ID: nht93-4.2

DATE: May 18, 1993

FROM: Richard Muraski -- President/CEO, Equa-Brake

TO: John Womack -- Acting Chief General Counsel, NHTSA

COPYEE: Armando Mena

TITLE: None

ATTACHMT: Attached to letter dated 8/5/93 from John Womack (signature by Kenneth N. Weinstein) to Richard Muraski (A41; Std. 121)

TEXT:

On July 2, 1992, the National Highway Traffic Safety Administration (NHTSA) denied a Petition of Rulemaking on an Air Brake System product presented by the Washington Corporation. The petition would have amended FMVSS Standard No. 121 to require a device that regulates air pressure differential between the two wheels on each axle. This ruling could impact our product, the Equa-Brake System which operates on a similar principal yet different design.

Equa-Brake is enclosing a packet on our product and would like an interpretation of this NHTSA action on it.

This interpretation is vital to our efforts. Equa-Brake understands that this denial of rulemaking does not prohibit Equa-Brake from installing its product on vehicles through manufacturers dealer or repair businesses provided it does not render the brake system to fall out of compliance with Standard 121. If you have any questions, please contact me at 702-329-7072 or Armando Mena at 703-938-5117. Thank you.

Attachment

EQUA-BRAKE is a MECHANICAL "auxiliary brake system" that increases brake force and improves brake performance on all vehicles that are equipped with air brakes.

Direct benefits of the Equa-Brake "auxiliary brake system" include safer, straighter, shorter (up to 30% shorter) stopping under panic braking situations.

Reduced one wheel lock-up coupled with significantly reduced brake drum temperatures (reduced brake fade) allows drivers to maintain control under emergency stopping conditions, virtually eliminating potential jack-knife problems.

Under normal braking - the increased brake force permits drivers to maintain their habitual braking patterns with substantially less application pressure. This reduces brake wear and also reduces the tendency for trailer wheels to lock-up - loaded or unloaded.

Tire life is extended from 10% to 20% or more by reducing flat spots caused by one wheel lock-up.

Additional direct benefits result in lower operating costs by extending brake component life up to 40% or more (some users claim extended brake life significantly exceeding 40%).

Indirect benefits derive from increased driver confidence in the vehicle being driven, along with potential insurance savings that result from a safer vehicle that could avoid costly accidents.

Unlike drive line retarders that have proven to be dangerous when activated on wet road surfaces - especially in turns or cornering the driver is always in control of any vehicle equipped with the Equa-Brake "auxiliary brake system".

The Equa-Brake "auxiliary brake system" is totally mechanical, does not use any type of electronics, does not require maintenance and is warranteed for five (5) years.

It is absolutely fail safe. In the unlikely event any component of the Equa-Brake "auxiliary brake system" should fail, the vehicle brake system will return to factory specifications.

Current users include fleets, concrete mixer trucks, fleets of trailers only and fire departments.

Users report improved brake performance, extended brake component life and increased driver confidence in the ability to control their vehicle during the braking sequence.

ID: nht78-1.27

DATE: 06/15/78

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

TO: Minnesota Claims Services

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your inquiry concerning the steering wheel system on a 1972 Plymouth Cricket. You ask whether Federal safety standards permitted non-collapsible steering columns on that vehicle model, whether the steering columns met all safety standards, and whether the vehicle manufacturer was exempted from Federal safety standards on the 1972 Plymouth Cricket because of hardship.

Federal Motor Vehicle Safety Standard No. 203, Impact Protection for the Driver from the Steering Control System (49 CFR 571.203), became effective for all passenger cars manufactured on or after January 1, 1968. Therefore, a 1972 Plymouth Cricket had to meet the performance requirements specified in that standard. I am enclosing a copy of Standard No. 203 for your information, and you should note that the standard does not specifically require "collapsible" loads that can be imparted by the steering column during a dynamic impact test.

Under Federal motor vehicle safety regulations, manufacturers are required to determine for themselves that their vehicles are in compliance and to certify the vehicles as being in compliance. The National Highway Traffic Safety Administration only conducts compliance tests on a "spot-check" basis for purposes of enforcement. Therefore, I cannot tell you whether the particular Plymouth with which you are interested was in fact in compliance with all safety standards. I can tell you that the agency has not made any determinations that the 1972 Plymouth Crickets failed to comply with Safety Standard No. 203.

Regarding your final question, no exemption from Standard No. 203 was granted for the 1972 Plymouth Cricket.

Please contact this office if you have any further questions.

SINCERELY,

April 4, 1978

Wayne C. Parsil Minnesota Claims Services

Dear Mr. Parsil:

This is in response to your March 29 letter regarding your investigation of an automobile accident involving a 1972 Plymouth Cricket, Serial Number 4C1L2R213949.

Your letter has been forwarded to the Associate Administrator for Enforcement, National Highway Traffic Safety Administration, Washington, D.C., for direct reply to your specific questions.

Ardella J. Pitts Highway Safety Management Specialist

MINNESOTA CLAIMS SERVICES

March 29, 1978

Department of Transportation National Highway Traffic Safety Administration

ATTENTION: Safety Standards Department

RE: Vehicle Involved: 1972 Plymouth Cricket

Vehicle Serial No.: 4C41L2R213949

Gentlemen:

Presently we are investigating an accident in which the driver of the subject vehicle sustained fatal injuries when she collided with the steering wheel as a result of an accident.

Kindly supply us with the following information:

1) Do vehicle standards on this model permit non-collapsible steering column?

2) Did the steering column in these vehicles pass all of your safety requirements at the time?

3) Was the manufacturer permitted to relax steering column safety standards on these vehicles because of hardship?

We will appreciate your assistance in answering these questions and in supplying us with any additional information which may be pertinent on this vehicle.

Wayne C. Parsil

ID: nht76-4.18

DATE: 03/31/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Adams County

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 5, 1976, request for written permission to deactivate the "121 brake system" of a school bus manufactured from a Ford chassis with a Kelsey-Hayes antilock system.

From the description of the problems you have encounted with this vehicle, I assume that you do not intend to disconnect the entire "121 brake system", but only one or more antilock systems installed in satisfaction of the "no lockup" requirements of S5.3.1 of Standard No. 121, Air Brake Systems. The National Highway Traffic Safety Administration (NHTSA) has made a finding that early models of the antilock system supplied on transit and intercity buses is characterized by malfunction that warrants its deactivation until a correction is fully developed. This finding was not made with regard to the Kelsey-Hayes system that equips your vehicle.

Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1397(a)(2)(a)) prohibits, with one exception, knowing disconnection of the antilock system by manufacturers, distributors, dealers, or repair businesses. A person that does not fall into those categories is not prohibited from disconnection of the system. Other State or Federal requirements, such as those of the Bureau of Motor Carrier Safety, may prohibit disconnection. In any case, the NHTSA urges that you not disconnect safety devices without consulting the vehicle manufacturer with regard to the safest configuration of the vehicle.

SINCERELY,

School District No. 12

MEMO NO: B-0093

DATE: MARCH 5, 1976

TO: CHIEF COUNCIL NATIONAL HIGHWAY TRAFFIC ADMINISTRATION

FROM: RON STACY SUPERVISOR OF TRANSPORTATION

RE: DE-ACTIVATE 121 BRAKES

A letter to Dr. Neil McCormick, (attached), telephone conversation with Brad Marks, "National Highway Safety Administration", Colorado, Dr. Steve Sacks, "National Highway Traffic Safety", Washington, D.C., explaining existing problems with the 121 brake, (Kelsey-Hayes, Ford Chassis).

December 1975, Kelsey-Hayes representative performed an inservice workshop. Problems still exist!

Refer, Fleet Maintenance Magazine, February 1976 issue, page 61. Washington Report; QUOTE: "NHTSA has also tentatively determined, at this writing, that virtually the only anti-lock system currently available for buses "is characterized by malfunction that warrants its deactivation on all vehicles on which it is installed while a correction is fully developed." UNQUOTE.

Request permission, in writing, to deactivate the 121 brake system, until such time corrections are complete.

Your cooperation and expedience is greatly appreciated.

RON STACY

School District No. 12 Adams County

TRANSPORTATION DEPARTMENT

MEMO NO: B-0085

DATE: NOVEMBER 13, 1975

TO: DR. NEIL MCCORMICK SUPERVISOR OF SUPPORTING SERVICES UNIT COLORADO DEPARTMENT OF EDUCATION

FROM: ROW STACY

REF: 121 BRAKES

1. Frequently one brake will grab at low speed.

2. Occasionally brakes will fade.

3. Occasionally all four wheels will lock-up on panic stop.

4. Occasionally brakes will fade completely: gradual stop, below 15 m.p.h.. Then, brakes will grab as if panic stop condition existed.

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

ID: nht76-4.20

DATE: 02/12/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: General Teamsters Local 959 - Alaska

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your January 29, 1976, questions whether an owner-operator of a vehicle manufactured to comply with Standard No. 121, Air Brake Systems, may legally disconnect portions of the brake system after a vehicle is delivered, or specify that the vehicle be delivered without certain portions of the brake system installed. Your members are asking about the antilock portion of the brake systems installed to meet the "no lockup" provisions of the standard (S5.3.1).

Two provisions of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1381 et seq.) are involved. Section 108(a)(1)(A) prohibits the sale of any vehicle unless it complies with all applicable safety standards that were in effect on the date of the vehicle's manufacture. This means that a member cannot purchase a newly-constructed tractor with portions of the brake system disconnected, if those portions are installed in compliance with the standard. The antilock portions of the system are, as far as I know, installed in compliance with the standard and therefore cannot be disconnected prior to sale.

Section 108(a)(2)(A) with which you are familiar prohibits, with one exception, knowing disconnection of the antilock system by manufacturers, distributors, dealers, or repair businesses. Thus, there is no prohibition on disconnection by an owner-operator of his own vehicle's system under the Traffic Safety Act. However, other State of Federal statutes, or the regulations of the Bureau of Motor Carrier Safety may prohibit disconnection. In any case, the NHTSA urges that you not disconnect safety devices without consultation with the vehicle manufacturer with regard to the safest configuration of the vehicle.

SINCERELY

General Teamsters Local 959 State of Alaska

January 29, 1976

Frank A. Berndt, Acting Chief Counsel U. S. Department of Transportation National Highway Traffic Safety Administration

Several of our members have obtained copies of your letter of September 29, 1975 to Mr. Joseph L. Casson, concerning Standard Number 121 and Section 108 (a) (2)(A) of the National Traffic and Motor Vehicle Safety Act. In that letter, you stated that manufacturers of air braked buses that conform to Standard Number 121 may instruct the owners of his products to disconnect the anti-lock system used to meet the Standard. For the period necessary to correct a safety-related defect in the system that may make its operation hazardous.

Several members of Local 959 either operate tractors or are in the process of obtaining newly built tractors. They have requested that I contact you to obtain your opinion on if they may disconnect the anti-lock system in the existing tractors, or not have an anti-lock system placed on their tractors which are presently being constructed. They are of the opinion that no anti-lock system currently on the market is safe. In other words, they wish to disconnect or not have placed on the newly constructed tractors any anti-lock system until the safety-related defects in the anti-lock system are corrected. If the anti-lock systems were disconnected, the defect report requirement of 49 CFR Part 573 and the defect notification requirements of 49 CFR Part 577 would be complied with.

Thanking you in advance for your attention to my request,

James A. Witt, General Counsel

CC: BILL SHANNON -- COPPER FREIGHT LINES

ID: nht76-4.24

DATE: 04/07/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Trail-O-Matic, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 8, 1976, request to know the status of "log trailers" under Standard No. 121, Air Brake Systems, whether the exclusion for "heavy hauler" trailers terminates September 1, 1976, and what the penalties are for non-compliance with an applicable Federal motor vehicle safety standard. You indicate that you may know of some manufacturers that do not comply with Standard No. 121 and suggest that all persons concerned with the standard be advised of the status of the regulation.

Without description of the "log trailers" in question, it is not possible to determine if Standard No. 121 applies to them. Most pole trailers and trailers equipped with any axle having a gross axle weight rating of 24,000 pounds or more are examples of vehicles that may be excluded from the standard. Mr. Herlihy of this office has already sent applicable documents to you under separate cover.

The exclusion from the standard for "heavy hauler" trailers was extended recently and now terminates September 1, 1977.

Section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1397(a)(1)) prohibits the sale and false or misleading certification of a non-complying vehicle to which a standard is applicable. Each violation of these provisions makes the manufacturer liable to a maximum civil penalty of $ 1,000 for each violation, up to a total of $ 800,000 for a related series of violations. (15 U.S.C. @ 1398). You may advise our Office of Standards Enforcement of any violations of which you are aware.

The NHTSA finds it impracticable to notify directly every interested person of each of its regulatory actions. Each action is made public and is widely distributed by commercial services and trade associations. Enclosed is an information sheet that explains the various means to obtain copies of our regulations.

YOURS TRULY,

Trail-O-Matic, Inc.

March 8, 1976

Richard B. Dyson, Assistant Chief Counsel U. S. DEPARTMENT OF TRANSPORTATION National Highway Traffic Safety Administration

RE: N40-30 (TH)

With reference to "anti-skid" brake regulation # 121 we have strictly conformed to all terms and conditions of the above but wish to report some our competition in Georgia and Florida are building log trailers without installing the anti-skid equipment.

It isn't quite fair to comply with the rules and then miss some sales because competition is selling much cheaper because the unit is not equipped to the D. O. T. # 121 requirement.

What are the penalties, if any, for not complying with this requirement OR has anything been changed basically that we are not aware of?

As a suggestion I think the government should advise all concerned as to the status of this regulation in order to clear the air and put everyone on equal footing.

Please let me hear from you as soon as possible with reference to the above and also will the September 1, 1976 date be applicable on low bed machinery trailers.

Thanking you for your prompt attention, we are

J. L. Chancey President

ID: nht76-4.47

DATE: 01/08/76

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

TO: American Safety Equipment Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to American Safety's December 5, 1975, question whether a state or local government agency such as a municipal police department may modify Type II seat belt assemblies to permit detachment of the upper torso restraint, and whether a seat belt manufacturer may "participate in the modifications of the vehicle and seat belt assemblies."

Section 108(a)(2) of the National Traffic and Motor Vehicle Safety Act (the Act) (15 U.S.C. @ 1397(a)(2) prohibits a manufacturer, distributor, dealer, or repair business from "knowingly [rendering] inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard [except during a repair]." This prohibition applies to changing a non-detachable upper torso restraint to a detachable upper torso restraint.

Under this language of the Act, the police department would not be prohibited from modification of the seat belts. A manufacturer could not actively participate in the modification of the vehicles. Sale of a seat belt assembly to the police department would not of itself, however, constitute a violation of the Act.

YOURS TRULY,

American Safety

December 5, 1975

Mr. Frank Berndt, Chief Counsel Office of Chief Counsel U. S. Department of Transportation National Highway Traffic Safety Administration

This will acknowledge receipt of your letter dated November 18, 1975, reference N40-30, which was in response to our letter of October 10, 1975.

Apparently there has been a misunderstanding as to the question(s) raised by our October 10th inquiry, as your letter makes reference to seat belt assembly installations in newly manufactured vehicles. The first paragraph of our October 10th letter is addressed to the question of modification of seat belt assemblies in existing vehicles; this modification would result in the shoulder belt portion of the assembly being a "detachable" belt.

In any event, your letter of November 18, 1975 advised that Standard No. 209 does not prohibit the manufacture of seat belt assemblies with detachable upper torso restraints. However, while your letter does state that a municipal government could not specify Type 2 seat belt assemblies with detachable upper torso restraints at the front outboard designated seating position, it is silent in the question of whether the government agency is still free to alter the vehicle after delivery to the agency. You will note that our letter of October 10, 1975 included a copy of an NHTSA letter of May 15, 1974 addressed to Los Angeles County Sheriff, Peter J. Pitchess wherein it was stated that the sheriff was free to alter the department vehicles after delivery. We are again including a copy with this letter for your information.

Accordingly, we would appreciate hearing from you with regard to the questions:

(a) are states and their political subdivisions free to alter their vehicles after delivery by modifying the seat belt assembly wherein the shoulder belt portion of the assembly is "detachable".

(b) assuming that states and their political subdivision may alter their vehicles after delivery, may a manufacturer of seat belt assemblies participate in the modification of the vehicle(s) and seat belt assembly(s) wherein the shoulder belt portion of the assembly(s) is "detachable".

We hope this will correct any misunderstanding.

W. A. May Corporate Secretary

ID: nht74-2.30

DATE: 05/02/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Maxi-Cab Enterprises

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 18, 1974, asking which Federal requirements apply to the Maxi-Cab, pictures of which you enclose. You describe the Maxi-Cab as a fiberglass shell that fits in the back of compact pickups, and indicate that it has been designed to be used to transport children.

Based on the pictures you have furnished, we have concluded that the Maxi-Cab is a "pickup cover", which is defined in S4 of Motor Vehicle Safety Standard No. 205, "Glazing Materials" (49 CFR 571.205), 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."

Since you describe the Maxi-Cab as designed to transport persons, the glazing material used in its construction must conform to Motor Vehicle Safety Standard No. 205. No other Federal requirements administered by this agency apply to it.

Yours truly,

ATTACH.

March 18, 1974

Chief Counsel -- National Highway Traffic Safety Adm.

Dear Sir:

Several months ago we first put a product on the market called the Maxi-Cab. The Maxi-Cab has two parts: The first part is a fibreglass shell that fits on the back of compact pickups. After the first installation the shell can be taken off or put on again in about five minutes. The rear window of the truck cab is removed and there is a waterproof boot between the cab and the shell. The second part is a utility box which slides in under the front part of the shell. This box is then locked in both by sliding bolts and by a clete in the tonneau which holds it in place when the tonneau cover is shut. There are two shelves on the sides and cushions are placed on the shelves either for storage for gear, or if the driver chooses, as seats for children.

We put this product out after checking first with the California State Department of Motor Vehicles who informed us that in their opinion the unit did not come under any existing regulations since it was completely removable.

We then talked also with the California Highway Patrol which in turn referred us to the NHTSA.

I have had a series of phone conversations with a Mr. Buckley in NHTSA and after discussions with legal people in your office he informed us that pending a ruling from your office it was his opinion that with the exception of certain glazing standards (with which we already comply) there were no federal regulations governing this product.

Both for our own peace of mind, and to answer questions from our dealers, we would like to receive some documentation of this opinion. Mr. Buckley indicated that the appropriate method for receiving a written opinion on this matter was to send a written request to your Office requesting a written opinion on this matter.

I am enclosing two photographs which will give you some idea of the appearance and mechanisms involved. I hope they will be sufficient.

Thank you for your attention to this matter.

Sincerely,

James L. Creighton -- MAXI-CAB ENTERPRISES

(Graphics omitted)

(Graphics omitted)

ID: nht74-3.14

DATE: 06/11/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Adams & Westlake Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 16, 1974, concerning an interpretation of the requirements of Motor Vehicle Safety Standard No. 217, "Bus Window Retention and Release" (49 CFR 571.217). You appear to ask whether bus windows containing tempered glass must meet the release requirements of paragraph S5.3.2 after (as well as before) the retention test required by S5.1 when the glass breaks during the retention test. You state that tempered glass, once broken, is easily removed from the entire lite by touch, implying that when this is the case there is no longer a need for any release mechanism to be further tested.

Paragraph S5.3.2 requires the release mechanism to meet specified requirements both before and after the window retention test of S5.1 irrespective of the glazing material used in the lite. Consequently, release mechanisms for windows of tempered glass must conform to the requirements even though the glass may be broken during the retention test

While your argument that the requirement seems unnecessary when tempered glass is used is not without some basis, it is also quite likely, in our view, that bus passengers in a crash may be ignorant of the quality of tempered glass to which you refer and thus still attempt to operate the emergency exit using its release mechanism.

Yours truly,

April 16, 1974 Larry Schneider Office of Chief Consul National Highway Traffic Safety Administration

In regards to Motor Vehicle Safety Standard No. 217, "Bus Window Retention and Release", please refer to S5.3.2 which states:

"When tested under the 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 by a single occupant using force applications each of which conforms, at the option of the manufacturer either to (a) or (b)"

In the design of our particular application, we use a single sliding lite in a vehicle less than 10,000 lbs. GVWR and have opted to meet the low force application described in (a). See attached drawing DM-8991-2.

Our question centers on the above quote from the specification particularly when tempered glass is used. We foresee no difficulty in meeting the release test before the retention test but does the tempered glass, once broken, qualify as an uncostructed opening due to the ease of removal of any glass that might remain in the opening. Tempered glass as you are probably well aware, once stressed to the point of breakage, crumbles into small cubes over the entire lite and may be easily removed by touch.

Your earliest reply will be appreciated.

Ronald J. Hansing Project Engineer

Attachment cc: H. C. Gildnor

C. M. Miller

R. Prey

E. V. Gordon

July 10, 1974

Office of Chief Consul National Highway Traffic Safety Administration

ATTN: Richard Dyson

Please find enclosed drawing DK-1553 which should have been sent with letter dated July 3, 1974.

Ronald J. Hansing Project Engineer

RJH:cpp Enclosure

ID: nht73-1.46

DATE: 04/26/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Young Windows, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 27, 1973, requesting information on requirements for marking glazing materials for use in motor vehicles, and whether you must finish cleaning instructions for glazing you manufacture.

Your questions regarding marking requirements are similar to those raised by Mrs. Lewis Cook of your company, in a letter of February 20, 1973. We responded to that letter on April 4, 1973 (a copy is enclosed), and you should have received our response by this time. In that letter we stated that your responsibilities as a manufacturer who cuts glazing materials are to mark that material in conformity with section 6 of ANS Z26.1-1966. We should amplify our response in that letter by stating that if the glazing material as you receive it already contains the required markings, you may use those markings in meeting the requirements.

You indicate your question concerning requirements for cleaning instructions arises from a customer to whom you furnished Rohm and Haas Plexiglas. Paragraph S5.2.1.3 of Standard No. 205 provides that glazing materials designated AS-12 or AS-13 must be labeled (using a label that is removable by hand) with cleaning instructions. If the Rohm and Haas Plexiglas is of either of these glazing designations, it must be so labeled. If it is not, there are no requirements that cleaning instructions be furnished.

Yours truly,

Enclosure

March 27, 1973

Office of Chief Counsel National Highway Traffic Safety Administration

Dear Sirs:

We at Young Windows, Inc. are in the business of manufacturing custom windows for the transportation industry. Recently a few questions were raised that have sent me seeking the correct answers.

My questions concern certification of certain glazing materials we presently use in our windows. Before I go any farther, let me explain that we do not manufacture windshields for the automotive industry but rather windows for campers earthmoving equipment, marine windows, and some rear windows for the truck industry. Therefore, what type of certification is needed concerning Federal Standard Number 205 of the Safety Code. I have heard a label is needed on the window, a label could be placed on the outside of the box, or a tag,(Illegible Word) that the glass in the windows meets Standard 205. Since our glass comes in stenciled with all necessary markings, would this be sufficient? If not, what would we be required to do to meet and conform to Standard #205?

Another question has been brought to our attention by one of our customers. We recently shipped 360 windows to a manufacturer of food serving and ice cream vending trucks. We supplied the sliding serving window. Per customer request, we supplied the windows using Rohm and Haas Plexiglas. The material was branded with all the necessary marking. Our customer has now come back and ask for cleaning instructions on the Plexiglas. Are we required by any Federal Standard to supply cleaning instructions with these windows?

I would appreciate your kind and prompt reply, as we want to conform to all standards without delay.

Regards,

Yours truly,

YOUNG WINDOWS, INC.

Charles E. Smith,

Purchasing Manager

ID: 77-4.49

TYPE: INTERPRETATION-NHTSA

DATE: 12/12/77

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

TO: Robert D. Scifres

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of October 27, 1977, asking whether the use of two rearview mirrors in one mounting is permitted if one of the mirrors fails to meet Federal requirements.

Safety Standard No. 111, Rearview Mirrors (49 CFR 571.111), requires each passenger car to have an outside rearview mirror of unit magnification (plane mirror) on the driver's side of the vehicle. Paragraph S4.2.1 of the standard specifies the field of view that must be provided by this outside mirror. Provided the vehicle is equipped with one mirror that meets the requirements of paragraph S4.2.1, the use of additional, non-complying, mirrors is not precluded by the standard, even if the mirrors are in the same mounting with the complying mirror.

Please contact us if you have any further questions.

Sincerely,

ATTACH.

October 27, 1977

TO: U.S. Department of Transportation -- National Highway Traffic Safety Administration

FROM: Robert D. Scifres

SUBJECT: Request for interpretation - Motor Vehicle Safety Standard No. 111, S3.2.1.1

As can be seen in the attached drawing(Exhibit I), this outside rearview mirror for passenger cars incorporates the use of two mirrors located in one assembly. One mirror(A) would conform in all respects to the current standards. The second mirror(B) would conform to all standards except as it relates to the field of vision. In itself the height would not provide the required reflected field of vision, but in conjunction with mirror (A) would provide an expanded field of vision to the extent the "blind spot" would be eliminated. Each mirror is adjustable both horizontally and vertically, allowing the driver to adjust each to give him the maximum reflection.

While the standards do not specifically nor indirectly state a single faced mirror only will be allowed; and although paragraph (1) of 32 F.R. 2413, dated February 3, 1967 relates to a "supplemental" mirror in addition to the inside and outside mirrors; and subsequent revisions do not change the above, I strongly feel an interpretation is in order.

My request comes about because of a very near accident involving me when I started to change lanes on a high speed highway. After checking both inside and outside rearview mirrors, I started to pull into the next lane to my left. Only because the driver of the vehicle behind me was alert prevented a serious accident. I have discussed this situation with about one hundred fifty of my acquaintences and almost all have experienced the same thing in one degree or another with several actually having an accident and three involved in rear end collisions because they had turned their head to make sure about the blind spot only to ram the rear of the cars in front of them.

In view of the standards as written, I feel an interpretation should be given and I shall appreciate an early response to this request

(Graphics omitted)

EXHIBIT I

Fig 1