ID: aiam3756

Dear Mr. Miller: The Department of Commerce has forwarded your letter of September 27 1983, to Mr. Vinson of this office, for our reply. You have asked about Federal standards for motorcycle headlamps in connection with your investigation of an accident in Indiana involving a motorcycle reputedly equipped with 'a custom light approximately 2 1/2' by 5 '...smaller than a stock light.' Indiana Law requires that motorcycles be equipped with headlamps meeting Federal standards.; The principal Federal standard on motorcycle headlighting is SA Standard J584a, incorporated by reference in 49 CFR 571.108, Motor Vehicle Safety Standard No. 108. The standards do not list permissible sizes for motorcycle headlamps that are not sealed beam, specifying only that the light emitted comply with requirements at various photometric test points. Thus, the small size of the lamp in question is not indicative that it failed to meet Federal motorcycle requirements.; However, we are not aware that motorcycle headlamps are available i rectangular sizes smaller than those used on passenger cars, i.e., 4 inches by 6 inches. Perhaps the lamp in question was intended by its manufacturer for use as a driving lamp on passenger cars, its size is consistent with that type of lamp. But without further information I'm afraid we can be of no greater asistance (sic).; Sincerely, Frank Berndt, Chief Counsel

ID: aiam4155

Dear Mr. Pezzulich: This is in reply to your letter of April 28, 1986, to Mr. Vinson o this Office pointing out that a center high-mounted stop lamp may be obscured when a luggage rack is in use, and asking for the legal ramifications involved in such use.; Compliance with the requirements of Federal Motor Vehicle Safet Standard No. 108 *Lamps, Reflective Devices, and Associated Equipment*, under which such lamps are now mandatory on new passenger cars, is judged with the luggage rack in place, but not in use. We are not aware of any State restrictions on use of a luggage rack if it would interfere with the output from a center high-mounted stop lamp.; You may have noted that the lamp is placed between the rack and th deck on the rear of some cars on which racks have been installed as standard equipment, and not behind the rack in the parcel shelf area. This appears to be an effective solution to the problem posed by luggage racks.; I hope that this answers your question. Sincerely, Erika Z. Jones, Chief Counsel

ID: nht71-2.38

DATE: 05/03/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Darden; Neef & Heitson

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 20, 1971, petitioning for rulemaking pursuant to 49 CFR 553.31, asking that the Tire Identification and Record Keeping Regulation be inapplicable to mobile homes. The points raised in your petition have been thoroughly considered, however, your petition, by copy of this letter, is denied. As you know, many of the points you raised were considered in connection with the interpretation of "Motor Vehicle" as it refers to trailers, issued March 31, 1970 (35 F.R. 5333) (Copy Enclose The interpretation concluded that a mobile home is a motor vehicle within the meaning of the National Traffic and Motor Vehicle Safety Act of 1966, (15 U.S.C. 1381 et seq.). As such, mobile home manufacturer are required to comply with the requirements of Part 574.

The burden placed on the mobile home manufacturer by the regulation does notaappear unreasonable. The regulation requires that the vehicle manufacturer or his designs maintain a record of the tires shipped on or in its vehicles and maintain the names and addresses of the purchasers of its vehicles. Locating the purchaser should be a comparatively easy task.

Mobile homes are constructed with a view, of course, to their over-the-road capabilities. The Tire Identification and Record Keeping Regulation should be applicable to mobile homes since it relates directly to one of the instrumentalities for moving a mobile home. Should a tire sold with a mobile home be defective, we consider it essential that the purchaser of the vehicle be notified of this fact.

ID: nht92-3.22

DATE: 10/08/92

FROM: T. KOUCHI, -- DIRECTOR & GENERAL MANAGER, AUTOMOTIVE EQUIPMENT DEVELOPMENT & ADMINISTRATION DEPARTMENT, STANLEY ELECTRIC CO., LTD.

TO: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TITLE: RE.: PHOTOMETRIC TEST METHOD OF HMSL

ATTACHMT: ATTACHED TO LETTER DATED 12-1-92 FROM PAUL J. RICE TO T. KOUCHI (A40; STD. 108)

TEXT: We Would like to ask you some questions about photometric test method of High-Mounted Stop Lamp (HMSL) using Light Emitting Diodes (LEDs) as light sources.

BACKGROUND: HMSL is required to conform to SAE J186a which is referenced in Table III of FMVSS 108. We know, however, that SAE J1889 has been published as a technical guide to standard practice for LED lighting devices. So, in making photometric measurement of HMSL incorporating LEDs, we usually follow testing method described in Sec. 3.1.5 (Photometry Test) of that SAE document.

PROBLEMS: When we conduct photometric measurements of HMSL incorporating LEDs according to the test method of SAE J1889 as mentioned above, the lamp must be energized, for the measurement of photometric minimums, "until either internal heat buildup saturation has occurred or 30 minutes has elapsed, whichever occurs first" as recommended in Sec. 3.1.5.3. However, since it is rather difficult to determine the exact time of internal heat buildup saturation every time when measuring lamps, we make it a rule to conduct measurement 30 minutes after the lamp energization. We think it is reasonable that the lamp should be energized for stabilization beforehand, because the light output of a lamp changes with time at the beginning of operation due to the unique character of LEDs. But, after energization for such a long time as 30 minutes, the light output decreases by approximately 30% of the initial value depending on the type of lamp.

So we must always allow a margin of the same percentage when designing initial light output of the lamp, which necessitates increase in the number of LEDs used, lamp size, product cost, and, therefore, user's expense.

SOLUTION: To solve the above mentioned problems, and for reasons as will be stated in the following, we consider that the warm-up time of HMSL incorporating LEDs should be 5 minutes for measurement of photometric minimums.

Reasons: 1) The time duration is usually within a minute or 3 minutes at the longest that a driver keeps to step on the brake pedal. We do not have the statistical data about this time duration, but some members of our staff who drive a car everyday gave us similar values.

2) The light output of the lamp does not always stabilize in 5 minutes, but it is not necessary to take a warm-up time above the time duration the lamp is continuously operated in real driving.

3) SAE J575 "Warpage Test on Devices with Plastic Components" prescribes, in Table 1, operating cycles of individual signal lamps during the warpage test, and it specifies 5 on-5 off operation for a stop lamp. This specification of 5-minute energization deserves attention because it seems to be established taking into consideration actual way of usage of stop lamps.

Based on the above explanation, we would like you to revise FMVSS 108 by adding a new provision, in certain place thereof, specifying that HMSL incorporating LEDs shall be energized for 5 minutes before measurement of photometric minimums. Your view on this matter is highly appreciated.

Furthermore, regarding actual steps of photometric measurement, we ask you to permit the following. We would like to have your comment on this matter also.

STEPS: 1. Measure luminous intensity at H-V axis after the lamp was energized for 5 minutes.

2. After the light output stabilized, measure luminous intensities at all test points including H-V axis.

3. From the results of Steps 1 and 2, calculate the decrease rate of the luminous intensity at H-V axis from the time the lamp was energized for 5 minutes to the time the light output stabilized.

4. Multiply the luminous intensities at test points excluding H-V axis obtained at Step 2 by the reciprocal of the decrease rate calculated at Step 3, to estimate the luminous intensities to be measured at respective test points after the lamp was energized for 5 minutes. Then the individual estimated values are deemed the measured photometric values and they are recorded.

ID: aiam0119

Dear Mr. Dando: Thank you for your letter of October 4, 1968, in which you inquire about the acceptability of affixing a 'paper type nameplate' to the cab door glass of partially completed chassis-cab trucks.; A assume that you are referring to the requirement for certification o conformity with Federal Motor Vehicle Safety Act of 1966. The Federal Highway Administration has recently issued a notice of proposed certification regulations, a copy of which is enclosed. While of course this proposal may be changed before it is issued as a final rule, it will give you an indication of the specific requirements that will probably be established within the next few months.; With specific reference to your questions, the proposed regulations d specify in S. 275.5 that a label be affixed to a window of a chassis-cab. Not material is specified, so paper or similar materials will be satisfactory under this proposal. You will note that the proposed requirements differs in several respects from the drawing that you submitted with your letter. As least twelve-point type is require, which has capital letters of approximately 1/8 inch, the place of manufacture must be specified, and the statement restricting use most conform substantially with item (c) of that section.; We are pleased to be of assistance. Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel fo Regulations.;

ID: aiam4200

Dear Mr. Cantrell: This responds to your letter regarding the LA-Z-START, a remote contro device which you manufacture for starting automobiles. You ask whether your device is compatible with Standard No. 114, *Theft Protection*. I regret the delay in responding to your letter.; For your information, this agency does not approve motor vehicles o motor vehicle equipment. Instead, NHTSA relies on the self-certification process in the National Traffic and Motor Vehicle Safety Act of 1966, as amended, which requires each manufacturer to certify that a motor vehicle or item of motor vehicle equipment complies with all applicable safety standards.; The product information enclosed with your letter indicates that thi device permits a person to use a remote control device to send a coded signal to start or stop a vehicle engine up to 500 feet away. Your device will shut off the engine immediately if any of the following events occur: (1) the transmission is removed from the park position, (2) the brake pedal is depressed, (3) the engine overspeeds or overheats, or (4) the hood is raised. In addition, the device will not start the engine if the transmission is in forward or reverse gear. The device automatically shuts off the engine after 12 to 14 minutes running time and allows remote shut-off at any time.; Standard No. 114 requires that passenger cars as well as trucks an multipurpose passenger vehicles with a gross vehicle weight rating of 10,000 pounds or less have a key locking system. When the key is removed, the system must prevent normal activation of the vehicle's engine and prevent either steering or forward self-mobility or both. You state that starting a vehicle with your device does not permit normal activation of the vehicle's engine and either forward motion or steering until the key is inserted into the ignition and turned to the on position. Therefore, the question is whether your device, which permits activation of the engine when the ignition key is removed, permits 'normal activation' of the vehicle.; In previous interpretations, the agency has determined that automotiv remote starting devices with characteristics similar to yours were outside the concept of 'normal activation.' These characteristics have included automatic deactivation of the remotely started engine when a vehicle door is opened, maintenance of the steering column or gear shift locking feature until the ignition key is inserted in the vehicle, and automatic deactivation of the remotely started engine after 15 minutes unless the key is inserted into the ignition.; Your device apparently has some of these same characteristics, as wel as other automatic deactivation features which are comparable in nature. Therefore, we conclude that your device does not conflict with the requirements of Standard No. 114, since it does not permit normal activation of the engine without the ignition key.; Although not related to compliance with Standard No. 114, the agency i concerned about the possibility that a child could accidentally press the transmitter button on your device and, thus, start a car by remote control. This situation could clearly raise safety problems. Therefore, we suggest that you add language to the purchasers' instructions making them aware of this possibility and urging them to take precautions to avoid use of the product by anyone who is not authorized to drive the car.; I hope this information is helpful to you. Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam1904

Dear Mr. Nakajima: This is in response to your letter of March 17, 1975, requestin clarification of the requirement and demonstration procedure for sliding doors specified in Federal motor vehicle safety standard No. 206, *Door Locks and Door Retention Components*.; You have indicated that it is your understanding that derailment of th guide roller or track and slide combination is permissible under Standard No. 206 as long as door stoppers and door locks withstand the specified transverse load. This interpretation is correct. Standard No. 206 requires in S4.3 that the track and slide combination *or other supporting means* for each sliding door not separate when a transverse load of 4,000 pounds is applied, with the door in the closed position. Since the track and slide combination is not designed to bear loads at the closed position, derailment of the combination is of no consequence. Other supporting means must support the test load.; You have also outlined three demonstration procedures and asked whethe they 'fall within the intent' of S5.3 of Standard No. 206. While all three procedures might satisfy the literal requirements of S5.3, procedure 'C' most thoroughly implements the intent of Standard No. 206.; The bench test fixture described in 'A' is particularly troublesome. O the Toyota vehicle in question, resistance against a transverse load applied at the leading edge appears to depend heavily on the lock at the trailing edge. Since the resistance of this lock must be transmitted to the leading edge stoppers through the door itself, the door plays an important role in the performance of the entire system. Yet the rigid door described in 'A' would almost certainly behave differently than an actual door, in which case the test results would not demonstrate compliance with S4.3.; A similar problem exists with regard to procedure 'B', in that th rigid pillar employed might provide much more resistance to bending than the actual vehicle pillar. Bending of the pillar at the door's leading edge would substantially lessen the resistance to opening provided by the stoppers (B & C in your Fig. 1).; Standard No. 206 does not set out separate requirements for every doo design. Indeed, this standard was adopted in anticipation that most sliding doors would incorporate a track- and-slide combination as a supporting means. Where a different design is employed, as in this instance, procedure 'C' best fulfills the intent of the standard by providing the most authentic demonstration.; Please do not hesitate to write if we can be of further assistance. Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: 10-000638_Bradley_trailer_tail2

ID: aiam1595

Dear Mr. Mueller:#Thank you for letter of August 14, 1974, pointing ou a discrepancy in the constriction test requirements for hydraulic brake hose found in Federal Motor Vehicle Safety Standard No. 106-74.#We are considering a change in out nest notice concerning Standard 106-74, so that S6.7.2(c) will conform with S5.3.1 as that paragraph was amended by Notice 11 (39 F.R. 24012).#Yours truly,Richard B. Dyson,Acting Chief Counsel;

ID: aiam0599

Dear Mr. Nishibori: This is in reply to your letter of February 7, 1972, in which yo stated your understanding of how Standard 210 applies to two shoulder belt assembly configurations.; In Figure 1, you show a shoulder belt that passes through a slotte plate (A) bolted to the roof rail. Contrary to the impression you have received, the plate is not a part of the anchorage, but is rather a part of the seatbelt assembly. The anchorage consists of the reinforced roof rail structure, including the bolt hole and any retaining ridges or projections on the roof rail. Plates such as Hardware (A) that bolt onto the roof rail are similar in function to the floor mounted attachment plates that have always been considered as part of the seatbelt assembly, and are similarly treated.; The same remarks apply to the plate shown as (B) in Figure 2. This i also a part of the seatbelt assembly, and not part of the anchorage.; The anchorage strength test should be conducted as you show in Figure 3 and 4, using the complete Type 2 assembly provided with the vehicle.; We regret the misunderstanding about the classification of th attachment hardware and hope that it has not caused you inconvenience.; Yours truly, Richard B. Dyson, Assistant Chief Counsel