ID: aiam1050

Dear Mr. Ferreira: This is in reply to your letter of March 8, 1973, requestin clarification on three points related to Federal Motor Vehicle Safety Standard No. 217, Bus Window Retention and Release.; >>>1. Glass Types. Glazing materials must conform with Standard No 205, Glazing Materials. ANSI Z26, incorporated into Standard No. 205 by reference, can be purchased from the American National Standards Institute, 1430 Broadway, New York, New York 10018. SAE J673a can be purchased from the Society of Automotive Engineers, Two Pennsylvania Plaza, New York, New York 10001.; 2. Locks. Paragraph S5.3.2 reads, When tested under conditions of S6 both before and after the window retention test required by S5.1, each emergency exit shall allow *manual release* of the exit...' (emphasis added).; 3. Tests. Two studies were contracted over the past few years whic related to bus windows. Reports of these studies may be purchased from the National Technical Information Service, 5285 Port Royal Road, Springfield, Virginia 22151.; (a) PB 195-231, Study of Bus Side Windows,' by All America Engineering Company. Cost: $3.00; (b) PB 198-772, Escapeworthiness of Vehicles and Occupant Survival Part 1' by University of Oklahoma Research Institute. Cost:$6.00; PB 198-773, Escapeworthiness of Vehicles and Occupant Survival - Part 2 and 3,' by University of Oklahoma Research Institute. Cost: $6.00.<<<; I am enclosing a copy of Standard No. 205. If I can be of further service, please do not hesitate to ask. Sincerely, Robert L Carter, Associate Administrator, Motor Vehicle Programs

ID: 8834

Mr. Dave Beidleman
Arizona Department of Transportation
Equipment Services

FAX 602-258-5193

Dear Mr. Beidleman:

We have received your FAX of July 2, 1993, to the attention of Taylor Vinson of this Office, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it pertains to the location of rear identification lamps.

The rear configuration of l0 dump trucks that are being constructed for the Arizona DOT is such that you would like to raise the center lamp of the three-lamp identification lamp cluster approximately 1 1/2 inches; the two outer lamps of the array cannot be raised due to the positioning of the underbody tailgate release mechanism.

Table II of Standard No. 108 requires that the identification lamps be mounted "as close as practicable to the top of the vehicle, at the same height, and as close as practicable to the vertical centerline." In our opinion, the lamps in an identification lamp cluster must be equally spaced laterally and mounted at the same height in order for the identification lamp system to perform its intended purpose. Therefore, I am afraid the agency cannot accept a lamp display that differs. Although the lamps could be mounted on the rear of the cab, we understand that in that position they could be obscured by the top lip of the dump body.

We realize that the contractor has pre-punched holes for the lamps, which would be flush-mounted in the rear cross sill of the truck body. If a way were found to cover the holes, there are surface-mounted lamps available which could be mounted at the same height (your desired height for the center lamp) in a manner than should not affect the positioning of the underbody tailgate release mechanism.

Sincerely,

John Womack Acting Chief Counsel

ref:108 d:7/29/93

ID: nht94-8.3

DATE: March 7, 1994

FROM: J. Roberts -- John H. Roberts Well Drilling Co.

TO: John Womack -- Acting Chief Counsel, U.S. Department of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 4/12/94 from John Womack to J. Roberts (A42; Part 571)

TEXT:

I received your letter of the 28th and thank you for your response.

Although I understand your department's position regarding the H.M.M.V.E., I would request your further assistance on clarification. Could you provide me with the list of the specific objections your department based its recommendation on.

Thank you in advance for your help.

ID: nht71-4.48

DATE: 11/16/71

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

TO: Barber-Greene Company

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive our delay in responding to your letter of August 27, 1971, asking if Department of Transportation safety equipment applicable to trailers is required for portable asphalt mixing machinery.

It is our current position that portable asphalt mixing machinery is a "trailer" and must be equipped with the lamps and reflectors required by Motor Vehicle Safety Standard No. 108. I am enclosing a copy for your information. A temporary lighting harness is an acceptable means of conformance. Mud flaps, incidentally, are not required under the Federal motor vehicle safety standards.

ID: nht94-1.69

TYPE: Interpretation-NHTSA

DATE: March 7, 1994

FROM: J. Roberts -- John H. Roberts Well Drilling Co.

TO: John Womack -- Acting Chief Counsel, U.S. Department of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 4/12/94 from John Womack to J. Roberts (A42; Part 571)

TEXT:

I received your letter of the 28th and thank you for your response.

Although I understand your department's position regarding the H.M.M.V.E., I would request your further assistance on clarification. Could you provide me with the list of the specific objections your department based its recommendation on.

Thank you in advance for your help.

ID: 2254y

Mr. Howard Kossover
CMI Trailer Division
P.O. Box 1985
Oklahoma City, Ok 73107

Dear Mr. Kossover:

This is in reply to your letter of December 8, l989, to Taylor Vinson of this Office. You have enclosed photographs of a semi-trailer that you are constructing, and wish to know whether the location of the rear turn signal, stop, and taillamps comply with the requirements of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

Table II of Standard No. l08 requires each of these lamps to be "on the rear". In addition, the SAE requirements for each of these lamps that are incorporated by reference into Standard No. l08 require that visibility of each lamp shall not be obstructed by any part of the vehicle throughout the photometric test angles for the lamp, unless the lamp is designed to comply with all photometric and visibility requirements with these obstructions considered. In addition, signals from lamps on both sides of the vehicle shall be visible through a horizontal angle from 45 degrees to the left to 45 degrees to the right. To be considered visible, the lamp must provide an unobstructed projected illuminated area of the outer lens surface, excluding reflex, at least 2 square inches in extent, measured at 45 degrees to the longitudinal axis of the vehicle.

The lamps on your semi-trailer are mounted 27 inches from the rear edge of the vehicle. In that position the lamps are not mounted "on the rear". Further, we question whether the 45 degree visibility requirements would be met, especially for the inboard lamps. We do not know whether the extended portion of the vehicle between the lamps is a sufficient obstruction to affect compliance with the photometric requirements. Overall, it does not appear that this design complies with Standard No. l08.

Sincerely,

Stephen P. Wood Acting Chief Counsel / ref:l08 d:l/9/90

ID: nht93-5.37

TYPE: Interpretation-NHTSA

DATE: July 29, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Dave Beidleman -- Arizona Department of Transportation, Equipment Services

TITLE: None

ATTACHMT: Attached to letter (fax) dated 7/2/93 from Dave Beidleman to Taylor Vinson (OCC 8834)

TEXT:

We have received your FAX of July 2, 1993, to the attention of Taylor Vinson of this Office, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it pertains to the location of rear identification lamps.

The rear configuration of 10 dump trucks that are being constructed for the Arizona DOT is such that you would like to raise the center lamp of the three-lamp identification lamp cluster approximately 1 1/2 inches; the two outer lamps of the array cannot be raised due to the positioning of the underbody tailgate release mechanism.

Table II of Standard No. 108 requires that the identification lamps be mounted "as close as practicable to the top of the vehicle, at the same height, and as close as practicable to the vertical centerline." In our opinion, the lamps in an identification lamp cluster must be equally spaced laterally and mounted at the same height in order for the identification lamp system to perform its intended purpose. Therefore, I am afraid the agency cannot accept a lamp display that differs. Although the lamps could be mounted on the rear of the cab, we understand that in that position they could be obscured by the top lip of the dump body.

We realize that the contractor has pre-punched holes for the lamps, which would be flush-mounted in the rear cross sill of the truck body. If a way were found to cover the holes, there are surface-mounted lamps available which could be mounted at the same height (your desired height for the center lamp) in a manner than should not affect the positioning of the underbody tailgate release mechanism.

ID: 10913

Ms. Bonnie Ward
Eagle County School District RE 50J
P.O. Box 740
Eagle, CO 81631

Dear Ms. Ward:

This responds to your May 2, 1995, letter following up on information provided you by Charles Hott and Leon DeLarm of this agency, concerning the safety of school buses and "over-the-road type coaches" (e.g., Greyhound-type buses). You ask for confirmation that our safety standards for school buses "are above and beyond the requirements for over-the-road coaches."

That statement is correct. Our Federal motor vehicle safety standards (FMVSSs) apply to vehicles according to vehicle type. We have FMVSSs that apply to "buses," and those that apply to "school buses." Since a "school bus" is a type of "bus" under our regulations, a new school bus must meet the Federal motor vehicle safety standards that apply to "school buses" in addition to those that apply to "buses." A new over-the-road coach would have to meet our "bus" standards, but not our "school bus" standards.

We would like to emphasize the importance that our agency attaches to the use of safe buses to transport children. A school bus meeting the school bus safety standards is the safest means of transportation for school children. It may not be the most comfortable for long trips, since it lacks the reclining seats and restroom facilities of some over-the-road coaches, but it has safety features that the coaches lack, such as seat backs designed to cushion impacts, windows that prevent ejections, and exits that facilitate escape after crashes. In the years since buses began to be manufactured with these features, there has been a marked improvement in school bus safety. We urge schools and school districts to consider these features when making school transportation decisions.

For your information, I am enclosing a pamphlet that gives a brief description of the FMVSSs, and an information sheet that explains how you can obtain copies of our standards.

If you other questions on this or any other issue, please do not hesitate to call Deirdre Fujita of my staff at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

Enclosure

ref:571 d:8/2/95

ID: nht92-5.30

DATE: July 6, 1992

FROM: Robert A. Dewey -- Captain, Rochester (NY) Police Department, Research and Evaluation Section

TO: Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8/20/92 from Paul J. Rice to Robert A. Dewey (A39; Std. 102)

TEXT:

The Rochester Police Department just took delivery of 46 1992 Ford police cars. Thirty five of the vehicles are Crown Victoria models and 11 are Taurus models. All of these vehicles are equipped with a device which requires the operator to depress the brake pedal in order to remove the car from the park position with the shift lever.

Upon discovering this feature, I spoke with representatives of the local Ford dealership and was informed that this was a federally required safety standard.

I recognize the safety advantage of this feature for the normal motoring public, however I do see some negative safety implications for police vehicle operators. An officer who comes under hostile fire while in his patrol car, could be delayed in a retreat from a dangerous situation.

I would like to know if this is a national safety standard and if so I would appreciate a copy of any regulation concerning this standard. I would further appreciate an interpretation from your office as to whether the Rochester Police Department can deactivate this switch if we determine that it is a safety hazard for our officers. Please keep in mind that all of our other patrol cars do not have this switch and many of our officers are assigned to drive a different car each day which may lead to confusion in a time of emergency.

I would appreciate a prompt response to this request in that we are preparing our new vehicles for service at this time.

ID: nht72-5.43

DATE: 08/23/72

FROM: LAWRENCE R. SCHNIEDER FOR RICHARD B. DYSON -- NHTSA

TO: Truck Body Equipment Association Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of July 20, 1972, concerning the Certification of vehicles having a dual purpose. You ask how you should determine weight ratings when a vehicle is intended to carry loads of varying weights, and cite as an example a vehicle designed to carry both gasoline and #2 fuel oil. You indicate that you are presently placing a second certification label on the vehicle, a copy of which you enclose, to inform the customer of the allowable weights.

The method you are using may not be consistent with the Certification regulations, as our position is that weight or axle values that may be confused with GAWP or GVWR cannot appear on the Certification (Part 567) label, or on adjoining labels. This will be the case if the "total" in the "chassis rated weight" column differs from the figure you provide on the Part 567 label for GVWR (assuming that the front and rear axle figures are identical to the GAWR figures on the Part 567 label). Gross vehicle weight rating is not necessarily the total of all axle weight ratings.

We recommend that the weight ratings be computed on the basis of the heaviest load that the vehicle is designed to carry, without attempting (for certification purposes) to anticipate the density of particular cargoes.