ID: nht75-1.26

DATE: 12/08/75

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

TO: Brainerd & Bridges

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your October 30, 1975, letter requesting clarification of the status of the banding requirement of Federal Motor Vehicles Safety Standard No. 106-74, Brake Hoses.

The National Highway Traffic Safety Administration (NHTSA) has granted petitions, filed by General Motors Corporation and Ford Motor Company, which requested deletion of the banding requirement. This deletion is the "change now being developed in our rulemaking proceedings" to which you have referred. The complete elimination of the banding requirement is inconsistent with any substitute labeling requirement. The petition of your client, Kugelfischer Georg Shafer & Co., was denied for this reason.

You should understand that our commencement of a rulemaking proceeding does not signify that the requested amendment will necessarily be issued. It does indicate, however, a determination that there is a reasonable possibility that the requested amendment will be issued. A final decision concerning the issuance of a proposal to amend the standard will be made on the basis of all available information developed in the course of the proceeding, in accordance with statutory criteria. If the NHTSA determines that such an amendment would not be appropriate, the amendment which you have requested will be considered as an alternative. We do expect to issue a proposal in the near future.

SINCERELY,

BRAINERD & BRIDGES

October 30, 1975

Robert L. Carter Associate Administrator Motor Vehicle Programs U.S. Department of Transportation National Highway Traffic Safety Administration

REF: N40-30

On September 29, 1975 you sent me a letter a photo of which is attached, in which your Department denied the petition of our client, Kugelfischer Georg Schafer & Co. for an amendment of the banding requirement of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses.

In your letter you stated that the amendment has been denied because it ". . . is inconsistent with the deletion of the banding requirement": Of course the amendment went specifically to the request that the banding requirement be waived under circumstances in which positive identification through multiple other means was at all times assured. Waiver of the banding requirement under such circumstances would not have relinquished any advantage or omitted any function inasmuch as the sole purpose of the banding requirement is to insure identity of manufacturer.

In any event, you have also stated that perhaps a "change now being developed in the rulemaking proceedings will be satisfactory" to Kugelfischer Georg Schafer & Co.. Would you be kind to advise me when such change is expected and what the nature thereof may be. Our client is intimately concerned with this problem and regrets that our prior petitions were sufficiently unclear as to have failed to explain the redundancy of the banding requirement under circumstances in which manufacturer-identity is otherwise clearly established.

Andrew W. Brainerd

ID: nht75-3.40

DATE: 06/01/75 EST

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

TO: Floyd, Kramer & Lambrecht

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of April 25, 1975, concerning the applicability of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, to the Wabco Westinghouse Duo-Matic Coupler.

You have described the Coupler as a device which replaces the glad hand coupler now used by most manufacturers to connect truck tractor and trailer brake lines. Because the brake hose which attaches to the Coupler is equipped with its own end fittings, the Coupler itself is not an end fitting. Therefore, Standard No. 106-74 is inapplicable.

The Coupler is, however, subject to the requirements of 49 CFR Part 393.45 and 393.46, of which I have enclosed a copy. Please direct any questions you may have concerning interpretation of these requirements to the Office of the Chief Counsel, Federal Highway Administration, at 400 Seventh St., S.W., Washington, D.C. 20590.

YOURS TRULY,

DOUBLE QUICK-RELEASE COUPLING DUO-MATIC "SEMTRA" FOR SEMI-TRAILERS

DUO-MATIC "SEMTRA" is a compressed air brake coupling for fitting on semi-trailers.

* No possibility of confusing the lines when connecting up.

* Simple to fit with or without attaching plate.

* Cover closes automatically -- no lost covers.

* Valves placed in the hose part.

* Takes up little room.

Ordering example: 452 803 500 0 Trailer part and towing vehicle part.

452 805 000 0 Towing vehicle part

For other combinations, see table.

PATENTED TRAILER PART TOWING VEHICLE PART TRAILER PART ASSEMBLY NO. ASSEMBLY NO. TOWING VEHICLE PART ASSEMBLY NO. 452 803 000 0 452 805 000 0 452 803 500 0 [Graphics omitted]

TOWING VEHICLE PART 452 805 000 0 Item Qty Part No. Description 1 1 152 805 230 1 Hose connection 2 2 896 010 680 1 Valve spring 3 2 152 802 190 1 Valve cap 4 2 897 181 100 1 Cylinder seal 5 2 805 070 430 1 Dished washer 6 2 810 518 018 1 Locking ring 7 2 899 504 400 2 Valve assembly 8 1 452 801 650 1 Dust cover 9 1 896 200 710 1 Spring 10 1 892 222 200 1 Shaft

Part marked x are included in spare parts set. E Packenhen kompl. Best. no. 452 805 000 2

TRAILER PART 425 803 000 0 Item Qty Part No. Description 4 1 152 802 100 1 Bracket 5 2 152 803 230 4 Sleeve 6 2 891 500 451 1 Nut 7 2 895 110 750 4 Press ring 8 1 452 802 550 1 Bettom plate 9 1 452 802 610 1 Dog for cover 10 1 452 802 555 1 Upper cover 11 2 452 802 690 1 Shaft 12 4 895 222 330 1 Locking ring 13 4 152 802 710 1 Lever 14 1 152 802 553 1 Holding-down P.

15 1 800 200 700 1 [Illeg.] springs 16 1 896 010 690 1 Compr. spring

Part marked x are included in spare parts set. E Packehen kompl. Best. no. 152 803 000 2

FITTING OF DUO MATIC "SEMTRA" ON SEMI-TRAILER IN ACCORDANCE WITH AMERICAN METHODS

[Graphic omitted]

ID: nht95-1.5

TYPE: INTERPRETATION-NHTSA

DATE: January 4, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Robert L. Hart -- Gerry Baby Products Co.

TITLE: NONE

ATTACHMT: Attached to 10/11/94 letter from Robert L. Hart to Dee Fujita

TEXT: Dear Mr. Hart:

This responds to your letter concerning your company's plans for manufacturing a new type of child restraint system, model #632. The new child restraint system has a removable five-point belt system. You state that, "When the [5-point] restraint is rem oved, it is a booster seat according to the definition in FMVSS 213." You explain that Gerry is developing the final name for the product from among a list of nine possible names, and you want to make sure that none of the names would violate any provisi on of Standard No. 213, "Child Restraint Systems."

As a general matter, Standard No. 213 has no restriction on how a child restraint system can be named. The standard defines several types of child restraint systems, such as "booster seat," "backless child restraint system," and "belt-positioning seat." (Section S4 of Standard No. 213.) These definitions are used to determine which of Standard No. 213's performance and test requirements apply to a particular seat. For example, if a child seat fits the definition of a backless child restraint system, t hen the seat must meet the performance and labeling requirements for backless child restraints, when tested to the test specifications set forth in the standard for backless child restraints.

Thus, the definitions in Standard No. 213 determine the applicability of particular performance and test requirements. Manufacturers are not required to name their restraints using the terminology provided in the standard. However, if a child seat fits the definition for a particular type of child seat under S4 of Standard No. 213, the seat will be evaluated to the criteria for that type of child seat, regardless of the name the manufacturer has given the seat.

While Standard No. 213 does not expressly restrict how you name your product, you should consider the following when making your decision. Three names on your list refer to model #632 as a "convertible" child seat ("convertible car seat," "convertible/b ooster," "convertible toddler seat"). Standard No. 213 does not define what is a "convertible" child seat. However, the term has long been used in the child passenger safety community to refer to a child restraint system that can be used rear-facing fo r infants and forward-facing for older children. We are concerned that calling model #632 a "convertible" seat could possibly confuse consumers about its suitability for infants, which may result in some consumers using the restraint with an infant. Wi th that possibility in mind, we suggest you avoid using the term "convertible" in naming the model #632 car seat.

I hope this information is helpful. If you have any further questions, please contact Deirdre Fujita of my staff at (202) 366-2992.

ID: nht91-5.11

DATE: July 31, 1991

FROM: Wayne Trueman -- Plant Manager, BX-100

TO: Barry Felrice -- Associate Administrator of Rulemaking, U.S. D.O.T.

TITLE: None

ATTACHMT: Attached to letter from Paul Jackson Rice to Wayne Trueman (A38; Std. 121); Attached to letter dated 9-24-91 from Wayne Trueman to Marvin Shaw

TEXT:

Once again please allow me to take this opportunity to thank you and your staff for the prompt response you gave to my previous inquiries to your office.

Currently, our BX-100 Brake Equalizers are being specified by numerous customers for installation on their new equipment (tractor and trailer) orders at the factory. There have been several inquiries by school districts from several states in reference to having these units retrofitted onto their current stock of school buses or included into the specification for their new bus orders. However, current California law requires that written approval be obtained from the chassis manufacturer prior to making any "Brake System Modifications ". (ref. California Highway Patrol Title 13, Section #1246c. - copy attached).

What we are trying to determine now is: 1. Whether or not a similar written authorization requirement exists for some or all other states in reference to school buses.

2. Are there any special regulations pertaining to school buses that need to be considered prior to installing or retrofitting product into their air brake systems.

Or are the remaining states simply subject to compliance with current FMVSS 121 regulations?

The effectiveness of the BX-100 Brake Equalizer has been documented by independent test labs, customer conducted tests and testing done with a "Minnetonka Warehouse" VC200 de-accelerotometer. I am enclosing a copy of the tests done at Nevada Automotive Test Center, and two "G" Force graphs done from the information obtained with the deaccelerometer. These and other tests have been done on a variety of air brake equipped vehicles both before and after installation of the BX-100 Brake Equalizers. The results consistently indicate shorter stopping distance with less application pressure, and increased driver control which allows the vehicle to stop in a straight line.

Once again, I would like to thank you in advance for your assistance on this matter. If we are successful in penetrating this market, the test and actual end user results, indicate that we will be instrumental in avoiding accidents and saving many lives.

Attachment A

California Highway Patrol Title 13 Section 1246C School Bus Brakes (text omitted)

Attachment B

Nevada Automotive Test Center Final Report for BX-100 International, Inc.

Brake Test Evaluations for the BX-100 Brake Equalizer Authorization: Purchase Order No: Verbal NATC Project No: 20-17-404 October 1989 Prepared by: Gene Smith Test Engineer

Nevada Automotive Test Center P.O. Box 234, Carson City, Nevada 89702 Telephone No. (702) 882-3261

(Text and graphics omitted)

ID: nht95-4.80

TYPE: INTERPRETATION-NHTSA

DATE: November 17, 1995

FROM: Samuel J. Dubbin -- Chief Counsel, NHTSA

TO: Jim Young -- Wheeled Coach

TITLE: NONE

ATTACHMT: ATTACHED TO 10/17/95 LETTER FROM Jim Young to John Womack (OCC 11303)

TEXT: Dear Mr. Young:

This is in reply to your FAX of October 17, 1995, asking for interpretations of Motor Vehicle Safety Standard No. 108, as in relates to "customer specifications for options incorporated into, or in addition to FMVSS lighting." You have described these op tions as:

"Brake override circuit for rear facing warning lights. The rear warning lights flash as warning lights until the brakes are applied, at which time they become stead burn. This option is in addition to the standard brake lights. If this is acceptable, should the lights be required to meet all requirements of stop lights? (ie.; maximum luminous intensity, color, etc. . .)"

As you clarified in a phone conversation with Taylor Vinson of this Office on November 2, the "rear facing warning lights" are part of the ambulance lighting system which is not a system required by Standard No. 108. This option is permissible. Althoug h there is no Federal legal requirement that governs the performance of ambulance warning systems, we recommend that the rear facing warning lights are red, the required color for stop lamps, inasmuch as the intent seems to be provide an additional indic ation that the brake have been applied.

"Brake Enhancer. Standard or additional stop lights are made to flash on/off several times before going steady burn."

This is not permissible. Standard No. 108 requires all stop lamps to be steady burning.

"Back-up alert strobes. Rear facing high intensity strobe lights that are activated when the gearshift lever is placed into reverse gear."

Optional equipment is permissible if it does not impair the effectiveness of lighting equipment required by the standard. You have not indicated the color of the strobe lamps. If they are red or amber, they could cause confusion in the eyes of an obser ver when operated simultaneously with the steady burning

P2

white backup lamp. There is a lesser possibility of confusion if they cast a white light, as long as they do not mask the steady burning backup lamp. In that event, the strobes could be fitted to the ambulances.

"Taillight flashers. Taillights or brake lights are flashed alternate to backup lights until brakes are applied, at which time they go steady burn. The option at times may be requested to only work of the rear doors on the ambulance are open."

This is not permissible. Standard No. 108 requires taillamps as well as stop lamps to be steady burning, under all circumstances.

If you have further questions, you may refer them to Taylor Vinson (202-366-5263).

Sincerely,

ID: nht68-1.16

DATE: 07/25/68

FROM: AUTHOR UNAVAILABLE; John D. Robinson; NHTSA

TO: Robert Bosch GMBH

COPYEE: DEPT. OF TRANSPORTATION

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge receipt of your letter dated May 21, 1968 copy of which was forwarded to the Secretary of Transportation, concerning the application of Federal Safety Standard 108 to lighting unise that are now being manufactured by Robert Bosch Gmbh.

The joint regulations of the Bureau of Customs and the Department of Transportation, copy enclosed, provides in section 12.80(b)(2)(i) for the importation of a non-conforming vehicle or equipment item if they were manufactured on a date when there were no applicable safety standards in force. Therefore, these lighting units manufactured prior to January 1, 1969, and offered for importation into the United States do not have to be in conformity with Federal Safety Standard 108.

Since your inquiry concerns a specific safety standard not yet in effect, we are forwarding your letter to the Department of Transportation, Highway Safety Bureau, Washington, D.C., for their consideration and direct reply.

Sincerely yours,

Enclosure 50359

ATTACH.

ROBERT BOSCH GMBH

Lester D. Johnson -- Commissioner of Customs, Department of the Treasury/ Bureau of Customs

CC: Alan S. (Illegible Word) Secretary of Transportation

May 21, 1968

Subject: Title 19-Customs Duties (T.D. 68-16) - Part 12-Special Classes of Merchandise - Importation of Motor Vehicles and Items of Motor Vehicle Equipment - Federal Register Vol. 33, No. 6 of January 10, 1968.

Gentlemen:

With the above mentioned publication, certain conditions are imposed for the importation of motor vehicle equipment into the United States.

In our opinion, one case occuring in practice is not covered by the exception granted under section (b). This is the case when replacement items are delivered for automotive vehicles manufactured before entering into force of a relevant Federal Safety Standard.

We are for instance to deliver lighting units equipped with white parking lamps for passenger cars which are evidently not conforming to Federal Safety Standard 108.

The problem is now, whether it is possible and missible to import such items and other ones into the United States after January 1, 1969. We add that it is well evident that such items are needed after this date, because vehicles are already equipped in such a manner and it would in our opinion be too costly to replace two lighting units conforming to the relevant Federal Safety Standard, if only one replacement unit not conforming to the relevant Federal Safety Standard is needed for a passenger car manufactured before January 1, (Illegible Words)

We should be very glad to have a repid answer from you, since we have already now to care for corresponding replacement units. Leadtime is already now very scarce.

Very truly yours,

A. Hammerstein

ID: nht68-1.23

DATE: 11/20/68

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Rolite, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 24, 1968, concerning glazing materials in your recreational vehicles.

FHWA Ruling 68-1, published in the Federal Register on March 26, 1969, (33 FR 5020) specified that campers must meet the requirements of Standard No. 205, Glazing Materials. Copies of FHWA Ruling 6S-1 and Standard No. 205 are enclosed.

We do not have any provision for exempting certain windows from the requirements of Standard No. 205 because of their foldaway position during transport. It is true, also, that your camper could be transported in the erected condition. Therefore, all glazing materials in the camper must meet the requirements of Standard No. 205.

Travel trailers are not included in the application of Standard No. 205; hence, do not have to meet the safety glazing requirements.

Sincerely,

Enclosures

October 24, 1968

Roy Dennison Motor Vehicle Safety Performance Service National Highway Safety Bureau Federal Highway Administration

Dear Mr. Dennison:

I have been in contact with Mr. Walter Peck, Standards Director for the Recreational Vehicle Institute, Inc. and he has recommended that I communicate with you in regards to National Highway Safety Standards on our pick-up camper.

I have enclosed a photograph of one of our trailers and I am sorry, but, we do not have a photograph of our pick-up camper, because this is our first run on a pick-up camper and we do not have our publications ready yet. This, print shows how our trailer collapses into the (down) position. All the windows in our travel trailer are inside and there are no visible outlets when the trailer is down because it was not designed for people to ride in when being towed.

On our pick-up camper the roof also folds to a height of approximately 16 inches over the cab, but we have provided 2 side windows that are of safety glass, which meets the National Highway Safety Bureau standards. The side walls on the camper that fold in have windows and I would like to have an opinion from you as to whether the folding windows, or the windows in the wall that fold in and are encased, would also have to be safety glass.

I realize that ours will be a special consideration, a case that will have to have a special reading from you or someone of your position, connected with the Highway Safety Bureau. I would appreciate any correspondence that you would be willing to offer on this matter. We need something on almost an urgent basis, as you can imagine, so that we comply with all regulations.

I will be waiting for your reply, and if you have any questions, do not hesitate to write.

Sincerely,

ROLITE, INC., Division of Larson Industries, Inc. --

Bob Dahlke Plant Manager

Enclosure

ID: nht70-1.43

DATE: 02/25/70

FROM: AUTHOR UNAVAILABLE; F. C. Turner; NHTSA

TO: FWD Corporation

TITLE: FMVSS INTERPRETATION

TEXT: RE: PETITION FOR RULEMAKING

This is in reply to your letter of October 16, 1969, requesting an exception from Paragraph S3.1 of Federal Motor Vehicle Safety Standard No. 205 ("Glazing Materials - Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses"), to allow the use of Lemen and Plexiglas in certain specified locations in twenty-one (21) fire fighting vehicles to be delivered to the city of New York.

You state the purpose of your request is to provide better protection for occupants of these fire fighting vehicles from objects thrown at them when, for example, the vehicles are enroute to a fire. Further, you state the use of these materials would eliminate replacing safety glass, which can be broken when hit by small objects. Because you are requesting a change in an existing standard your letter has been treated as a petition for rulemaking to amend Standard No. 205, pursuant to the provisions of 49 CFR @@ 353.31, 353.33. For the reasons stated below, your petition is denied.

It is not completely clear from your letter and the enclosed drawing where the interior or canopy partitions in which you wish to use Lexen and Plexiglas are located. Standard No. 205 presently permits the use of rigid plastics in interior partitions of fire fighting vehicles if these materials meet the requirements for plastics designated AS4 and AS5 (the latter can only be used when not requisite for driving visibility) in American Standards Association Test Z26.1-1966, July 15, 1966. We understand that Plexiglas meets these requirements and may therefore be used in this location. We also understand, however, that Lexen does not, failing specifically to meet certain chemical and abrasion resistance requirements applicable to AS4 and AS5 rigid plastics under the Standard. If our understanding regarding Lexen is correct, we believe its failure to meet these minimum requirements renders its unsuitable for use in areas of motor vehicles where a possible loss of transparency may affect the safe operation of the vehicle.

With reference to glazing in side and door windows of fire fighting vehicles, Standard No. 205 allows the use of glazing specified AS1, AS2, and AS10 in ASA Test-226.1-1966 and also allows the use of AS11 and AS3 glazing at levels not requisite for driving visibility. This glazing may be either laminated, tempered, or bullet resistant safety glass meeting the applicable requirements. Plastics meeting AS4 and AS5 requirements, while appropriate for certain locations such as partitions, are not considered appropriate for use in side and door windows as they do not possess chemical and abrasion resistance qualities necessary for exterior glazing and which the types of safety glass specified above possess. The occupant protection which you desire can be provided by using AS10 (and AS11 where appropriate) bullet resistant glass which contains both structural advantages over normally used safety glazing and satisfactory chemical and abrasion resistance for use in side and door windows.

ID: nht70-2.12

DATE: 06/15/70

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: Montgomery Ward

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 19, 1970, concerning the new Motor Vehicle Safety Standard No. 213, Child Seating Systems.

In your letter, you ask whether the Montgomery Ward catalog can contain a statement to the effect that child seats advertised for sale in the catalog have been certified as meeting the requirements of Standard No. 213. There is no law or other prohibition against retailers of products covered by safety standards advertising the fact that the manufacturers have certified the products as conforming to the standards.

Motor Vehicle Safety Standard No. 213 has a January 1, 1971, effective date. As a result, manufacturers of child seating systems will be required to certify that they conform to the standard only if the systems are manufactured on or after January 1, 1971. There is, however, to Federal law which prevents a manufacturer from voluntarily certifying that a child seating system manufacturered before the effective date of the standard conforms to the standard's requirements.

If I can be of further assistance, please do not hesitate to call upon me.

MONTGOMERY WARD

May 19, 1970

Mr. Douglas W. Toms U. S. Department of Transportation

In the next week we will present to our management selections for our Spring General Catalog for 1971. Included will be our selection of child seating systems. We assume today that the products of the two or three resources under consideration will qualify for certification under Standard 213. We are faced then with a problem of indentication unique to a catalog presentation.

Over a period of years the catalog shopper has had a choice of many seats covering a fairly wide price spectrum. As we see the results of this ruling, the customer will face a shortened selection and higher prices. Essentially the seats will not be visibly different from many previous seats to any substantial degree.

We also believe that there should be a significant amount of publicity attendent to the effective date of this Standard. It should be our responsibility to assure concerned parents that the seat purchased from Montgomery Ward was indeed built in compliance with these regulations. We are very much aware of consumer reaction to some disclosures by the Commission on Product Safety. Simply, we want to answer the question first and assure the consumer.

Therefore, in this Spring 1971 General Catalog can we add to the general copy a statement that "The manufacturer of these car seats had certified that they meet the requirements of the Federal Motor Vehicle Safety Standard Number 213, effective January 1, 1971?"

We appreciate your consideration to a problem facing the catalog oriented portion of a chain merchandising organization. We need the help of your office, because we feel we must let people, to whom we can not speak individually, know that we are aware of their concern.

H. W. Wollin, Buyer Furniture Mdse. Office

ID: nht68-2.15

DATE: 06/07/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Ideal Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: In response to your trailer lighting questions during your visit with Mr. W. R. Eason and the questions in your letter of March 26, 1968, the following information is provided.

1. Your letter of March 26, 1968, indicates provision of two red tail lamps, two red or amber stop lamps, one white license plate lamp and two red or amber turn signal lamps for compliance with Motor Vehicle Safety Standard 103 after January 1, 1969. In addition to the afore specified lamps the Motor Vehicle Safety Standard 108 requires side reflex reflectors and side marker lamps as specified in the standard. Location of all lamps and reflectors shall be in accordance with Motor Vehicle Safety Standard 10 requirements. Additional requirements are specified for trailers that are 80 inches or more overall width.

2. Your statement (March 26 letter) that, "The above may be combined and may be Class A in photometric value but Class B in size," is essentially correct except that turn signal lamps "shall" be of Class A photometric value rather than "may."

3. The provision of two Class A red reflectors and two Class A amber reflectors does not completely conform to Motor Vehicle Safety Standard 108 requirements, because four Class A red reflectors and two Class A amber reflectors are required. Two of the red reflectors are for rear mounting and two are for aft side mounting, while the two amber reflectors are forward side mounting. Your interpretation that either reflective material conforming to specification L-S-300 or reflectors conforming to SAE Standard J594C may be utilized for the side reflex reflector requirements of Motor Vehicle Safety Standard 108 is correct.

4. With regard to the question of applicability of Motor Vehicle Safety Standard 103 to chassis trailers, enclosed is a copy of Federal Register Volume 33, Number 1, dated January 3, 1968. If the chassis trailer meets the requirements of this document, primarily that it is an incomplete vehicle and is properly labeled in accordance with paragraph 255.13, then the original manufacturer need not install all of the required lighting of Motor Vehicle Safety Standard 108.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

The nomenclature as used on your proposed label drawing would be considered acceptable for certification requirements and we would appreciate your sending of an actual label sample when they are available. In addition, we would like to have for our records, the actual starting serial number that will identify your vehicles as being built on or after January 1, 1969.

Thank you for your interest in the safety program and we trust this information will be of assistance to you in regard to your inquiries.