ID: nht88-1.19

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Bob Carr

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Bob Carr United States House of Representatives Washington, DC 20515

Dear Mr. Carr:

Thank you for your letter, cosigned by Congressmen William Broomfield and Carl Pursell, urging favorable consideration of a petition for reconsideration of Standard No. 208, Occupant Crash Protection. This petition was filed by C&C, Incorporated, and ask ed us to reconsider our decision to treat convertibles just like all other passenger cars for the purposes of Standard No. 208, as of September 1, 1989. Further, the petition asked us to change our long-standing interpretation that T-top vehicles are not convertibles.

We have not yet completed our analysis and response to this petition. We will consider your views, as well as the arguments presented in the petition, in reaching our final decision. I will see that you are informed of our response to this petition as so on as the analysis is completed.

I have placed a copy of your letter and this response in the public docked for this petition. If you have any further comments or need additional information on this subject, please let me know.

Sincerely,

Diane K. Steed

cc: The Honorable John D. Dingell The Honorable William Lehman

Congress of the United States House of Representatives Washington, DC 20515

January 11, 1988

The Honorable Diane K. Steed Administrator National Highway Traffic Safety Administration Department of Transportation 40O Seventh St., S.W. Washington, DC 20590

Dear Ms. Steed:

We understand that on April 29 and October 19, 1987, C and C, Incorporated of Michigan filed a petition for reconsideration (Docket No. 74-14, Notice 51) of a Notice published in the March 30 Federal Register (52 F.R. 10122). We am also aware of your age ncy's notice of October 17, 1986 (51 F. R. 37028, 37029) wherein you concluded that a "vehicle with a T-bar roof would not be considered a convertible." In the March Notice, we understand NHTSA declined reconsideration of a Toyota petition "to exclude T- bar roof vehicles from the automatic restraint requirement." Your Notice explains:

Toyota said that "due to the lack of a door frame or a roof side rail structure, it is impossible to install an automatic belt that is acceptable to customers to the T-bar roof vehicles in view of current technology." Toyota said it will have to disconti nue T-bar roof vehicles after September 1, 1989, unless those vehicles are excluded from the automatic restraint requirement.

NHTSA has decided to retain its current interpretation of the term convertible and thus, is not adopting the proposed revision requested by Toyota. As discussed earlier in this notice, driver-side air bags and automatic safety belt systems will be availa ble for use in convertibles. Since those systems are available for convertibles, Toyota and other manufacturers of cars with T-bar roofs can use those same systems to comply with the performance requirements of the standard.

We observe that C and C's April 29 letter takes issue with the basis for this conclusion, such as your reference to an device.

We understand that you have not acted on the C and C petition which raises factual and economic issues unique to this firm and not to Toyota. Those issues, particularly the potential job loss, are not addressed in your March 30 Notice. They would probabl y not be significant in the case of Toyota. They are very significant for this firm. We understand that one manufacturer, Ford Motor Company, has canceled a T-roof contract. That may or may not be related to this matter, but it bodes badly for this firm and its workers.

We point out also that C and C is not seeking a permanent exemption from the 208 rule.

We urge favorable consideration of this petition for reconsideration and development of a proposal that will not cause a job loss at this firm.

Sincerely,

WILLIAM BROOMFIELD BOB CARR CARL PURSELL Member of Congress Member of Congress Member of Congress

cc: The Honorable Jon D. Dingell, Chairman Committee on Energy and Commerce

The Honorable William Lehman, Chairman Subcommittee on Transportation and related Agencies Committee on Appropriations

ID: nht94-3.25

TYPE: INTERPRETATION-NHTSA

DATE: June 8, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Paul L. Anderson -- President, Van-Con Inc.

TITLE: None

ATTACHMT: Attached To Letter Dated 5/19/94 From John Womack To Paul Anderson

TEXT: Dear Mr. Anderson:

This responds to your letter of May 19, 1994, requesting an interpretation of the requirements of S5.5.3(c) of Standard No. 217, Bus Emergency Exits and Window Retention and Release. Section S5.5.3(c) reads:

Each opening for a required emergency exit shall be outlined around its outside perimeter with a minimum 3 centimeters wide retroreflective tape, either red, white or yellow in color . . .

Your letter states that you are unable to continuously outline the perimeter of the rear emergency doors on your school buses due to the proximity of door hinges, tail light lenses, and a rubber gasket between the bottom edge of the door and the bumper. You ask:

Would we be in compliance with Reflective Tape requirements of FMVSS 217 if we put a continuous strip of tape across the top of both Emergency Rear Doors on the roof cap above the doors and down the left and right side of the double door opening with bre aks in the tape for door hinges & tail light lenses. This would outline the Emergency Rear Doors on three sides. No tape would be put across the bottom?

As an alternative, if the above is not acceptable, could we put tape across the bottom on the doors?

As explained below, your planned placement for the top and sides of the door, and your alternative placement for the bottom of the door would be acceptable. In a July 7, 1993 letter to the Blue Bird Body Company, NHTSA stated:

NHTSA interprets S5.5.3(c) to allow interruptions in the tape necessary to avoid and/or accommodate curved surfaces and functional components, such as rivets,

2

rubrails, hinges and handles, provided, however, that the following requisites are met. In the November 2, 1992, final rule, NHTSA indicated that the purpose of the retroreflective tape would be to identify the location of emergency exits to rescuers an d increase the on-the-road conspicuity of the bus. Accordingly, the retroreflective tape may have interruptions if they satisfy both of these purposes. The occasional breaks in the tape you described would not appear to negatively affect a rescuer's ab ility to locate the exits, or reduce the conspicuity of the bus. However, the tape should be applied as near as possible to the exit perimeter . . . When rivets are present, NHTSA will defer to a manufacturer's decision to apply the retroreflective tap e immediately adjacent to the rivets, rather than over the rivets, if the manufacturer decides that this will increase the durability of the tape.

According to this July 1993 letter, interruptions in the retroreflective tape to avoid and/or accommodate hinges (such as the hinge on the side of the rear emergency door) and other functional components are permitted if the interruption does not negativ ely affect a rescuer's ability to locate the exits, or does not reduce the conspicuity of the bus. NHTSA considers tail light lenses to be "functional components" which do not have to be covered by the retroreflective tape. (Indeed, placement of the ta pe on the tail light lense could affect the efficacy of the light.) The interruptions in the tape for these components would not appear to negatively affect a rescuer's ability to locate the exits, or reduce the conspicuity of the bus. Thus, the interru ptions are permitted for the tape along the sides of your door.

With regard to the bottom of your door, based on the pictures provided with your letter, it appears that there is no location available for the placement of retroreflective tape outside of the door's bottom edge. Since not outlining an entire side of an exit might affect a rescuer's ability to locate the exit and would reduce the conspicuity of the exit, the bottom side of the door must be marked with the retroreflective tape. In this situation, NHTSA interprets S5.5.3(c) as allowing placement of the retroreflective tape on the door itself, as near as possible to the lower edge of the door.

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I hope you find this information 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: nht93-8.12

DATE: November 15, 1993

FROM: Thomas D. Turner -- Manager, Engineering Services, Blue Bird Body Company

TO: John Womack -- Acting Chief Council, NHTSA

COPYEE: Ben Newberry; Jim Swift

TITLE: Request for Interpretation; REF: 49 CFR Part 571 - Docket No. 90-05; Notice 4, FMVSS 222, Final Rule on Wheelchair Securement Devices and Occupant Restraint Systems

ATTACHMT: Attached to letter dated 3/25/94 from John Womack to Thomas D. Turner (A42; Std. 222)

TEXT:

Section S5.4.3.2 of the referenced final rule requires that each wheelchair location have at least one anchorage for the upper torso restraint and at least two floor anchorages for pelvic and upper torso restraint.

Section S5.4.3.2 of the rule states:

"Each wheelchair occupant restraint floor anchorage shall be capable of withstanding a force of 13,344 Newtons applied as specified in paragraphs (a) through (d). When more than one wheelchair occupant restraint share a common anchorage, the anchorage shall be capable of withstanding a force of 13,344 Newtons multiplied by the number of occupant restraints sharing that anchorage."

It is our understanding that the phrase, "When more than one wheelchair occupant restraint share a common anchorage, . . . ." is intended to address the possible situation where restraints from two different wheelchair occupant restraint systems share a common anchorage. It is not intended to address the common situation where the lower end of an upper torso restraint joins the pelvic restraint and goes to one of the rear floor anchorages of a single occupant's restraint system.

If the phrase was intended to apply to the latter, common situation, then rear floor anchorage could be required to be capable of withstanding a force of 13,344 newtons for the upper torso restraint plus 13,344 for the pelvic restraint for a total of 26,688 Newtons (6000 lbs). If the floor anchorage was also as one of the wheelchair securement anchorages, as is typically the case, Section S5.4.3.2(e) would require that the anchorage be capable of withstanding 3 x 13,344 Newtons (9000 lbs) total.

Blue Bird believes that the phrase referenced above was not intended to require double loading of an anchorage if the anchorage is intended to secure only one occupant. Referring to the attached drawings of two typical systems, we believe the following force capability requirements apply to the floor anchorages:

Left front floor anchorage - 13,344 Newtons (3000 lbs) because only one wheelchair securement device is attached.

Right front floor anchorage - 13,344 Newtons (3000 lbs) because only one wheelchair securement device is attached.

Left rear floor anchorage - 2 x 13,344 Newtons (6000 lbs) because both the left side of the pelvic restraint and the left rear wheelchair securement device are attached:

a. For Figure 1 through separate belts.

b. For Figure 2 through a common belt.

Right rear floor anchorage - 2 x 13,344 Newtons (6000 lbs) because the right side of the pelvic restraint and the lower end of the upper torso restraint are for only one occupant and along with the right rear wheelchair securement device are attached:

a. For Figure 1 through separate belts.

b. For Figure 2 through a common belt.

It is our understanding that the intent of Sections S5.4.3.2 and S5.4.3.2(e) of the standard, for single occupant systems as illustrated in figures 1 and 2, is for the rear anchorages to be capable of withstanding 2 x 13,344 Newtons (6000 lbs) rather than 3 x 13,344 newtons (9000 lbs).

Blue Bird is in the final stages of certification testing of several systems and must complete our work immediately in order to meet the January 17, 1994 effective date. We, therefore, request urgent attention be given to this matter and that confirmation of our understanding, as stated above, be provided by FAX or telephone in the next few days. A formal written interpretation can be provided at a later date, but we need the answer immediately.

Thank you for your consideration of this urgent request.

ATTACHMENTS

Figure 1 - Typical wheelchair securement and occupant restraint system (separate belts to floor anchorage)

Figure 2 - Typical wheelchair securement and occupant restraint system (single belts to floor anchorage)

(Graphics omitted)

ID: nht76-4.32

DATE: 12/29/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood for F. Berndt; NHTSA

TO: Department of Police - Detroit

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 9, 1976, asking whether Federal regulations permit manufacturers to equip police vehicles with "push bumpers" and with bullet-proof shields located between the front and rear seating compartments.

Standard No. 215, Exterior Protection, establishes requirements for the impact resistance and the configuration of front and rear vehicle surfaces of passenger cars. This standard does not prohibit "push bumpers" and manufacturers are free to equip passenger cars with any bumper design they choose as long as the requirements of Standard No. 215 are met.

Standard No. 205, Glazing Materials, specifies requirements for glazing for use in motor vehicles, including the permissible locations for the various types of glazing. The standard permits bullet-resistant glazing to be used anywhere in a motor vehicle, provided such glazing meets specified performance requirements. Therefore, vehicle manufacturers are permitted to equip vehicles with the bullet-proof shields mentioned in your letter if such shields are constructed with glazing that conforms to the requirements in Standard No. 205.

You also asked whether the police department or a business could install the equipment in question. If the equipment is installed after the first sale of the vehicle for purposes other than resale, the Federal safety standards would no longer be applicable under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1397(b)(1). However, @ 108 (a)(2)(A) prohibits, with one exception, manufacturers, distributors, dealers, and motor vehicle repair businesses from knowingly rendering inoperative a safety device or element of design that has been installed in compliance with a motor vehicle safety standard.

Therefore, whether or not a business could install the equipment depends on the nature of the business. If the business is a "motor vehicle repair business", it can only install the "push bumpers" and shields if such installation does not knowingly render inoperative devices or elements of design installed in the vehicle in compliance with applicable safety standards. Section 108(a)(2)(A) defines "motor vehicle repair business" as any person who holds himself out to the public as in the business of repairing motor vehicles or motor vehicle equipment for compensation.

I have enclosed copies of Standard No. 205 and Standard No. 215. I have underscored the pertinent sections of Standard No. 205 (and the ANS 226 standard incorporated by reference in Standard No. 205) for your information.

SINCERELY, Department of Police Detroit, Michigan

Hugh Oates National Highway Traffic Safety Administration

Pursuant to our phone conversation on November 1, 1976, the Equipment Control Section of Detroit's Police Department has experienced a degree of reluctance by the auto manufacturers in providing police vehicles with specialized equipment. The purpose of this communique is to resolve the following two questions:

(1) The auto manufacturers state that per regulations issued by the National Highway Traffic Safety Administration, they are unable to equip police vehicles with a special "push bumper". To more clearly delinate this concern, enclosed please find several photographs of the "push bumpers" and how they are attached to the car's bumper system. The Detroit Police Department prefers to order vehicles from the manufacturers with the "push bumper" attached. In furtherance of this desire, a ruling by your administration allowing the manufacturers to construct police vehicles with "push bumpers" and sell same to our department, would clearly alleviate this dilemma.

(2) The auto manufacturers also state that they cannot sell vehicles equipped with a bullet proof shield located between the front and rear seating compartments. My research uncovered no federal statute or regulation prohibiting this. Your advise on this matter would clear any ambiguity.

In responding to the above requests, assuming the auto companies could not lawfully sell us police vehicles with any of the above special equipment, I would appreciate you probing the possibility of the City installing such equipment subsequent to our purchasing the vehicles, or having a private business perform these tasks. Please note that both the "push bumper" and bullet proof shield are removed from the vehicle when same is later sold at public auction.

If further information is needed, please feel at liberty to call me (313-224-4426).

JOSEPH E. PAPELIAN Legal Advisor Section

cc: INSPECTOR JOHN DOMM

ID: nht76-4.34

DATE: 07/13/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: "Lucite" Acrylic Sheet Products

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of April 9, 1976, concerning the certification and marking requirements for glazing specified in Section 6 of Standard No. 205, Glazing Materials. You asked whether the standard prohibits use of the "DOT" symbol and manufacturer's code number by anyone other than a "prime glazing material manufacturer," as that term is defined in paragraph S6.1.

Our letter to Dupont explained the separate certification and marking requirements that are applicable to glazing prepared by prime glazing material manufacturers, distributors, and vehicle manufacturers. The standard specifies that the "DOT" symbol shall be placed on glazing that is designed by the prime glazing material manufacturer as a component of any specific motor vehicle. The agency's interpretations of several years ago pointed out that the standard requires a person other than a prime glazing manufacturer who cuts glazing materials to mark it in accordance with section 6 of ANS Z26 and to certify it in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act of 1966. These interpretations emphasized that a person who cuts and shapes the glazing material received from a prime glazing manufacturer should not include the "DOT" symbol in his marking and certification.

At the time of the earlier interpretations, the NHTSA considered it necessary from the standpoint of enforcement to distinguish between glazing that had been manufactured by the prime glazing manufacturer for use in specific motor vehicles and glazing that had been cut, shaped, or otherwise altered by another party before installation. The agency was also concerned that the use of the "DOT" symbol by anyone other than the prime glazing manufacturer would be misleading and could create confusion.

Since that time, the certification procedures have become more widely understood and uniformly practiced throughout the industry, and this has aided the "traceability" of glazing materials for enforcement purposes. Therefore, the agency no longer prohibits the use of the "DOT" symbol and the prime glazing manufacturer's code number by the distributor or manufacturer who cuts the glazing, if the prime glazing manufacturer grants permission for such use of his code number to the distributor or manufacturer.

Sincerely,

ATTACH.

E. I. DU PONT DE NEMOURS & COMPANY

INCORPORATED April 9, 1976

Mr. Frank A. Berndt, Esq. Office of Chief Counsel Department of Transportation National Highway Traffic Adm. 400 Seventh Street, S.W. Washington, D.C. 20591

Dear Mr. Berndt:

We have received a letter written by Robert L. Carter, Assoc. Adm., Motor Vehicle Programs reference N41-42, a copy of which is enclosed, relative to identification of plastic glazing under Federal Motor Vehicle Safety Standard No. 205, Glazing Materials.

Considerable quantities of "Lucite" * AR abrasion resistant sheet are used for bus glazing as well as motorcycles and recreational vehicles. We supply large sheets of glazing material which are fabricated into bus windows by our Official Distributors. The bus manufacturers have required that these suppliers hot stamp the windows with a DOT number in addition to the other required identification and we have authorized these Official Distributors to use our DOT number 80. A literal reading of Mr. Carter's letter would seem to prohibit such practices. This has resulted in confusion and could prove to be quite costly to our business. If the fabricators are prohibited from using the manufacturers' DOT numbers, it will mean the bus manufacturers will have to revise all of their glazing blueprints and specifications removing the DOT number identification. We would like to avoid this extreme if possible. In discussing this with the enforcement group of NHTSA, I was informed that "while the DOT number was not required to be used by our Distributors, it would not be specifically prohibited."

* Du Pont Co. trademark

We are uncertain which interpretation is correct or if they are compatible and have been advised to request from you a clarification and official opinion.

Would you please review the above and advise whether or not our Official Distributors can use the Du Pont DOT number 80 on glazing of "Lucite" AR going into bus and other transportation glazing in order to comply with bus manufacturers' specifications.

Sincerely,

Russell H. Berry -- Marketing Specialist, "Lucite" Acrylic Sheet Products

ID: nht74-2.6

DATE: 09/26/74

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

TO: Eagle International Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 16, 1974, request for approval of the Bendix "dual circuit air brake system" for use on your buses in satisfaction of Standard No. 121, Air brake systems. In a subsequent phone call with Mr. Herlihy of this office, you stated that your only concern was whether the standard requires a parking brake system that meets the axle-by-axle retardation force requirements of S5.6.1 and the grade holding requirements of S5.6.2.

The National Highway Traffic Safety Administration is unable to "approve" plans or prototype systems for compliance with a standard in advance, because there is no way to establish that a vehicle so equipped actually meets the requirements until it has been manufactured.

With regard to your specific question, S5.6 states that each vehicle shall have a parking brake system that meets the requirements of S5.6.1 or S5.6.2 at the manufacturer's option. This means that you are free to choose a system which meets either of these requirements but does not meet both.

Yours truly,

ATTACH.

July 16, 1974

Sid Williams; 400 7th Street, S.W.; Washington, D.C. 20024

Dear Sid:

Enclosed is a copy of our Dual Circuit Air Brake System as developed by the Bendix heavy vehicle system group (their drawing number SA-8117-99). With this is an explanatory writeup describing a circuit operation for normal running, parking position and for service brake failure on the rear or front axle.

We would appreciate receiving your comments and possibly your approval for use in compliance with safety standards #121.

As previously mentioned we would like to avoid the use of spring brakes especially on the tag axle because these wheels are independently sprung and have a tendency to lock up because they do not have a load dividing connection with the drive wheels.

I would appreciate your help on these matters and hope to hear from you soon.

With warmest personal regards,

Sincerely yours,

Harry L. Cuthbert -- Chief Engineer, Eagle International Inc.

Enc: 2

SA-9117-99

EXPLANATORY WRITE-UP

NORMAL RUNNING

1. All reservoirs charged and accessory pressure protection valve open.

2. Parking Control Valve handle in release position. DD-3 Valve (Item 20) does not deliver air. DD-3 locks are disengaged. Service Interlock Valve controlled from its delivery line.

3. "Stand-by" Valve (Item 15) does not deliver any brake valve air, and low pressure indicator switches are open.

4. Service brakes can be applied by treadle valve; primary section of the brake valve applies rear axle and secondary section of the brake valve applies front axle.

SECONDARY BRAKES

1. A service brake failure, which would result in a rear axle circuit reservoir pressure loss will cause the "Stand-by" Valve (Item 15) to open. This will supplement the front axle brakes with rear axle brakes by applying modulated from axle circuit service pressure to the parking diaphragm.

2. A front axle circuit service brake failure will only cause a loss of front axle braking. Full service brakes can be applied on the rear axle through the treadle valve (Item 14).

3. In event of a broken treadle, the parking brakes can be applied as a "Back-up" emergency.

PARKING POSITION

1. When Parking Control Valve Handle (Item 18) is moved to the "park" position, the DD3 locks engage. The parking DD3 Valve will first deliver adequate pressure to the DD3 parking diaphragm, and then exhaust it automatically. In this condition, the parking application will remain applied strictly by "a mechanical means."

2. Service Interlock Valve being decontrolled, is closed and parking brakes cannot be released until PP-1 is pushed and a full service application is made and released, in this sequence.

RCF: dw Current for Drawing Revision #7; 6/18/74 (Graphics omitted) ITEM QTY DESCRIPTION 1 1 AIR COMPRESSOR 2 1 GOVERNOR 3 1 RESERVOIR-SUPPLY 4 1 (Illeg.) 5 1 (Illeg.) 6 1 (Illeg.) 7 1 (Illeg.) 8 3 DRAIN COCK 9 1 SAFETY VALVE 10 1 PRESSURE PROTECTION VALVE 11 3 SINGLE CHECK VALVE 12 3 LOW PRESSURE SWITCH 13 2 AIR PRESSURE GAUGE 14 1 (Illeg.) 15 1 (Illeg.)

TWO-STEP RELEASE OF DD-3 ACTUATORS.

2. (Illegible Words)

3. (Illegible Words)

(Graphics omitted)

(Illeg. table)

ID: 77-4.21

TYPE: INTERPRETATION-NHTSA

DATE: 10/18/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Lucas Industries North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of August 19, 1977, we advise you that your mistake in referencing S4.5.2 of Standard No. 108 instead of S4.5.1 in your earlier letter of May 13, 1977, does not alter our previous interpretation of June 16, 1977.

Your design appears to meet the specifications of J564a allowing compliance of the headlamp beam switching system with S4.5.1 when installed in a motor vehicle.

YOURS TRULY,

AUGUST 19, 1977

Ref NOA-30

Joseph J Levin, Jr Chief Counsel U.S. Department of Transportation National Highway Traffic Safety Administration

Subject Lucas 21SA Headlamp Switch Circuit

We thank you for your opinion on the subject switch circuitry that we requested in our letter dated May 13, 1977.

Inadvertently, we had referred to section S4.5.2 of Federal Motor Vehicle Safety Standards 108 when requesting your help, instead of section S4.5.1 of standard 108.

Section S4.5.1 referes to the SAE recommended practice J564a "Headlamp Beam Switching" and it is part 4 of this standard which we are primarily concerned with, that is, "the switch shall be designed so that the headlight circuits are never maintained open" (The absence of a dead spot).

We again submit the wiring circuitry for the subject headlamp switch and ask that you re-evaluate this circuit as per section S4.5.1 and forward your opinion to us.

Eric E Gough Staff Assistant (Technical)

cc: K. J. JONES 21SA HEADLAMP BEAM SWITCH CIRCUIT

[Graphic omitted) (Illegible Text) (Illegible Text)

JUN 16 1977

Eric E. Gough Staff Assistant (Technical) Lucas Industries North America, Inc.

DEAR MR. GOUGH:

This is in reply to your letter of May 13, 1977, to the Administrator asking whether the circuitry diagram that you enclosed would allow compliance with S4.5.2 of Federal Motor Vehicle Safety Standard No. 108.

Paragraph S4.5.2 requires that "each vehicle shall have a means for indicating to the driver when the upper beams of the headlamps are on that conforms to SAE Recommended Practice J564a, April 1964 . . . ." Your diagram appears to meet the specifications of J564a allowing compliance of the system with S4.5.2 when installed in a motor vehicle. The entity legally responsible for compliance with S4.5.2, of course, is the vehicle manufacturer who must certify that its products meet all applicable Federal motor vehicle safety standards.

YOURS TRULY,

Joseph J. Levin, Jr. Chief Counsel

cc: MR. VINSON; MR. CARTER

MAY 13, 1977 The Administrator National Highway Traffic Safety Administration

Our sister company in Birmingham England, Lucas Electrical Limited, requests clarification of Section 4.5.2 of Standard 108 - Lamps, Reflective Devices and Associated Equipment - and SAE Recommended Practice J564, which is referenced in Standard 108, Section 4.5.2.

We submit a diagram of a four headlamp installation in which a Lucas Model 21SA switch and a normally closed relay is used to ensure that the headlight circuits cannot be held in the open condition. Manual and auto reset switches are also included in the circuit to ensure correct circuit operation. We are also submitting traces showing the transient voltage conditions when switching from:

a) Main beam to dip beam

b) Dip beam to main beam

This circuitry we have developed allows, as far as we are aware, for us to comply with Section 4.5.2 of Standard 108. We look forward to receiving whatever comments you deem applicable and will be pleased to supply additional material if you so desire.

LUCAS INDUSTRIES NORTH AMERICA INC

Eric E Gough Staff Assistant (Technical)

ENC

21SA HEADLAMP BEAM SWITCH CIRCUIT

[Graphics omitted)

b) LUCAS 21SA SHY DIP BEAM --> MAIN BEAM

(Graphics omitted) (Illegible Text)

ID: nht74-5.53

DATE: 08/05/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Adams & Westlake Company

TITLE: FMVSS INTERPRETATION

TEXT: Dear Mr. Hansing:

This is in reply to your letter of July 3, 1974, regarding Motor Vehicle Safety Standard No. 217. You requested that we reconsider our opinion of June 11, 1974, that a bus emergency release mechanism which you describe must meet the requirements for emergency exit release in S5.3.2 of the standard after as well as before the retention test required by S5.1, when the glass breaks during the retention test.

Paragraph S5.3.2 requires that the release requirements be met both before and after the retention test. We do not find sufficient justification to relax this requirement in the situation you described. First, it is not clear that it is as easy as you represent to eliminate by hand all of the glazing material left in the frame. More importantly, however, we still question whether most persons are sufficiently cognizant of the qualities of tempered glass to attempt to remove the remaining fragments in an emergency situation. Finally, glazing with completely different breakage characteristics may be used to replace the original tempered glass at some time during the life of the bus. For these reasons, our conclusion of June 11 remains the same.

Yours Truly,

July 3, 1974

Office of Chief Counsul

National Highway Traffic Safety Administration

Attention Mr. Richard Dyson

In regard to Motor Vehicle Safety Standard #217, "Bus Window Retention and Release S5.3.2 and our previous correspondence (here enclosed), please reconsider our request for exemption from having operable release mechanisms after the retention test when glazing with tempered glass.

In my letter to you of April 16, 1974 we noted that tempered glass once broken made the operation of any release mechanism unnecessary, as any glass remaining in the opening would be easily removed by touch. We therefore asked for exemption from the requirement that the release mechanism be operable after the retention portion of the test on the basis that the release mechanism would no longer be necessary in the event of glass breakage.

Our design, which is proposed for use on short and mid-range transit busses, uses an extruded aluminum frame which is screwed to the coach body. The glass is glazed directly into the frame; the stationary lite being returned by a rubber extrusion and bedding tape. The sliding glass is also retained directly in the frame and glides horizontally in a pocket weatherstrip. The release lock mechanism is bonded directly to the sliding lite and retains it in a closed position by engaging a groove in the extruded frame rail.

To meet the opening requirement of S5.2.2B of the spec, the release lock mechanism is disengaged and the sliding lite is moved foreward or rearward, depending on which half contains the sliding lite, until the minimum opening width of 20 inches is obtained. See drawing #DK-1553 and test pictures which show the type of window proposed.

This system meets the preliminary release test and the retention test without question, but if the tempered sliding glass shatters during the lotter test most of the glass, often including the release lock mechanism, falls out of the opening. This obviates any further practical need for the release

lock mechanism as the required opening, if not immediately obtained by the breakage of the sliding lite, can be obtained by touching any remaining glass cubes which will cause them to crumble and fall out. In the event that the tempered glass does not break during testing, or more importantly during crash impact, the mechanism would obviously be required to function.

We feel that our system fully meets the intent of the specification in providing unobstructed openings for emergency agress. We respectfully request that you reconsider our request for exemption from the portion of paragraph S5.3.2 which requires that the release lock mechanism remain operable after the retention test when tempered glass is used in this manner and has broken out during that test. Please give this request your earliest consideration as a reply is urgently needed by August 1, 1974.

Ronald J. Hansing Project Engineer

(Graphics omitted)

ID: nht75-1.13

DATE: 05/16/75

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

TO: Toyo Kogyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 16, 1975, question whether the test procedure of S7.7.1 of Standard No. 105-75, Hydraulic brake systems, permits reapplication of the parking brake if the vehicle fails to hold on the required grade after the first application of a force or series of forces. You also ask whether a brake warning indicator which signals a short-lived loss of pressure during a spike stop brake application would conform to S5.3.1(a)(1).

Section S7.7.1 directs (in part) application of the parking brake with a force or series of forces, release of the service brake which has been holding the vehicle on the required grade, and indicates that in release of the service brake, "it may be necessary to reapply it, if the vehicle moves slightly, to take up the parking brake system slack." (emphasis added).

The word "it" refers to the service brake system, and not the parking brake system. This sentence permits application of the service brake only, which has the effect of taking up parking brake system slack due to rotation of the brake shoes and drum prior to bottoming against the anchor pin. This service brake application is intended to provide the best opportunity for a static test of the parking brake.

You state that a differential pressure can occur within the Mazda master cylinder during a spike stop brake application because the piston travels beyond the outlet port to the rear wheel brake lines. This pressure differential causes momentary activation of the brake warning indicator lamp.

The NHTSA would consider in this case that, as a technicality, momentary failure of the rear wheel subsystem has occurred because continued braking pressure cannot be applied to the rear wheels. You point out that the system corrects immediately and the signal lamp is extinguished.

From your description of the Mazda system, NHTSA concludes that the activation of the signal lamp conforms to the requirements of S5.3.1(a)(1) as long as it is designed to extinguish as soon as the system corrects and continued brake force could be applied to the rear wheels.

Yours truly,

Enclosure

April 16, 1975

James C. Schultz -- Chief Counsel, National Highway Traffic Safety Admin.

Dear Mr. Schultz: In determining the final system for meeting MVSS 105-75, we are having some trouble in following some of the test requirements. We would highly appreciate it if we could have your view on the following questions until April 25, 1975 in order to relief them.

1. Re: Parking Brake Test Procedure in S7.7.1

When we run the test according to this section, we understand the following sequence (a) through (h) acceptable.

a) Bring the vehicle on the grade and hold it by applying the service brake.

b) Apply the parking brake by keeping the service brake working with specified force.

c) Release the service brake.

d) Check the movement.

e) If moved slightly, reapply the service brake and hold it.

f) Then reapply parking brake with the specified force to take up its slack without releasing it.

g) Release service brake again.

h) Check the movement.

2. Re: Brake Indicator Lamp

During the spike stop test on our model, it was observed that the "brake indicator lamp" lit while the test driver kept depressing the service brake pedal. We studied this problem and found that as shown in the drawing its master cylinder piston can travel beyond the hole which supplies brake fluid to the rear brake cylinder, that generates the difference in the pressure of front and rear.

As the brake indicator lamp works by sensing the difference in pressure of the front and rear, this lamp becomes "on" accordingly.

(Graphics omitted)

However, this piston does not travel beyond its hole under normal operation. If this lamp should light during spike stop, this will not give any problem to the drivers because this lamp will turn out after releasing pedal force.

We would like to have your view on the acceptability of the above condition.

Sincerely yours,

H. (Speedy) Hirai -- Technical Representative, Toyo Kogyo Co., Ltd. (Mazda), Representative office

cc: V. Bloom; T. Herliny

ID: nht75-4.36

DATE: 11/10/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Takata Kojyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Takata Kojyo's ctober 1, 1975, questions whether a Type 2 seat belt assembly with non-detachable shoulder belt (1) may be labeled in accordance with S4.1(k) of Standard No. 209, Seat Belt Assemblies, in only one location on either the upper torso or pelvic portion (A-I), (2) must be submitted (with the labeling modification) to a test laboratory or other facility as the basis for continued certification to the standard (A-II), (3) must be retested after a change is made to webbing length as the basis for continued certification to the standard (B-I), and (4), if testing is not required, must be submitted to a test laboratory or other facility as the basis for continued certification to the standard (B-II).

One label on either portion of a Type 2 seat belt assembly with non-detachable shoulder belt may be used to satisfy the requirement of S4.1(k) of Standard No. 209.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) requires manufacturers, to produce products covered by standards in compliance with those standards, as set by the National Highway Traffic Safety Administration (NHTSA), and to certify the products. It leaves the choice of testing methods up to the manufacturers. The NHTSA does not require retesting or submission to test laboratories as a basis for certification. A company like yours is free to choose any method that assures you that your products will conform if they are tested by the NHTSA as specified in the standard. This may take the form of tests, engineering calculations, or other means necessary to provide this assurance.

The answers given above pertain only to the Federal requirements for seat belts. It may be necessary to contact other regulatory authorities as to the effect of these changes under their regulations.

SINCERELY,

TAKATA KOJYO CO., LTD.

October 1, 1975

Frank A. Berndt U.S. Department of Transportation NHTSA

Re: Questions of alternation of labelling and webbing length on a safety seat belt assembly

We would like to appreciate sincerely for your previous kind and fine response to our questions of July 29, 1975.

We are very sorry to trouble you again but here are second times our questions underneath as follows referring the caption. So we shall be very pleased if you could let us have your instructions responsive to them.

(A) As you see and can realize a sketch in the figure attached here, in present system of a Type II seat belt assembly where both sections of webbing restraining upper torso and pelvic are sewed together with a tongue to result in no releasing of it from them, each of fabric labels indicating date of production, maker name, model expression and so on is stitched respectively on the torso section and pelvic section of webbing.

Our questions

(A-1) Can it be permitted that any one of above two fabric labels is deleted (for example; One for upper torso section will be expected)?

(A-2) In present usual case, we have been submitted from U.S.T.C. the test approval on a seat belt assembly attached with two labels. Even if above (A-1) is realized, are we required to submit new sample to the authorizer of U.S.T.C. and AAMVA (American Association of Moter Vehicle administrators in each State) in advance?

(B) In the case that in connection with the above seat belt assembly, we wish to alter the webbing length on it,

(B-1) Are we required to take a new approval test additionally for the assembly sample provided with altered length of webbing?

(B-2) If no new approval test be required at above (B-1), can we be permitted to do it only with submitting the new altered sample to the test authorizer of U.S.T.C., E.T.L. or so on?

ALTERATION we wish:

FROM:

TO:

upper torso restraint webbing, 1130+/- 5(Illegible) mm no change pelvic restraint webbing, 1100+/- 5(Illegible) mm 1130+/-5(Illegible) mm

We would be very happy to have your yes or no in so earlier time you could.

Mitsuru Masada

October 1, 1975 75-TD-424 attached to,

(Graphics ommitted)