ID: nht92-3.47

DATE: 09/21/92

FROM: KEVIN MITCHELL -- DEVELOPMENT ENGINEER, THE GOODYEAR TIRE AND RUBBER CO.

TO: PAUL JACKSON RICE -- CHIEF COUNCIL, NHTSA

COPYEE: J. GRAGG -- QUALITY ASSURANCE MANAGER; B. HENRY -- DEVELOPMENT MANAGER; R. ANDERSON -- PRODUCTION MANAGER; H. HILSON -- MARKETING MANAGER

TITLE: SUBJECT: CHANGE IN DOT PRINT LINE ON GOODYEAR HYDRAULIC BRAKE HOSE.

ATTACHMT: ATTACHED TO LETTER DATED 11-25-92 FROM PAUL J. RICE TO KEVIN MITCHELL (A40; STD. 106)

TEXT: Goodyear is currently in the process of improving the quality of our printing on hydraulic brake hose. The hose in question is used on passenger car brake systems and falls under the FMVSS 106 specification. The purpose is to improve the quality of the print by removing excess information which will improve the mechanical printing process.

Under section 5.2 labeling, Goodyear has in the past and is meeting all requirements of section 5.2.1 and 5.2.2. The question that has arisen involves section 5.2.2.c. Goodyear currently adds two additional letters to the date code for further traceability. The two additional letters spell out the "batch" and "shift" the hose was manufactured under, see below for current and new printing.

DOT print line old.

(1/16" Stripe) DOT - GY - 01/92 - 1/8 - HL

DOT print line new.

(3/32" Stripe) DOT GY 01/01/92 AA - 1/8 HL

SAE print line old.

(1/16" Stripe) GY - 1/8 - 5030 - 01/01/92 AA - SAE J1401

SAE print line new.

(3/32" Stripe) - 5030 SAE J1401

The batch and shift letters have always been added on the SAE line. To keep the information in a format which our customers are used to, we have moved them to the DOT and expanded the date to include month/day/year from month/year. Since section 5.2.2.c does not specifically say these letters can or cannot be added to the DOT print line, Goodyear is being proactive and asking for a written letter from the DOT committee to authorize these improvements before production starts.

We wish to begin the improved printing as soon as possible. If you could please expedite this request as quickly as possible it would be appreciated.

ID: nht90-2.30

TYPE: INTERPRETATION-NHTSA

DATE: 04/25/90

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: LARRY F. WORT -- BUREAU OF SAFETY PROGRAMS DIVISION OF TRAFFIC SAFETY ILLINOIS DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: LETTER DATED 03/27/90 FROM LARRY F. WORT -- ILLINOIS DEPARTMENT OF TRANSPORTATION TO TAYLOR VINSON -- DOT; OCC 4613; FORD RATIONALE FOR FMVSS 108 COMPLIANCE BY CLARKS GORTA -- FORD DATED 03/19/90

TEXT: This is in reply to your letter of March 27, 1990, to Taylor Vinson of this Office with respect to Federal requirements for front side marker lamps on trucks. The Ford C-CT Series Cab is equipped with a reflex reflector (apparently mounted on the door, to judge by the Exhibit A that you enclosed), but does not have a separate front side marker lamp. Ford states that it uses "the roof mounted corner marker lamps to satisfy the side marker lamp requirements", and that they satisfy photometry and all oth er Federal requirements. You have asked whether "the top of the cab clearance light [may] be used to fulfill the requirements for front side market lights. . . on cab over engine vehicles."

The answer is yes. Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, does not prohibit combining the front side marker lamp with any other lamp, and prohibits a front clearance lamp only from being optic ally combined with a front identification lamp (section S5.4, formerly S4.4). Although, under Table II of Standard No. 108, Location of Required Equipment, a front side marker reflector may not be mounted higher than 60 inches from the road surface, the re is no corresponding limitation on the mounting height of front side marker lamps, which would preclude it from being located on top of the cab. The marker lamp must be located "as far to the front as practicable", and the agency generally defers to t he manufacturer's discretion in determining whether a location is practicable, unless it is clearly erroneous. Judging by the location of the combination clearance-side marker lamp shown in Exhibit A that you enclosed, we have no reason to question Ford 's decision to locate the lamp there.

I hope that this answers your question.

ID: perea

Gilbert A. Perea, State Transportation Director
New Mexico Department of Education
School Transportation Unit
Education Building
300 Don Gaspar
Santa Fe, NM 87501-2786

Dear Mr. Perea:

This responds to your letter asking about the modification of your large school buses (school buses with a gross vehicle weight rating (GVWR) of over 10,000 pounds) by the installation of a new seating system that has an integral lap and shoulder belt system. I regret the delay in responding.

You explain that an equipment manufacturer, Busbelts Development Corporation (BDC), has been promoting its seating systems for school buses in New Mexico. You enclose photographs of the BDC product and copies of material provided by BDC. The seating systems appear to be standard school bus bench seats that have been modified to incorporate an integrated lap and shoulder belt system. The shoulder belt portion of the system attaches to the top of the school bus seat back. You state that Mr. Gary H. Murphy of BDC has informed you that "all of the required tests have been completed to conform to applicable [FMVSSs] in a National Highway Traffic Safety Administration certified and approved testing Lab." ⁽¹⁾ Further, a BDC brochure states that its system "enhances and complies with compartmentalization . . . ."

In a telephone conversation with Dorothy Nakama of my staff, you asked that we respond to four questions. Each question concerns the safety of the BDC system and whether a school bus that has had its original seats replaced with the BDC seating systems would continue to meet Federal Motor Vehicle Safety Standard No. 222, School Bus Passenger Seating and Crash Protection. Our answers are provided below. In addressing those questions, it might be helpful to have some background information concerning seat belts on school buses.

In response to the Motor Vehicle and Schoolbus Safety Amendments of 1974, we issued a number of safety standards under our Vehicle Safety Act (49 U.S.C. 30101 et seq.) to improve protection to school bus passengers during crashes. One of these standards was Standard No. 222, which provides for passenger crash protection through a concept called "compartmentalization." Prior to issuance of Standard No. 222, we found that the school bus seat was a significant factor contributing to injury. We found that seats failed the passengers in three principal respects: by being too weak; too low; and too hostile. In response, we developed requirements to improve the performance of school bus seats and the overall crash protection of school buses. Those requirements comprise the "compartmentalization" approach we adopted for providing high levels of crash protection to school bus passengers.

Compartmentalization is directed toward ensuring that passengers are surrounded by high-backed, well-padded seats that both cushion and contain the children in a crash. If a seat is not compartmentalized by a seat back in front of it, compartmentalization must be provided by a restraining barrier. The seats and restraining barriers must be strong enough to maintain their integrity in a crash yet flexible enough to be capable of deflecting in a manner which absorbs the energy of the occupant. They must meet specified height requirements and be constructed, by use of substantial padding or other means, so that they provide protection when they are impacted by the head and legs of a passenger.

It is helpful to bear in mind the following highlights about compartmentalization:

1. Compartmentalization provides effective occupant crash protection, minimizes the hostility of the crash environment and limits the range of movement of an occupant, without using seat belts;
2. Compartmentalization ensures that high levels of crash protection are provided to each passenger independent of any action on the part of the occupant; and,
3. Seat belts are needed on passenger cars and other family vehicles and on small school buses (school buses with a GVWR of 10,000 pounds or less) because the crash pulse, or deceleration, experienced by the lighter vehicles is more severe than that of larger vehicles in similar collisions. Large school buses are inherently safer vehicles because they are larger and heavier than the vast majority of the other vehicles on the road. In addition, occupants in large school buses sit above the forces that are typically imparted to the bus by smaller impacting vehicles during a crash. The training and qualification requirements for school bus drivers and the extra care taken by other road users in their vicinity add to the safety of school buses.

With this background in mind, we now turn to your questions.

1. Does the Busbelts Development Corporation's integrated shoulder belt and/or occupant restraint system meet all applicable FMVSSs?

Because the BDC system is an item of equipment that is sold separately from a school bus, there are almost no safety standards that directly apply to it. Our safety standards for school buses apply to new, completed vehicles, not to separate components systems such as the bench seat and integrated belt system. As such, Standard No. 222 does not apply to the BDC product, assuming the product is sold in the aftermarket and is not sold as part of a new school bus. Our standard for seat belt anchorage strength (Standard No. 210) also applies to new, completed vehicles. A representation that a product meets crash protection standards that do not apply is misleading.⁽²⁾

The only safety standard that applies to the aftermarket product is Safety Standard No. 209, Seat Belt Assemblies. Standard No. 209 specifies strength, ease-of-use and other requirements for seat belt webbing, buckles, and other components. Section S4.1(c) of Standard No. 209 requires that a lap-and-shoulder belt system (a "Type 2 seat belt assembly") must provide upper torso restraint without shifting the pelvic restraint into the abdominal region. Some of the photographs you provided depict children wearing the Type 2 seat belt with the lap portion in the middle of their bodies, above the pelvic region. Placement of the lap portion of the seat belt in the abdominal area of a passenger is prohibited by S4.1(c). A belt positioned over the abdominal area will load the abdomen in a crash, resulting in a greater likelihood of injury to the abdomen and surrounding organs.

It appears from some of the photographs that the lap belt is pulled on to the abdominal area of some of the children by a device that adjusts the positioning of the lap and the shoulder belts on small children. We refer to these types of devices as "belt positioning devices." Due in part to our concerns about positioning a lap belt over a child's abdominal area and about how some devices introduce excessive slack into the shoulder belt, we recently began a rulemaking action to regulate these devices. We issued a notice of proposed rulemaking (NPRM) proposing to require belt positioning devices to be labeled with a warning not to use them with children under a certain size (e.g., a child smaller than the average 6-year-old), and not to have the lap belt positioned over the child's abdomen. A copy of our NPRM is enclosed for your information.

If the BDC system were installed on new school buses, the vehicle would have to meet Standard No. 222 and the other school bus standards with the product installed. Without testing a vehicle, we cannot make a positive determination of whether the standard could be met with the product installed. However, as explained below, we believe that a new school bus may not be able to meet the standard with the seating system. We have other safety concerns as well, apart from whether the requirements of Standard No. 222 could be met.

2. Would retrofitting a school bus with the Busbelt integrated shoulder belt system make the school bus no longer meet Standard No. 222?

We believe it is possible that the incorporation of a shoulder belt into existing school bus seats would reduce the benefits of compartmentalization. As we explained in the background section, Standard No. 222's compartmentalization requirements rely on the school bus seat backs to help cushion and contain the occupants in a crash. Each seat back protects not only the occupant of that seating position, but also the occupant seated rearward of that seating position. If a shoulder belt were attached to a school bus seat back, the belt may prevent the seat back from deflecting forward in the manner required by S5.1.3 of Standard No. 222 to protect the rearward passenger. In other words, in a crash the seat back will not perform in a manner that would provide protection to an unrestrained passenger.

Even if the seat back deflects as required by Standard No. 222, it is possible that compartmentalization could be compromised by the attachment of a shoulder belt to a school bus seat back. These relate to possible problems resulting from a load application of two different forces on the school bus seat in a severe crash. In a forward collision, a passenger restrained by the shoulder belt would load the belt at an earlier point in time than the point at which the seat back is impacted by an unbelted occupant seated directly rearward of the seat. The forward force on the seat back from the shoulder belt would tilt the seat back forward prior to the impact of the rearward unbelted occupant against the seat back. The unbelted occupant would ramp up the tilted seat back in the crash, rather than be contained in what had been a compartmentalized space. That occupant not contained in the compartment would be at greater risk of injury due to possible ejection and/or impacts against hard or unforgiving surfaces.⁽³⁾ Both the head of the unrestrained passenger and the head of the restrained passenger could impact, possibly injuring both children.

The head of the unrestrained passenger could impact the head of the restrained passenger, resulting in possible injury to the two passengers.

Compartmentalization could be compromised in other ways as well. The seat backs of school buses must meet head protection requirements specified in S5.3.1. The performance requirements in S5.3.1 generally lead manufacturers to pad their seat backs with energy-absorbing foam and to ensure that there are no hard structures in the seat back that can cause head injuries to the passenger rearward of the seat back in a crash. Anchoring a shoulder belt to the seat back may require the installation of rigid components, which may cause the seat back to no longer meet S5.3.1.

The seat backs must also meet leg protection requirements specified in S5.3.2 of Standard No. 222. The requirements are generally met by padding and other measures to protect passengers' knees as they impact seat backs in a crash. Apparently BDC modifies the school bus seat by installing a cross bar and D-ring structure to mount the belts and by installing a steel lap and shoulder belt retraction system within the seat back. The knee and leg protection requirements of the standard must continue to be met with the retrofitted components in the seat back.

In addition to the issues discussed above, care should be taken to ensure that passengers will not be entangled in the shoulder belt webbing material in a crash. Shoulder belts that have a considerable amount of webbing around the head and neck area of children pose a risk of strangulation or other neck injuries.

For the above reasons, we believe that a school bus seating system with an integrated lap and shoulder belt system might reduce the crash protection provided by compartmentalization. ⁽⁴⁾ There is limited information about how an integrated lap and shoulder belt system on a school bus seat would perform in a crash or affect the current safety of school buses. We are undertaking a comprehensive school bus safety research program to evaluate better ways of retaining occupants in the seating compartment. As part of that program, we will be looking into possible ways of redesigning the school bus seat as well as integrating a lap and shoulder belt into the seat that is compatible with compartmentalization. Also, we plan on conducting some research on extra padding, not only for the seat itself but also for the bus side wall. Information from this research program will help researchers better understand and develop the next generation of occupant protection systems for school buses.

3. Would retrofitting a school bus with an integrated shoulder belt system make inoperative the bus's compliance with FMVSS 222?

Section 30122 of our statute prohibits a motor vehicle manufacturer, dealer, distributor, or repair business from installing any modification that "make[s] inoperative any part of a device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard . . . ." Any person in the aforementioned categories that makes inoperative the compliance of a device or element of design on the vehicle would be subject to fines of up to $1,100 per violation and to injunctive relief.

The compartmentalization requirements of Standard No. 222 include requirements that a protective seat back must be provided to protect an unrestrained passenger. We believe that replacing a school bus seat with a seating system that has a torso belt is likely to make inoperative an element of design installed as part of the compartmentalization concept. We are concerned about the continued compliance of the bus with Standard No. 222's seat deflection and head and leg protection requirements. We are concerned about the ability of the bus to continue to provide required crash protection to children regardless of whether a belt is used.

4. If a school bus were retrofitted with the Busbelt integrated shoulder belt system, will the school bus continue to meet all applicable Federal motor vehicle safety standards?

Compartmentalization is intended to restrain passengers in a crash regardless of whether they buckle up. A torso belt may reduce that level of safety to an unbelted passenger. As previously stated, we have concerns about a product that might interfere with the ability of a school bus to protect unbelted occupants. We will be evaluating integrated lap and shoulder belt systems in our school bus research program. The program will provide information that will help us better assess the merits, costs and feasibility of having integrated seat belts on school buses.

Before closing, we wish to address a statement that BDC made in its marketing literature in support of seat belts on large school buses. BDC states that its "dynamic test data" shows that in a 30 mile per hour (mph) school bus crash, an unbelted occupant "suffered fatal head injuries (2000 HIC level) when his/her head came in contact with a standard school bus seat." These test data apparently result from computer simulations conducted for BDC. The data do not reflect the data we have obtained in actual crash testing of school buses. Actual crash test data from a 30 mph barrier crash conducted by NHTSA indicate that HIC measurements recorded by calibrated test dummies are all well below the 1,000 threshold level.

On a final note, we would like to point out that many of your newer school buses may still be under the school bus manufacturer's warranty. Before you decide to retrofit any school bus with any seat belt, it may be prudent for you to share BDC's information with the school bus manufacturer, and request a determination whether the school bus manufacturer will continue to honor warranties if the BDC seat belts are placed on school buses.

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:222
d.10/28/99

^1. We note that this statement is misleading. NHTSA does not "certify" or "approve" test laboratories or facilities to conduct compliance testing or for any other purpose.

^2. Regardless of whether a safety standard applies to the product, our statute at 49 U.S.C. 30120 requires manufacturers of motor vehicles and motor vehicle replacement equipment to provide remedies if it is determined their products have safety-related defects. If it were determined that the seating systems had a safety-related defect, the manufacturer would have to notify all purchasers and repair or replace the defective item without charge.

^3. Another concern associated generally to the use of lap and lap and shoulder belts on large school buses relates to the potential for seat failure resulting from combined stresses exerted simultaneously or in close succession on a school bus seat by: (1) the belted occupant of the seat, where the seat belt is attached to the seat frame; and (2) an unbelted occupant, seated directly rearward of the seat, impacting the seat back. In a severe crash, the combined force applications on a particular seat resulting from a belted occupant and an unbelted occupant in the rearward seat could increase the likelihood of seat failure or seat deformation. We do not believe that school buses are frequently involved in the type of severe frontal crashes where this phenomenon is likely to occur. However, there is a risk that compartmentalization could be compromised in this circumstance.

^4. The concerns discussed above relating to the compatibility of compartmentalization with existing designs of lap and shoulder belts also apply to the situation where a belt system is retrofitted to existing school bus seats (i.e., where the original bench seat is modified but not replaced).

ID: 005340drn

Mr. Robert L. Douglas
Director of Product Integrity
IC Corporation
751 South Harkrider
Conway, AR 72032

Dear Mr. Douglas:

This responds to your request for an interpretation of whether an "aluminum extrusion" to be used to mount the upper longitudinal edge of the light bar is excluded from the definition of "body panel joint" as set forth in Federal Motor Vehicle Safety Standard No. 221, School Bus Body Joint Strength. Our answer is yes.

Standard No. 221 requires, among other things, that each body panel joint, when tested in accordance with the procedure of S6, shall hold the body panel to the member to which it is joined when subjected to a force of 60 percent of the tensile strength of the weakest joined body panel determined pursuant to S6.2 (S5.1). Standard No. 221 defines "body panel joint" as:


the area of contact or close proximity between the edges of a body panel and another body component, including but not limited to floor panels, and body panels made of composite materials such as plastic or plywood, excluding trim and decorative parts which do not contribute to the strength of the bus body, members such as rub rails which are entirely outside of body panels, ventilation panels, components provided for functional purposes, and engine access covers.

You state that your company is considering changing the method of mounting the upper longitudinal edge of a light bar. You will be replacing screws with an aluminum extrusion to insert and retain the upper longitudinal edge of the light bar. The aluminum extrusion will be attached to the roof inner liner with screws.

Our opinion is that the aluminum extrusion is a "trim" part and thus is excluded from FMVSS No. 221. The extrusion is similar to the plastic wire trim parts that NHTSA, in an August 31, 2000, letter to Mr. Thomas Turner, determined were trim. The aluminum extrusion does not contribute to the structural integrity or joint strength of the bus. As a manufacturer, however, it is your responsibility to secure the extrusion in such a manner that it is not likely to come unattached and cause injuries in a crash.

If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:221
d.12/3/03

ID: 1982-1.34

TYPE: INTERPRETATION-NHTSA

DATE: 03/30/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Norton Motors Limited

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 5, 1982, asking whether a proposed motorcycle taillamp assembly would comply with Motor Vehicle Safety Standard No. 108.

As you point out, the standard requires a minimum distance of 4 inches edge to edge between turn signal lamps and stop/tail lamps. Since you state that you cannot achieve this with your design, the lamp as currently designed would not be permitted by our standard. This will confirm the oral interpretation provided by Taylor Vinson of this office when you telephoned on March 22.

You will be interested to know that we are presently studying side and rear conspicuity of motorcycles. This research is being conducted by Ketron in Philadelphia. Pennsylvania, and the final report is expected in July 1982 should you wish to obtain a copy of it from us.

As you requested confidential treatment of your engineering drawing, we are returning it to you.

ENC.

CONFIDENTIAL DRAWING

NORTON MOTORS (1978) LIMITED

MARCH 5, 1982

Frank Berndt Legal Counsel National Highway Traffic Safety Administration Dept of Transportation

Dear Sir,

NORTON REAR LAMP UNITS 92-1068

1. We have designed a new rear lamp unit, and enclose a print of the drawing, which we would ask you to regard as confidential.

2. As you will see, the rear lamp unit comprises a very wide stop/ tail light assembly, with three separate lenses.

3. Your regulation (MVSS 108 issue 1, March 79) calls for minimum horizontal separation centre line to centre line, of 9 inches between turn signal lamps. Ours are 12.2 inches apart.

4. However, you also call for a minimum distance of 4 inches, edge to edge between turn signal lamps and stop/tail lamps. This we cannot achieve because of our very wide rear light.

5. We feel the wide rear light makes a positive contribution to road safety. We need your assistance to determine whether or not you consider this rear lamp unit satifies the spirit of your legislation, if not the letter.

We shall await your reply with great interest, and thank you for your assistance.

G.K. BLAIR SALES MANAGER

ID: 1916y

Dear :

This is in reply to your letter of June 30, l989, to John Donaldson of this Office titled "Request for Interpretation", submitted on behalf of your client. You request "that all identifying references to myself, my firm and [my client] in this letter and the responsive letter of interpretation" be deleted. Your request is granted on the basis that it relates to confidential business information and may be withheld under applicable Departmental regulations, 49 CFR Part 512.

You describe a lamp system as follows:

"The product is a headlamp consisting of a plastic lens and reflector, arc tubes (two each for high and low beam) and electronics for instant start and re-start of the headlamps as well as management of the operating current. A 12 volt connection is supplied for connection of vehicle line voltage".

You have asked for a letter "confirming" that this lamp system is designed to conform to the integral beam headlamp requirements of paragraph S7.4 of Federal Motor Vehicle Safety Standard No. l08, "subject only to compliance with the appropriate photometric requirements of FMVSS l08."

A headlighting system of the nature described must be designed to conform to all the pertinent requirements of S5.5, S7.1, S7.2, and S7.7, as well as S7.4, including mechanical aim and environmental requirements. However, since this headlamp does not use filaments for converting the electrical energy to light energy, certain configurations of such systems may not conform, because some requirements are predicated upon the existence of filaments (e.g., S5.5.9 and S7.4(f)). If the headlamp you describe meets all requirements, then it would appear to be an integral beam headlighting system designed to conform to S7.4. Whether the headlamp in fact meets those requirements is for the lamp manufacturer to determine, as it must assure the manufacturer of the vehicle on which it is installed that he may certify compliance of the vehicle with Standard No. l08. Further, the headlamp manufacturer itself must certify compliance of replacement equipment. If the headlamp is incompatible with these requirements and cannot meet them, then it would not appear to be an integral beam system. In that case, rulemaking would be required to accommodate it within the framework of Standard No. l08.

Sincerely,

Stephen P. Wood Acting Chief Counsel

/ ref:l08 d:7/2l/89

ID: 1124

Mr. Dennis G. Moore
President
Sierra Products, Inc.
1113 Greenville Road
Livermore, CA 94550

Dear Mr. Moore:

This responds to your letter of July 31, 1995, with respect to lens area requirements of amber turn signal lenses.

You believe that "by reducing the minimal area of the Amber Turn Signal light lens from 12 square inches to approximately 8 square inches or 6 square inches the U.S. would have more practical rules for U.S. Exports at no expense to Safety. You ask that, "If NHTSA's Legal Council feels this error should be corrected through the Petitioning Process, I ask that this writing be considered a `Petition for Change of FMVSS #108 Request'".

Standard No. 108 contains two relevant regulations, one applicable to vehicles whose overall width is less than 80 inches, and one to those whose overall width is 80 inches or more.

Under paragraph S5.1.1.26(a), the functional lighted lens area of a single turn signal lamp of either red or amber on a vehicle whose overall width is less than 80 inches shall be not less than 50 square centimeters. This is approximately 8 square inches. Therefore, no rulemaking is required to implement your recommendation.

The standard that applies to turn signal lamps on vehicles whose overall width is 80 inches or more is SAE Standard J1395 APR85, incorporated by reference in Standard No. 108. Under its paragraph 5.3.2, the functional lighted lens area of a single turn signal lamp shall be at least 75 square centimeters, or approximately 12 square inches. Therefore, rulemaking is required to implement your recommendation.

We are transmitting your letter to our Office of Safety Performance Standards for consideration as a petition for rulemaking to change the minimum lens area requirement for

turn signal lamps on large vehicles from 75 to 50 square centimeters. On September 4, 1995, I determined that your letter met our procedural requirements for a petition. Accordingly, the Office of Safety Performance Standards will inform you not later than January 1, 1996, whether your petition has been granted.

If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,

John Womack Acting Chief Counsel ref:108 d:9/20/95

ID: 1982-1.35

TYPE: INTERPRETATION-NHTSA

DATE: 03/30/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: British Standards Institution

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of January 5, 1982, concerning Standard No. 209, Seat Belt Assemblies. You are correct that my letter of June 1, 1981, should have referred to S5.1(d) rather than S5.2(d). Likewise, I assume that where you have referred to sections 4.1(d), (e), and (f) in your letter, you mean sections 4.2(d), (e), and (f).

My letter of June 1, 1981, was not meant as a definitive statement of what specific action the agency intends to take on Standard No. 209, but rather to acknowledge that the standard's provision on abrasion needs modification. The notice of proposed rulemaking for this action will allow you and other interested parties to comment on what precise changes you think should be made to the standard. I am placing a copy of your letter with its current suggestions in the public docket.

Sincerely,

ATTACH.

January 5, 1982

FRANK BERNDT -- CHIEF COUNSEL, US Department of Transportation, NHTSA

Dear Sir

With reference to your letter to us of June 1 1981, I assume that where you have referred to Clause 5.2(d) in your letter you mean 5.1(d).

You state in your letter that Clause 5.1(d) will be amended and that strength after abrasion will be compared to the breaking strength specified in Clause 4.2(b). For consistency, Clause 5.1(e) and 5.1(f) would also need to be altered.

I would suggest that it is not Clause 5.1(d) that needs changing, it is 4.1(d) to bring it into line with 4.1 (e) and (f). Clauses 5.1(d)(e) and (f) need no change. Additionally I feel sure that the minimum breaking strengths listed in 4.2(b) should remain, even after abrasion, light or micro-organisms test and that clause 4.2(d) might finish . . . . shall have a breaking strength of not less than 75% of the strength before abrasion and greater than the appropriate strength listed in @@ 4.2(b). Clause 4.2(e) might read . . . . have a breaking strength of not less than 60% of the strength before exposure to the carbon arc and greater than the appropriate strength listed in Clause 4.2(b). Clause 4.2(f) might finish . . . . have a breaking strength not less than 85% of the strength before subjected to micro-organisms and greater than the appropriate strength listed in @@ 4.2(b).

Yours faithfully

J E BINGHAM -- SENIOR TEST ENGINEER, BRITISH STANDARDS INSTITUTION

ID: 1982-2.24

DATE: 07/26/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Puerto Rico Marine Management, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

JULY 26, 1982

Mr. William Croix Technical Maintenance, Manager Puerto Rico Marine Management, Inc. G.P.O. Box 71306 San Juan, Puerto Rico 00936

Dear Mr. Croix:

This is in response to your letter of July 9, 1982, to Mr. Elliott of this agency.

You have asked about Federal requirements for lighting of portable containers secured to flat bed trailers. As those containers are the cargo of the trailers and not an integral part of them, the Federal lighting requirements (Motor Vehicle Safety Standard No. 108) apply only to the trailer. However, the individual States in which the trailers are operated may impose their own lighting requirements.

Sincerely,

Frank Berndt Chief Counsel

PUERTO RICO MARINE MANAGEMENT, INC. SAN JUAN, PUERTO RICO 00936

July 9, 1982

Department of Transportation Mr. Elliogt, Safety Standard Eng.

400-7th. Street South West, Room #5307 Routing NRM-11 Washington, D.C. 20590

Dear Mr. Elliogt:

I refer to our telephone conversation on July 7, 1982, in which my question pertained to lighting on the chassis of a container and chassis comnbination.

In transit our containers are secured to the cahssis for safety purposes. My prime question is are we in conformance with the lighting regulation set forth by your department with proper lighting on the chassis only, when the container is secured to the chassis.

Per your request I put in writing the substance of our conversation. Your response to this subject will be appreciated.

Cordially yours,

Mr. William Croix Technical Maintenance Manager

WC/umc

c: SAN JUAN - A. Colon, Executive J. Dillon, Corp. Maint.

W. Smith, Corp. Maint.

ID: 1982-2.3

DATE: 04/12/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nebraska Department of Education

TITLE: FMVSS INTERPRETATION

TEXT:

APR 12 1982

NOA-30

Mr. Vernon J. Clark Transportation Supervisor Nebraska Department of Education 301 Centennial Mall South Box 94987 Lincoln, Nebraska 68509

Dear Mr. Clark:

This responds to your March 23, 1982, letter asking whether it is permissible to install side-facing seats in school buses designed to transport the handicapped. The answer to your question is yes.

Standard No. 222, School Bus Passenger Seating and Crash Protection, specifies the requirements for school bus passenger seats and, in general, requires those seats to be forward facing. However, the definition of "school bus passenger seat" in section S4 of the standard excludes seats installed to accommodate handicapped or convalescent passengers as evidenced by installing those seats longitudinally. Therefore, seats installed in the buses to which you refer in your letter need not comply with the school bus seat requirements if they are designed to accommodate the handicapped and are side facing.

We caution, however, that side-facing seats afford less protection than forward facing seats. Accordingly, only those seats necessary to accommodate the handicapped should be altered in this manner.

Sincerely,

Frank Berndt Chief Counsel

March 23, 1982

Mr. Roger Tilton Office of Chief Council National Highway Safety NTS 400 7th St. Washington, D. C. 20590

Dear Mr. Tilton:

We are interested in obtaining an opinion from your office regarding the placement of seats in a school bus used for transporting handicapped students. Is it legal or permissible to place a seat or seats in a longitudinal position to provide space for moving wheel chairs through the isles? We have several schools in our state that have a problem with this and are requesting permission to make these alterations.

I would appreciate any information you could give me on this matter as soon as possible.

Sincerely,

VERNON J. CLARK Transportation Supervisor

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