ID: nht69-1.13

DATE: 02/26/69

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Mr. T. Sudderth

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 22, 1969, concerning safety glazing in your motor home.

We do not know what is meant by the description "Windows-Double Density - glass - set."

Glasing materials in a motor home must be in accordance with Federal Standard No. 205. Glass in the windshield must be AS1, not AS2 as your letter states. The windows on either side of the driver's compartment may be AS2, and AS2 may be used in the balance of the windows when needed for driver visibility or AS3 may be used in the balance of the windows when not needed for driver visibility.

The markings of glazing materials cited in your letter indicate that the materials used in your motor home are in accordance with Federal Standard No. 205, with the exception that you state that AS2 is marked on the windshield.

Please advise me if AS1 is not installed in the windshield of your motor home.

Sincerely,

January 22, 1969.

The National Highway Safety Bureau Department of Transportation

Gentlemen:

A few months ago I bought a new Dodge Motor Home (Travco) and it was ordered out from production with a number of option equipment items. One was identified as -

"Windows - Double Density - glass - Set

As of this date I am not too sure that this was included in the assembly and I have no way to identify the item and judge if I have paid a fair price.

Will you please assist me - The glass in the windshield and two side of driver compartment are marked as

Guardian Safety Glass As 2-67

Tempalite Solid Tint GG M 66

The glasses on the side walls are market's as follows - TWI-Lite Safety-Lite AS 3 M 21

The rear window is marked -

AT Asorbing Safety Glass

Solid Tempered M " 286

I am unable to see any identification on the two small glasses in the entrance doow assembly.

Your prompt comments will be appreciated.

Yours very truly

T. Sudderth

PO Box 757 - Laurens 29360

ID: nht70-2.46

DATE: 12/18/70

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

TO: Electrical Testing Laboratories, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your request for clarification of S4.4.2 of Federal Motor Vehicle Safety Standard No. 108 (Lamps, Reflective Devices, and Associated Equipment), as published in the Federal Register on October 31, 1970 (35 F.R. 16843).

You have asked the following questions:

"1. How many flashers constitute a sample for test?"

"2. How many failures, and of what types, are allowed for compliance?"

The safety standards do not specify sampling provisions or failure rates. The reference to test samples in the SAE materials referenced in Standard No. 108 were deleted in the above notice, to bring the standard into conformity with the requirements of the National Traffic and Motor Vehicle Safety Act, which requires that all items conform to the standards. It is the manufacturer's responsibility to institute a test program that will ensure that his products meet the standards.

"3. Which sentences or paragraphs in SAE J590b and SAE J345 are specifically referenced for omission?"

I attach copies of the two SAE Standards marked to show omissions.

"4. Does the statement 'tested consecutively' refer to the combination turn signal and hazard warning signal flasher or the SAE standards?"

This statement means that the combination unit is tested first to determine compliance with SAE J590b and then tested in accordance with SAE J945.

"5. * * What statement of test results is available to the testing organization?"

How you state your test results is a question to be decided between you and your clients. If you find that an item fails the standard in a particular respect, I presume that you will so state.

"6. * * Can or should all current tests on these devices be made according to the above modified procedures during this interim period prior to [the effective date of the amendment]?"

As stated above, the method and timing of a manufacturer's tests is not regulated by the Bureau. The test program should be sufficient to legally constitute are care, on a continuing basis, to ensure that all products manufactured after the effective date of a standard meet the applicable requirements.

I hope this answers your questions.

ID: nht71-1.16

DATE: 07/02/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Drake America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of June 18 you ask for confirmation "that automotive brake fluids SAS 7OR1 Heavy Duty and SAE 7OR3 Super Heavy Duty currently meet U.S. standards."

Federal Motor Vehicle Safety Standard No. 116, Motor Vehicle Hydraulic Brake Fluids, specifies performance requirements for SAE Type 7OR1, Type 7031 Arctic, and Type 70R3 brake fluids. Thus if those Types of brake fluids conform to the performance requirements of Standard No. 116 they will meet current Federal requirements.

You also ask for confirmation "that it is illegal for SAE 70R2 Moderate Duty to be sold in the U.S. . . . ." Paragraph S4 of Standard No. 116 does allow the manufacture and sale of types other than 70R1, 70R1 Arctic and 70R3, however, "when the type indicated is not the of these three types, the hydraulic brake fluid shall comply with [Standard No. 116's performance] requirements for SAE Type 70R1 ...." Since SAE Type 70R2 does not meet these requirements, its manufacturer, sale, and importation into the United States is precluded.

For your information I enclose a copy of a new amendment to Standard No. 116, a revised version of the Standard effective March 1, 1972, and an advance notice of proposed amendment which would allow fluids other than petroleum base, all of which appeared in the Federal Register for June 24.

Sincerely,

June 18, 1971

National Highway Traffic Administration Department of Transportation

Att:Lawrence R. Schneider

Acting Chief Counsel

Gentlemen:

As requested during our telephone conversation of this afternoon, we would appreciate your confirming to us the fact that automotive brake fluids SAE70RI Heavy Duty and SAE70R3 Super Heavy Duty currently meet U.S. standards.

If you can likewise indicate that it is illegal for SAE70R2 Moderate Duty to be sold in the U.S., it will be of assistance to us in establishing for a foreign government the standards followed by our government in the use of automotive brake fluids.

Many thanks for your assistance.

Yours very truly

Automotive Export Division

DRAKE AMERICA CORPORATION --

Paul M. Pancirer, Manager

ID: nht71-2.35

DATE: 04/30/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Hamill Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 16, 1971, in which you ask certain questions concerning a child booster seat that you plan to market. You describe the booster seat as a rectangle about 6 inches in height, tapering to 4 inches in the front, and state that it would be advertised for use by children under 50 pounds and would not be designed to fall into the category of child seating systems under Standard No. 213. You also state that your engineers feel a booster chair will "definitely help more five, six and seven year old children to use seat belts simply because these children will be able to see out of a vehicle."

While you state that the booster seat "would not be designed to fall into the category of child seating systems under Standard No. 213," it is not clear from your description of the device that this is actually the case. If you wish an opinion on this matter, we will provide one, but to do so we will need some additional information. Specifically, we will need to know if the booster seat is to be designed or advertised for use with the vehicle seat belts, and if so, how it will be so designed or advertised.

The questions you ask concerning the booster seat are: (1) Can we set a minimum of 50 or 60 pounds? (2) Exactly what is the maximum child weight covered under MVSS #213? and (3) What recommended weight can we advertise as a minimum for our booster seat?

The answers to these questions do not depend on whether the standard applies to your booster seat. If the device is a child seating system, Standard No. 213 does not specify the minimum or maximum heights or weights for children who may use it. Under the standard, it is up to the manufacturer to determine, based upon the design of each particular child seating system, the heights and weights of children for which he recommends the child seating system.

If the device is not a child seating system, the manufacturer is not required to recommend any heights or weights for children who can use it. Should he choose to do so, however, the heights and weights recommended must be consistent with the safe use of the device.

ID: nht71-2.7

DATE: 02/16/71

FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA

TO: Ford Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter dated January 22, 1971, to the National Highway Traffic Safety Administration, requesting the addition of the 5 1/2-J alternative rim size for the 175 SR 13 tire size designation to Table I - Appendix A of Federal Motor Vehicle Safety Standard No. 110.

On the basis of the data submitted indicating compliance with the requirements of Federal Motor Vehicle Safety Standards No. 109 and No. 110 and other information submitted in accordance with the procedural guidelines set forth in the Federal Register, Volume 33, No. 195, page 14964, dated October 5, 1963, the 5 1/2-JJ alternative for the 175 a 13 tire size designation will be listed within Table I - Appendix A of Standard No. 110. Our substitution of rim size 5 1/2 J by 5 1/2 JJ follows our practice of not listing the "J" or "JK" rim contours since a footnote to Table I, Appendix "A" states "Where JJ rims are specified in the above table, J and JK rim contours are permissible."

The above change will be published in the Federal Register in the near future.

The addition of new alternative rims to the table is accomplished through an abbreviated procedure consisting of the publication in the Federal Register of the petitioned alternative rim. If no adverse comments are received, the amendment becomes effective after 30 days from date of publication. If comments objecting to amendments are received, additional rule making pursuant to Part 553 of the Procedural Rules for motor vehicle safety standards will be considered.

As we reviewed your attachments we note on attachment I - page 1 a statement that "in compliance with Legal Requirements 4.04 for the U. S. A., the tires were to be burst not only for one wheel position, but for all of the four wheel positions. Federal Motor Vehicle Safety Standard No. 110 - Section 4.4.1 requires that only one tire be tested for retention on the rim under conditions of rapid deflation. There is a possibility of some misunderstanding in these items which may be causing the overseas people doing more testing than necessary.

He also note in attachment III that the(Illegible Words) data is referenced to specific tires but the rim is not identified. This lack of rim identification precludes using the data for petition purposes even though the data level is of interest and shows that a(Illegible Word) seating problem is very unlikely. Fortunately for the purposes of this petition, Attachment II - page 2 contained adequate but less information(Illegible Word) Unseating data.

ID: nht72-1.42

DATE: 02/29/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mr. Richard F. Hirsch

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 29, 1972, on the subject of test procedures under Standards 207 and 210.

Your questions deal with the general and frequently asked question of whether a manufacturer may devise his own test procedures to determine compliance with a standard. Our answer is that he is free to use whatever method he thinks appropriate to test his product, so long as his method reliably predicts the performance of the product when tested according to the procedures set out in the standard.

In answer to your first question, therefore, if testing of seats in a mock up accurately indicates their performance in a vehicle, then mock up testing might be an appropriate test method. Our laboratories will be testing the seats in the vehicle. If a failure occurs, a manufacturer must show that he exercised due care in the development and production of the seat. To do this it will be necessary to show, among other things, that the development tests you conducted were, in fact, equivalent to the test procedures of the standard.

The same comment is appropriate in response to your second question. If you apply force through the seatbelt that approximates the combined forces of the belt anchorage test and seat anchorage test, you should take care to be sure that the test is, in fact, equivalent to a test in which the anchorages are tested simultaneouly in the manner specified in Standards 207 and 210.

Your third question is whether the test must be conducted with seatbelts and body locks, and if so, whether this would not be a redundant test of the seatbelt that is already required to conform to Standard 209. Although the response given to your first two questions is also appropriate for the third, there are practical reasons for using the vehicle's belts in the test. If the belt breaks, for example, it may be that your client would want to re-examine the sufficiency of the belt. Under Standard 208, the vehicle manufacturer is required to install a belt that conforms to Standard 209. If the belt fails in our testing under Standard 209, the vehicle manufacturer will have to show that he exercised due care in determining that the belt conformed to the standard. Using the belt in testing for Standard 210 is one way of detecting potentially serious belt problems.

ID: nht72-2.16

DATE: 05/19/72

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

TO: Norman W. Quinn, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 5 on behalf of your client Lee Ross. Mr. Ross has developed a motor vehicle deceleration warning system that, as described by you, activates two amber lights on the rear of a vehicle. Your letter indicate that these lamps would be incorporated into a vehicle back-up lamp system and that Mr. Ross envisions his system as an aftermarket accessory item rather than as new vehicle original equipment. You state your understanding that Motor Vehicle Safety Standard No. 108 would not preclude marketing the system as an aftermarket accessory, and that back-up lamps are required to be white in color. You ask our advice whether Standard No. 108 prohibits amber lamps in the back-up lighting system and, if so, whether a proposal for amendment of the Standard to allow the system would be feasible.

Standard No. 108 would in certain instances preclude the aftermarket sale of an amber deceleration warning system incorporated into a back-up lamp system. Standard No. 108 as of January 1, 1972, does cover certain aftermarket equipment items, and in some instances would preclude the sale of a back-up light system with amber lamps. Lighting equipment manufactured on or after that date as replacement for similar equipment on vehicles manufactured on or after January 1, 1972, must meet Standard No. 108 which, as you have noted, requires that the color of the back-up lamps be white. Federal law would not preclude sale of this system for use on motor vehicles manufactured before January 1, 1972, or purchase of an amber system by the owner of a vehicle manufactured after that date if he wished to change over from a white to amber system. As a practical matter, however, I believe That virtually every State has a requirement that back-up lamps be white, and that a back-up light with amber bulbs or lenses would be forbidden. Standard No. 108 would not preclude sale of the Ross System as a separate lighting device. I do not know what position the States would take on such a matter.

Our research contracts on deceleration warning system indicate that further development and testing under field conditions is necessary before specific proposals can be made by NHTSA. Therefore, I do not think action on a proposal by Mr. Ross would be feasible at this time, though we would welcome his comments to our Docket 69-19 as a comment to be considered in future rulemaking on this subject.

ID: nht72-2.49

DATE: 10/18/72

FROM: C.A. BAKER FOR E.T. DRIVER -- NHTSA

TO: Bandag, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of September 27 you suggest that Standard 117-paragraph 5.2.1(b) which relates to exposing fabric during the buffing operation of the retread process might be interpreted as forbidding the retreading of casings containing nail holes. You further quote the conclusion of an outside contractor of a Department of Transportation sponsored tire repair study that "while test wheel tests could not be passed on repaired tires, road tests showed them all to be satisfactory."

We do not consider nail holes to constitute an exposure of cord fabric within the meaning of the standard. Briefly, our examination of retread tires to date shows that nail holes which have been repaired with the repair materials vulcanized to the inside of the tire are very satisfactory. We have cut through such repairs and find them to be sound even after being subjected to Federal Motor Vehicle Safety Standards No. 109 and No. 117, Endurance and High Speed Wheel Tests. Providing the nail holes are permanently sealed on the inside of the tire they appear to be no more objectionable than the casing penetrations made by new tire manufacturers and retreaders in their awl venting procedures.

The Discussion Paper presented at the National Highway Traffic Safety Administration Technical Heating hold on April 10, 1969, contained rather detailed requirements for casings that were to be retreaded. Included within this extensive list were requirements for not retreading a casing if "two closed punctures (nail hole type) which extend through the fabric, or are less than 15" apart or are outside of the tread area." As a result of the comments received at the April 10, 1969, technical conference, at which you and Mr. Vischer attended, the Administration changed the casing condition requirements to only prohibit retreading of casing which had cord or bead wire exposed. The Administration considers the casing as part of the raw material used in the retreading process and as such, each retreader must use his exportise in casing selection prior to applying his DOT self-certification symbol.

Supplementing the above, we have noted that repairs with the repair materials not bonded to the carcass loosen during flexing and have a high incidence of failure on the Endurance and High Speed Wheel Tests.

ID: nht72-3.35

DATE: 05/05/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Resources Applications, Designs & Controls, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 12, 1972, on the subject of the test procedures of Motor Vehicle Safety Standards 207 and 210.

Your first question is whether the center of gravity referred to in S5.1.2 of Standard 207 is the center of gravity of the seat bench alone or the center of gravity of the seat bench in combination with the supporting structure. It is often a close question in recreational vehicle seating where the seating system ends and the vehicle structure begins. In cases such as the one depicted in Attachment 1 to your letter, where the supporting structure consists of a storage cabinet that is integrated into the interior structure of the vehicle, it is our opinion that the storage cabinet should not be considered in determining the weight and center of gravity of the seat bench under S5.1.2.

Your second question asks us to concur in your opinion that separate tests are not required under Standards 207 and 210 when identical seats are installed in different vehicles. Our reply is that the number of tests you perform is a matter for you to decide; we do not, as a rule, comment on the adequacy of a test program. The standards do not require a manufacturer to test his product in a specific manner or with a specific frequency, so that failure to test is not, in itself, a violation. If our Office of Standard Enforcement should happen to test one of the vehicles in question, however, and it fails when tested in accordance with the standard, the manufacturer may be subject to civil penalties unless he can establish that he exercised due care in the design and manufacturer of the vehicle. Whatever your decision on the subject of testing, it should be carefully made.

Our reply to your third question follows the reasoning set forth above. If we conduct a test in accordance with S4.2(d) and the seat fails, the manufacturer will have to establish that he exercised due care in making that seat. Without a set of specific facts before us, we cannot say what the result of our inquiry would be.

The label proposed for the rotating seat to indicate that it is not to be used while the vehicle is in motion except in the forward facing position would be an acceptable label under Standard 207.

ID: nht71-5.45

DATE: 09/16/71

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

TO: Electrical Testing Laboratories, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 8, 1971, concerning the recent amendment of Standard 108 concerning turn signal and hazard warning flashers (36 F.R. 17343, August 28, 1971).

You noted that test-condition temperatures are listed without tolerances, and asked what tolerance is acceptable for testing.

In the case of motor vehicle safety standards, the testing that a manufacturer may perform or have performed on its products is not an end in itself, but is done to enable the manufacturer to certify that the products meet the required performance levels under the specified conditions. Thus, the requirement that a product meet or exceed certain values at 75 degrees F. refers to a legal conclusion that is to be drawn from appropriate testing, and no tolerance is necessary or appropriate in the text of the standard. In practical terms, it is up to the manufacturer to determine what tests will enable him to certify his products as conforming. Normally, this is done by testing his products under slightly more adverse conditions than those specified in the standard. If, for example, higher temperatures constitute more adverse conditions for a flasher, the laboratory should test at a temperature slightly higher than that specified. In sum, the testing should be sufficient to support the conclusion that, if tested under the specified conditions, the product would perform as required.

RB

cc

ELECTRICAL TESTING LABORATORIES, INC.

September 8, 1971

Docket Section National Highway Traffic Safety Administration

Re: Docket No. 71-12588

69-18, notice 5

We have reviewed the above mentioned notice to amend Motor Vehicle Safety Standard No. 108 relative to automotive turn signal and hazard warning signal flashers. We find that in Section S4.6.1.3, subparagraphs (b)(ii) and (c)(ii) have been interchanged relative to current testing procedures. We also note that paragraph S4.6.1.3, subparagraph (c)(iv) 11 volts is shown as 11.00. The additional zero indicates accuracy beyond normal testing procedure.

We find that in all cases the ambient temperature is shown as 75 degrees F. without a tolerance. We would like to ask what tolerance is acceptable for testing.

W. Glenn Pracejus Manager Electrical/Electronic Division