ID: nht81-1.46

DATE: 03/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Eidal International Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

M. William E. Medcalf Engineering Manager Eidal International Corp. P.O. Box 2087 Alburquerque, NM 87103

Dear Mr. Medcalf

This is in response to your letter forwarding your firm's vehicle identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115 -Vehicle identification number.

The National Highway Traffic Safety Administration (NHTSA) does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.

Sincerely,

Frank Berndt Chief Counsel

November 7, 1980

National Highway Traffic Safety Administration 400 South Street, S.W. Washington, D.C. 20590

Attention: VIN Coordinator

Dear Coordinator:

Pursuant to the requirements of 49 CFR 575.115, as revised and amended per Docket No. 1-22, please find enclosed the information required to decipher the characters contained in VIN's to be assigned by the Eidal International Corporation (EIC).

Additionally, EIC petitions for a waiver of the sixty (60) day advance filing requirement, as it applies to the attached character decipher information. Our small firm was not made cognizant of this new requirement until late September 1980, and has proceeded with all possible deliberation to develop the attached character codes.

EIC is a small, low volume (less than 500 trailers per year) manufacturer of transportation equipment. Our products, with few exceptions are custom designed to meet the needs of our customers in the heavy-haul, oilfield, and military equipment markets. Accordingly, the Society of Automotive Engineers has assigned the codes 1E9 and 015 for EIC use in VIN positions 1-3 and 12-14, respectively, of the complete 17 digit VIN.

It is our belief that the enclosures, which are preceeding completion of our procedure, fully explain the method of encoding the required information. A copy of the finalized procedure will be filed as soon as it becomes available. If additional information is required, please do not hesitate to contact me.

Sincerely,

EIDAL INTERNATIONAL CORPORATION William E. Medcalf Engineering Manager

dw

Enclosure

ID: nht81-2.18

DATE: 04/28/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Weinblatt & Knee

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of March 5, 1981, in which you requested a copy of Federal Motor Vehicle Safety Standard No. 205, Glazing Materials. You are apparently trying to determine what types of glazing material may be used in "caps" installed on truck bodies.

Safety Standard No. 205 specifies performance requirements for glazing materials to be used in motor vehicles and motor vehicle equipment. The standard incorporates by reference the American National Standard "Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways," Z26.1-1966 (ANS Z26). Copies of both standards are enclosed. ANS Z26 and Standard No. 205 list 13 "Items" or types of glazing that vary in terms of the performance tests each item must pass and the locations in which each type of glazing may be used. While the meaning of the word "cap" as used in your letter is somewhat unclear, we presume you are referring to a "pickup cover." A "pickup cover" is defined in paragraph S4 of Standard No. 205 as a camper having a roof and sides but without a floor, designed to be mounted on and removable from the cargo area of a truck by the user. All 13 items of glazing may be used in pickup covers. However, some items (e.g., Item 6) may not be used in forward-facing windows, and others (e.g., Item 5) may not be used at levels requisite for driving visibility.

Certification and marking requirements for glazing are found in paragraphs S6.4 and S6.5 of Standard No. 205.

We hope you find this information helpful. Please contact this office if you have any further questions.

Sincerely,

ATTACH.

March 5, 1981

U.S. Department of Transportation -- Attn: Regulatory Division

Gentlemen:

I have been informed by a client that there is a Federal regulation promulgated by your Department requiring a certain safety stamping with a number of every peice of glass or plastic substitute for glass used on any auto, truck, camper, cap, etc.

I would greatly appreciate a copy of that regulation since it involved a legal question as to what my client is allowed to install as part of his business of selling caps that go on truck bodies.

Thank you for your immediate attention in this matter.

Very truly yours,

SEYMOUR S. WEINBLATT -- WEINBLATT & KNEE COUNSELLORS AT LAW

ID: nht81-2.32

DATE: 06/09/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Robinson L. P. Gas Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter requesting information regarding the conversion of school bus fuel systems to dual fuel carburetion running on propane gas. Specifically, you ask whether any regulations require that a protective cage be placed around a propane fuel tank, if propane carburetion is installed on a school bus.

The answer to your specific question is no. Federal motor vehicle safety standards and regulations do not require protective cages for propane fuel tanks. In fact, the Federal safety standard regarding fuel system integrity, Standard No. 301, is not directly applicable to propane fuel systems.

I am enclosing a fact sheet for your information which discusses the Federal implications of installing auxiliary fuel tanks and of converting fuel systems to use alternate fuels. From that fact sheet you will see that there may be certain responsibilities which must be met by persons converting school buses to use dual fuel systems. Please feel free to contact Hugh Oates of my staff if you have any further questions after reviewing this information (202-426-2992).

You will have to contact your State department of motor vehicles to determine if there are any local laws or regulations which would require the installation of a protective cage around propane fuel tanks.

SINCERELY

May 12, 1981

National Highway Traffic Safety Administration

Attn: Roger Tilton Legal Counsel

I recently had a conversation with Billie Renyolds, Executive Director of the National School Transportation Association and she directed me to your office for information regarding the conversion of school buses to dual fuel carburetion running on propane fuel.

More specifically, I am interested in finding if the application of a cage around a propane tank is necessary for installation of propane carburetion on school buses. There has been much controversy regarding this subject during the past year. Because Robinson L. P. Gas Company will be converting school buses to propane, we, of course, are very interested in knowing what the proper procedures should be according to state and federal codes.

As of this date, all propane conversions done in the state of Pennsylvania have not had a cage around the fuel tank. The tanks have been installed according to Pamphlet 58 and we are using ASME motot fuel 312 PSI tanks.

Thank you for your consideration. I will be looking forward to your reply in the near future.

Carol Kirk Marketing Representative

CC: RICHARD C. MARTIN -- ROBINSON L. P. GAS CO.

ID: nht74-1.10

DATE: 10/04/74

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

TO: Nissan Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 11, 1974 asking for an interpretation of paragraph S5.3.5 of Standard No. 105-75. You indicate that a prospective Nissan design uses a common indicator lamp to show both loss of fluid pressure and low brake fluid level. You ask if the indicator lamp lens may be labeled "Brake Failure."

The answer is no. If separate indicator lamps are used, Standard No. 105-75 allows words in addition to "Brake" to indicate the specific area where a problem may exist, e.g. an indicator lamp may be labelled "Brake fluid" to indicate a low level of fluid. However, if a lamp indicates more than one type of condition, paragraph S5.3.5 specifies that only a single word, "Brake," may be used. This alerts a driver in a general way that a problem exists somewhere in the brake system. We think the restriction of S5.3.5 preferable for most circumstances. In the configuration you propose for example, the word "Failure" would not accurately describe a low level of brake fluid.

We appreciate your continued interest in vehicle safety.

Yours truly,

ATTACH.

September 11, 1974

Richard B. Dyson -- Acting Chief Council, National Highway Traffic Safety Administration

Dear Mr. Dyson:

This is to ask your interpretation of S.5.3.5, indicator lamp requirement of MVSS 105 - 1975, which states:

"If separate indicator lamps are used for one or more of the various functions described in S5.3.1(a) to S5.3.1(d), the lens shall include the word 'Brake' and appropriate additional labeling (use 'Brake Pressure', 'Brake Fluid' for S5.3.1(a) and S5.3.1(b) except that if a separate parking indicator lamp is provided, the single word 'Park' may be used."

As I explained to Mr. Vinson on the phone, Nissan's 1976 model will be equipped with two sensors, brake fluid level sensor and pressure loss sensor (if one of the two sensors or both operate, the indicator lamp turns on). Therefore, since we cannot use either the word "Brake Pressure" or "Brake Fluid" as requested in the standard, we would like to use the word "Brake Failure" instead.

Would you kindly advise us as to whether or not this word "Brake Failure" is acceptable; and if not, please recommend a suitable word for our use. Your cooperation would be greatly appreciated.

Thank you.

Very truly yours,

NISSAN MOTOR COMPANY, LTD.; Tatsuo Kato -- Staff, Safety

ID: nht74-1.29

DATE: 08/13/74

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. Eric L. Clabourgh

COPYEE: L. OWEN

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your recent letter to the Administrator, National Highway Traffic Safety Administration, concerning the placement of front turn signal lamps on fire trucks.

Federal Motor Vehicle Safety Standard No. 108, "Lamps, Reflective Devices, and Associated Equipment" (copy enclosed) requires that front turn signal lamps be located "at or near the front and be spaced "as far apart as practicable." We would, therefore, have no objection to moving the front turn signal lamps on the fire truck from the side to the front. Locating the lamps on the front could also reduce the chance of damage to them, which might occur if they were located on the side.

Sincerely,

ATTACH.

Administrator And Counsel N.H.T.S.A. Washington, D.C.

Gentlemen:

I am in need of urgent information deciding a standard, specifically, standard 108, I understand, applies to big trucks. All effective 1-1-68. Soon we, the city of (Illegible Word) town commissioners, will receive a fire truck chassis made by international and the rest by the American fire apparatus co. of (Illegible Word), Iowa.

In a few months it will be delivered and it was bought with (Illegible Words) sharing money.

We are in debate! the Fire (Illegible Text)

(Graphics omitted)

These International beauties won't make the taxpayers see red.

Fires and fire departments come in a lot of different sizes -- and so do international Fire Truck chassis.

There's one to fit your budget, sure, but more important they'll also fit the kind of community you serve and the kinds of fires you fight.

I like the CARGOSTAR(R) top right, a short wheel base lets you turn in tight spots. The cab-over design gives you better visibility, and the cab also tilts forward for quicker, handier engine access. You can get it equipped the way you want it, with power to pump up to 1,250 gallons a minute.

On the left is a customized FLEETSTAR* chassis it comes with GVW ratings from 23,000 to 54,000 pounds and pound for pound it's the most efficient, economical fire-fighter around.

Down front is international's LOADSTAR* it can be customized as an assist-type vehicle, rescue truck pumper, or ladder truck. And this one has an engine and fuel capacity big enough to keep on working till the smoke clears.

(Graphics omitted)

ID: nht78-1.44

DATE: 09/21/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: West Seneca Central School District

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 4, 1978, letter asking whether you can modify several buses that you have purchased by adding stanchion bars near the front door to facilitate the loading of smaller school children.

The National Highway Traffic Safety Administration does not prohibit the use of stanchion bars in school buses. Some manufacturers, however, have discontinued putting them in buses because it is difficult to pad them sufficiently such that they comply with the head impact zone requirements when the bars fall within the head impact zone.

The National Traffic and Motor Vehicle Safety Act of 1966 (the Act) prohibits modification of vehicles by repair businesses, dealers, or manufacturers that would render inoperative compliance with safety standards (section 108(a)(2)(A)). Therefore, if a dealer, repair business, or manufacturer were to install stanchion bars in your school buses, it would be required to ensure that the installation does not render inoperative compliance with the head impact zone requirements. The Act does not prohibit, however, modifications by individuals of their vehicles even when such modification would not comply with Federal safety standards. Accordingly, a school district could itself install stanchion bars that do not comply with the head impact zone requirements.

SINCERELY,

May 4, 1978

National Highway Traffic Safety Administration

Reference: Code of Federal Regulation, Part 571.222 School Bus Passenger Seating & Crash Protection

Gentlemen,

Recently we purchased 20 65-passenger buses. These buses, according to your regulations, had crash pads near the entrance way but the stanchion bars for help in boarding and leaving the buses were removed. Our Board of Education is not objecting to the crash pads but there is a strong feeling that some protection has been removed in the process of getting on and off the buses, particularly for small children.

We checked this matter out with the New York State Department of Transportation and this agency suggested that we write to you to see if we could get your approval. The question is this; may we install one or two stanchion bars at the entrance steps on the recently purchased 20 buses. If this meets your approval please write us a letter accordingly. It certainly would not be our intent to remove the pad.

Thank you for your early attention to this matter.

J. W. Yarbrough Assistant Superintendent for Business

ID: nht79-1.37

DATE: 04/03/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

APR 3 1979

NOA-30

Mr. Hisakazu Murakami Nissan Motor Co., Ltd. P.O. Box 1606 560 Sylvan Avenue Englewood Cliffs New Jersey 07632

Dear Mr. Murakami:

This responds to your letter of January 23, 1979, concerning a new design belt system for rear seat lap belts that you would like to use in future vehicles. You ask if the proposed design would comply with the requirements of Safety Standard No 208.

The answer to your question depends in which seating position in the rear seat of the vehicle the proposed belt system would be used. The new design would not comply with paragraph S7.1.1 of Safety Standard No. 208 if installed at outboard designated seating positions in the rear seat. That paragraph requires lap belts to adjust by means of an emergency-locking or automatic-locking retractor to fit persons whose dimensions range from those of a 50th-percentile 6-year-old child to those of a 95th-percentile adult male. In some cases your proposed design would not adjust automatically to fit a 95th-percentile adult male.

The proposed design would comply with the standard, however, if installed in the center seating position of the rear seat, since paragraph S7.1.1.2 specifies that a seat belt assembly installed at any designated seating position other than the outboard positions of the front and second seats shall adjust either by a retractor or by a manual adjusting device.

Since your new belt system design would currently be precluded for outboard designated seating positions, you may wish to petition for amendment of Safety Standard No. 208. Any petition should include an adequate description of the belt design, including: (1) seating positions for which the belt system would be applicable, (2) advantages of the system, (3) size of the belt system hardware, and (4) problems, if any, associated with automatic retraction of the belt system.

The National Highway Traffic Safety Administration hereby grants your request for confidentiality of the new belt system design described in your letter. Please notify us if the design becomes public in the future. Also, please note that if you petition for rulemaking in this area, the details of your belt design would probably have to be disclosed to the public, at least in general terms.

Sincerely,

Frank Berndt Acting Chief Counsel

ID: nht79-1.5

DATE: 11/29/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: United States Senate

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Honorable S. I. Hayakawa United States Senate Washington, D.C. 20510

Dear Senator Hayakawa:

This responds to your October 25, 1979, letter enclosing correspondence from your constituent Mr. Morrill N. Farr asking about the agency's air brake standard. Mr. Farr also asked about the highway use tax. We understand that the Federal Highway Administration will respond to you directly with an answer to that question.

With respect to the air brake standard, Mr. Farr asked whether the Government would reimburse him for a portion of the costs of installing the no lockup portion of his air brake system. Mr. Farr stated that a court has held the no lockup requirement of the air brake standard invalid, and accordingly, the Government should reimburse vehicle owners for the installation of no lockup systems that have been proven to be faulty.

The court in PACCAR v. The National Highway Traffic Safety Administration, 573 F.2d 632 (9th Cir. 1978) cert. den'd 439 U.S. 862 (October 2, 1978), stated that the no lockup portions of the standard were invalid because some of the systems constructed in accordance with the requirements were unreliable. The court also indicated that a proper no lockup device could substantially improve the safety of vehicles. Our air brake standard does not specify a particular design or construction of brake system. It is a performance standard, and manufacturers are free to choose any design or construction that complies with the performance requirements. The fact that some manufacturers chose faulty systems is unfortunate. If the system on Mr. Farr's truck is faulty, his remedy lies with the manufacturers of the truck and the system, not with the Government.

This agency has attempted over the past several years to address the problem of faulty systems by initiating several investigations under the statutory provisions requiring manufacturers to recall and remedy defective vehicles and equipment. Those investigations contributed to the decisions of a number of manufacturers to conduct recalls.

Sincerely,

Frank Berndt Chief Counsel

Enclosure Constituent's Correspondence

October 25, 1979

Department of Transportation Congressional-Liaison 400 Seventh St. SW Washington, D.C. 20590

Gentlemen:

Enclosed is a copy of correspondence I received from Mr. Morrill Farr. I would appreciate any information you could provide regarding this matter.

Please forward your reply, in duplicate, to the attention of my staff assistant, Samuel R. Buck, Room 6217, Dirksen Senate Office Building, Washington, D.C. 20510.

Sincerely,

S. I. Hayakawa

SIH/pw Enclosure

ID: nht79-1.50

DATE: 11/09/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Toyo Kogyo U.S.A.

TITLE: FMVSS INTERPRETATION

TEXT: This letter is in response to your October 19, 1979, request for an interpretation of the requirements of Federal Motor Vehicle Safety Standard No. 110 and 49 CFR Part 575. Specifically, you inquired if it is permissible for Mazda to place information concerning the 185SR13 tire size on the tire placard, as required by section 4.3(d) of Standard No. 110, and in the consumer information booklet, as required by 49 CFR @ 575.102(c)(2), for vehicles which may have 185HR13 tires installed by dealers at a customer's request. This would be permissible.

A 185SR13 tire and a 185HR13 tire are the same size and have the same load-carrying capacity. The "S" and "H" only denote different high-speed capabilities for what are, otherwise, identical tires.

This agency requires the manufacturer to list recommended tire sizes on the tire placard and in the consumer information booklet for two reasons. First, the information is required to ensure that any replacement tires installed on the vehicle will be a proper size for the rims mounted on that vehicle. Second, the information helps to ensure that the tires installed on the vehicle will have sufficient load-carrying capacity to be used safely on that particular vehicle. Neither of these safety concerns would be frustrated by a manufacturer putting information on the placard and in the booklet about a tire with a lower speed rating. Therefore, your proposed plan would not violate any of our consumer information regulations.

Sincerely,

ATTACH.

October 19, 1979

Chief Counsel -- National Highway Traffic Safety Administration

Dear Sir,

RE: Request for Interpretation on MVSS 110 & Part 575

MVSS 110 Sec. 4.3 (d) requires the vehicle manufacturer's recommended tire size designation on the tire placard and also Sec. 575.102 (c)(2) requires recommended tire size designations in the consumer information booklet. One of our MAZDA models has 185SR13 as the standard tires. Currently, we are considering 185HR13 as a dealer option because some customers want a higher performance tire on their cars. We do not believe that we should put 185HR13 as the recommended tire on the tire placard, for it is a higher performance than 185SR13 and it is not installed at our factory. Please grant us your interpretation.

Your earliest response would be highly appreciated.

Sincerely yours,

M. Ogata -- Branch Manager, TOYO KOGYO U.S.A. OFFICE

ID: nht87-3.38

TYPE: INTERPRETATION-NHTSA

DATE: 12/07/87

FROM: RICHARD H. SCHULTZ -- AMERICAN PULSE LIGHTS INC

TO: ROBERT J. KNAUFF

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/24/89 FROM STEPHEN P. WOOD -- NHTSA TO ROBERT KNAUFF; REDBOOK A33; FMVSS 108; LETTER DATED 06/08/89 FROM ROBERT J. KNAUFF -- APPLIED RESEARCH AND DESIGN INC TO KATHLEEN DEMETER -- DOT; LETTER DATED 08/16/88 FROM RICH ARD H. SCHULTZ -- AMERICAN PULSE LIGHTS INC TO ROBERT KNAUFF

TEXT: Dear Mr. Knauff:

It was good to hear from you today and I'm glad that you are proceeding in a proper manner regarding the single-pulse signal enhancement feature that you propose to market for use in certain stop signal lamps.

As we discussed, there should be no intensity problem with the use in W, W2 and W3 types because there is no maximum intensity written into the standards for those lamp types. The lamp design intensities also generally far exceed what the three "W" stan dards call for, so any masking of the reflector in the lamp by the photo tube should not prevent adequate performance.

The flash energy formula described in SAE J1318 APR86 (S2.11) may be used to determine compliance with the maximum intensity requirement of SAE "U" type supplementary stop lamps. In J1318, class 1 directional lamps (table8) require 50 candela-seconds of flash energy at H-V. The same functions type lamp and test location in SAE J595 AUG83 (table 1) requires 300 cd intensity. This is a ratio of 1:6. It therefore follows that the maximum from flash energy in an SAE "U" type with a 60 cd limit should be 10 candela-seconds.

When you can obtain a test report that indicates the candela-seconds in an SAE "U" lamp, I would like to see a demonstration of the tested arrangement for assurance that there is no "discomfort" glare at that level. This is primarily because we have a t otally new concept here and we want to be on the safe side. Same goes for use in school bus type "W2" lamps. The momentary light will be paler than the limit for red specified in SAE J578d color standard, but if it is not within the limit for white, it will be an acceptable color.

You said that there is no problem with setting higher or lower intensities if necessary, so you should be able to proceed with your formal request for authorization after the test and demonstration go as anticipated.

Sincerely,