ID: nht75-3.5

DATE: 07/07/75

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

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 21, 1975, requesting answers to two questions "relating to the requirements for 16 or 18 gage wire specified by [SAE Standard] J589" ["Turn Signal Switches"] in Motor Vehicle Safety Standard No. 108.

You first asked:

"1. Once the switch has met test requirements using the 16 or 18 gage wire, can a switch manufacturer change the wire gage to a smaller or larger size for installation and use on a vehicle?"

We are uncertain as to what you mean. If you intended to refer to the vehicle manufacturer, the answer to the question is yes. He may use a gage other than 16 or 18 when the switch is installed in his vehicle. The test set forth in J589 is a laboratory test measuring voltage drop that must be met by a switch when 16 or 18 gage wire is used.

You next asked:

"2. Would a switch which was tested with other than 16 or 18 gage wire (larger or smaller) meet the certification requirements of Part 567 of the federal standards?"

When a manufacturer certifies conformance to Standard No. 108, he is indicating that the turn signal switch will meet the requirements of SAE J589 if tested with 16 or 18 gage wire. He may use any method he chooses to ensure this. This agency does not, through its certification requirements or otherwise, instruct manufacturers how to test their products.

Thank you for your suggestion that we amend Standard No. 108 to incorporate SAE J589 which does not specify the gage of wire for test purposes. We have already proposed adoption of J589b in Notice 3 of Docket No. 69-19.

Yours truly,

ATTACH.

May 21, 1975

File No.: 61.A1588.A3107

James C. Schultz -- Office of Chief Counsel, National Highway Traffic Safety Administration

Dear Mr. Schultz:

Federal Motor Vehicle Safety Standard No. 108 specifies that signal switches meet the requirements of SAE J589. The durability test for switches in J589 states among other things that the voltage drop from the input terminal of the switch to each lamp terminal (including 3 inches of No. 16 or 18 gage wire from each side of the switch) should be measured at the beginning and at intervals of not more than 25,000 cycles during and upon completion of the test.

We would like answers to the following questions relating to the requirements for 16 or 18 gage wire specified by J589.

1. Once the switch has met test requirements using the 16 or 18 gage wire, can a switch manufacturer change the wire gage to a smaller or larger size for installation and use on a vehicle?

2. Would a switch which was tested with other than 16 or 18 gage wire (larger or smaller) meet the certification requirements of Part 567 of the federal standards?

We also note that the current version of J589 is J589b. This version does not specify the gage of wire for test purposes. If the answer to question one above is yes, we strongly recommend that consideration be given to amending Federal Standard No. 108 to indicate that switches meet the requirements of SAE J589b instead of J589.

Very truly yours,

WARREN M. HEATH -- Commander Engineering Section, DEPT. OF CALIFORNIA HIGHWAY PATROL

ID: nht95-1.12

TYPE: INTERPRETATION-NHTSA

DATE: January 5, 1995

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

TO: Randal Busick -- President, Vehicle Science Corporation

TITLE: NONE

ATTACHMT: Attached to 10/14/94 letter from Randal Busick to Mary Versailles

TEXT: 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 3 9472). 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 be tween 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 min imum 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 t han 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 cau ses 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 o f 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,

ID: nht95-4.22

TYPE: INTERPRETATION-NHTSA

DATE: September 18, 1995

FROM: Yoshiaki MATSUI -- Manager, Automotive Equipment, Stanley Electric Co.

TO: Chief Counsel, NHTSA

TITLE: Accessory Lamp with LEDs

ATTACHMT: Attached to 11/9/95 letter from Samuel J. Dubbin to Yoskiaki Matsui (Std. 108)

TEXT: We, a Japanese manufacturer of automotive lighting devices, are now developing a new type of combination rear lamp that contains red LEDs as accessory lamps. (Please refer to the attached drawing). Would you please advise us about the categorization of this kind of LED accessory lamps.

The operating condition of the LED accessory lamps are as follows,

a) Construction of the combination rear lamp

Tail & stop lamp and turn signal lamp vertically arranged. Red LEDs are disposed along the outer edge of the combination lamp to be used as accessory lamps.

Light source Colour of Colour of the lens light emitted Tail & stop Incandescent bulb Red Red Rear turn Incandescent bulb Amber Amber signal

b) Operating condition for the accessory lamps

When the tail lamp is switched on, the Accessory Lamp A of red LEDs, which is adjacent to the tail lamp, and the Accessory Lamp B of red LEDs, which is adjacent to the rear turn signal lamp, are lit.

Question 1: Red LEDs adjacent to the tail lamp (Accessory Lamp A)

The tail lamp is designed to comply with FMVSS No. 108 using incandescent bulb only, therefore red LEDs need not to be lit for the purpose of the regulatory requirements. Moreover, when the tail lamp and the red LEDs (Accessory Lamp A) are lit together, the intensity of the light emitted from them does not exceed the maximum intensity specified for one lighted section tail lamp.

In such a condition, we believe the red LEDs (Accessory Lamp a) could be regarded as an accessory.

As for the safety, red LEDs (Accessory Lamp A) will contribute to safety by improving the comspicuity of the vehicle, when lit with the tail lamp.

If our interpretation is not acceptable, please inform us of the conditions required in order to regard the red LEDs portion (Accessory Lamp A) as an accessory.

Question 2: Red LEDs adjacent to the rear turn signal lamp (Accessory Lamp B)

Q2-1: As for the red LEDs adjacent to the rear turn signal lamp (Accessory Lamp B), the LEDs emit a red colour light through the amber lens. The lighted section of the red section of the turn signal lamp by a parting rib prepared in the housing, so that the red light from red LEDs will not be emitted through the lens area of the lighted section of the rear turn signal lamp. Therefore, we believe the light from the red LEDs (Accessory Lamp B) will not adversely affect the rear turn signal function even if the red LEDs (Accessory Lamp B) continues to operate when the rear turn signal lamp is operated. Please advise us if our interpretation is acceptable.

Q2-2: If our interpretation described in the above A2-1 is not acceptable, are the red LEDs (Accessory Lamp B) regarded as an accessory provided that the red LEDs (Accessory Lamp B) are turned off during the rear turn signal operation?

Following table shows the lighting condition of Accessory Lamps and our interpretation.

Tail lamp ON Operating Accessory Lamp A ON condition Accessory Lamp B ON OFF Rear turn signal lamp ON OFF ON OFF STANLEY's question Q2-1 Q2-2 Question STANLEY's interpretation OK OK OK OK NHTSA's answer

Your answer will be highly appreciated.

(Drawing omitted.)

ID: nht95-3.99

TYPE: INTERPRETATION-NHTSA

DATE: August 28, 1995

FROM: Lawrence A. Beyer, Esq. -- Attorney for Liphardt & Associates

TO: Administrator -- NHTSA

TITLE: Petition for Exemption for Inconsequential Defect or Noncompliance

ATTACHMT: ATTACHED TO 10/20/95 LETTER FROM JOHN WOMACK TO LAWRENCE A. BEYER (A43; REDBOOK 2; PART 556)

TEXT: This petition for inconsequential defect or noncompliance is submitted under 49 CFR Part 558, on behalf of:

Liphardt & Associates 15 Trade Zone Drive Ronkonkoma, NY

a New York State corporation.

[Illegible Lines]

The non-compliance relates to

49 CFR Part 592.5(f) Notification of change of facility information:

49 CFR Part 592.8(e) Hold period for inspection

49 CFR Part 592.6(f) Poor compliance photography

49 CFR Part 592.6(d) Label may not have correctly identified RI

BACKGROUND:

Liphardt & Associates has been a DOT Registered Importer since 1990, concentrating in the importation of noncomplying vehicles from Europe. However in 1994, due to sudden economic conditions, importation of vehicles from the Canadian market to the US ma rket became viable, and there was significant need for Registered Importers to assist in vehicle importation and certification. The Office of Vehicle Safety Compliance (OVSC) was also deluged with Canadian vehicle importation situations. Liphardt was ap proached by a Customs House Broker in upstate New York, and was requested to set up an additional facility for the processing (modification, documentation and holding) of [Illegible Line] this facility. It turns out that Liphardt's control over these ve hicles was lost, that the processing was handled by persons other than Liphardt authorized personnel and the inconsequential defect or noncompliance occurred. Liphardt notified OVSC of this situation in February, 1995 and conducted its own investigation . In March, 1995, Liphardt voluntarily suspended all Canadian importations, and met informally with NHTSA staff.

SAFETY COMPLIANCE

NHTSA has reviewed compliance packages submitted on these vehicles, and the vast majority have been deemed sufficient for release of compliance bond.

Canadian vehicles, for the most part, differ from US FMVSS only in the following areas:

1. Odometer may not be labeled KM;

2. Passive restraint systems for passenger cars;

Certification Labels must also be affixed to the vehicles in accordance with 49 [Illegible Word]

Many odometers are labeled KM by the original manufacturer. In any event, the odometer/speedometer is routinely changed to a miles based instrument, since the marketability of kilometer based vehicles is severely impaired. All passenger [Illegible Word ] Certification labels may have misnamed the Registered Importer. While this in unfortunate, the purpose of naming the RI on the certification label is to ensure that the responsible RI is known for subsequent defect/recalls. OVSC maintains a very accur ate computer system in which the VIN and the responsible RI are listed. Therefore, if a vehicle with the wrong name listed on the RI section of the certification label was involved in a situation where the actual RI needed to be involved, NHTSA could ea sily provide the correct RI name.

Clearly these defects and non-compliance are not significant and are inconsequential to vehicle safety. Liphardt has tried to work within the regulatory framework to advise OVSC of the situations and seeks this petition and exemption process to finalize this matter.

Liphardt has corrected the cause of the noncompliance and will continue to abide by the duties of a registered importer as defined in 49 CFR 592.

Thank you.

ID: 9418

Herr Dr. Thomas Lckemeyer
ITT Automotive Europe
Bietigheim-Bissingen
Dept. VER/LB

FAX 07142/73-2895

Dear Dr. Lckemeyer:

This responds to your FAX of December 10, 1993, to Taylor Vinson of this Office. You have asked the following questions with respect to the permissibility of rear fog lamps on U.S. cars:

"Is the rear fog lamp in a combined rear lamp unit permissible in all the states of the U.S.? There is no statement in the FMVSS 108."

Paragraph S5.1.3. of Standard No. 108 prohibits the installation as original equipment of additional lamps such as rear fog lamps if the additional lamp "impairs the effectiveness of lighting equipment required by the standard." The determination of whether a rear fog lamp in a combined rear lamp unit impairs the effectiveness of other lighting equipment is initially that of the manufacturer of the vehicle on which the lamp is installed. Unless such a determination is clearly erroneous, this agency will not question it.

We do not know whether a rear fog lamp in a combined rear lamp unit is permissible in all the States. Because a fog lamp is not required motor vehicle equipment under Federal law, each State in which it is used may regulate it according to its own laws. We are unable to advise you on the laws of the individual States, and suggest that you ask the American Association of Motor Vehicle Administrators (AAMVA) for an opinion. Its FAX number is 001 703 522 1553, and its address is 4600 Wilson Boulevard, Arlington, Virginia 22203.

"Which photometric requirements do we have to fulfill for the rear fog lamp?"

There are no Federal requirements that apply to rear fog lamps, and, as noted above, we are not conversant with state requirements. For your information, the latest specification of the Society of Automotive Engineers for this item of equipment is SAE Recommended Practice J1319 AUG87 "Fog Tail Lamp (Rear Fog Light) Systems."

"Is the certification of the combined rear lamp unit binding upon the whole states of the U.S.?"

No. The certification of the vehicle manufacturer is its representation that the vehicle complies with all applicable Federal motor vehicle safety standards, including paragraph S5.1.3 of Standard No. 108. A State has no authority to question this certification.

However, a State is permitted to have a State vehicle lighting standard provided that the State lighting standard is identical to the Federal lighting standard in those areas covered by the Federal lighting standard. Under these circumstances, a State may enforce the State lighting standard even if the vehicle is certified as conforming to the Federal lighting standard. Furthermore, a State may have its own State lighting standard in those areas where there is no Federal lighting standard, such as fog lamps.

"Do you have a list of lighting equipment for cars and the necessary requirements in the different states of the U.S."

AAMVA may be able to provide you with this information as we are unable to. Because State requirements must be identical with respect to the lighting equipment required by Standard No. 108, State specifications and prohibitions will differ only with respect to supplementary lighting equipment not covered by Standard No. 108 such as cornering lamps and front and rear fog lamps.

Sincerely,

John Womack Acting Chief Counsel

ref:108#VSA d:12/23/93

ID: nht68-1.11

DATE: 09/27/68

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Blaw-Knox Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 11, 1968, in which you provided certification information.

With reference to the Service Bulletin dated "4-10-68" in the second paragraph you state that mixer units mounted at the factory will display a "Certification of Compliance" plate. Blaw-Knox, when it is the party mounting a mixed to a chassis-cab, must insure compliance with Federal Standard No. 108 in effect on the date of manufacture of the chassis-cab, but it is required to furnish certification only when the completed vehicle is being shipped to a dealer or distributor for sale to the ultimate purchaser. No certification is required when such a purchaser brings a chassis-cab to the factory for mixer installation. With reference to the third paragraph, it is not necessary for you to supply a certification plate for mixer equipment, which is shipped from the factory for mounting elsewhere. Compliance with Federal Standard No. 108 is the responsibility of the party who mounts the mixer to the chassis-cab.

Since the chassis-cab manufacturer will have provided serial number information sufficient to determine the requirements of Standards No. 108 in effect on the date of manufacturer of the chassis-cab, it is not necessary to include the mixer serial number on the certification plate. We would suggest that you may comply with the certification plate. We would suggest that you may comply with te certification requirements of Section 114 of the Act when you deliver the completed vehicle to a dealer or distributor for sale to the ultimate purchaser by wording your certification as follows:

"Blaw-Knox Company certifies to the distributor or dealer that it has mounted the mixer unit to the chassis and that the completed vehicle conforms with Federal Motor Vehicle Safety Standard No. 108."

A notice of proposed rule making which will result in more specific requirements with reference to certification will be published in the Federal Register in the near future. A copy of the notice will be sent Blaw-Knox.

Sincerely,

July 11, 1968

U.S. Department of Transportation Federal Highway Administration National Highway Safety Bureau

Attention: Joseph R. O'Gorman -- Acting Director, Office of Performance Analysis Motor Vehicle Safety Performance Service

Subject: Motor Vehicle Safety Standard No. 108

Gentlemen:

The following information is being sent to you at the direction of Mr. David A. Fay, Office of Standards on Accident Avoidance, Motor Vehicle Safety Performance Service, per his letter of June 27th, 1968 (copy enclosed).

Mr. Fay's letter was in answer to the writer's letter of May 6th (copy enclosed) requesting approval of the method being used by Blaw-Knox Company in order to comply with the certification requirements of Motor Vehicle Safety Standard 108. Mr. Fay indicated that the following additional information would be required.

1. The location on the vehicle at which the certification label or tag will be placed: This location is indicated on Blaw-Knox drawing C-8450-911 (enclosed).

2. Actual sample certification tag: Enclosed

3. The means by which the certification tag will be attached: Also indicated on drawing C-8450-911.

Should any additional information be required please write or call Blaw-Knox Company, Construction Equipment Division, Mattoon, Illinois.

Very truly yours,

BLAW-KNOX COMPANY

Construction Equipment Division --

J. M. Wright,

Assistant Sales Manager

Enclosures

ID: nht68-1.27

DATE: 06/21/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: ATECO Equipment Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter to Mr. Slagle dated March 8, 1968, in which you ask for information as to your company's responsibility under the National Traffic and Motor Vehicle Safety Act and regulations issued pursuant to the Act.

As I understand the description of the modification your company makes to trucks the only standard now in effect that is applicable is Standard No. 205, the glazing standard. Therefore, the glass that you install in place of the original glass in the truck cab would have to comply with this standard.

Your company might also be affected by the enclosed Advanced Notice of Proposed Rulemaking. Your particular attention is directed to Docket No. 2-12 which would, if finalized, make the standard concerning anchorage of seats (No. 207) applicable to trucks.

Sincerely,

Enclosure

March 8, 1968

National Highway Safety Bureau Edwin Slagle, Director Motor Vehicle Safety Performance Service

Dear Mr. Slagle:

I talked to David Schmeltzer who I understand is in the Office of the Chief Council of the Federal Highway Administration. Mr. Schmeltzer advised me to approach you for information concerning matter mentioned in the above subject.

This company is a manufacturer and a distributor of motor truck mounted equipment. We are generally to date and are currently practicing the requirements set forth in Federal Regulation #108 and #111 effective January 1, 1968.

Or to January 1, 1968, we had modified Ford, Model C-600 tilt-cabs by handing the original configuration approximately 15-1/4" longer than standard. We incorporate within this change two (2) one-man seats behind the driver-passenger compartment. One of these seats is located on a right angle behind the driver's seat and faces the street side of the vehicle. Another seat is installed behind the passenger's seat in reverse position to the one mentioned. We did not furnish any escape hatch, yet the glazed opening to which the passengers faced was made larger than the original factory furnished glazing. This glazing was set in rubber and locked in place through the use of standard rubber key locks that are used for this purpose in the motor truck industry. This glazing principle did not offer a push-out convenience, yet we at this time could leave the key lock strip out, thereby offering a convenience of a push-out window. We did not change or modify the factory furnished rear window glass.

We now wish to make similar changes to the equipment that we have described. We have researched all printed material and instructions that have been made available to us, to determine a correct and legal path to follow, but we have not found any information by which we should proceed, therefore we have taken the liberty to approach you for help and advice on this matter.

Attached please find the copy of a sketch of the equipment that we are concerned about, on which we have shown a dotted line vertically on the rear portion of the truck cab to indicate the approximate length that we extended the cabs done prior to January 1, 1968.

We need correct information and printed material or a written testimonial from a proper Federal agency telling us if we can or cannot make these changes to fulfill our obligation to Federal requirements.

We wish to take this opportunity to thank you in advance.

Very truly yours,

ATECO EQUIPMENT COMPANY--

R. A. Moynihan

Sales Manager - Truck Equipment

JWT FILE JWT S.O. David Schmeltzer RAM(Illegible Words)

(Graphics omitted)

ID: nht68-2.27

DATE: 07/26/68

FROM: AUTHOR UNAVAILABLE; R. M. O'Mahoney; NHTSA

TO: The City of New York Police Department

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 21 asking how an owner can be penalized for violating vehicle equipment standards, and, in addition, whether or not taxicab owners may remove head restraints, which will be required on vehicles manufactured on or after January 1, 1969, so as to install a sliding glass panel separating a taxicab driver from his customer required by New York police regulation.

As to the first question, in general, the standards have very little application to vehicle owners at this time. In the future, through State-Federal cooperation with reference to vehicles in used standards, it is possible that some sanctions as to owners will be applied. At the present time the principal effect on owners has to do with imported cars. An owner may not import a vehicle into the United States which does not conform to the Federal motor vehicle safety standards in effect at the time of its manufacture, whether it is new or used.

Your second question is answered in part by my answer to your first question. At this time there is no prohibition against an owner of a vehicle removing an item of safety equipment which the manufacturer must install to conform with the standards. We are aware that some owners, particularly taxicab owners, may remove such required items as seat belts. We view this as unfortunate since it removes a built-in protection for driver and passenger.

The removal of head restraints to accommodate a different kind of safety device presents a more difficult question. If the absence of any sanction prohibiting the removal of the head restraint the question, from a safety point of view, is whether or not the danger from whiplush injuries in rearend collisions, which are, as you know, frequent occurrences in city traffic; is a greater danger than the threat of assault from the taxicab passengers. Certainly the ideal would be to provide both kinds of protection for the driver, and it would seem that it would be possible for manufacturers to provide a design that would afford both sorts of protection.

We have had informal conversations from the City of New York's Washington office concerning what we understood(Illegible Word) proposed city ordinance governing the glass panel separating drivers and passengers in taxicabs. Your letter mentions a "police regulation." Could you supply us with more complete information as to what the City of New York's requirements are and whether they are by city ordinance, State laws, or police regulation? Appropriate citations or copies of applicable laws or regulations would be appreciated.

POLICE DEPARTMENT -- CITY OF NEW YORK

June 21, 1968 Robert M O'Mahoney Counsel Transportation Department.

I have your letter of June 11th with the booklet on Federal motor vehicle safety standards, for which I thank you very much.

I inquire now, relative to these standards:

1. Illustrate how an owner can be penalized for vidating the vehicle equipment standards. The literature on the market concerning violations by the dealer and the manufacturer is clear but what set of circumstances would bring an automobile owner into a breach of the vehicle equipment standards.

2. In New York City taxicabs require (by police regulation) a sliding panel isolating the taxi driver from his customer. When future taxicabs come from the assembly line, with the headrest included, there will be interference with the glass panel. Question: are the taxicab owners permitted to remove the headrest in this type of a case or do your standards forbid removal thereof?

Thank you once again Bob for your reply to my first communication and I hope you can furnish us the information desired in this letter.

ID: nht69-1.11

DATE: 01/27/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: THE NEW YORK AIR BRAKE COMPANY

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 30, 1968, regarding location of reflex reflectors and side marker income relative to trailer envelope dimensions. From your subsequent phone conversation on October 18, 1968, with Mr. Zolley of our office, I understodd that you are concerned about the possible obstruction of visibility of those devices by the trailer body.

Federal Motor Vehicle Safety Standard No. 168 specifies that side marker lamps must be in accordance with SAS Standard(Illegible Words) to end reflect reflectors in accordance with SAS Standard JS94c. These standards specify photo-metric requirements for side marker lamps at angle 45o to the right and left of the lamp vertical axis and for reflex reflectors at angles 20o to the right and left of the reflector vertical axis.

Although Standard No. 108 does not specify that these devices provide the test photometrics when installed on the vehicle, it should be noted that Tables II and IV of the standard do require that the devices be located "on the side" of the car vehicle. Therefore, devices that are recessed to an extent that would impair their effectiveness would not(Illegible Words) the requirements of Standard No.(Illegible Words).

Section S3.1.1.S of Federal Motor Vehicle Safety Standard No. 108, as amended effective January 1, 1989, specifics that for trailers less than 89 inches overall wide and less than 30 feet overall length, the photometric requirements specified in SAE J502, why be(Illegible Words) or inboard less points at a distance of 15 feet from the vehicle and on a vertical plane that is perpendicular to the longitudinal axis of the vehicle and located midway between the front and rear side marker lamps. For vehicles less than 20 feet in overall length, this establishes a point less than 45o on one side of the side marker lamps. This is the only sets of relief from the requirements of SAS J592b.

I trust this information will be helpful to you. If you should have my further questions concerning safety standards, I would be most happy to discuss them with you.

Sincerely,

September 30, 1968

Office of Motor Vehicle Performance Service National Highway Safety Bureau

Attention: Bruce A. Kelley --

Room 8213A Subject: Federal Motor Vehicle Safety

Standards - May, 1968

Dear Sir

In reply to my letter concerning an interpretation of the Federal Motor Vehicle Safety Standards, Mr. John A. Hanson, Regional Federal Highway Administrator suggested that I contact your office.

The point that I would appreciate clarification on is as follows:

1. Table IV, under Columns 2 and 4, for trailers less than 80" overall width clearly defines the location of the Reflex Reflectors and Side Marker Lamps as to vertical height above the road surface and that they appear on a horizontal level plane.

2. The question arises in determining the location of said lights in relation to the trailer envelope dimensions.

Mr. Kelley suggested that SAE Standards J594c and 592b are more specific and may answer my question.

Any comment you may have to clarify this situation would be greatly appreciated.

Very truly yours,

KINNEY VACUUM DIVISION,

The New York Air Brake Company --

D. F. Rusconi --

Project Engineer

ID: nht70-2.52

DATE: 02/03/70

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Bloom and Drobner

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 22, 1969, to the National Commission on Product Safety, which was referred to this Bureau for further reply. We have noted the Commission's response to you of December 29, 1969.

A review of our files has failed to produce any specific data relevant to the exact nature of the case you have cited. This is attributable to the fact that the accident investigation methodology on which we depend does not break out data in that particular category.

We would like to advise, however, that Federal rule making sections do address door latch releases, or handles, in a different aspect. We are particularly concerned over configurations of door handles which incorporate sharp features or which tend to protrade excessively, as those types of handles increases the likelihood of the door opening as a result of contact by the body of an occupant during a crash situation. Moreover, if they contain sharp features, they can contribute to increased injury levels resulting from occupant impact when the door remains closed.

I regret we are unable to be more responsive to your inquiry. Thank you for writing.

BLOOM AND DROBNER

DECEMBER 22, 1969

NATIONAL COMMISSION ON PRODUCTS SAFETY

I represent Mrs. Sarah Glover who was a passenger in a 1966 Pontiac. As she lifted up her purse, preparatory to disembark, the purse handle caught on the door handle and the door flew open.

I would appreciate learning if there have been any other cases similar to this in which design negligence concerning the operation of the door handle was the issue.

Thank you in advance for this courtesy.

December 29, 1969

SHERWIN DROBNER

We are in receipt of your letter of December 22, 1969.

As you may know, Congress created this Commission to develop the means to protect the consumer from unreasonably hazardous products used in and around the American household. The scope of inquiry is limited, however, to those products not now the subject of regulations prescribed under existing Federal statutes. These laws are enumerated in Section 6 of Public Law 90-146 (81 Stat. 466).

As your correspondence concerns motor vehicles, it would best be considered by the Department of Transportation. That agency is responsible for the administration of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.). Accordingly, I am directing your correspondence to the Department of Transportation and have asked that they reply directly to you with a copy to this Commission.

Thank you for your interest in the Commission and its work.

LARRY A. SCHOTT CHIEF, INVESTIGATION UNIT

cc: DR. ROBERT BRENNER -- DOT

NATIONAL COMMISSION ON PRODUCT SAFETY

DECEMBER 29, 1969

TO: DR. ROBERT BRENNER -- DOT

We would appreciate your handling the attached correspondence as indicated below:

COMMENT

FOR DIRECT REPLY

FOR BACKGROUND BRIEFING ON WHICH TO BASE REPLY FROM THIS OFFICE

FOR SUITABLE ACKNOWLEDGEMENT OR OTHER APPROPRIATE HANDLING

FOR YOUR INFORMATION

Please furnish this office with a copy of your reply. YES

Your cooperation is very much appreciated.