ID: nht68-2.49

DATE: 09/04/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: General Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 1, 1968, to Messrs. Eugene Laskin and J. E. Leysath of this Bureau, requesting comments on the Distributors Association's bulletins on lamps, reflective devices and associated equipment required by Motor Vehicle Safety Standard No. 108.

The five bulletins adequately illustrate the requirements of Standard No. 108 to the vehicles shown except as follows:

(1) Pages 1, 3, and 4 -- The statement "Identification, clearance and side market lights and side and rear reflectors are not required unless vehicle with body is 80 or more inches wide overall" should be changed, because Table III of Standard No. 108, effective January 1, 1969, specifics requirements for side marker lights and side and rear reflex reflectors on vehicles less than 80 inches wide.

(2) Page 2 -- The numbers indicating clearance and identification lamps in lower right view should be reversed, i.e., 10 and 11, respectively. Also, the turn, tail and stop lamps do not appear to be located as far apart as practicable.

(3) Page 4 -- The front clearance lamps mounted on the chassis cab are optional, because those on the van body meet the requirements of Standard No. 103.

(4) Page 5 -- (a) Identification and clearance lamps are not required if vehicle width is under 80 inches. (b) Two red reflectors are required on the rear of the vehicle.

(5) General, all pages -- Paragraph S3.1.1.6 permits vehicles less than 80 inches overall width manufactured before January 1, 1970, to be equipped with a combination of two side marker lamps and side marker reflectors on each side instead of two each as specified in Table III.

(6) General, Pages 1 through 4 -- Parking lamps are not required on vehicles that are 80 inches or were in overall width.

With respect to the requirements of Standard No. 108, this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying hat the assembled vehicle meets the requirements of the standard.

ID: nht68-3.15

DATE: 05/15/68

FROM: AUTHOR UNAVAILABLE; William Hadden, Jr.; NHTSA

TO: Mercedes Benz of America, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your telegram of May 3, 1968, concerning the use of tabular-type bulbs to back the requirements of Federal Motor Vehicle Safety Standard No. 108.

Paragraph S3.1 and Tables I and III of Standard No. 108, as amended (32 F.D. 13933, December 10, 1967), specify that certain lamp assemblies such as license plate lamps, backup lamps and tail lamps, shall conform to the basic SAE Standards for the lamp assemblies. These basic standards in turn refer to SAE Standard 7573 on bulbs and to SAE Standard 3567 on bulb sockets. This relationship between the basically referenced standards and subreferenced standards has been the subject of prior communications with the industry and appears to be in need of clarification.

The basically referenced SAE Standards also refer to SAE Standard J575, "Test for Motor Vehicle Lighting Devices and Components." Paragraph "C" of SAE Standard J575 states in part as follows: "Where special bulbs are specified, they should be submitted with the devices and the same or similar bulbs used in the tests and operated at their rated mean epherical candlepower." This provision of SAE Standard J575 permits the use of special bulbs, including tubular-type bulbs, which do not conform to the detailed requirements of Table I of SAE Standard J573. It also follows that the sockets for these special bulbs need not conform to SAE Standard J567. I must emphasize, however, that these provisions for special bulbs in no way except the lamp assemblies from testing all performance requirements specified in Standard No. 108, including those specified in the basically referenced SAE Standards and in subreferences SAE Standard J575.

In view of the several inquiries we have resolved on this particular(Illegible Word) of the requirements of Standard No. 108, we anticipate that an official interpretation, providing the clarification presented in this letter, will be published in the Federal Register in the near future.

Thank you for your continued interest in the Federal Motor Vehicle Safety Standards.

ID: nht68-3.8

DATE: 01/14/68

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

TO: The Armstrong Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Bridwell has asked that I reply to your letter of December 5, 1967, which asks if the labeling requirements of S4.3 of Standard No. 109, can be complied with by placing some of the information on one sidewall of a tire and other information on the other sidewall.

The Standard requires that all of the labeling information be on both sidewalls and placing some of the necessary information on one sidewall of the tire and some on the other would not satisfy this requirement.

The standard provides that until August 1, 1968, the labeling requirements of S4.3 may be met by affixing to each tire a label or tag that incorporate all specified information not molded into or onto the tire."

THE ARMSTRONG RUBBER COMPANY

December 5, 1967

Mr. L.K. Bridwell Federal Highway Administrator National Highway Safety Bureau

Ref: Labeling of Tires where S.4.3 Requirements Appear on One Side of the Tire Only.

The mechanics of complying with the labeling requirements of S.4.3 MVSS No. 109 can become very cumbersome and expensive.

Here was our thinking over a year ago - we placed all the required information on what would be the white sidewall part of the mold, leaving the black side free to add that which would be required by the U.S. Department of Transportation, in the standards which we now have.

The attached sheet with this explanation will reveal the problem. Label No. 1 is basic. Labels 2 to 11 inclusive would have to be added to the tire. The workmen would first affix the basic label than a label to supply this missing information. As can be seen there are 56 sizes involved and ten other labels which shows a basic of conbinations to be 560.

We request an early reply whether labels are required, when the information already appears on one sidewall, except the basic label. It is also our feeling that labeling is not a serious requirement to meet minimum safety standards.

R.L. Donnelly Corporate Secretary

ID: nht68-4.7

DATE: 09/02/68

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

TO: General Supply and Equipment Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 7, 1969, to the Federal Highway Administration, concerning head restraints on your 1969 Lincoln Continental Sedan.

Federal Motor Vehicle Safety Standard No. 202: Head Restraints Passenger Cars, specifies that a head restraint must be provided at each outboard front seating position on cars manufactured on or after January 1, 1969. This standard does not prohibit an individual from modifying or removing the head restraints once he purchases the car. However, a particular state may have inspection laws which prohibit such actions. I suggest you check the matter with your state inspection authorities.

Our Highway Safety Program Standards, copy enclosed, set minimum performance requirements for state inspection programs. Each state is free to establish its own program which meets or exceeds the Federal guidelines. The fact that our Federal Motor Vehicle Safety Standard requires head restraints to be installed on all new passenger cars is evidence of our belief in the level of safety provided by these devices in rear collisions. We would strongly endorse a state inspection program which supported this and our other standards. I am enclosing a booklet which describes all of our motor vehicle standards.

Regarding your particular case, we agree that good visibility is necessary for the safe operation of an automobile. However, properly designed head restraints should not significantly restrict visibility. The injury-reducing benefit far outweights the slight loss of visibility which may occur in certain passenger cars. See(Illegible Word) to the head restraint standard enclosed.

As a practical matter, I would not recommend removal of your head restricts. Aside from the level of rear collision protestion which they provide, their removal may mean that their support structure within the seat back is exposed and this may present a hazard to any rear seat occupants who may hit their heads on the front seat back in a forward collision.

I would suggests the alternative of an additional rear view mirror on the right side of your vehicle to provide increased rear visibility.

Your interest in our progress is appreciated.

ID: nht72-1.26

DATE: 04/24/72

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

TO: National Tire Dealers & Retreaders Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 28, 1972, asking whether passenger car tires that have been reclassified, under Standard 109, as "Unsafe for Highway Use" because they do not conform to the standard may be sold with, or for use on, a vehicle other than a passenger car. For the reasons given below, our answer to your question is no.

Section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act states that:

"No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this title unless it is in conformity with such standard except as provided in subsection (b) of this section." (Emphasis supplied.)

We presume that the argument for allowing use of a nonconforming passenger car tire on another type of vehicle (in your case a boat trailer) would be that by so using the tire, it ceases to be a "tire for use on passenger cars" in the words of the application section of Standard 109, that the standard does not apply to it, and since there is currently no standard for tires on vehicles other than passenger cars, anything may be used on such vehicles.

We would reject this argument. We interpret Standard 109 as applying to tires that are designed and produced for use on passenger cars, and in this view a tire so designed and produced does not become something else because it is ultimately used for a different purpose. The effect of section 108, then, is not merely to prohibit nonconforming passenger car tires from being sold on passenger cars, but to prohibit them from being sold at all, as "motor vehicle equipment."

As an entirely separate matter, any reclassified tire sold as motor vehicle equipment would be presumed to contain a safety-related defect within the meaning of sections 111 and 113 of the Act.

ID: nht72-2.23

DATE: 09/13/72

FROM: AUTHOR UNAVAILABLE; E. T. Driver for R. L. Carter; NHTSA

TO: Hon. P. H. D. Fratinghuysen - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 31, 1972, to Secretary of Transportation John A. Volpe, concerning Mr. Richard J. Orgass' comments on headlighting for motor vehicles.

The National Traffic and Motor Vehicle Safety Act of 1966 required that the initial Federal motor vehicle safety standards be based on existing standards. In this respect, Federal Motor Vehicle Safety Standard No. 108, the initial Federal standard on lighting requirements, specifies that headlamps conform to existing standards, these of the Society of Automotive Engineers (SAE Standards J579a and J5SCa) for sealed beam headlamps. The SAE standards were developed by authorities in the field of vehicular lighting and were adopted by a number of State and Federal regulatory agencies prior to the existance of Standard No. 108. Specifying the use of these standard headlamp assemblies enhances traffic safety, since replacement assemblies are readily available when needed by the vehicle operator.

It is recognized that a number of currently available headlamps produce higher lighting intensities than those permitted by Standard No. 108. Such headlamps, while providing a more effectively illuminated roadway for the driver behind the lamps, could under certain traffic environments produce an annoying or even blinding effect on approaching drivers. Therefore, all aspects of highway safety must be considered during the development of new or revised requirements which will eventually be included in Standard No. 108.

As an indication of the National Highway Traffic Safety Administration's plans for improving headlighting, I am enclosing a copy of an Advance Notice of Proposed Rule making relating to Standard No. 108. Included In the Notice are several proposals which affect the present requirements for headlamps. Also, a recently completed research program on improved forward lighting included studies and evaluations on the performance and other technical aspects of several types of headlamps, including the quartz-halogen type. Results of this research will assist in the development of requirements for more effective headlighting systems. It is anticipated that a second notice including new and revised requirements for headlighting will be Issued late in 1972.

Thank you for bringing Mr. Orgass' comments to my attention.

ID: nht72-3.14

DATE: 07/05/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mr. Robert T. Sanders

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 1, 1972, requesting an interpretation as to the application of Federal Motor Vehicle Safety Standard No. 205. "Glazing Materials," to certain recreational vehicles and equipment, pictures of which you enclosed. These components consist of slide-in and chassis-mount campers, trailers, and motor homes.

In a recently issued amendment to Standard No. 205, the NHTSA has clarified the application of the standard to campers. As amended, the standard applies to campers, both slide-in and chassis-mount, that are designed to transport occupants while in motion. Accordingly, the pick-up cap which you illustrate appears to be except from the standard. In addition, Standard No. 205 does not apply to trailers, and would not apply to the fifth-wheel unit illustrated in the drawing forwarded to us.

With reference to the chassis-mount and slide-in campers, any window except forward facing windows, which include both front-facing windows and behind-the-cab windows, may be manufacturered of any glazing material (AS 1 through AS 11) specified in ARS Z26.1-1966, and two additional materials (Items 32 and 33), the requirements for which are specified in the recent amendment. With reference to forward-facing camper windows, all of the above materials may be used, except for AS 6 and AS 7 glazing materials, as specified in ANS Z26.1-1966 and item 13 glazing specified in the new amendment.

With respect to motor homes that are not campers, these vehicles are multipurpose passenger vehicles and must meet the glazing requirements for trucks. Accordingly, the windshield must be manufactured of either AS 1 or AS 10 glazing materials, side windows to the (immediate right or left of the driver must be either AS 1, AS 2, AS 10, or AS 11 materials, and other side windows must be either AS 1, AS 2, AS 3, AS 4, AS 5, AS 8, AS 9, AS 10, or AS 11 glazing materials. We would consider the overhead window in the motor home you (illustrate to be an "opening in the roof," and any of the materials allowed in side windows, or the materials allowed to be used by the recent amendment, may be (Illegible Word) in this location.

ID: nht72-3.38

DATE: 09/25/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Renault, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 12, 1972, concerning the automatic adjustment of seat belts required by S7.1.1 of Standard No. 208.

The belt system that Renault is considering for use after August 15, 1973, employs a continuous length of webbing that runs from a floor-mounted emergency-locking retractor up through a metal ring mounted high on the B-pillar, then downward across the occupant's chest to the buckle, where it passes around a knurl bar and back across the occupant's lap to an outboard floor anchorage. Your question concerns the amount of friction that may be produced by the knurl bar before the lap belt would be considered to have lost the automatic adjustment capacity required by S7.1.1.

After examining the buckle enclosed with your letter, we have concluded that in its present (Illegible Word) the (Illegible Word) produced by the knurl bar is such that the belt would probably not adjust automatically as required by S7.1.1.

In evaluating belts of similar design, we have not attempted to quantify the amount of allowable buckle friction. The characteristic to be avoided is the tendency of the buckle to trap an excessive amount of webbing on the lap belt side of the buckle. This tendency is overcome if the friction in the buckle is low enough that the normal motion of the occupant against the shoulder belt cinches up the lap belt, or if the buckle slides down of its own weight while the assembly is stored on the B-pillar so that the next occupant must lengthen the lap belt as he fastens the buckle.

In the case of the Renault buckle, a person using the assembly after its use by a larger person would find the buckle in the position appropriate for the larger occupant. After buckling it, he would have a slack lap belt. It appears that the friction in the buckle is great enough that the occupant's normal motion would not tighten the lap belt and that he would have to adjust it manually in order to have it fit him properly. We do not consider this to be satisfactory.

If you have further questions, please advise us.

ID: nht72-3.40

DATE: 08/04/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: General Motors Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of July 11, 1972, raises two substantive questions concerning the belt system requirements of Motor Vehicle Safety Standard No. 208.

The first question concerns S7.4.1, which provides that the engine starting system shall not be operable "unless the belt system at each occupied front position is operated after the occupant is seated". You ask whether a system that you submitted for our inspection, which does not use electronic logic circuits, would conform to this requirement.

The belt system in question is designed to make it quite difficult to enter the vehicle if the belt system is fastened. The occupant is thus forced to unfasten the belt (if it has been left fastened) to enter the vehicle, then to fasten it in order to start the engine. The system employs an inboard-mounted shoulder belt with the outboard attachment point for the lap and shoulder belts mounted in the door. The ignition system employs a buckle switch, so that the belt must be buckled for the engine to start. Upon entering the vehicle, an occupant may find that the belt is either buckled or unbuckled, depending on the action of the previous occupant, but if it is buckled, he will find entry difficult if he does not first unbuckle it. After evaluating the system, we have concluded that the occupant is essentially compelled to operate the belt system after being seated in order to start the car. The system therefore conforms to the requirements of S7.4.1.

In view of the lack of logic circuits, we urge that the design of the buckle be given careful attention, to prevent defeat of the system by the insertion of objects into the buckle.

Your second question concerns the acceptability of belts which require "some action during normal vehicle entry or egress" under the requirements for passive belts. As presently drafted, S4.5.3 does not permit such belts to be classified as passive belts. We will treat your request for amendment of this requirement as a petition for rulemaking and give it prompt consideration.

ID: nht71-3.42

DATE: 07/19/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Harley-Davidson Motor Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 21, 1971, concerning a dispute you are having with your supplier of glazing materials concerning who is the "prime glazing material manufacturer" as specified in S3.4 of Standard No. 205, and who would consequently be required to obtain a manufacturers' code number under S5.2 of the proposed amendment to Standard No. 205, published January 9, 1971 (Docket 71-1, Notice 1) (36 F.R. 326). You indicate that you purchase the glazing material from your supplier, and cut it to size for motorcycle windshields. You state that your supplier claims that although he manufactures the material to specification, he considers it to be purely a raw material, and that he is not a motor vehicle window or windshield manufacturer.

Federal Motor Vehicle Safety Standard No. 205 applies to "glazing materials for use in . . . " specified types of motor vehicles, one of which is motorcycles. It applies to glazing material that is manufactured for use in these vehicles before as well as after it has been cut to size or installed in the motor vehicle.

If a manufacturer is producing glazing materials that he knows are for use in motor vehicles he is, under the National Traffic and Motor Vehicle Safety Act, manufacturing glazing (1) which must comply with Standard No. 205 and (2) which he must certify, as specified in section 114 of the Act, and the Certification regulations (49 CFR Part 567, copy enclosed) as complying with the standard. A prime glazing material manufacturer may certify the material by the alternative method specified in S3.4 of Standard No. 205.

The standard clearly distinguishes between the prime manufacturer and those who merely cut the material, and places responsibility for compliance and certification on the former as well as the latter.

A producer of the basic glazing material, to be used in motor vehicles, is a "prime glazing material manufacturer" under the standard, and would be required to obtain the manufacturers' code mark under S5.2 of the proposed standard.

That proposal is currently under consideration, however, and it is recommended that no action be taken until a final regualtion is published.

ENCLOSURE