a new motor vehicle, subject to Federal motor vehicle safety standards, including Standard No. 121 after March 1, 1975. Typically, a "glider kit" is a truck chassis on which a cab and front axle system are mounted, which is purchased to permit the re-utilization of a power train from another vehicle.

Re-use of components from an existing vehicle in the construction of another vehicle may or may not result in the manufacture of a new vehicle. The NHTSA has established that the addition of new components (such as a truck body) to the chassis of a used vehicle does not constitute the manufacture of a new vehicle. Conversely, the addition of used components to a new chassis which has never been certified in a vehicle constitutes the manufacture of a new vehicle, subject to the safety standards in effect for that vehicle class on the date of manufacture. This criterion has been relied on in the area of chassis-cab multistage manufacture.

Since a glider kit typically incorporates a new chassis (as well as a new cab and front suspension), the NHTSA finds that the use of such a glider kit in the construction of a motor vehicle constitutes the manufacture of a new motor vehicle. To conclude otherwise would mean that a vehicle composed entirely of brand new components except the rear axle and perhaps the engine and transmission, would qualify as a used vehicle.

You noted that our decision could eliminate the use of glider kits because Standard No. 121 certification would prevent re-use of rear axles which do not meet 121-level performance requirements. We believe that our determination will contribute to motor vehicle safety by introducing more 121-type vehicles on the highway and will not interfere with the use of glider kits in the long term. Glider kits can be made to meet Standard No. 121 as soon as 121-type rear axles become available on the used market. Until that time, the rear axles of present vehicles may be utilized as replacement parts in used vehicles which are not required to meet Standard No. 121.

ID: nht74-3.39

DATE: 05/06/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Rozner and Yorty

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 26, 1974, request for information on seat belt regulations as they concern reclining passenger seats.

Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, requires passenger cars to be equipped with seat belt assemblies, but it does not contain performance requirements to regulate the effectiveness of the belt assembly with the seating system in the reclining position.

Federal Motor Vehicle Safety Standard No. 207, Seating Systems, specifies minimum safety requirements for motor vehicle seats. The requirements of the standard are based on conventional seat designs that normally incorporate a seat back angle of approximately 25 degrees rearward inclination from the vertical. Standard No. 207 requires that reclining seats be tested in their most upright position and does not require seats to be tested in the reclining position.

The National Traffic and Motor Vehicle Safety Act of 1966 preempts state motor vehicle safety regulations which are not identical to the Federal standards with regard to the same aspect of performance and therefore any state law would be identical to Standards Nos. 207 and 208 on these aspects of performance (15 U.S.C. @ 1392 (d)).

The engineering staff is not aware of any studies in the area of seat belts and reclining seats.

Yours truly,

ROZNER AND YORTY

March 26, 1974

National Highway Traffic Safety Admin.

Re: Three point restraint on reclining passenger seat

Gentlemen:

I represent a passenger who was injured while she was sleeping in a bed-like reclining passenger seat. She slid out the back. She had a conventional seat belt on, but it did not help.

Are there any regulations either in the past or the future that would apply to this situation, either State or Federal? Have there been any studies on this subject or any interest in this subject. I shall appreciate whatever help you can give me.

Very truly yours,

William A. Goichman

ID: nht74-4.28

DATE: 07/03/74

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

TO: The Bendix Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 29, 1974, request for approval of your banding designs to meet the requirements of Standard No. 106, Brake hoses, for labeling brake hose assemblies.

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 these statements, 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 any design.

Yours Truly,

Bendix

Heavy Vehicle Systems Group

National Highway Traffic Safety Admin.

Docket Section, Room 5219

400 Seventh Street, S.W.

Washington, D.C. 20590

April 29, 1974

Subject: Docket 1-5, Notice 8 & 10, Standard 106

Reference: @ 5.2.4 of Notice 8; Page 7426, Second Paragraph of Notice 10

Gentlemen:

Attached are prints of our Dwgs. 247650 and 245353 showing a date band and a date ring for hose assemblies as used to date. The band is wrapped around the hose, the narrower portion fed into the slot and folded over. The ring is slid over the hose prior to assembly of the fittings.

In both cases, the part is held captive between the fitings of the hose assembly.

An interpretation would be appreciated as to whether both dating methods fulfill the intent of Standard 106 referenced material.

Yours truly,

F. R. Schubert

Enclosures

(Graphics omitted)

DATE BAND BLANK

HOSE ASSEMBLY

BENDIX-WESTEICHO AUTOMOTIVE AIR BRAKE CO.

(Graphics omitted)

DATE RING FOR HOSE

BENDIX-WESTINCHOUSE AUTOMOTIVE AIR BRAKE CO.

ID: nht74-4.41

DATE: 01/11/74

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

TO: Corner Sterling & Machell Avenues

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 21, 1973 to "U.S. Bureau of Safety" expressing your view that "the automobile industry should . . . have some type of clutch to reverse action when the closing motion of the (power) window meets any resistance."

I enclose a copy of Federal Motor Vehicle Safety Standard No. 118 Power-Operated Window Systems which has applied to all passenger cars and multipurpose passenger vehicles with power windows manufactured since February 1, 1971. The objective of the standard is to minimize the likelihood of injury or death occurring when a person is caught between a closing window and its frame, channel, or seat. The NHTSA determined that the most cost-effective way to accomplish this objective was by prohibiting operation of power windows when the ignition key is either in the ignition "off" position or removed. As you will see from the enclosure, consideration was given to mechanisms that would reverse the direction of the window.

We appreciate your interest in motor vehicle safety.

ENC.

December 11, 1973

Dr. Irvin Jacobs, M.D.

The circumstance and comment in your letter of November 21, 1973, regarding automatic window closing operation is noted. The matter is deemed to be in the jurisdiction of the U. S. Department of Transportation (DOT). Therefore, we are forwarding your letter with a copy of this acknowledgement to DOT for their attention and an appropriate reply.

JOHN J. KLOCKO Chief, Materials Handling Technology Center

cc: FMSMUSS-118 U.S. Dept. of Transportation

November 21, 1973

U. S. Bureau of Safety Washington D. C.

Gentlemen:

Recently one of our young patients was brought in after having his head caught in the window of a car door after the automatic window closing operation had been started. Fortunately, this was not a serious accident; however, it could have been.

It seems the automobile industry should be prevailed upon to have some type of clutch to reverse action when the closing motion of the window meets any resistance.

Sincerely,

IRVIN JACOBS, M.D.

ID: nht73-1.10

DATE: 07/23/73

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

TO: Mr. Gorou Utsunomiya

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 11, 1973, regarding the application of section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1403) to Motor Vehicle Safety Standard No. 107 "Reflecting Surfaces". You refer to language in a letter dated April 10, 1973, from this agency to Mr. Kazushi Sakashita of Toyo Kogyo., Ltd., in which we indicated that certification of replacement vehicle parts pursuant to section 114 is required only with respect to parts to which a safety standard specifically applies.

Standard No. 107 applies to motor vehicles -- passenger cars, multipurpose passenger vehicles, trucks, and buses (paragraph S2 of Standard No. 107) -- and not to items of motor vehicle equipment. Consequently the certification of conformity to the standard required by section 114 is accomplished by the label affixed to each vehicle in accordance with 49 CFR Part 567, "Certification". That label represents a certification of conformity to all standards, including Standard No. 107, applicable to the vehicle. There is no requirement that the individual components listed in S4 of the standard, i.e. the windshield wiper arms and blades, the inside windshield moldings, the horn ring and hub of the steering wheel assembly, and the inside rearview mirror frame and mounting bracket, be certified independently.

Yours truly,

June 11, 1973

Richard B. Dyson -- Assistant Chief Counsel, National Highway Traffic Safety Administrator, U.S. Government of Transportation

Dear Mr. Dyson:

Re: Replacement Vehicle Parts.

Enclosed is a letter from NHTSA, which states:

"There are no requirements for the certification of replacement vehicle parts, unless the parts themselves are subject to a safety standard. At present, Standards Nos. 106, 108, 109, 116, 117, 205, 211, and 213 apply to items of motor vehicle equipment subject to these standards that certification is required under Section 114 of the National Traffic and Motor Vehicle Safety Act."

By the way, is MVSS 107 Reflecting Surfaces, a requirement under S. 114 of Safety Act, or not? Your answer to this question would be appreciated. Thank you.

Yours truly

Gorou Utsunomiya --

Branch Manager,

Toyo Kogyo U.S.A. Representative Office

ID: nht73-1.11

DATE: 09/27/73

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

TO: Southwestern Transportation Company

TITLE: FMVSS INTERPRETATION

TEXT:

This is in reply to your letter of July 18, 1973, requesting information on an NHTSA ruling that you understand prohibits tire companies from surrendering damaged tires to carriers for salvage purposes.

The NHTSA has not issued a ruling in the precise terms you describe. However, a recent amendment (copy enclosed) to the Federal motor vehicle safety standard applicable to passenger car tires, Standard No. 109, could be viewed as having that effect. That amendment prohibits the sale, the offer for sale, or the introduction or delivery for introduction in interstate commerce of any tire designed for use on a passenger car that fails to meet the requirements of the standard, unless the tire is altered so that it cannot be used or repaired for use on a motor vehicle (including a trailer). Tire manufacturers may be understandably reluctant to claim that damaged tires will still conform to the safety standard, and when that is the case they cannot sell them unless they are altered so that their use as motor vehicle equipment is prevented. This may reduce their value for salvage purposes. There is no specific prohibition to their surrender for use as salvage, however, and they may have salvage value if a purpose, such as scrap, unrelated to motor vehicles, is intended for them.

Sincerely,

Enclosure

Southwestern Transportation company

July 18, 1973

Department of Transportation Federal Highway Administration Washington, D.C. 20590

Gentlemen:

We recently received a claim from Firestone Tire & Rubber Company for damage to a passenger tire. Since they were claiming the full value of the tire, we questioned them concerning salvage. They replied by stating that the Department of Transportation ruled that tire companies could no longer surrender damaged tires to any carrier for salvage purposes.

As we are not familiar with this ruling, we would appreciate your furnishing us with a copy. Thanking you in advance for your cooperation.

Yours truly, C. C. King

MGR. OF FREIGHT CLAIMS

ID: nht73-1.41

DATE: 06/28/73

FROM: Richard B. Dyson; NHTSA

TO: Transportation Sash Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 21, 1973, requesting that we clarify the certification and marking requirements for glazing materials. You indicate that you purchase block size glass and cut it to suit your customers.

The requirements to which you refer are found in Federal Motor Vehicle Safety Standard No. 205, "Glazing Materials" (49 CFR @571.205). They require each item of glazing material to be labeled with certain information, that specified in section [Illegible Number] of ANS @26.1-1966, which includes the manufacturer's trademark, the symbol AS or the words American Standard, a model number, and a reference, in the form of a number, that indicates the type of glazing material. All glazing materials for use in motor vehicles must be labeled with this information, which can be stencilled onto the material if it is removed during the cutting process.

In addition to these identifying markings, each item of glazing material must be certified as conforming to the Federal standard. Prime glazing material manufacturers (those who fabricate, laminate, or temper the glazing material) certify glazing that is designed for use in any specific vehicle by including with the above markings the symbol DOT and a code number assigned to the manufacturer by this agency. Glazing that is not designed for a specific vehicle is certified pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), which includes, as you indicate, the use of a label or tag affixed to the glazing material that states that the material conforms to all applicable Federal motor vehicle safety standards. Manufacturers other than prime glazing material manufacturers, such as those, like yourself, who cut larger sheets to size, are required to certify in the same fashion; that is, in accordance with section 114, and may certify by labels or tags affixed to the material.

I have enclosed a copy of the marking requirements of Standard No. 205 for your information. If you wish to obtain a copy of the American National Standard @@26.1-1966, you should write to the American National Standards Institute, 1430 Broadway, New York, New York 10018.

ID: nht73-2.18

DATE: 04/24/73

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

TO: Flex-N-Gate

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of April 17, 1973 to Mr. Schneider you ask whether the Federal lighting standard, No. 108, applies to you as a manufacturer of rear step-hitch bumpers for pick-up trucks. Since the bumper installation interferes with the original vehicle license plate mounting bracket, provision is made for relocating the license plate mounting bracket, provision is made for relocating the license plate in the bumper. You apparently do not yourself mount the bumper to the vehicle, as your letter indicates that they are sold as after market items "to purchasers of new trucks" and to two truck manufacturers "who install these items before the trucks are released to the dealers".

Under the circumstances you describe, Standard No. 108 would not apply to you. Compliance and certification of new vehicles is the responsibility of the truck manufacturers who install the bumpers, although you may have a contractual obligation with them to provide license plate lighting meeting Federal requirements. In the aftermarket, if the bumper is installed prior to delivery of the truck to the purchaser, the dealer making the installation is legally responsible for compliance with Standard No. 108.

Yours truly,

April 17, 1973

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

Dear Mr. Schnieder:

We manufacture rear step-hitch bumpers for pick-up trucks, and market them through dealers who sell them as add on accessories to purchasers of new trucks. We also are an O.E.M. supplier to Jeep Corporation and Toyota who install these items before the trucks are released to the dealers. As the bumper installation interferes with the original license light mounting bracket on the vehicle we make provisions for relocating the license plate onto the bumper (see attached brochure).

I would like to get your interpretation of Standard 108, i.e. whether it applies to us or not, if it does then the proper way of certifying that the license lights meet the federal requirements.

Sincerely,

SHAHID R. KHAN Engineer -- FLEX-N-GATE (Graphics omitted)