ID: nht71-4.14

DATE: 09/20/71

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: Automobiles, Peugeot

TITLE: FMVSS INTERPRETATION

TEXT: We appreciate the opportunity to further discuss the questions you raised during our visit of June 9 and 10. I will try to answer each question as fully as possible.

1. It would be unfortunate if the effect of our standards on domestic passenger car production in Europe is to raise costs to the point where significant numbers of people are forced to rely on cheaper and more dangerous vehicles such as motor driven cycles. However, we do not think this result likely in the light of the continuing demand for inexpensive passenger cars and in the absence of legislation by the European nations to compel adoption of the costlier safety features.

2. We are aware of the concern of foreign manufacturers with the effects of the standards. The National Highway Traffic Safety Administration will attempt to be as flexible as possible, consistent with its mandate to insure the safety of vehicles sold in the United States. The discretion allowed the agency to exempt vehicles from a standard is a matter that Congress will have to decide. At the present time, the exemption authority given the National Highway Traffic Safety Administration by the 1966 Act has expired, and we are therefore unable to agree to any exemptions unless Congress chooses to recreate the exemption authority in some form.

3. In the development of standards, the National Highway Traffic Safety Adminstration attempts to evaluate their effects on foreign as well as domestic manufacturers. As you are aware, it is sometimes not possible to reconcile all points of view on a standard, but we would urge you to make every effort to set forth your position on proposed rules during the comment period.

4, 5. Your comments on the proper height for bumpers and the problem of the license plate location have been considered in the context of the rulemaking on Standard No. 215. The amendment issued on June 22, 1971, should serve to lessen the height problem to some degree, and on the basis of present data we regard the height thereby established as reasonable for the overall vehicle population. The share of the license plate itself is determined by the individual states and is not within our authority.

6. The crash characteristics which you suggest for a vehicle's front end seem reasonable, but because they fall beyond the scope of the present rulemaking on Standard No. 215, any consideration of them will have to be deferred. Although we realize that the front seats can supplement the side structure of a car in a side impact, the question as to whether the seats should be retained was considered in the development of the final version of Standard No. 214, and it was determined at that time that the standard would provide a more reliable measure of side strength if the tests were conducted with the seats removed.

The National Highway Traffic Safety Administration is still of that opinion, although it would consider any additional information presented in support of a petition to amend the standard to allow retention of the seats.

7. On the subject of prospective standards, the National Highway Traffic Safety Administration is currently preparing a new version of the program plan for motor vehicle safety standards. The plan is intended to map the course of rulemaking for the next several years, and should serve to answer most of your questions on timing. We expect to announce the new plan in the very near future.

I hope this letter has been responsive to your questions. If not, or if additional questions arise, do not hesitate to ask us.

ID: nht71-5.27

DATE: 12/21/71

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

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 6, 1971, in which you enclosed copies of drawings illustrating clearance and side marker lamps installed on several types of trucks and trailers in compliance with the requirements of the California Vehicle Code and asked for our advice as to whether there are any conflicts with the Federal requirements.

There are several such conflicts, and our comments follow:

1. REQ BUL-3 SUPPLEMENT 1

(a) Page 2 - Standard No. 108 prescribes the general location of clearance lamps and side marker lamps without specifying tolerances. The first sentence of each of the paragraphs on clearance lamps and side marker lamps adequately reflect the Federal requirements. These general requirements of Standard No. 108 preempt the authority of a State to prescribe tolerance for alternate locations of the lamps and subsequent sentences in these paragraphs which do so are improper.

(b) Page 3 - Figure 3, Combination Clearance and Sidemarker Lamps, does not appear to properly illustrate the requirement that a clearance lamp be visible at an angle of 45 degrees to the right.

2. Truck tractors

(a) Statements appear frequently that front amber side marker lamps are "Not required on pre-1969 Tractors." This is incorrect; front amber side marker lamps are required on any truck tractor 80(Illegible Word) inches in overall width, manufactured on or after January 1, 1968.

(b) Various figures illustrate truck tractors with red rear clearance and side marker lamps. It is unclear whether California requires truck tractors to be equipped with these lamps, or whether the figures illustrate acceptable counting locations if a vehicle is so equipped. Standard No. 108 provides that(Illegible Words) preemption provisions of the Vehicle(Illegible Words) to require them.

3. Clearance lamps

(a) The figures do not clearly illustrate whether the widest point of vehicles is the front fender or body (i.e. tank on tank trucks, flat bed on "dromedary" trucks and flat bed trucks, van on van body trucks, body on utility trucks). If the body is the widest point of the vehicle, amber clearance lamps must be mounted there, but if the widest point is at the front fenders, the clearance lamps must be mounted at that location. No alternate locations are permissible, though shown in your figures, and in any event, cab-mounted clearance lamps are inappropriate whether single or combined with another lamp.

(b) The widest point of a horse trailer is the fender, and clearance lamps must be mounted here, not on the body.

4. Logging dolly. Logging dollies are "pole trailers" for purposes of the Federal motor vehicle safety standards and are specifically excluded from Standard No. 108. Therefore, we have no comments on California's requirements.

5. Boat trailers

(a) Clearance lamps are not required if the trailer is less than 80 inches wide.

(b) A combination clearance lamp (amber to front, red to rear) is permitted, if it is located atop the fender, as an alternative to separate amber and red clearance lamps.

(c) The required location of the front amber side marker lamp for trailers (not shown on your figure) is "as far to the front as practicable," with a permissible location "as far forward as practicable exclusive of the trailer tongue."

We are returning to you copies of the drawings you enclosed, marked to reflect our comments.

ID: nht71-5.34

DATE: 12/29/71

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

TO: National Committee on Uniform Traffic Laws and Ordinances

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 3, 1971, concerning the preemption of State vehicle safety standards under section 103(d) of the National Traffic and Motor Vehicle Safety Act, 15 U.S.C. 1592(d). We apologize for the oversight that resulted in not answering the letter until this date.

You asked whether State laws requiring that vehicles having two red tail lamps, mounted on the same level and as widely spaced laterally as practicable, are preempted by Motor Vehicle Safety Standard No. 108. In our opinion the answer is no. Standard 108 has many detailed requirements that go beyond those described. Among them, however, are requirements that are substantively identical to your example, though not stated in precisely the same words. We do not interpret section 103(d), which prohibits a State standard "which is not identical to the Federal standard," as requiring the State requirement to be a verbatin copy of its Federal counterparts substantive identity of requirements is sufficient. Also, we do not interpret the statute as requiring the State to adopt all the Federal requirements on a given aspect of performance. It is sufficient that there be a Federal requirement that is substantively identical to the State requirement in question.

You also asked about two other requirements, as to which the answer may depend on a more detailed examination of their purposes and the circumstances under which they are enacted. One was the requirement that the light from the tail lamps be visible from a distance of 1,000 feet to the rear; the other was that a vehicle have "at least one tail lamp."

The guiding principle that we would apply to this situation is that State requirements that regulate the design of motor vehicles must be identical to the Federal standards, with the qualifications stated above. It was clearly the intent of Congress to provide for uniformity of regulation of the manufacturers in areas where the Federal agency has acted, and they did so by the identity requirement of section 103(d). By contrast, State requirements concerning the condition or adjustment of vehicles generally do not affect the requirements placed on manufacturers, and therefore do not fall within the section 103(d) identity provisions.

Applying this principle to your question, if the visibility requirement is construed by the State, and reasonably appears, to be basically a quantitatively stated requirement that the tail lamps be in good working order and not nearly degraded by conditions encountered in use, we would consider the requirement not to be preempted by section 103(d). Similarly, if the one tail lamp requirement is essentially a statement of required minimum working condition (as it appears to be on its face), it would not be preempted.

The issue you mentioned concerning the preemption of State laws applicable to vehicles in use was dealt with in detail in(Illegible Word). Tens' letter to you of December 21, 1970. As stated in that letter, our position is that the preemption question does not turn on whether the State law applies to pre-sale or on-the-road vehicles, and we feel that this position was upheld by the clear and compelling implication of the Super Lite cases. In light of the interpretations set forth in this letter, however, we do not believe that the problems of State law and enforcement that you felt may arise will be realized.

ID: nht71-5.49

DATE: 07/01/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Messrs. Modrall, Seymour, Sperling, Roehl & Harris

TITLE: FMVSS INTERPRETATION

TEXT: RE: GIGLER V. VOLKSWAGEN

In your letter of June 16 to Roman Brooks of this agency you ask for background information on Federal Motor Vehicle Safety Standard No. 301, Fuel Tanks, Fuel Tank Filler Pipes, and Fuel Tank Connections, effective January 1, 1968.

Section 103(h) of the National Traffic and Motor Vehicle Safety Act of 1966 required that the initial safety standards be "based upon existing safety standards." Standard No. 301 was based upon General Services Agency Standard No. 515/26, Fuel Tanks and Tank Filler Pipes, effective October 13, 1967. As you know, the GSA standards were applicable only to vehicles purchased by the Federal Government. The two standards, however, are not identical; as an example, Standard No. 301 includes fuel tank connections, while GSA Standard No. 515/26 included a rear end collision test at 20 miles per hour and a side collision test at 15 miles per hour. Perhaps GSA can provide you with background information on their standard if you deem it essential to your case.

MODRALL, SEYMOUR, SPERLING, ROEHL & HARRIS

June 16, 1971

Roman Brooks U. S. Department of Transportation

Re: Volkswagen Gas Caps Our File: Gigler v. Volkswagen

As I mentioned to you when we discussed this matter on the telephone sometime ago, one of the issues in this case will be the applicability of safety standard 301. It is my understanding that on November 30, 1966, the department issued public notice that it was proposing to adopt standard 301, together with the other initial 22 standards. This notice was published on December 3, 1966, in Volume 31 of the Federal Register, pages 15212 through 15221. The publication gave notice that standard 301 was anticipated to become effective on September 1, 1967, and invited interested parties to submit such written data, views, or arguments as they may desire. On January 31, 1967, the order establishing the standard was entered and the same was published on February 3, 1967, in Volume 32 of the Federal Register, pages 2408 through 2416. Standard 301 was adopted, but was to become effective January 1, 1968, rather than September 1, 1967, as originally proposed.

I recognize that safety standard 301 was not technically applicable to the 1966 VW and that it did not go into effect until after our accident (September 20, 1967) had occurred. It is my contention, however, that standard 301 was nothing more than a codification of a pre-existing standard or general custom commonly recognized in the automotive industry. What I need to find out is whether or not this is true and exactly where the standard came from. If you have any committee reports or other data which you could send me concerning the history and background of safety standard 301, I would be most appreciative. If you are not the proper party to handle this for me would you please see to it that this letter reaches the proper destination.

2

This issue is one which the court wants to resolve before trial and in a very short period of time. Consequently, I need this information as soon as possible. In the event that you have such reports and perhaps transcripts of hearings, etc., but the same would be bulky and rather expensive for me to purchase, please let me know since my clients have already built up enormous expenses in this case and we are going to have to start economizing.

Thank you for your very kind cooperation.

Kenneth L. Harrigan

ID: nht72-4.25

DATE: 09/18/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: British Standards Institution

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of July 26, 1972, concerning the seat belt retractor test protector test procedures of section S5.2(k) of Motor Vehicle Safety Standard No. 209.

In our initial reply of August 21, we stated that the belt was to be retracted completely during the cycling, even though some vehicle installations might prevent complete retraction. After further examining the consequences of this position, we have concluded that it is in error.

The intent of the cycling sequence is to reflect the normal use of the belt over time. If the belt is designed to be installed in a vehicle in such a manner that during normal cycling a part of the webbing cannot be wound onto the retractor, a compliance test should employ the same restrictions of movement. We therefore conclude that you are correct in considering a belt to be fully retracted for purposes of Standard No. 209 when it is retracted as fully as the geometry of its installation permits.

Sincerely,

L R Schneider -- Chief Counsel, US Department of Transportation, 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, RAC DANDY --Senior Engineer Head of Mechanical Section

ID: nht73-4.20

DATE: 05/21/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Help of Nebraska, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 30, 1973, in which you ask whether an "infant car hammock" which you manufacture is required to conform to Motor Vehicle Safety Standard No. 213. A picture of the hammock, which you enclosed, shows the hammock attached to both rear doors of a vehicle, and extended between them, with a child lying on it.

As pictured, the hammock is not subject to Standard No. 213. The standard applies, at present, to devices for seating and restraining a child being transported in a motor vehicle. Effective November 1, 1973, it will apply to all devices for seating a child being transported in a motor vehicle, irrespective of whether the device is used for restraint. Because the hammock is not designed to seat a child, it is not subject to the standard. A copy of the standard is enclosed.

We are presently developing proposed amendments to the standard that would apply to all types of infant and child restraints, including devices in which children do not sit. These proposals will be published in the Federal Register when completed.

We are enclosing a copy of our consumer information booklet, "What to Buy in Child Restraint Systems". Our recommendations for infant carriers and car beds are found at the center pages of the booklet.

We hope the information we have provided answers your questions and we appreciate your concern for child restraint safety.

Sincerely Yours,

ENCLS.

HELP OF NEBRASKA, INC.

April 30, 1973

National Highway Traffic Safety Administration Department of Transportation

Gentlemen:

We have acquired the rights to an Infant Car Hammock from the inventor. We are making the first production run now. The question has come up as to whether or not Federal Standard 213 is applicable to this item. We have tried to obtain a copy of this Standard but no one in the Omaha area seems to have a copy.

A photo of the hammock as mounted in a car is enclosed. The hammock itself is made of poplin material which is 65% Kodel and 35% combed cotton. It is permanent press, mercerized and has a 1% shrinkage factor. There are two belts on top of the hammock, one of which goes around the childs waist, the other goes from one hip across the body to the opposite shoulder. These safety belts are stitched through the hammock and through another piece of belting on the bottom that has a "D" ring fastened to it. The "D" Ring is secured to a two inch wide piece of web belting by passing a one inch piece of web belting through the "D" ring and then stitching the two pieces of belting together. By stitching through all safety belts we have a solid base both for the two belts around the child and for the "D" ring. A separate belt with a snap hook is anchored through the floor of the car by placing a bolt through the floor and then through the heavy washer fastened to the end of this belt. The snap hook is then fastened through the "D" ring on the hammock. This gives a down pressure on the hammock and puts the steel tubing brackets placed in the window wells under tension. These belts are not shown in the enclosed photo.

If Federal Standard 213 does apply to this type device, please send us a copy of it. We will be more than happy to send you one of the hammocks for your inspection and/or testing.

Any assistance you can give us will be appreciated.

Sincerely,

John L. Wilson Jr. President

(Graphics omitted)

ID: nht92-5.38

DATE: June 30, 1992

FROM: Lyle Walheim -- Lieutenant, Motor Carrier & Inspection Services, Wisconsin Department of Transportation

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

COPYEE: Thomas Turner -- Bluebird Body Company

TITLE: None

ATTACHMT: Attached to letter dated 9/14/92 from Paul Jackson Rice to Lyle Walheim (A39; Std. 131)

TEXT:

I am writing regarding a concern raised by Mr. Thomas D. Turner, Manager, Engineering Services, Bluebird Body Co. In his letter of April 21, 1992, he requested information regarding FMVSS Standard 131. He also asked for an interpretation of how it applies to Wisconsin as well as other states that require the four warning-light system on school buses rather than the eight warning-light system now used in several states.

Wisconsin Statute S346.48(2)(a) requires that a school bus operator shall actuate such red lights at least 100 feet before stopping to load or unload pupils or other authorized passengers, etc. As stated in 346.48(1), a driver shall stop when the bus is displaying the flashing red warning lights. In addition, when the bus comes to a atop, the "stop-arm" is actuated by the opening of the service door. The service door may not be opened until the bus comes to a complete stop as stated in Administrative Rule, Trans 300.64.

In states that require an eight warning-light system, the amber warning lights are actuated when the school bus is preparing to stop; the red lights are not actuated until the bus comes to a stop. At that point, the red lights come on; the stop lights are actuated and the service door is opened. As you can see, it would not be practical to have the stop-arm extend until the bus actually stops and the door is opened.

It was our understanding that the Bluebird proposal to install a warning device that will sound when the alternating red lights are activated until the service door is opened and the stop-arm is extended would meet the requirement found in S5.5 exception.

The Wisconsin red light system has been required since 1954 and there are no plans to change to the eight light system. Conversion would be very costly and would create a great deal of confusion for the public who is used to the four light system.

It would appear that when the standard was written and implemented, no consideration was given to states who had implemented the stop-arm requirements (for safety purposes) well before they were considered for implementation in Standard 131.

Wisconsin urges you to consider approval of the warning system proposed by Bluebird Bus Company that appears to comply with the exception found in S5.5 for states that require the four red warning-light system.

Wisconsin continues to be in full compliance with SS131 except there now appears to be a difference of how S5.5 is interpreted for states with the four light system.

As previously indicated, requiring the stop-arm to be activated when the red warning lights come on will require Wisconsin to change both Statutes and the Administrative Rule to require an eight light system. This would be both very costly to retrofit and confusing to the public until total conversion by replacement of vehicles placed in operation prior to the effective date of SS131.

I have enclosed copies of Wisconsin Statutes and Administrative Rules for your information. If you have questions or need further information, feel free to call me at (608) 266-0305.

(Enclosure omitted)

ID: nht92-7.46

DATE: April 10, 1992

FROM: Larry Nunn -- President, Automotive Lighting Technologies, Inc. (ALTECH)

TO: Office of Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/22/92 from Paul Jackson Rice to Larry Nunn (A39; Std. 108; Std. 218; VSA 108 (a)(2)(A); VSA 102(4))

TEXT:

LeGrand Systems Inc. of Grand Rapids, Michigan has contracted Automotive Lighting Technologies Inc. of Southfield, Michigan, to design and develop a helmet lighting system for use by motorcyclists, snowmobilers, moped operators, and other recreational vehicles. LeGrand applied for patent on the lighting system on February 13, 1990.

LeLite, the products assumed name, is intended to improve safety in the industry by increasing rider visibility. Many motorcycle accidents result from poor visibility or failure of other motorists to see motorcyclists in time to react.

The idea is consistent with reasoning for the Center High Mounted Stop Lamp introduced in 1986 to decrease rear end collisions. However, LeLite includes a wrap around rear stop/running lamp with two amber turn signals. (Enclosure)

The electrical system of the unit is accomplished via a three (3) wire cord which snaps into the base of the unit and connects to a simple harness unit mounted at a location of the operator's choosing on the handlebars, fairing, or rear portion of the motorcycle. This supply harness attaches directly into the associated brake/running lamp wires feeding from the battery terminal. Since it is wired directly in the motorcycle's existing wiring harness, the LeLite works in perfect harmony with the brake/running lamps on the vehicle.

Automotive Lighting Technologies is dedicated to excellence in vehicle lighting design and development and to any role it can play in the improvement of vehicle safety. We believe this product has merit and could prove effective in reducing accidents.

ALTech realize that there are no SAE or FMVSS requirements for this lighting system. However, it is our opinion that this system will not interfere with the function of any other lighting component on the vehicle but rather augment their purpose.

Due to size, weight, and heat limitations of mounting such a system on a helmet, it is not practical that the system can be design to meet vehicle standards. Therefore, ALTech will take every precaution insure the integrity of the product. During product development, we will keep you informed of test results on vibration, moisture, dust, heat, corrosion, photometry and any other area determined to be prudent.

ALTech is asking for your comments on any legalities which we should consider and your support in bringing this product to market in a manner that does not conflict any state or federal requirements. But more important, we ask for any comments or ideas that will enhance the practicality of our product and the safety of our customers.

If you require any additional information or have any questions, please feel free to contact me at my office. I have enclosed a business card.

Your support in this matter is appreciated.

Attachment

Legrand Systems Inc. 1-800-848-0894

Welcome ...... to the Future

(drawing of helmet omitted)

We bikers have a right to be seen. It is the sincere goal of the people at LeGrand Systems to improve biking safety. With a soon to be introduced line of attractive helmet light packages, we can concentrate on what we enjoy most -- the joy of the road.

Look for our ads in your favorite cycle magazine coming soon - and SEE you on the road!

ID: nht76-2.25

DATE: 05/11/76

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Thomas Kupensky

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 8 to the Department of Transportation, regarding your CAUTION and THANK YOU signals which would flash simultaneously with the turn signal lamps on trucks and trailers.

Since such signs, flashing CAUTION or THANK YOU when actually "turn" is intended, may be confusing in many circumstances, they would be prohibited by paragraph S4.1.3 of Federal Motor Vehicle Safety Standard (FMVSS) No. 108, "Lamps, Reflective Devices and Associated Equipment," (copy enclosed), because they would appear to impair the effectiveness of the turn signals. If these signs were manually operated by the driver, separately from the turn signals, at appropriate times, whether flashing or steady burnings, they would be considered auxiliary devices which did not impair the effectiveness of the turn signals, and would be permitted by Standard No. 108. In this situation, however, they would be subject to the motor vehicle regulations of the individual States.

Sincerely,

Enclosure

ATTACH.

April 8, 1976

Department of Transportation 400 - 7th Street, S. W. Washington, DC 20590

Gentlemen:

Enclosed is a copy from my Patent Attorney of a description of Safety Signal Lights, which I would like to market. I feel these lights add safety for over the road truckers, and act as a backup system for a burned out turn signal, as explained in the attached write-up. They also indicate to the vehicle following of the drivers' intentions.

I have called on a major trailer manufacturer and found that this is creating quite an interest. But the question remains -- would these be acceptable by the Department of Transportation.

Hoping that you can advise me on the above, I thank you for your assistance and any information you might be able to forward.

Sincerely,

Thomas Kupensky

Enc.

(Graphics omitted)

VEHICLE SIGNAL LIGHT ABSTRACT OF THE DISCLOSURE

A signal light system for a vehicle. A pair of auxiliary lights are mounted, preferable, on the rear of the vehicle and operate in conjunction with the vehicle turn indicator lights. Each of the lights is a (Illegible Words) enclosure having a replaceable face plate. The removable plates carry suitable logooda which are visible when the light is illuminated.

SPECIFICATION

The present invention relates to a vehicle signal system and more particularly to a system which (Illegible Word) additional information to other drivers on the road.

The continuous increase of super highway mileage and of the volume of traffic on those highways has brought (Illegible Words) systems which rapidly convey information between the vehicle and other drivers on the road. (Illegible Word) and others who do a considerable amount of high speed driving have developed (Illegible Words). The (Illegible Word) of turn signals to indicate (Illegible Word) changes and the blinking of lights by a vehicle being overtaken to indicate that the passing vehicle has cleared and can pull back into the slower speed lane (Illegible Word) among (Illegible Words). Also, a vehicle which has completed passing will blink his lights to thank the following vehicle. However, there are many people who do relatively little super highway driving and are not aware of these conventions. There is a need for a signaling system which will clearly convey the intentions of the signaling vehicle (Illegible Words) inexperienced drivers do not become confused. (Illegible Word) the practice of blinking the vehicle lights causes the vehicle driver to be momentarily distracted from his primary function, thereby increasing the risk of accident.

It is the primary object of the present invention to provide a signaling system for a vehicle which will clearly alert the following vehicles even if the operators of such vehicles are not aware of the usual signaling conventions.

It is also an object of the present invention to provide a vehicle signaling system which permits the vehicle operator to signal to following vehicles without being distracted from the primary function of driving the vehicle.

Yet another object of the invention in the provision of a signal system which may be easily applied to existing vehicles with a minimum of modification thereof.

The above and other objects of the invention which will become apparent in the following detailed description are achieved by providing a vehicle signal system which employs a pair of auxiliary light units mounted on the rear of the vehicle with the units operating in conjunction with the right and left turn signals, respectively, and with each light unit consisting of an enclosure having a removable face plate which is provided with information conveying markings visible when the signal is illuminated.

For a more complete understanding of the invention and the objects and advantages thereof reference should be had to the following detailed discription and the accompanying drawing wherein there is shown a preferred embodiment of the invention.

In the drawing:

Fig. 1 is a rear (Illegible Word) view of a trailer equipped with the signal lights of the (Illegible Word) invention;

Fig. 2 is a perspective view of one signal light unit of the present invention;

Fig. 3 is a sectional view of the light assembly of Fig. 2;

Fig. 4 is a transverse sectional view taken along the line 4-4 of Fig. 3; and

Fig. 5 is a schematic showing of the control circuit for the lights of the present invention.

A conventional semi-trailer 10 is shown in Fig. 1. The trailer is provided with rear brake lights 12 and left and right turn indicator lamps 14 and 16, respectively, in accordance with conventional practice. These lights are controlled from the vehicle cab in the usual manner. In order to convey additional information to motorists following the trailer two illiminated signs 18 and 20 are also provided on the rear of the trailer 10. While these signs are shown as being mounted at approximately the vertical mid-point of the trailer, it will be understood that the two units may be positioned at any convenient locations.

As will be described in greater detail below, the illuminated sign 18 operation in sequence with the left turn signal 14 while the illuminated sign 20 operates in sequences with the right turn signal 16. Any suitable wording or other indicators may be provided on the two signs 18 and 20. The two signs illustrated, "CAUTION" and "THANK YOU" are considered desirable as these indications reinforce the conventional turn signal indications. Thus, when the left turn signal is operated the word "CAUTION" is flashed simultaneously thus clearly alerting the following motorist to the fact that the vehicle is about to shift to the left lane. This is particularly advantageous when the truck in one of a line of trucks as following motorists frequently cannot see the right turn signals of such a truck and may misinterpret the flashing turn signal as a flashing brake light.

The use of the word "THANK YOU" in conjunction with the right turn signal allows the overtaking vehicle to express his consideration to the vehicle which has been passed without requiring him to perform any action except the operation of his right turn signal which is conventionally done when pulling back into the right lane.

The construction of the light assembly 18 is shown in greater detail in Figs. 2, 3, and 4. It will be understood that the unit 20 is of identical construction. Each of the light units consists of a rectangular bon-like housing 22 which is open on one face to receive a plastic face plate 24 which is provided with the desired indecia. The indecia 26 may be incorporated in any suitable arrangement such as the use of contracting colors or of opaque and translucent regions. The casing 22 has a rear wall 28, and walls 30, and top and bottom walls 32 and 34, respectively. The forward wages of the top and bottom walls are bent to form (Illegible Word) 36. These (Illegible Word) 36 define a channel in which the facing plate 24 in slidably received, the end walls 30 (Illegible Word) the engage the inner face of the plate 24. If desired and depending on the material used to form the face plate 24 a ridge 40 may be provided on the inner surfaces of the upper and lower walls 32 and 43, respectively, in spaced parallel relation to the (Illegible Word) 36 to provide for additional support to the face plate 24. Suitable gaskets 38 and 41 are provided to form a fluid tight seal between the face plate 24 and the casing 22. The wire leads 43 for the lamps within the casing are routed through a suitable grommet 45 to provide a fluid tight seal between the wires and the casing 22.

A vertically extending wall 42 is provided within the casing 22 and midway between the opposite ends 30. The wall may, for example, have a tab portion 44 which is welded or otherwise secured to the rear wall 28 of the casing 22. Affixed to opposite sides of the wall 42 are sockets 46 and 48 for receiving (Illegible Word) 50 and (Illegible Word) respectively. As is shown in Fig. 4, a number of holes or apetures 54 may be provided in the plate 52 so that light can be transmitted from either bulb or both sides of the casing. This assures that even if one bulb should fail at least partial illumination of the whole sign will still be possible.

One possible circuit for controlling the signal lamps 18 and 20 of the present invention is illustrated in Fig. 5 where the vehicle power source, such as the battery 60, is connected to the conventional turn signal switch 62 through a flasher assembly 64 which is also a conventional (Illegible Word). In a first position the turn signal switch 62 causes the left front signal lamp 661, the left rear lamp 14, and the two lamps 50 and 52 of the unit 18 to flash in unison. In the opposite position the switch 62 (Illegible Word) the right forward signal lamp 66r, the rear right signal lamp 16 and the two bulbs of the unit 20. It will be noted that the two bulbs 50 and 52 of each unit are connected in parallel to one another and in parallel to the other signal lamps on the corresponding side of the vehicle. If desired, suitable means such as the double hole signal throw switch 70 may be provided for disconnecting the signaling units 18 and 20 when desired.

While only the best known embodiment has been illustrated and described in detail herein, it will be clearly understood that the invention is not limited thereto or thereby. Reference should therefore be had to the appended claims in determining the true scope of the invention.

What is claimed is

1. An auxiliary signal system for a vehicle having a conventional turn signal system which comprises:

a pair of lamp housings, each having a removable face plate carrying a distinctive legend, the housings being mounted on the rear of the vehicle and adjacent the opposite sides thereof;

at least one lamp within each housing for illuminating the face plate thereof to make the legend visible; and circuit means connecting the lamp of each housing to the actuating circuit of the respective turn signal whereby the lamp operates in conjunction with the respective turn signal.

2. The auxiliary signal system according to Claim 1 wherein each housing comprises a bon-like member having a rectangular opening in one side thereof, the face plate covering the opening.

3. The auxiliary signal system according to Claim 2 wherein two lamps are provided within each housing, the lamps being connected in parallel and positioned so as to illuminate opposite ends of the enclosure.

4. The auxiliary signal system according to Claim 3 wherein each housing has a vertically extending center wall, the two lamps being mounted to the center wall on opposite sides thereof.

5. The auxiliary signal system according to Claim 1 wherein the legend carried by the facing plate of the left housing is "CAUTION" and the legend carried by the facing plate of the right housing is "THANK YOU".

ID: 17170.volvo

Mr. William Shapiro
Director, Regulatory Compliance and Environmental Affairs
Volvo Cars of North America, Inc.
Volvo Drive
Rockleigh, NJ 07647-0913

Dear Mr. Shapiro:

This responds to your January 30, 1998, letter to the National Highway Traffic Safety Administration (NHTSA) following up on an earlier interpretation to you concerning Volvo's manufacture of a rear-facing toddler restraint. The restraint would be used rear-facing only, and recommended for children weighing between 20 and 40 pounds (lb.). I regret the delay in responding.

Your earlier letter asked about the labeling requirements in Federal Motor Vehicle Safety Standard No. 213, "Child Restraint Systems," for a rear-facing restraint that would be recommended only for children weighing 20 to 40 lb. You did not describe the restraint in detail. Your present letter provides the following description:

[T]he Volvo CRS [child restraint system] is secured by a Type I seat belt assembly (as defined by in FMVSS 209). Additionally, the Volvo CRS is secured by a bar which is attached to the back of the Volvo CRS, the other end of the bar resting against the vehicle (certification platform) floor. This same configuration and installation procedure would be used in a vehicle during normal, i.e., "everyday," use.

You specifically ask about the "installation" requirement in S5.3.2 of the standard, as it would apply to your restraint. S5.3.2 states, in pertinent part:

When installed on a vehicle seat, each add-on child restraint system . . .shall be capable of being restrained against forward movement solely by means of a Type I seat belt assembly (defined in 571.209) that meets Standard No. 208 (571.208), or by means of a Type I seat belt assembly plus one additional anchorage strap that is supplied with the system and conforms to S5.4. . . .

You ask for confirmation that the term "additional anchorage strap" would include the bar you would use in your system. We have carefully considered your suggested interpretation and regret that we cannot confirm it. We interpret a "strap" to consist of flexible material. S5.3.2 specifies that a strap may be provided so long as the strap conforms to S5.4. Because S5.4 sets forth requirements for belts, belt buckles and belt webbing, it is clear that any "strap" provided must be of belt webbing. Further, S5.3.2 is meant to support the standardization of the means of attaching child restraints to increase the likelihood that child seats are properly installed.  The reference to the "additional anchorage strap" made allowances for the provision of a top tether anchorage strap, which was at one time provided on most, if not all, forward-facing child restraints. The bar you ask about would be unique to your system and inconsistent with the standardized method of attaching a child restraint.

It should be noted that determining conformance with S5.3.2 is made when the child restraint seat is "on a vehicle seat." Due in part to the quoted language, the agency will assess the performance of the child seat using just the vehicle seat and not the floor. Also, under S6.1.2 of Standard 213, your type of child restraint system must meet performance requirements when "secured to the standard vehicle seat using only the standard vehicle lap belt." The quoted phrase means that NHTSA will not use a means supplemental to the lap belt, such as a bar, of securing a child seat to the vehicle seat in the agency's compliance test. The lap belt alone is used because the agency found that a very high percentage of parents did not use the supplemental tether strap to secure their child seats even when they knew the strap was needed to provide their child protection. Your bar would be supplemental to the lap belt attachment, similar to a tether on a child seat. Similar to a tether, there is a strong likelihood that the bar would be misused with the seat. Accordingly, for the same reasons that a tether is not used in the compliance test, the bar could also not be used in the compliance test.

I hope this answers your questions. If we can be of further assistance, please contact Deirdre Fujita of my staff at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:213
d.7/6/98