ID: nht81-3.11

DATE: 08/28/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Sigma Six Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your July 29, 1981, letter asking whether a three-wheeled vehicle would be classified as a motorcycle for purposes of complying with the motor vehicle safety standards.

The term "motorcycle" is defined in our regulations as "a motor vehicle with motive power . . . designed to travel on not more than three wheels in contact with the ground" (Volume 49, Code of Federal Regulations, Part 571.3). Since your vehicle is designed to travel on three wheels, it would be classified as a motorcycle for purposes of complying with the safety standards. The agency plans no major rulemaking at this time that would change the definition of motorcycle or the standards with which these vehicles comply.

SINCERELY,

29 July 1981

Office of the General Counsel Department of Transportation NHTSA

Dear Sirs:

We wish to obtain information on the proper procedures to obtain certification of a specialty vehicle for manufacture in the United States.

I have attached some of the sales literature describing the vehicle. I have previously talked with the rulemaking and compliance personnel at NHTSA in an attempt to clarify the problems that may be encountered.

The "Ant" is a three wheel vehicle and is currently manufactured in Britain. It is certified in the UK under category N[1], "Vehicles used for the carriage of goods and having a maximum weight not exceeding 3.5 metric tons". It is also certified for French import.

In my discussion with the rulemaking section I was told that three wheeled vehicles are currently classed as a motorcycle, however, they were under review for possible changes to the rules. The classification required to be met and any changes being made could have a major impact on the investment required to properly set up the manufacturing facility to insure that all applicable FMVSS standards are met in the vehicle engineering and manufacturing practices and procedures.

The investors are currently planning a production rate of 1000 per year in two years with a possible expansion to 5000 per year in five years.

Your attention to our problem and assistance in obtaining a solution is appreciated.

Sigma Six Inc.

Marshall Zaun President

Sales Literature Omitted.

ID: nht80-3.21

DATE: 07/21/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mercedes-Benz

TITLE: FMVSS INTERPRETATION

TEXT:

Dear Mr. Gerth:

This responds to your recent letter requesting an inter pretation concerning the term "overall width" as used in Safety Standard No. 104, Windshield Wiping and Washing Systems (49 CFR 571.104). You asked whether passenger car door handles would be included in the measurement of a vehicle's overall width.

Safety Standard No. 104 defines "overall width" as the maximum overall body width dimension "W116," as defined in section E, Ground Vehicle Practice, SAE Aerospace-Automotive Drawing Standards, September 1963. The "W116" standard specifies that overall width is measured across the body, excluding hardware and applied moldings, but including fenders when integral with the body. We would consider passenger car door handles to be vehicle "hardware." Therefore, door handles would not be included in the measurement of overall vehicle width.

Sincerely,

Frank Berndt Chief Counsel

June 5, 1980

Attn: Office of Chief Counsel

Subject: Motor Vehicle Safety Standard No. 104 - Windshield Wiping and Washing Systems, Request for Interpretation

Dear Madame or Sir:

Your interpretation i s requested on the definition of "overall width" as used in Motor Vehicle Safety Standard No. 104 -Windshield Wiping and Washing Systems. Section S3 of that Standard defines "overall width" as being the maximum overall body width dimension "W116" as defined in Section E, Ground Vehicle Practice, SAE Aerospace-Automotive Drawing Standards, September 1963. This second Standard contains the statement that "overall width" is measured across body, excluding hardware and applied mouldings, but including fenders when integral width body.

Your interpretation of this definition is requested as to whether or not the term "hardware" would include passenger vehicle door handles. This would exclude door handles from the measurement of the overall width of a vehicle.

Should you require additional infomation on this request, do not hesitate in contacting Mr. G. M. Hespeler of our Safety Engineering Department, (201) 573-2616. As a point of infomation, your response dated March 18, 1980, to a previous request for interpretation regarding body trim mouldings is also attached for your review.

Very truly yours,

HG:Web

ID: nht81-1.11

DATE: 02/09/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Synnestvedt & Lechner

TITLE: FMVSS INTERPRETATION

TEXT: This replies to your letter of December 11, 1980, in which you ask us to reconsider the interpretation we issued on April 22, 1980, regarding Safety Standard No. 205, Glazing Materials. We stated in our letter to you on that date that the abrasion test for vehicle windshield glazing must be conducted on both the exterior and the interior surfaces of the windshield (i.e., both surfaces must comply with the requirements of the standard).

After further consideration, we reaffirm our earlier interpretation. However, on January 19, 1981, the NHTSA did issue an Advance Notice of Proposed Rulemaking (ANPRM) requesting comments on whether Standard No. 205 should be amended to adopt less stringent requirements for glass-plastic glazing. A copy of that notice is enclosed for your information.

Please contact this office if you have any more questions.

Sincerely,

ATTACH.

SYNNESTVEDT & LECHNER

December 11, 1980

Frank E. Berndt, Esquire -- U.S. Department of Transportation, National Highway Traffic Safety Administration

Re: NOA-30

Dear Mr. Berndt:

By letter of December 9, 1980 from Mr. Michael M. Finkelstein, we have been advised of the granting of the petition of our client, Saint-Gobain Vitrage, to amend Federal Motor Vehicle Safety Standard No. 205.

In the context of a rulemaking proceeding in progress, we ask that prompt attention be given to our letter of May 7, 1980, copy enclosed, requesting that you reconsider the interpretative ruling we seek. By the interpretation we urge, some actual on-road experience in the United States could be gathered during the pendency of the rulemaking proceeding. This would come about through the supply from Saint-Gobain Vitrage to European car manufacturers who are already customers for the Securiflex inner guard windshield, of additional such windshields to be used in cars being shipped to the United States. Audi and Peugeot are obvious candidates to begin such introduction, although there are other European car manufacturers who would probably do the same, perhaps as an optional feature.

We will look for your response.

Very truly yours,

John T. Synnestvedt

Enclosures

cc: Joan Claybrook

ID: nht81-1.42

DATE: 03/16/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: L. O. Willbrand, Esq.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Lawrence O. Willbrand, Esq. Suite 873 Paul Brown Bldg. 818 Olive Street St. Louis, MO 63101

RE: Ms. Sharon James

Dear Mr. Willbrand:

This is in reply to your letter of February 19, 1981, with respect to motorcycle tires.

The agency has issued Federal Motor Vehicle Safety Standard No. 119 (49 CFR 571.119), New Pneumatic Tires for Vehicles Other Than Passenger Cars. This standard specifies requirements for new tires designed for highway use on motorcycles, among other vehicle types. I enclose a copy for your information. The agency has issued no standards for off-road vehicle tires such as trail bike tires as our jurisdiction is limited to those items produced for installation on vehicles manufactured primarily for use on the public roads.

If the motorcycle in question was originally sold with trail bike tires installed (i.e., any tire not stamped with a DOT symbol indicating its conformance to Standard No. 119), that sale might be a violation of Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A)). But the Act does not prohibit the owner of an on-road motorcycle from putting off-road tires on his bike and using it on the public roads.

If you have any further questions, I would be pleased to answer them.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

February 19, 1981

Federal Motor Vehicle Safety Standards % Department of Transportation Washington, D.C. 20591

RE: Mrs. Sharon James

Dear Sir:

Does your office possess or prepare standards relating to tires on a trail bike or and public road motorcycles.

Specifically I am seeking this material in connection with a tire for said vehicle which propells rocks because the tire was made with "knobs" for trails but was being used on the public roads and had equipment qualifying it to do so.

I would be happy to pay for such materials, references, or citations.

I am most appreciative for any attention you might give this matter.

Very truly yours,

Lawrence C. Willbrand

LCW: mw

ID: nht73-6.1

DATE: 10/16/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Twin Coach Highway Products Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 22, 1973, concerning the requirements of Federal Motor Vehicle Safety Standard No. 217, Bus Window Retention and Release.

Following are answers to your four questions:

1. In a phone conversation with Richard Dyson on September 26 you explained that the window mechanism in question (which you mentioned you are no longer using) requires the release of both mechanisms before the window releases -- that is, before the window will no longer conform to the retention requirements in paragraph s5.1, s5.1.1, and s5.1.2 of the standard. In this case, only one of the force applications necessary to operate both mechanisms need differ by 90 degrees to 180 degrees from the direction of the original push-out motion of the emergency exit.

2. You are correct that the post in front of the window is not an obstruction so long as it permits passage of the ellipscid. However, when a post cuts a window opening into two segments as shown in your enclosed sketch, only the segment that passes the ellipscid, not the entire window opening, may count toward the measurement of total area specified in paragraph s5.2.

3. Although Figure 30 shows only the boundaries for high and low force access regions when the bus is upright (and when an obstacle is between the occupant and the unit), these same dimensions are these that are to be applied when the bus is overturned on either side, with the side on which the

bus is resting being considered as the floor. The transposition of these dimensions is illustrated to some extent in Figure 3D.

Whether or not both rear windows must be made into emergency exits rests solely on whether both windows are necessary for the bus to meet the unobstructed opening requirements, and the emergency exit release requirements of s5.3 and s5.5 when the bus is upright and overturned on either side.

4. The cut-off date for windows which do not comply with the standard is that of the date of manufacture of the bus in which the window is installed. All buses manufactured on or after September 1, 1973, must comply with the requirements of Standard No. 217.

If I can be of further assistance, please do not hesitate to ask.

ID: nht74-1.43

DATE: 04/28/74

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Mark Bedrossyan

COPYEE: L. OWEN

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 21 to the National Highway Traffic Safety Administration concerning your "Straight Ahead" directional signal for motor vehicles.

Federal Motor Vehicle Safety Standard No. 108. "Lamps, Reflective Devices and Associated Equipment," permits lamps, reflective devices or other motor vehicle equipment in addition to those that are required (headlights, parking lamps, turn signal lamps, etc.) providing that the effectiveness of the required devices is not impaired. It does not appear that your device would impair the effectiveness of the required lamps; therefore, it would be permitted, either as original equipment, or as an aftermarket item.

Since the performance aspects of your device are not covered by Standard No. 108, the individual States are free to regulate the sale and use of your device. If your "Straight Ahead" signal flashes, its use would probably be prohibited in most of the States, because of their restrictions on flashing lights for motor vehicles.

Thank you for your interest in highway safety.

Not controlled

ATTACH.

ATLANTIC ELECTRONICS LABORATORIES

March 21, 1979

The National Highway Traffic Safety Administration Washington, D.C.

Gentlemen:

Subject: "Straight Ahead"

Directional Signal for Motor Vehicles

Over two decades ago, the use of electrical (Illegible Word) signals on motor vehicles became mandatory nation-wide, this decision has proved both useful and effective in preventing accidents.

It is believed there is room for an additional device, and to fill this need, we have designed the "Straight-Ahead" electrical directional signal for cars and trucks, which is controlled from the dashboard by a switch. This is intended to be used at intersections and certain other road conditions. (Please see the inclosed pictorial representations).

I have already installed such a device on my own car on an experimental basis.

It is respectfully requested that you evaluate this idea, and permit its use, if deemed appropriate, since we plan to market it in kit form.

New car manufacturers are being contacted to bring this new idea to their attention.

An (Illegible Word) reply would be greatly appreciated.

Very truly yours,

Mark B. Bedrossyan

(Graphics omitted)

ID: nht74-2.1

DATE: 01/17/74

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

TO: Aeroquip Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your request of January 8, 1974, made to Mr. Herlihy of this office, for an interpretation of S5.1.2.3 of Standard No. 121, Air brake systems, as it applies to a check valve which is designed to bleed back no more than 5 psi pressure from the service reservoir toward the source of air pressure.

The check valve described in the specification you enclosed would satisfy the requirements of S5.1.2.3 as long as there is no air loss in excess of the designed bleed off, and that total air loss never lowers the pressure at any time below the air compressor "cut in" pressure.

Yours truly,

ATTACH.

AEROQUIP CORPORATION/INDUSTRIAL DIVISION

January 4, 1974

John Womack and Richard Dyson -- Chief Council, National Highway Traffic Safety Administration

Gentlemen:

This letter is a request for approval of our XFF9260-50 check valve for use in truck and bus air brake systems as detailed in the Motor Vehicle Safety Standards #121, Paragraph S5.1.2.3.

The function of the subject check valve is to allow air bleed back of no more than 5 psi pressure from the maximum pressure setting on the primary reservoir. The purpose of the air bleed back is to increase the service life of our Aerofiner Air Purifier (P/N FF9260-01). The air volume used off the #1 air reservoir (pre-dried air) is used to back flush the desiccant bed in the Aerofiner at approximately 3 cfm until the pressure in the reservoir drops to the relief valve setting, (5 psi below maximum reservoir operating pressure) at which time the valve is completely closed. In all other respects, it functions as a typical safety check valve.

Attached is a layout sketch of the subject check valve showing the seal surfaces and flow paths under various conditions.

Also attached, is a copy of Bulletin #5212, describing our Aerofiner brake system air purifier.

Please supply me in writing, the council's approval of our XFF9260-50 check valve in truck and bus air brake systems.

If there are any questions, feel free to contact me.

Sincerely yours

Donald T. Fischer -- Project Engineer, Coupling Section

ID: nht74-2.18

DATE: 06/07/74

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

TO: Certain-Teed Products Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 5, 1974, question whether S5.6.1 or S5.6.2 of Standard No. 121, Air brake systems, requires parking brakes on all axles other than front steerable axles.

S5.6.1 requires "parking brakes on an axle other than a steerable front axle" to have certain static retardation force values. "An axle" refers to any axle other than steerable front axles and therefore S5.6.1 requires parking brakes on all axles other than steerable front axles. A tandem axle consists of two separate axles for purposes of this requirement.

S5.6.2 has no specific axle-by-axle requirements. Its performance standard may be met by any means which hold the vehicle stationary and conform to S5.6.3 and S5.6.4. It should be emphasized that this requirement cannot be met simply be equipping the vehicle with parking brakes which hold to the limit of tractive ability but permit vehicle movement.

Yours truly,

ATTACH.

CERTAIN-TEED PRODUCTS CORPORATION

April 5, 1974

Chief Council -- National Highway Traffic Safety Adm., U.S. Department of Transportation

RE: Federal Vehicle Motor Safety Standards No. 121-Air Brake System Docket No. 74-10; Notice 1

Dear Sir:

We are requesting clearification of Paragraph S. 5.6.1 and S. 5.6.2.

Is the intent of Paragraph S. 5.6.1 to require parking brakes on all axles other than a steerable front axle, and is a tandum axle from the viewpoint of this regulation considered to be made up of two (2) separate axles?

In Paragraph S. 5.6.2, is it necessary to have parking brakes on each axle of the vehicle, or would a vehicle be acceptable if parking brakes mounted on only a portion of the axle were adequate to meet the grade holding requirements.

There appears to be questions in the minds of vehicle manufacturers, who are our customers, as to whether a trailer or a truck and bus with a modulated emergency system would require parking brakes on all non-steerable axles or whether only a portion of the axle requires parking brakes. We would appreciate an early reply to this inquiry.

Yours very truly,

B. D. Sibley -- Chief Product Engineer, Brake Products

ID: nht74-2.20

DATE: 05/13/74

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

TO: American Trailers, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 12, 1974, question whether a permanently attached steerable axle on a trailer is required (1) to meet the S5.3.2 stopping distance requirement with no uncontrolled lockup of any wheel above 10 mi/h, and (2) to meet the parking brake requirements for trailer converter dollies or for all other vehicles.

The answer to your first question is yes. The steerable axle(s) of any trailer must meet the stopping distance requirements of S5.3.2 with no uncontrolled lockup of wheels above 10 mi/h.

In answer to your second question, the permanently attached steerable axle you describe is not a separate vehicle which would qualify as a trailer converter dolly. Therefore the axle is simply part of a trailer which must meet the parking brake requirements of either S5.6.1 or S5.6.2. Neither of these options specifies that there be parking brakes on steerable axles, although in satisfaction of S5.6.2 (grade holding), the manufacturer could utilize parking brakes on the steerable axle.

Yours truly,

ATTACH.

April 12, 1974

James B. Gregory -- Administrator, National Highway Traffic Safety Administration

Dear Sir:

We manufacture a complete line of semi-trailers. Among these is a doubles grain trailer setup. In this doubles grain setup the lead trailer is a 24 foot, single axle semi-trailer which connects to the truck-tractor by means of a standard kingpin. The second trailer is a two axle, four wheel type of trailer, 21 foot long, which is connected to the lead trailer by means of a pintle hook-lunette eye attachment. The front axle on the second trailer is part of a dolly, which is steerable, and is permanently attached to the trailer by means of a bolted 360 degrees turntable.

Our question is one of interpretation. Is the front axle dolly a "converter dolly" in the sense that it would be exempt from having "antilock" and spring brakes as outlined in S5.8 of standard 121? Or is it to be classed so that it will require anti-lock and spring brakes? Your expeditious answer as to interpretation is appreciated.

Sincerely, Al Zajic -- Project Engineer, AMERICAN TRAILERS, INC.

Encl:

(Graphics omitted)

LEAD TRAILER

SECOND TRAILER

PERMANENT 360 DEGREES TURNTABLE

ID: nht79-1.2

DATE: 11/20/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Continental Hydraulic Hose Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Allan E. Cameron Continental Hydraulic Hose Corp. State Route 182 East P.O. Box 337 Upper Sandusky, Ohio 43351

Dear Mr. Cameron:

This responds to your recent letter asking questions concerning the labeling requirements of Safety Standard No. 106-74, Brake Hoses, as they would apply to "permanently crimped" hydraulic brake hose assemblies.

Under the standard, a brake hose assembly must be labeled according to the specifications of either S5.2.9 or, at the option of the manufacturer, S5.2.4.1. Under S5.2.4.1, the brake hose end fitting must be permanently labeled with a designation (at least one-sixteenth of an inch high) that identifies the manufacturer and has been registered with the National Highway Traffic Safety Administration. It is not necessary under this option, however, to stamp the symbol "DOT" on the end fitting, to stamp a date on the end fitting or to attach a band or label to the hose assembly. The band or label is only required under the first option, S5.2.4.

Sincerely,

Frank Berndt Chief Counsel

October 2, 1979

Highway Safety Law Division Federal Highway Administration Department of Transportation Washington D.C. 20590

Attention: Mr. Hugh Oates.

Subject: MVSS - 106

Dear Mr. Oates,

Continental Hydraulic Hose Corporation is a manufacturer of hydraulic brake hose assemblies. Our products are permanently crimped. We are not a vehicle manufacturer.

Our interpretation of Paragraph S-5.2.4 and new S-5.2.4.1 as it applies to our labelling requirements is:

1) One end fitting shall be steel stamped with the designation "CH" in letters 1/16" high or more. This designation is on file with your office.

2) It is not necessary that the letters "DOT" be stamped on the hose fitting.

3) It is not necessary that a date be stamped on the hose fitting.

4) It is not necessary that a band or label be attached to the hose assembly, so long as designation in item 1 above is met.

Please advise if you disagree.

Sincerely,

Allan E. Cameron Vice President

AEC/rw