ID: nht72-3.31

DATE: 11/27/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Recreational Vehicle Institute, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Your letters of September 8 and October 16, 1972, raise a question concerning the applicability of S4.3 of Standard 207 to certain folding seats in recreational vehicles. Your position is that the typical dinette seat that folds down to form a bed is "a seat having a back that is adjustable only for the comfort of its occupants" and is therefore excepted from the restraining device requirement of S4.3.

In a letter that we sent to Auto Top, Inc. on September 8, 1972, we distinguished between excepted seats and non-excepted seats on the basis of the degrees of arc through which the back could be adjusted. A back adjusting only a few degrees would be excepted under this interpretation, while a seat that folded flat to make a bed would not be excepted and would therefore have to have a restraining device. After reconsidering the background of these exceptions, we have decided to modify that interpretation. Although there is likely to be a difference between these seats in the degree of protection they give the occupant, we cannot find that this difference was reflected in the drafting of the S4.3 exceptions.

The S4.3 exceptions were created by a notice of rulemaking published April 4, 1967 (32 F.R. 5498). The exception in issue here was adopted in response to a petition by the Rover Company, who requested special treatment for a seat with a back that had a range of adjustment from 77 degrees to the horizontal down to 19 degrees to the horizontal. In granting an exception to the type of seat depicted by Rover, the agency therefore included seats with backs that folded until they were substantially horizontal. We must thus conclude that a seat whose back folds backward with respect to the seat cushion to form a bed is not required under S4.3 to have a device to restrain the backward folding of the seat back.

However, the exemption granted in response to the Rover petition does not cover the case you have described. A seat having a back that folds for the occupant's comfort but that also folds in another manner is required to have a restraining device for the second folding mode. The usual example of such a seat is a front seat in a two-door sedan that folds forward for entry to the rear and has a back that adjusts through a rearward arc for the occupant's comfort. Such a seat must have a restraining device to prevent forward movement because the adjustment of the back is not "only" for the occupant's comfort. A dinette seat that has an additional folding or hinging mode must therefore have a restraining device to guard against the effects of the seat's folding in this mode during a crash. For example, a seat whose base is hinged to move the bottom cushion into the space between the dinette seats must be restrained by a device conforming to S4.3.

With specific reference to the type of seat shown in the attachments to your letters, the downward motion of the seat back would be exempt under S4.3, but the motion of the bottom cushion is such that it would have to have a restraining device conforming to S4.3.

As you describe the seat, a restraining device is provided. However, without subjecting it to a compliance test under S4.3.2 we are unable to say whether it conforms to S4.3.

ID: nht72-4.27

DATE: 01/01/72 EST.

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: British Standards Institution

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 26, 1972, on the subject of seat belt retractor testing under S5.2(k) of Motor Vehicle Safety Standard No. 209.

Your outline of the emergency locking retractor test procedure is essentially correct. During the initial 5,000 cycles, however, the belt is to be retracted completely, even though some vehicle installations may prevent complete retraction. The assumption in (3)(ii) of your letter is therefore incorrect.

The remaining points in your interpretation are correct.

Sincerely,

ATTACH.

British Standards Institution

L R Schneider -- Chief Counsel, U S Department of Transporatation, National Highway Traffic Safety Administration

JULY 26, 1972

Dear Sir

F M V S S 209

We are writing as a National Test Laboratory concerned with automotive safety testing and, in particular, seat belt assemblies to your specifications. Some parts of the specification are open to interpretation and we are, of course, concerned that we should operate our test procedure in the accepted manner.

In particular, we would request that you confirm our test methods in connection with Clause S5.2(k) "Performance of retractor". In the case of emergency locking retractors, we proceed as follows:-

1) Corrosion test.

2) Manual withdrawal retraction for 25 cycles.

3) 2500 cycles from full extension to full retraction with an application of 20 lbs force at full extension.

Note (i) As this force is dynamically applied, the mass concerned is less than 20 lbs.

(ii) Full retraction is assumed to mean the full possible retraction of the assembly when installed in a motor vehicle. This will be less than the capability of the retractor, but reflects the practical conditions providing the installation data is obtained from the belt submittor.

4) Temperature resistance test.

5) 2500 additional cycles as (3).

6) Dust test.

7) Manual withdrawal and retraction for 25 cycles.

8) For emergency locking retractors, 45000 cycles operated between the limits of 50% extraction and 100% extraction.

Note (i) The stroke will therefore be half of that applied for the initial 5000 operations and will fully extract the webbing on each occasion.

(ii) Because full extraction occurs, the 20 lbs force will be applied during the 45000 operations as well as the previous 5000 operations.

9) During the initial 5000 operations, 1000 locking operations occur and during the final 45000 operations, 9000 locking operations occur. The locking operations are applied at any point between 50% extraction and 100% extraction.

10) The 20 lbs force is applied on every cycle including the locking cycles.

We should be grateful for your assistance in this matter as a considerable quantity of test work is awaiting clarification of this particular test procedure.

Yours faithfully for Director

R A C DANDY -- Senior Engineering; Head of Mechanical Section

ID: nht73-4.23

DATE: 05/30/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Volvo of America Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 8, 1973, concerning the intent of Section S4.7 of the amendment of Motor Vehicle Safety Standard No. 201 proposed by the notice of September 25, 1970. Although we have recently issued a notice advising the public that we intend to issue a further proposal on this subject before adopting a final rule, we can provide a brief explanation of the intent of Section S4.7.

The principal portions of the "A" and "B" pillars to which S4.7 was directed, are those portions lying above the low line of the vehicle's window. However, the breadth of S4.7 is such that it would also include all contactable areas of the pillars lying below the window line.

You will have further opportunity to comment on the use of force distributing materials and response to the rulemaking of Standard 201.

Yours truly,

Volvo of America Corporation

May 8, 1973

Lawrence Schneider, Esq. General Counsel National Highway Traffic Safety Administration

Re: Request for clarification of Federal Motor Vehicle Safety Standard No. 201 49 CFR Part 571

Volvo of America Corporation hereby requests clarification of Federal Motor Vehicle Safety Standard No. 201 as it relates to the "A" and "B" pillars of a vehicle.

It is our understanding that the standard as currently in effect does not specify requirements for the "A" and "B" pillars. However, Docket No. 2-1, Notice 2 as published in the September 25, 1970 Federal Register (page 14936) proposed an upgrading of Standard 201 which would have required force-distributing material on these surfaces. Although this proposed amendment has never been adopted, it is the best indication that we have to date of N.H.T.S.A.'s thinking in regard to requirements for the "A" and "B" pillars and we are using the information for planning purposes.

It is in regard to paragraph S4.7. of Docket No. 2-1; Notice 3 that we require clarification as follows:

S4.7. Pillars.

(quote)

The contactable surface of each "A" and "B" pillar, with the doors and windows closed, shall -

(a) Be covered with force-distributing material having a thickness of at least 0.50 inch; and

(b) With the force-distributing material removed, have no rigid contactable edge with a radius less than 0.50 inch.

2

Paragraph S3. "Definitions" of Docket No. 2-1; Notice 3 defines the term "contactable" as follows:

"Contactable" means able to be contacted from any direction by a 6.5-inch diameter rigid head form under a 90-pound static force.

Question:

Is it N.H.T.S.A's intention in paragraph S4.7. of the proposal to require that the "A" and "B" pillars be covered with force-distributing material for their entire length, i.e. from the roof to the floor, providing that the entire length is "contactable" as defined in paragraph S3.?

Your consideration of and a reply to our inquiry is requested as soon as practical. Thank you in advance for your consideration.

Very truly yours,

Donald W. Taylor Engineering Liason Representative

cc: D. Jarman L. Larsen G. Nield C. Simerlein E. Skarin

ID: nht90-4.95

TYPE: Interpretation-NHTSA

DATE: December 24, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Stanley S. Zinner -- Greene & Zinner, P.C.

TITLE: Re FMVSS No. 123

ATTACHMT: Attached to letter dated 12-4-90 to Paul Jackson Rice from Stanley S. Zinner (OCC 5479); Also attached to letter dated 2-16-82 to Brian Gill from Frank Berndt (Std. 123); Also attached to letter dated 10-26-73 to Brian Gill from Richard B. Dyso n

TEXT:

This is in reply to your FAX letter of December 4, 1990, requesting an interpretation of section S5.2.4 of 49 CFR 571.123 Motor Vehicle Safety Standard No. 123 Motorcycle Controls and Displays. Specifically, you wish an opinion "as to the meaning, purpo se, and intent" of that section.

Section S5.2.4 Stands states that "A stand shall fold rearward and upward if it contacts the ground when the motorcycle is moving forward." As Taylor Vinson of this office explained to you, this requirement was one of the original provisions in Standard No. 123 when it became effective in 1974. However, unlike many other requirements in the standard, it was both proposed and adopted without any discussion of its meaning, purpose, and intent in the preambles to both these rulemaking actions other than the bare remark that the notices contained a requirement for stands. Furthermore, in the 16 years that the requirement has been in effect, the agency does not appear to have issued a single legal opinion relating to section S5.2.4.

However, the agency has issued two interpretations of section S5.2.5 which we believe are relevant to an understanding of S5.2.4. In pertinent part, S5.2.5 Footrests states that "Each footrest for a passenger other than an operator shall fold rearward a nd upward when not in use." In a letter of February 16, 1982, to American Honda Motor Co., Inc., with respect to a proposed footboard design, the then chief counsel commented that "We consider that the purpose of S5.2.5 is to prevent accidents caused by rigid footrests contacting the ground in a banking turn." In a letter of October 26, 1973, also to American Honda, the then Assistant Chief Counsel commented that S5.2.5 did not require automatic folding but only the direction in which the footrests sh all retract "so that if they are inadvertently left down when not in use they will fold rearward and upward should they hit an obstacle while the motorcycle is travelling forward." I enclose a copy of each of these letters for your information.

The meaning of S5.2.4 is, we believe, clear and unambiguous: if a stand is left down, it shall fold rearward and upward if it contacts the ground (which includes the roadway) while the motorcycle is moving forward. Because both sections S5.2.4 and S5.2.5 require motorcycle equipment "to fold rearward and upward", we further believe that the purpose and intent of both sections are the same, and that S5.2.4 could be substituted for S5.2.5 in the sentences of the two letters quoted in the preceding paragra ph.

I hope that this is responsive to your request.

ID: nht88-1.76

TYPE: INTERPRETATION-NHTSA

DATE: 03/18/88

FROM: R. C. ROST -- PRESIDENT; MINNESOTA BODY & EQUIPMENT CO.

TO: CHIEF COUNCIL -- U. S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: WE REQUEST THAT HEADSTART BUSES NOT BE REQUIRED TO HAVE ROOF WARNING LIGHTS IF A COLOR OTHER THAN SCHOOL BUS YELLOW IS USED.

ATTACHMT: ATTACHED TO LETTER DATED 08/26/88 TO R.C. ROST FROM ERIKA Z. JONES; REDBOOK A32, STANDARD 108; LETTER DATED 12/21/77, TO JAMES TYDINGS FROM JOSEPH J. LEVIN; LETTER DATED 02/11/88 TO SHANON L. FOND FROM JERRY SMITH RE FEDERAL INTERPRETATION OF S CHOOL BUS USER; LETTER DATED 02/25/88 TO SHARON FOR FROM JERRY SMITH; UNDATED BROUCHERS ON SCHOOL BUS BY WAYNE CORPORATION

TEXT: Dear Council:

We request clarification of a matter pertaining to buses sold to Headstart organizations. As a bus dealer we are in a catch 22 situation where no matter what we do it is wrong. According to Department of Transportation Chief Council in 1977 Headstarts must comply as a school bus which would include construction, seats, roof warning lights and all items covered in FMVSS part 571, amended in the federal register (40FR60033) on Dec. 31, 1975.

1. All "school" buses over 10 passenger require roof warning lights whether yellow or non yellow.

2. Regional Headstart in Kansas City, Mr. Frank Magona, 816-426-5401, tells his district roof lights are not required on non yellow headstart buses and it is up to the individual states to set their own regulations and that Headstart does not recognize federal D.O.T. rulings. The same is true of Central Headstart in Atlanta.

3. The State of Iowa D.O.T. and Department of School Transportation say buses used for Headstart cannot be yellow and cannot have roof warning lights.

J. P. Golinvaux District Representative Iowa Department of Transportation Air and Transit Division State Capitol DesMoines, IA 50319 515-281-4265 Dwight R. Carlson Assistant Chief Bureau of School Adm. and Accreditation Grimes State Office Building DesM oines, IA 50319-0146 515-281-5811

4. The State of Wisconsin Department of School Transportation and Wisconsin D.O.T. say buses used for Headstart cannot be yellow and can not have roof warning lights.

Mr. Frank Potts Division of Planning Wisconsin Dept. of Transp. Po Box 7913 Madison, WI 53707 Donald Schneider Director School Transportation Supv. Pupil Transportation Po Box 7841 Madison, WI 53707 608-266-2853

5. We have no problem building a bus to meet school safety standards. School standards do not require the bus to be yellow so color is no problem. The only problem is the requirement for roof warning lights on a non yellow bus. If the conflict was no t considered in the previous 1977 ruling we ask that it be considered at this time. Since the buses do not say "school bus" they cannot use the lights to safely stop traffic.

6. What ever your decision we request that you start enforcing your ruling and make public to Headstart, all the states and the bus manufactures what your ruling is.

Since Headstart has several million dollars set aside to buy buses in 1988 we ask you to make this ruling as soon as possible.

Yours truly,

ID: 10441

Mr. Randal Busick
President
Vehicle Science Corporation
315 East Eisenhower Parkway, Suite 211
Ann Arbor, MI 48108

Dear Mr. Busick:

This responds to your letter of October 14, 1994, concerning whether a belt design would comply with S7.1.2 of Standard No. 208, Occupant Crash Protection, as amended in a final rule published on August 3, 1994 and effective on September 1, 1997 (59 FR 39472). As described in your letter, for this belt design, "the inboard lower FMVSS 210 anchorage is located on the seat frame and thus, as the seat moves fore and aft, the system allows a minimum of two seat belt adjustment positions and the distance between the two extreme adjustment positions of the system is more than 5 cm."

The August 3 final rule amended Standard No. 208 to improve the fit and increase the comfort of safety belts for a variety of different sized occupants. After the effective date, S7.1.2 will, in pertinent part, read as follows:

... for each Type 2 seat belt assembly which is required by Standard No. 208 (49 CFR 571.208), the upper anchorage, or the lower anchorage nearest the intersection of the torso belt and the lap belt, shall include a movable component which has a minimum of two adjustment positions. The distance between the geometric center of the movable component at the two extreme adjustment positions shall be not less than five centimeters, measured linearly.

As illustrated in the drawing provided with your letter, the inboard anchorage on your seat design is the "the lower anchorage nearest the intersection of the torso belt and the lap belt."

It would appear that, under the definition of "seat belt anchorage" in Standard No. 210, Seat Belt Anchorages, the seat would be considered part of the anchorage for your design. Standard No. 210 defines a "seat belt anchorage" as

any component, other than the webbing or straps, involved in transferring seat belt loads to the vehicle structure, including, but not limited to, the attachment hardware, seat frames, seat pedestals, the vehicle structure itself, and any part of the vehicle whose failure causes separation of the belt from the vehicle structure.

If the seat is part of the anchorage, and if the seat can be adjusted more than 5 cm, measured linearly, it appears that your design will meet the requirement of S7.1.2.

While not directly relevant to your question, agency technical staff raised concerns about a device in the drawing enclosed with your letter. The drawing of the system shows a device labeled "Slider Bar" to which the outboard lower end of the seat belt anchorage is attached. While no detail is provided on this device, agency staff are concerned that the device (which appears to function as the lower outboard anchorage) allows the seat belt webbing attachment to slide freely fore and aft longitudinally. If our interpretation of the drawing is correct, this device may prevent the belt system from meeting the occupant protection requirements of Standard No. 208, as well as prevent the anchorage from meeting the anchorage location requirements of S4.3 of Standard No. 210. Finally, the device may introduce slack in the belt system, preventing the belt from adequately securing a child safety restraint in the seat or providing complete protection to an adult.

I hope this information has been helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Philip R. Recht Chief Counsel

Enclosure

ref:208 d:1/5/95

ID: 1982-1.16

TYPE: INTERPRETATION-NHTSA

DATE: 02/17/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Indiana Mills & Manufacturing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

FEB 17 1982

NOA-30

Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing, Inc. 120 West Main Street Carmel, Indiana 46032

Dear Mr. Lawler:

This responds to your recent letter asking whether the requirements of paragraph S7.1.1.3 of Safety Standard No. 208, Occupant Crash Protection, apply to motor homes and school buses with a GVWR of 10,000 pounds or less. It is your assumption that only those vehicle applications which must have seat belt assemblies meeting S7.1 generally are required to have emergency locking retractors on lap belts.

Your interpretation is incorrect. It is true that belt assemblies installed pursuant to S4.2.1.2 are not required to comply with paragraph S7.1.1 of Standard No. 208, since that paragraph states that it is applicable to lap belts installed pursuant to S4.1.1 and S4.1.2. However, paragraph S7.1.1.3 is not so limited. It states that:

A lap belt installed at any front outboard designated seating position in a vehicle manufactured on or after September 1, 1982, shall meet the requirements of this section by means of an emergency-locking retractor that conforms to Standard No. 209.

This means that S7.1.1.3 applies to all lap belts installed in any vehicle in compliance with the standard, including belts installed under S4.2.1.2. Therefore, both motor homes and school buses with a GVWR of 10,000 pounds or less would have to comply with the requirement.

Sincerely,

Frank Berndt Chief Counsel

November 25, 1981

Mr. Frank Berndt, Chief Counsel National Highway Traffic Safety Administration 400 7th Street S.W., Room 5219 Washington, D.C. 20590

Dear Sir:

The Federal Register dated January 8, 1981, carried a final rule amending Standard No. 208 (49-CFR 571.208) which becomes effective September 1, 1982. According to the final rule, the amendment applies to "seat belt assemblies installed in all vehicles with GVWR of 10,000 lbs. or less." The amendment pertains to section 7.1 of the standard.

Most trucks and multi-purpose passenger vehicles covered by S4.2.2 must comply with one of the sections under S4.1.2, each of which refers to S7.1. However, there are several exceptions listed which may meet the requirements of S4.2.1.2.; the later contains no reference to S7.1.

It is our interpretation that it is only those vehicle applications which require seat belt assemblies meeting S7.1. that are required to have an emergency-locking retractor on a lap belt installed in the front outboard designated seating positions.

Please send us your written explanation of the intent of S7.1.1.3. of Standard No. 208, and specifically it's application to motor homes and school buses with a "GVWR of 10,000 lbs. or less."

Thank you for your help.

Yours very truly,

William E. Lawler Specifications Manager

WEL:ld

ID: 1982-1.2

TYPE: INTERPRETATION-NHTSA

DATE: 01/06/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Rogers Ferraro & Cody, P.C.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 2, 1981, to Dr. Robert L. Henderson of this agency asking for an opinion regarding the legality of a warning system devised by your client, David Stepkin.

Mr. Stepkin's system "flashes the rear brake lights continuously when either brake is applied on a motorcycle." With respect to Federal regulation of motorcycle lighting systems, I refer you to 49 CFR 571.108, Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment, a copy of which is enclosed. Paragraph S4.6(b) in essence requires that brake lamps (or stop lamps as we call them) be steady burning. This requirement would appear to preclude use of your system.

In addition, the substitution of a flashing signal for the steady one to which the public is accustomed might create confusion, thereby impairing the effectiveness of the stop lamp. You will note also that paragraph S4.1.3 prohibits the installation of motor vehicle equipment that impairs effectiveness of required lighting equipment.

ENC.

ROGERS FERRARO & CODY, P. C.

December 2, 1981

Dr. Robert L. Henderson c/o NHTSA Driver and Pedestrian Research Department of Transportation

Re: Motorcycle-Pulsating and/or Modulating Rear Lights

Dear Dr. Henderson:

I am an attorney who practices in the State of New York and I represent the interests of one, David Stepkin. Mr. Stepkin has devised a warning system which basically flashes the rear brake lights continuously when either brake is applied on a motorcycle. Of course, the purpose of the item is to create rear visability and therefore to prevent the driver of another vehicle travelling behind a motorcycle, from striking the motorcycle due to poor visability.

I am sure you are aware of the fact that motorcyclists are one of the highest prospective candidates for injuries on our roads. Mr. Stepkin, and I as his attorney, feel that this particular item would certainly help to reduce that statistic.

The item in question is a small unit which is attached by splicing the wire between the brake light switch and the rear brake light. The unit is then attached and is ready for operation. Mr. Stepkin, of course, considered attaching the unit to the rear of the bike but has found that this approach is impractical since many bikes will not accommodate an additional auxilliary light. Experience has shown that this is the most effective and practical method. It also, of course, saves energy because no additional lights are needed.

It has come to our attention that there may be certain restrictions in the use of these particular lights. However, we feel that this particular mechanism should not be in conflict with any such regulations because the filament of the bulb is always on.

I am not aware of any specific regulation outlawing such items on the Federal level and certainly, we have been able to ascertain that no such regulation outlawing such lights exists on the State level.

Therefore, I would appreciate it if you would take the time to drop us a short letter advising us whether any regulations concerning this particular item exist and, if you have a copy of those regulations, we would appreicate receiving same. If you feel that the matter should be handled by another department, please advise and we will forward it promptly.

I wish to thank you in advance for your time and courtesy in this matter.

THOMAS J. CODY

ID: 1982-1.25

TYPE: INTERPRETATION-NHTSA

DATE: 03/17/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Transportation Products Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 17 1982

NOA-30

Mr. E. L. Anderson Project Engineer Transportation Products Inc. P.O. Box 329 Suffern, New York 10901

Dear Mr. Anderson:

This responds to your February 18, 1982, letter asking for an interpretation of Standard No. 217, Bus Window Retention and Release. In particular, you question the requirement of section S5.3.3 which specifies that a continuous warning device shall sound when a school bus ignition is in the "on" position and the release mechanism for an emergency door is not closed. You ask whether depressing the button on the outside of the door should activate the warning device.

The actual requirement of S5.3.3 states that the warning device must be audible when the release mechanism is not in the closed position. The release mechanism is that mechanism that keeps the door from opening. So, for example, if the outside button were depressed but the actual door latch did not open and the door would not itself open, it would not be necessary for the warning device to actuate. However, I assume that the outside button releases the latch which in turn allows the door to open. If this is the case, then at the moment that the latch is released, the warning device must be audible. If this did not occur, it would be possible that the door could be in an open position with the vehicle operating and without the knowledge of the occupants.

I hope that this resolves the question for you.

Sincerely,

Frank Berndt Chief Counsel

February 18, 1982

U.S. Department of Transportation National Highway Safety Administration Office of Chief Counsel 400 Seventh Street, S.W. Washington, D.C. 20590

Gentlemen:

We are requesting an interpretation of Paragraph S 5.3.3. of Federal Motor Vehicle Safety Standard 217. The paragraph in question is: "When the release mechanism is not in the closed position and the vehicle ignition is in the "on" position, a continuous warning sound shall be audible at the driver's seating position and in the vicinity of the emergency door having the unclosed mechanism."

The standard two and three point locking mechanism used on our school buses complies with this paragraph. However, in compliance with a specific application for a customer, the van manufacturer's locking mechanism which consists of a push button outside the van body and a pull type handle on the interior of the van body were retained. In order to comply with the aforementioned paragraph, a warning light and buzzer, a door jamb switch and related micro switch and related wiring were installed by us. (Wiring schematic attached).

The question concerns the push button outside the van body that actuates the door release mechanism. Does depressing the button on the outside of the door require a visible and audible device as outlined in paragraph S 5.3.3?

Trusting we have provided you with sufficient information to provide me with an answer in the next few days, we remain,

Very truly yours,

E. L. Anderson Project Engineer

EA/ms Enc. cc: Paramount

ID: 1982-2.13

DATE: 05/19/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Transequip Industries Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking whether Federal regulations allow a brake hose to be used as a dual purpose hose for both the service brakes and the emergency brake.

Standard No. 121, Air Brake Systems, does not preclude the use of common components in parking, emergency, and service air brake systems. Accordingly, nothing would prevent you from using a common hose in those systems. However, the common component would have to comply with the requirements for each system. This means that a failure of the hose would always be treated as a failure in the parking, emergency and service brake systems. Applying this to the standard in section S5.2.1.1, it would be necessary for the parking brakes to be capable of being released with a failure of the common hose at any time. If your system cannot perform in this manner, which it appears it cannot, it could not comply with the safety standard.

Our engineering staff has reviewed your brake system very carefully over the past years. It appears that your system can be properly plumbed in a manner that it would seem to comply with the requirements. You have continued to seek slightly less expensive methods to plumb your system. In our opinion, these methods would not be capable of complying with the standard. We cannot see how your system can comply with the standard without traditional plumbing that is being used by many brake manufacturers today. Accordingly, we suggest that you concentrate your efforts on constructing your system in that manner.

SINCERELY,

transquip industries, inc.

March 22, 1982

Chief Counsel, NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Sir:

In an air actuated, mechanically held system for trailers, such as described in the enclosed drawing, a single diaphragm brake chamber is provided using one delivery hose per chamber.

The brake hose (#25 on the drawing) is used as a dual purpose hose; It is used as a service brake hose when the service brakes are applied, and it becomes an emergency brake hose when the emergency brakes are applied. The destinction is in the application.

Should the hose break or puncture while applying the service brakes, three of the brakes would apply while air from the broken hose would go to atomosphere.

With the use of two 1400 cu in air tanks and the supply line continuously refilling the tanks, it is virtually impossible to cause a mechanical lock-up while using service brakes.

Should the trailer be parked with the emergency brakes applied and then cut the brake hose the air tanks would drain to zero. When the driver pushed in the tractor protection valve the broken hose would be sealed off, the tanks would refill and the parking brakes would then release when air pressure reached about sixty PSI. The failure which caused the lock-up could only occur when the trailer is in emergency.

My question is as follows: "Can a hose be used as a dual purpose hose and be considered a service brake hose while applying the service brakes and as an emergency brake hose while applying the emergency brakes"? Please advise.

Edward H. Clapp, President

(Graphics omitted)

NOTES:

1. DASHED ITEMS (Illegible) ARE NOT INCLUDED IN KIT.

2. FOR USE WITH DISC BRAKES, CONTACT FACTORY.

3. LENGTH TO BE DETERMINED BY CUSTOMER.

(Graphics omitted)

TRANSQUIP INDUSTRIES, INC.

614 West Main Street

Memphis, Texas 79245

TITLE TWO TANK - SINGLE VALVE SYSTEM TANDEM AXLE (2800 C.I.)