ID: nht79-3.14

DATE: 08/14/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. D. J. Arneson

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 27, 1979, which inquired whether there are any regulations governing the installation of a propane-fueled engine, or the conversion of a gasoline-fueled engine to a propane-fueled engine, in vehicles registered for use on Federal, State, and local highways.

To date, the National Highway Traffic Safety Administration (NHTSA) has not exercised its authority pursuant to the National Traffic and Motor Vehicle Safety Act, as amended 1974 (15 U.S.C. 1381 et seq.) (the Act), to issue a safety standard applicable to propane-powered vehicles. Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity, applies only to vehicles which use fuel with a boiling point above 32 degrees F., and propane has a boiling point well below this temperature. Despite the absence of safety standards specifically applicable to propane-powered engines, however, an installer of these systems may be subject to other Federal requirements.

Under NHTSA safety regulations, a person who alters a new vehicle prior to its first purchase in good faith for purposes other than resale is required to attach an additional label to the vehicle certifying that, as altered, the vehicle remains in compliance with all applicable safety standards (49 CFR 567.7). This requirement would apply to a person who alters a new vehicle to install a propane fuel system. (See the enclosed pamphlet listing the Federal motor vehicle safety standards and an information sheet explaining where to obtain copies of the standards.) Additionally, should a noncompliance or safety-related defect be discovered in such a vehicle, as a result of the modification, the alterer could be liable for a civil penalty unless he or she could establish that he or she did not have actual knowledge of the noncompliance and that he or she did not have reason to know in the exercise of due care that the vehicle did not comply. (Section 108 (b)(2)) Defects in the propane-fueled engines or in components used for converting a gasoline-fueled engine would be the responsibility of their manufacturers, regardless of whether they were installed in new or used vehicles. Upon discovery of a safety-related defect by either the Secretary of Transportation, the NHTSA Administrator or the manufacturer himself, the manufacturer would be required to notify vehicle owners, purchasers, and dealers and provide a remedy for the defect.

A person who installs a propane-fueled engine or converts the gasoline-fueled engine in a used vehicle is not required to affix an alterer's label. However, if that person is a manufacturer, distributor, dealer, or motor vehicle repair business, he must not in the course of installing the propane components knowingly render inoperative any device or element of design originally installed in the vehicle in compliance with applicable Federal motor vehicle safety standards. (Section 108(a)(2)(A) of the Act)

I hope that you will find this response helpful and have not been inconvenienced by our delay in sending it to you.

SINCERELY,

Information Officer U.S. Dept. of Transportation

June 27, 1979

Dear Sir,

Please send me a complete set of regulations governing the installation or conversion of a gasoline fueled engine to a propane fueled engine for use in registered vehicles on federal, state and local highways, if any.

If there are no regulations governing such a conversion, please inform me.

D. J. Arneson

ID: nht81-3.41

DATE: 11/18/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mazda (North America), Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter requesting an interpretation regarding Safety Standard No. 207 as it would apply to a new seat design your company is considering. This design includes additional seat track forward of the seat track positions that are included as normal riding positions. Since there are no locking positions on this additional seat track, the vehicle seat cannot comply with the loading requirements of Standard No. 207 when in this position. Those requirements must be satisfied in any position to which a seat can be adjusted. You ask whether the extended track would be considered part of the seat track for purposes of Standard No. 207 and for purposes of the adjustment requirements in testing under Safety Standard No. 208.

The answer to your question is yes unless some mechanism is included which will automatically return the seat to a locked position on the track when the seat back is in its upright position and no force is being applied. Most motor vehicle seats will travel some short distance forward of the forward-most adjustment locking position. However, they are designed to return to the nearest locked adjustment position when the adjusting force is removed from the seat, i.e., when the occupant releases the adjustment lever and stops pushing the seat forward. Many seat designs accomplish this result by spring-loading the seat. Therefore, the seat track portion labeled "A-B" in your diagram would not be considered part of the seat track for purposes of Safety Standard No. 207 and Standard No. 208 if the seat is designed to return automatically to position "B" and lock when the seat back is in its upright riding position.

None of the other alternative solutions you mentioned would be sufficient. All of the alternatives fail to prevent the seat with its seat back in the upright position from being adjusted to a position on the "A-B" portion of the track, all of which are unlocked positions. With one limited exception, none of the alternatives would aid the seat in meeting the forward and rearward loading requirements when the seat is adjusted somewhere on the "A-B" portion of the track. The exception concerns the alternative of strengthening the stopper at the "A" position. This alternative might enable the seat to meet the forward loading requirements of Standard No. 207, but only when the seat was adjusted to the "A" position on the "A-B" portion of the track. The seat would not be able to meet the aft loading requirements at the "A" position, however.

I would like to point out that the agency does not provide advance approval of any device or element of design in a motor vehicle. The National Traffic and Motor Vehicles Safety Act makes the vehicle manufacturer responsible for determining whether its vehicles are in compliance with all applicable safety standards and for certifying that compliance. This letter only represents the agency's informal opinion based on its understanding of the information supplied in your letter.

Also, if you desire to have the information concerning this seat design treated as confidential business information by the agency, you will have to submit sufficient information to justify such treatment. I am enclosing proposed guidelines for seeking confidential treatment. If you do not choose to follow this procedure, we will have to place this interpretation in our public redbook file for the benefit of all interested persons.

ENC.

ID: nht81-3.5

DATE: 08/06/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Saunders Leasing System, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent request for an interpretation of our requirements concerning the presence of a "DOT" symbol on retreaded truck tires. Specifically, you asked whether a retreader would be in violation of any regulations if the retreader purchases casings (used tires to be retreaded) from which the "DOT" symbol has already been removed, and whether the retreader itself has a duty to remove the "DOT" symbol.

The retreader is not liable for using casings from which the "DOT" symbol has been removed, although any manufacturer, distributor, dealer, or motor vehicle repair business other than a retreader which removes that symbol from the casings is violating Federal regulations. The retreader does have an affirmative duty to remove the "DOT" symbol from the sidewall of retreaded truck tires.

The "DOT" symbol is required to appear on new truck tires as a certification that those tires fully comply with all the requirements of Safety Standard No. 119 (49 CFR @ 571.119), pursuant to the requirement of section S6.5(a) of that standard. Any manufacturer, distributor, dealer, or motor vehicle repair business who removes this symbol would be removing an element of design installed on the tire in compliance with an applicable Federal motor vehicle safety standard. Such removal is expressly prohibited by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1397(a)(2)(A)). However, there is no prohibition against subsequent use of these tires for further manufacturing operations, such as retreading. Hence, a retreader using these casings would not subject itself to any liability for violating section 108(a)(2)(A) or any other regulation.

The retreader has an affirmative duty to remove the DOT symbol from the tire during the course of the retreading operation. Part 574, Tire Identification and Recordkeeping (copy enclosed) sets forth the basic tire making requirements for retreaders of truck tires. Section 574.5 imposes two basic duties on truck tire retreaders - (1) the retreader is required to mold or brand a tire identification number into the sidewall of each tire it retreads, except those retreaded solely for the retreader's own use, and (2) the "DOT" symbol shall not appear on tires to which no Federal motor vehicle safety standard is applicable. Since there is no safety standard applicable to retreaded truck tires, it follows that no "DOT" symbol may appear on the sidewall of those tires.

Should you have any further questions or need further information on this matter, feel free to contact me again.

ENC.

SAUNDERS LEASING SYSTEM INC.

June 10, 1981

Office of Chief Counsel NHTSA

Dear Sir:

Please advise us concerning the potential violations of your regulations for which a retreader of truck tires would be held responsible if a said retreader purchased tire casings on which the D.O.T. identification markings had been buffed off. Also, please advise as to a retreader's duty to remove said D.O.T. identification markings in conjunction with his retreading process.

Thank you for your assistance in this matter. If you have any questions, please feel free to contact the undersigned.

Brian T. Williams Assistant Counsel

CC: BILL JENKINS TRUCK CENTRAL/DIST. CENTER

ID: nht87-1.100

TYPE: INTERPRETATION-NHTSA

DATE: 06/04/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Barry Bartlett

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Barry Bartlett President Canadian Automotive Radiator Air Industrial Park P.O. Box 189 Debert, Nova Scotia, BOM 1GO CANADA

Dear Mr. Bartlett:

Thank you for your letter of May 5, 1987, concerning Standard No. 301, Fuel System Integrity. You asked the agency to confirm that the requirements set out in the standard apply only to fuel systems installed as items of original equipment in new vehicles and do not apply to aftermarket fuel systems. Several of the Federal Motor Vehicle Safety Standards apply both to original any aftermarket equipment. Standard No. 301, however, applies only to fuel system; installed as items of original equipment in new vehicles.

Although the agency does not have any standards that directly apply to aftermarket fuel systems, manufacturers of motor vehicle equipment, which includes aftermarket fuel systems, are subject to the requirements in sections 151-159 of the Vehicle Safety Act concerning the recall any remedy of products with defects related to motor vehicle safety. I have enclosed an information sheet which briefly describes those responsibilities.

In addition, installation of your product can be affected by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. This section prohibits commercial businesses from knowingly rendering inoperative devices or elements of design installed in a vehicle in compliance with the Federal motor vehicle Safety Standards. Thus, a manufacturer, dealer, distributor or motor vehicle repair shop that installs replacement fuel tanks most ensure that it does not knowingly render inoperative the vehicle's compliance with Standard No. 301.

The prohibition of section 108(a)(2)(a) does not apply to individual vehicle owners who alter their own vehicles. Thus, under Federal law, they may install or remove any items of motor vehicle equipment regardless of its effect on compliance with Federal Motor Vehicle Safety Standards. However, the agency encourages vehicle owners not to remove or otherwise tamper with the vehicle safety equipment.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

May 5, 1987 Ms. Erika Z. Jones, Chief Counsel National Highway Traffic Safety, 400 7th St. S.W., Washington, D.C. 20590

Dear Ms. Jones:

Recent discussions with Mr. Steven Wood, representative of the Legal Regulations Office of the National Highway Safety Transportation, regards gas tank production for the automotive market, has prompted my writing this letter to you for clarification and confirmation. It is Mr. Wood's opinion that regulation standard number 301 as outlined in your Federal Motor Standards Act governs gas tank specifications aimed at original equipment production and does not cover products produced solely for aftermarket consumption. We would appreciate it greatly if you would confirm Mr. Wood's observations.

Thanking you in advance for your assistance in this matter, I remain,

Yours very truly,

CANADIAN AUTOMOTIVE RADIATOR EXCHANGE AND MANUFACTURING LIMITED

Barry Bartlett, President

ID: nht87-1.12

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Chikada:

This is in reply to your letter of November 21, 1986, with reference to the distance between a front turn signal lamp and a lower beam headlamp.

In brief, SAE Standard J588e, incorporated by reference in Standard No. 108 requires a minimum separation distance of 4 inches between the optical axis (filament center) of the front turn signal lamp to the inside diameter of the retaining ring of the lo wer bean headlamp. You have pointed out that a replaceable bulb headlamp does not have a retaining ring, and you have presented two possible substitutes as a measuring point. The first (your Item A) is the outer edge of the headlamp, and the second (your Item B) is the end of the effective area of the reflector. You believe that Item B is the more appropriate.

We concur with your interpretation. Of the two options, the distance to the edge of the effective area of the reflector is the one most similar to the inside diameter of the retaining ring of the lower beam headlamp. The basis for this interpretation is the assumption that the headlamp lens between the outer edge of the headlamp and the edge of the effective area of the reflector is not used for production of the lamp's bean, has mo significant luminance, and therefore will not mask the turn signal.

Sincerely,

Erika Z. Jones Chief Counsel

November 21, 1986

Erika Z. Jones Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones,

Re : Distance between a front turn signal lamp and a low beam headlamp)

In Motor Vehicle Safety Standard N0.108, Paragraph 4.3.1.7, the following is prescribed:

S4.3.1.7 The requirement that there be not less than 4 inches between a front turn signal lamp and a low beam headlamp, specified in SAE Standard J588e, "Turn Signal Lamps," September 1970, shall not apply if the sum of the candlepower values of the turn signal lamps Measured at the test point within each group listed in Figure 1c is not less than two and one-half times the sum specified for each group for yellow turn signal lamps.

According to the SAE Standard J588e, the distance is defined as from the optical axis (filament center) of the front turn signal lamp to the inside diameter of the retaining ring of the headlamp unit providing the lower beam. This definition applies only to a standardized headlamp. What definition is appropriate for a replaceable bulb headlamp, in other words, an unstandardized headlamp? We think B in the following definition is appropriate.

A : From the filament center of the front turn signal lamp to the outer edge of a low beam headlamp

B : From the filament center of the front turn signal lamp to the end of the effective area of the reflector of a low beam headlamp

SEE HARD COPY FOR GRAPHIC ILLUSTRATION

ID: nht87-1.14

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Lynn Walker -- Sales Manager, Panamasia West Coast, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Lynn Walker Sales Manager Panamasia West Coast, Inc. 16205 Distribution Way Cerritos, CA 90701

This is in reply to your letter of September 17, 1986, to Mr. Vinson this office asking whether a lamp you wish to import "is legal for highway use in the U.S." The lamp is an aftermarket auxiliary turn signal that is mounted on top of each front fender. The lens is green, but could be any color that is legal for highway use. The lens is visible "from all directions" but could be designed so that it is visible only to the rear, i.e. to the driver.

Federal motor vehicle lighting requirements do not currently apply to aftermarket lamps of this nature. Whether the lamp is legal, therefore, is a question to be answered under the laws of each State in which it will be sold and operated. While we are no t familiar with State lighting laws you nay find that there is a greater likelihood that the auxiliary turn signal lamp will be acceptable if it has a yellow lens, or if its green lens is visible only to the driver.

I hope that this is helpful to you.

Sincerely,

Erika Z. Jones Chief Counsel

PANAMASIA WEST COAST, INC. 16205 Distribution Way Cerritos, CA 90701 (213) 926-5591

Sept. 17, 1986

Dear Mr. Vinson,

We are an Import-Export Company specializing in Automotive Parts and Accessories.

We are interested in importing the automotive lamp which is described on the following page.

We wish to know if this type of lamp is legal for highway use in the U.S. If any alterations are necessary to make this lamp legal, please advise us of them.

If we can give you more information please don't hesitate to contact us at the above address or telephone number.

With our best regards, PANAMASIA WEST COAST, INC.

Lynn Walker Sales Manager Auto Parts

DIRECTIONAL LAMP - 12 VOLT

APPLICATION:

THIS IS AN ADD-ON ACCESSORY FOR PASSENGER CARS.

INSTALLATION:

IT IS INSTALLED ON TOP OF THE FRONT FENDERS ABOVE THE HEAD LAMP. APPLICATION IS STICK-ON. THE WIRE CAN BE RUN INTO THE ENGINE COMPARTMENT AS IN THE ILLUSTRATION, OR THE INSTALLER MAY DRILL A HOLE IN THE FENDER DIRECTLY UNDER THE LAMP AND RUN THE WIRE THR OUGH IT.

VISABILITY:

THE LENSE IS VISIBLE FROM ALL DIRECTIONS. THE LENSE AREA IS THE AREA HIGHLIGHTED IN YELLOW IN DIAGRAM 1. ALSO, PLEASE ADVISE US OF THE LEGALITY OF THE SAME LAMP IF IT WERE VISIBLE ONLY TO THE REAR (VISIBLE TO THE DRIVER).

MATERIAL: THE BASE IS OF FLEXIBLE PLASTIC. THE HOUSING AROUND THE LENSE IS OF METAL. THE LENSE IS PLASTIC. LENSE COLOR IS GREEN, BUT COULD BE ANY COLOR THAT IS LEGAL FOR HIGHWAY USE.

INSERT GRAPHICS HERE

ID: nht87-1.29

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/87

FROM: HANNS-OTFRIED WESTERMANN--HELLA KG HUECK & CO.

TO: DR. BURGETT--NHTSA

TITLE: RE MULTI BULB DEVICES

ATTACHMT: ATTACHED TO LETTER DATED 8-22-90 TO H. WESTERMANN FROM P. J. RICE; (A36; STD. 108)

TEXT:

We intend to equip motor vehicles with signalling devices, which have - opposite to conventional lamps - a great number of replaceable miniature bulbs instead of e.g. one 32 cp bulb. The miniature bulbs are about 2 to 3 cp each, as is actually applied t o CHMSL.

This design shows a number of advantages:

1. The failure probability of the signal function of a device is very low, because the burn out of a single bulb does not drop the light-out-put of the lamp below the minimum value required.

2. The average life of the miniature-bulbs is greater than the one of current 32 cp bulbs: about 3 per cent mortality rate after 1500 burning hours.

3. The devices can be built smaller and particularly with less depth.

4. The openings in the vehicle's body work can be avoided in part or totally, because the devices can be surface mounted.

5. The absence of body work openings increases the vehicle's stability and avoids sealing problems.

Summary: "Multi-bulb-devices" increase the traffic safety and lower the system costs over the vehicle's life time.

FMVSS No. 108 opposes this idea, because it is required that lamps with 2, 3 or more lighted sections have to comply with higher intensity requirements than a lamp with only one compartment or bulb. The reason for this requirement is to assure a uniform ly conspicuous surface luminance. These higher intensity requirements because of the larger overall lens area are not applicable to our design with a great number of miniature bulbs.

In spite of the great number of bulbs (10 to 20, depending on function) the total area of the lamp is not larger than the one of current one-compartment-lamps. The luminous Intensity requirement for 3- or more compartment lamps for this lamp size would c ause undesirable high luminances.

For each of the many bulbs the lighted lens area is substantially smaller than the required minimum area (22 inches square) for each compartment of multi-compartment lamps, but the total area of all bulbs is in compliance with the requirement for one-com partment-lamps.

We kindly ask for your comment on the legal aspects of this deviating design with many miniature bulbs and in particular, whether the intensity requirements of single-compartment lamps are applicable. (For LED-lamps it is even discussed, that for their higher conspicuity the intensity requirements could be lowered below those of single-compartment lamps). In our opinion the minimum requirements should not depend on the type of design (number of bulbs or compartments) but on the overall visible lens ar ea.

We want to draw your attention to the changes of ECE Regulations R6 and R7:

"If with a single lamp containing more than one bulb one of this bulbs fails, the lamp with the remaining bulbs shall comply with the minimum value required ...

Any failure of a bulb in such a lamp shall be clearly visible, if the lamp is switched on."

ID: nht80-2.1

DATE: 04/14/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: American Moped Associates

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of March 11, 1980, forwarding to Mr. Schwartz of my office the proposed vehicle identification number (VIN) scheme for American Moped Associates, and in confirmation of your subsequent telephone conversation with Mr. Schwartz.

Your VIN scheme complies with the requirements of Federal Motor Vehicle Safety Standard No. 115, with the following exceptions. The fourth through eighth characters of the VIN are required by S4.5.2 and Table I of the Standard to encode certain descriptive characteristics of the vehicle. For motorcycles, which include mopeds, this information is (1) type of motorcycle, (2) line, (3) engine type and (4) net brake horsepower. While the information which American Moped Associates proposed to encode in the fourth through eighth characters will undoubtedly be useful to your company, it is not necessary to advise the agency of your internal coding. Further, while much of the information the Standard requires to be decoded from these characters is self-evident because of your product line, it is none-the-less necessary to forward this information to the agency as specified in the Standard.

Based on your discussions with Mr. Schwartz, it appears this may be easily accomplished utilizing essentially the same format as you currently propose. It is my understanding that you no longer intend to encode the color in the fifth position of the VIN, but rather utilize a single "filler" character such as an "M". Further, I understand that all your mopeds utilize the same engine and comprise two lines characterized by the number of speeds. Consequently, based on your product line, your submission to the agency might read:

Characters 1-3 LAM: WMI assigned to American Moped Associates. Character 4 (internal use) Character 5 M: Indicates moped type; gasoline, one cylinder engine with a displacement of ; net-brake horsepower measured at the crankshaft of . Character 6 (internal use). Character 7 1 indicates one-speed Indian line. Character 7 1 indicates two-speed Indian line. Character 8 (internal use) Character 9 Check digit. Character 10 Model year. Character 11 T: Indicates Taipei plant of manufacture.

Y: Indicates Yuanlin plant of manufacture. Characters 12-17 Sequential number.

Please feel free to contact Mr. Schwartz should you have any further questions on this matter. Sincerely,

ATTACH.

AMERICAN MOPED ASSOCIATES

March 11, 1980

Frederic Schwartz -- Office of the Chief Counsel, National Highway Traffic Safety Administration

Dear Mr. Schwartz:

Pursuant to our recent telephone conversation concerning implementation of our VIN number, please find below for your approval a sample VIN number with notes explaining our coded identifiers.

LAMMB11A - AT123456

LAM - WMI assigned to American Moped Associates

M - Carburetor Type - alternate would be K

B - Color Black - G; Green - R; Red - W; White

1 - Wheel Type 1; Spoke - 2; Mag

1 - Number of Speeds 1; 1 Speed - 2; 2 Speed

A - Series changes letter from A to Z --- Check digit

A - Year of manufacture

T - Plant of mfr. T; Taipei - Y; Yuanalin

12346 - Numerical Sequence

If you have any questions, please feel free to call me at 1-800-854-6213.

Sincerely,

Bart Achille -- National Sales Manager

ID: nht80-2.28

DATE: 04/30/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Continental Products Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

In reply refer to: NOA-30

Mr. Arnold van Ruitenbeek Vice President Continental Products Corporation 1200 Wall Street West Lyndhurst, New Jersey 07071

Dear Mr. Ruitenbeek:

This responds to your March 28, 1980, letter to this office in which you inquired about permissible markings on motorcycle tires. Specifically, you asked whether you could insert language in addition to that specified in Standard No. 119 when labeling the load rating and inflation pressure on certain tire sizes. The answer to your question is no.

Standard No. 119 (49 CFR S 571.119) specifies certain requirements which all motorcycle tires offered for sale in this country must meet. One of these provisions is the labeling requirement set forth in paragraph S6.5 of the standard. Subparagraph (d) of S6.5 requires the maximum load rating and corresponding inflation pressure to appear on the tire in the following words: "Max load lbs at psi cold." The language of the subsection is mandatory and does not permit any variations. Therefore, the insertion of the phrase "in USA and Canada," as you suggest, would mean the tire would not comply with the labeling requirement of Standard No. 119.

The reason for this strict wording requirement is to ensure that the information labeled on motorcycle tires conveys necessary safety information to the purchaser of the tire in a clear, straightforward manner that is uniform with all motorcycle tires. Adding language which suggests that the maximum load of a tire depends on the country in which the tire is being used could confuse the user of the tire. Further, it suggests that the printed maximum load is not really the maximum. Either of these results frustrates the purpose of the labeling requirement in Standard No. 119.

Sincerely,

Frank Berndt Chief Counsel

Continental Products Corporation

March 28, 1980

Mr. Steve Kratzke U.S. DEPT. OF TRANSPORTATION Nat'l. Hwy. Traffic Safety, Rm 5219 Washington, D.C. 20590

Dear Mr. Kratzke:

On three of our motorcycle tire sizes we plan to have the following inscription on the sidewall:

450H(V)17: Max Load in USA and Canada 835 lbs at 42 PSI Cold

120/90H(V)18: Max Load in USA and Canada 805 lbs at 42 PSI Cold

MT90S16: Max Load in USA and Canada 960 lbs at 42 PSI Cold

The underlined part will all be on one line on the sidewall of the tire. Besides the above information, all the other required DOT information will, of course, appear on the tire.

What sets these apart from our other sizes is the notation that this load is in USA and Canada.

We would appreciate it if you could let us know latest 4/11/80 whether or not your department has any objections.

Very truly yours,

Arnold van Ruitenbeek Vice President

AVR/sms

ID: nht80-2.3

DATE: 04/15/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Cosco Home Products

TITLE: FMVSS INTERPRETATION

TEXT:

APR 15 1980

NOA-30

Mr. Don Gerkin Product Engineer Cosco Home Products 2525 State Street Columbus, Indiana 47201

Dear Mr. Gerkin:

This responds to your letter of January 23, 1980, to Mr. Vladislav Radovich concerning Standard No. 213, Child Restraint Systems. Your letter was forwarded to my office for reply.

You asked whether a crotch strap that is "permanently attached to a movable shield can be attached during the 20 mph test required for child restraint systems that have fixed or movable shields. Sections S6.1.2.3.1(c) and S6.1.2.3.2(b) provide that, in the 20 mph tests, the child restraint belts are not to be attached unless "they are an integral part of the fixed or movable shield." The agency used the word "integral" in its ordinary sense to mean something that is "formed as a unit with another part." (Webster's New Collegiate Dictionary, 1977). A crotch strap that is permanently affixed to the shield is formed as a unit with the shield, and therefore, can remain attached during the test.

You also asked, whether, if the movable shield "were designed in such a way that moving it into position for use it automatically locked in that position, and a child was unable to unlock it", would the 20 mph test be conducted with the shield locked into place? Sections S6.1.2.3.1(c) and S6.1.2.3.2(b) provide that each movable surface is to be positioned in accordance with the manufacturer's instructions. Therefore, as long as your instructions explain how to lock the movable shield, it can be locked into place prior to the testing.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

Mr. Vladislav Radovich Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D. C. 20590

January 23, 1980

RE: (49CFR Part 571) (Docket No. 74-9; Notice 6)

Dear Mr. Radovich:

After reviewing our arm rest model and shield model Child Restraints, it is obvious we can salvage nothing. We must start over with some new concepts.

As there is no time for us to waste, we need the Agency's official answer on some points in order to continue.

1. If a barrier were designed in such a way that the top end of the crotch strap was permanently attached to it. The other end of the strap was removable from its anchorage point below the plastic shell attached to a frame only by removing some hardware that is never intended to be removed as long as the barrier is attached to the child restraint.

Can the 20 MPH test for compliance be conducted with the barrier and crotch strap hooked up as described above?

2. If a barrier were designed in such a way that moving it into position for use it automatically locked in that position, and a child was unable to unlock it. Would the 20 MPH test for compliance be conducted with it locked as described above?

We would appreciate your attention to these points at the earliest moment.

Sincerely,

Don Gerken Product Engineer

rm