ID: aiam2665

Dear Mr. Hildebrandt: This is to advise you that the National Highway Traffic Safet Administration (NHTSA) has decided to grant The Bendix Corporation's September 14, 1977, petition requesting the revision of the parking brake release requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 121, *Air Brake Systems*. A similar petition was received from Fruehauf Corporation and it is also being granted.; You should understand that our commencement of a rulemaking proceedin does not signify that the rule in question will be issued. A decision to the issuance of the rule will be made on the basis of all available information developed in the course of the rulemaking proceeding, in accordance with statutory criteria.; You also requested written confirmation that the interpretation o S5.6.3 of FMVSS No. 121 given by NHTSA to Motor Coach Industries, Inc. on April 14, 1976, would pertain to the air/spring parking brake system described in your letter. Your assumption is correct, and this letter constitutes such written confirmation.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: aiam0981

Dear Mr. Monk: This is in further response to your letter of January 5, 1973, to Mrs Virginia Knauer, regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 125, *Warning Devices*.; As you already know from Mr. E.T. Driver's letter of January 24, 1973 and previous correspondence from my office and the Department of Transportation, the National Highway Traffic Safety Administration issued the standard as an equipment item that would be suitable for use in all types of vehicles, from trucks to passenger cars.; In issuing the standard, we were concerned with the great variety o devices presently available, which can create confusion and misunderstanding to the motoring public. We were also concerned with wind stability, and your comments were most useful in our consideration of this aspect of the requirements. FMVSS No. 125 is an attempt to achieve a standardized device having a proper balance of the factors affecting shape, size, cost, visibility, wind stability and weight. These are minimum standards and the manufacture and sale of devices that exceed these requirements is not prohibited.; Again, thank you for your comments. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: aiam3788

Dear Mr. Schmitt: This is in response to your letter asking for an interpretation on th permissibility of using two type 2A1 headlamps mounted symmetrically disposed about the vertical centerline of the motorcycle.; Federal Motor Vehicle Safety Standard (FMVSS) No. 108, 'Lamps Reflective Devices, and Associated Equipment (sic) states in S4.1.1.34 that a motorcycle may be equipped with one of the following headlamp systems, one of which is the 'A' type headlamp system described as follows:; >>>Type 1A1 or Type 1A . . . . 1 lamp and either Type 2A1 or Type 2A . . . . 1 lamp<<<< The standard is specified this way because the 2A1 lamp is a lower bea lamp and the 1A1 is an upper beam lamp. While the 2A1 lamp does have an 'upper beam', photometrically it provides only 'fill-in' light. The 1A1 lamp provides the high output upper beam. It is not possible to achieve safe upper beam light using only the 2A1 lamp, regardless of how many are used. Therefore, your proposed headlighting application would not be permitted by FMVSS No. 108.; Sincerely, Barry Felrice, Acting Associate Administrator for Rulemaking

ID: nht72-3.12

DATE: 06/09/72

FROM: ELWOOD DRIVER FOR ROBERT L. CARTER -- NHTSA

TO: S.P.A. Carrozzeria Pininfarina

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 25, 1972, inquiring about the applicability of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, and FMVSS No. 302, to the rear windows of convertible cars.

In FMVSS No. 302, the convertible top is not intended to refer to the rear window, but has reference only to the overhead material. Flammability of the transparent glazing material is regulated by FMVSS No. 205.

ID: aiam4121

Dear Mr. Ogura: This responds to your request for an interpretation concerning th reservoir strength requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 121, *Air Brake Systems*. You asked how those requirements apply to multi- chamber reservoirs.; By way of background information, the National Highway Traffic Safet Administration does not give approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to certify that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.; The issue raised by your letter concerning the application of FMVSS No 121's reservoir strength requirements to multi-chamber reservoirs appears to be the same issue discussed in a letter of interpretation dated May 23, 1978, addressed to the Johnson Manufacturing Company. As discussed in that letter, only the circumference of the outer reservoir shell is measured, and internal baffles are not stressed by separate compartment-by- compartment testing. We are enclosing a copy of that letter and two *Federal Register* notices cited by the letter. (Please note that an interpretation provided in the earlier of the two notices was withdrawn by the later notice.); Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam3532

Dear Mr. Ziwica: This responds to your letter asking several questions about the use o informational readout displays in relation to FMVSS 101-80 *Controls and Displays*, 105 *Hydraulic Brake Systems* and 208 *Occupant Crash Protection*.; Each of your questions assumes the use of informational readou displays as telltales. The light intensity requirements of Standard No. 101- 80 currently prevent informational readout displays from being used as telltales. Section 5.3.3 of the standard requires that informational readout displays must have at least two light intensity values, a relatively high one for daytime use and a relatively low one for nighttime use. The same section requires that the light intensity of telltales shall not be variable. Since it is not possible for an informational readout display to simultaneously meet both requirements, such a display cannot be used as a telltale.; The agency has recently issued a notice of proposed rulemaking (NPRM that would permit informational readout displays to be used as telltales. We have enclosed a copy of that notice.; I would like to point out the following statement in the NPRM: >>>Various amendments may be necessary to Standard No. 101-80, as wel as to several other safety standards which include requirements for warning indicators, to permit fuller use of informational readout displays. The amendments proposed by this notice are a first step in that direction.<<<; We would welcome any comments that you might have on this matter t assist us in future rulemaking. You may also wish to consider submitting a petition for rulemaking on any changes that you believe should be made.; The following discussion explains the effect that the proposal woul have on your questions.; *Question 1* Your first question asks whether the words 'Fasten Seat Belts' may b used in an informational readout display instead of the seat belt warning symbol under FMVSS 101-80 and 208.the answer would be yes under the proposal. The NPRM states:; >>>Sections S4.5.3.3(b) and S7.3 of S571.208 would be amended to permi the words 'Fasten Belts' or Fasten Seat Belts' as an alternative to the seat belt warning symbol in informational readout displays.<<<; *Question 2* Your second question concerns the possibility of allowing cancellatio of telltales by voluntary action on the part of the driver. The question asks whether it is permissible to provide a push button that enables drivers to cancel telltales. The answer to this question, which is not dealt with in the NPRM, is no.; While the question is asked separately for the seat belt telltale an telltales not required by any safety standard in the first place, the answer is not dependent of that distinction. Section S5.3.3 of Standard No. 101-80 requires that the light intensity of each telltale shall not be variable and shall be such that, when activated the telltale and its identification are visible to the driver under all daytime and nighttime conditions. We interpret this section to mean that a telltale cannot be cancellable. If it were cancellable, the telltale would not meet requirements that it not be variable and that it be visible to the drive under all daytime and nighttime conditions.; We note that the activation requirements for the seat belt telltal depend on whether it is for a manual belt or automatic belt. For a manual belt, section S7.3 of Standard No. 208 states that the seat belt assembly provided at the driver's seating position must be equipped with a warning system that activates for a period of not less than 4 seconds and not more than 8 seconds a continuous or flashing light. Thus, while a manufacturer has the discretion to provide an activation time of between 4 and 8 seconds, the telltale still may not be cancellable.; Section S4.5.3.3 requires a different type of warning system fo automatic belts. While the audible signal must be activated for a period of not less than 4 seconds and not more than 8 seconds, the visual warning light must be activated for as long as the belt is not fastened.; *Question 3* Your third question asks whether it is permissible to use a information readout display to meet the visual brake warning system requirements of Standard NO. 105. The answer would be yes under the proposal.; Section S5.3.5 of Standard No. 105 states: >>>Each indicator lamp shall have a lens labeled in letters not les than 1/8-inch high, which shall be legible to the driver in daylight when lighted. The lens and letters shall have contrasting colors, one of which is red....<<<; It is our interpretation that the illuminated pattern of letters an glazing of an information readout display would constitute a 'lens labeled in letters.' This interpretation leaves unanswered other questions about whether a particular informational readout display would meet other requirements of Standard No. 105, such as the color requirement of section S5.3.5.; *Question 4* Your fourth question asks whether an informational readout displa specifying specific brake problems constitutes separate indicator lamps under the language of Standard NO. 105, if a brake warning lamp is present which separately fulfills the requirements of S5.3.5 of Standard No. 105. The answer is no.; Section S3 of Standard No. 105 specifies various performanc requirements for brake system indicators lamps. Under section S3.5, a manufacturer may meet the requirements either by a single common indicator or by separate indicator lamps.; It is our interpretation that if a manufacturer separately meets th requirements of section S3 by a single common indicator lamp, additional indicator lamps that are added voluntarily by the manufacturer are not subject to Standard No. 105's requirements.; *Question 5* Your fifth question asks about the requirements for an informationa readout display which is a telltale. The NPRM proposes the following language:; >>>S5.3.3.2 Telltales and gauges incorporated into informationa readout display--<<<; >>>(a) Shall have not less than two levels of light intensity, a highe one for day and a lower one for nighttime conditions.<<<; >>>(b) In the case of telltales and gauges not equipped with a variabl light intensity control, shall have a light intensity at the higher level provided under paragraph (a) of this section whenever the headlamps are not illuminated.<<<; >>>(c) In the case of telltales and gauges equipped with a variabl light intensity control, shall be visible to the driver under all daytime and nighttime conditions when the illumination level is set to its lowest level.<<<; The agency does find the system that you are considering developin very interesting. If you do submit a petition for rulemaking, there is one issue that we would appreciate your addressing. Our initial reaction to the idea of permitting drivers to cancel telltales is one of concern, since drivers might either cancel a telltale inadvertently or simply forget that they have done so. An informational readout display which flashed its warnings in sequence might answer those concerns. We would appreciate your addressing the safety consequences of those and any other alternatives that your might be considering.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0655

Dear Mr. Walters: Thank you for your letter of March 7, 1982, requesting the lates information regarding Federal Motor Vehicle Safety Standard (FMVSS) No. 301, clarification of 'leakage' and comments regarding U.S. Patent No. 3,610,263.; An amendment to FMVSS No. 301 will be issued in the near future i response to the Notice of Proposed Rule Making published earlier, 35 F.R, 13799. The substance of this action involves extending the scope of the rule as indicated in the Notice, but the details of the final amendment will not be disclosed before issue. A copy of the Notice is enclosed.; Paragraph S4.4 does not mention leakage but refers to fuel spillag which is defined in S3. There is no assurance that this proposal will remain intact in the final rule since the comments from the industry, continued research, and development work, and many other inputs will influence the course of this rule making.; We are not in a position to comment of the features of any particula device, since our concern is primarily with performance requirements in order to permit originality and choice of different means for design of improved performance. We appreciate the information about your patented fuel tank safety valve assembly, and shall place a copy of this patent in our Docket No. 70-20. This docket is a public file to receive information and comments on matters pertaining to the rule making action on fuel system integrity.; We appreciate you interest in motor vehicle safety. Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs;

ID: aiam2474

Dear Mr. Quie: This is in reply to your letter of December 15, 1976, regarding complaint by Mr. Russ Fink, that tires marked within a certain size classification are not uniform.; Mr. Fink's letter does not report any actual tire dimensions and doe not fully explain the age of his tires, the amount of treadwear, the type of tread pattern, inflation pressures, and the width of the rims when he was making his measurements. All of these factors have an effect on tire size matching, and must be considered in making dimensional comparisons.; Contrary to Mr. Fink's claim, tire manufacturing is carefull controlled to meed rigid dimensional requirements. These requirements are a part of our Federal Motor Vehicle Safety Standards (FMVSS) No. 109 for new passenger car tires, No. 119 for other new motor vehicle tires, and No. 117 for retreaded passenger car tires. A copy of each is enclosed . Every effort is made in our standards enforcement program to assure that manufacturers and retreaders comply with the specified dimensional requirements.; Referring to the tables in Appendix AS of FMVSS No. 109, Mr. Fink ca see that there are differences is specifications for the three tires he mentions:; Tire Rim Max. Load Section Min. Size Size Width at 24 psi Width Facto H78-15 6'' 1450 8.55 36.50 7.60-15 5-1/2'' 1450 7.90 36.05 8.55-15 6'' 1510 8.45 36.57; In purchasing new or retreaded tires from a tire dealer, consumers ar entitled to dimensions held within specified tolerances, and when tires are found to exceed these tolerances we would appreciate being notified so that we may initiate investigation.; Sincerely, John W. Snow, Administrator

ID: aiam3199

Dear Lieutenant Dale: This is in response to your letter of January 24, 1980, asking whethe Federal motor vehicle safety standards prevent the installation of aftermarket trailer hitches in a manner which diminishes the damage resistance performance of the vehicle bumper. Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act (Safety Act) (15 U.S.C. 1397(a)(2)(A)) provides that,; >>>'No manufacturer, distributor, dealer, or motor vehicle repai business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard,...'<<<; However, Federal motor vehicle safety standard (FMVSS) 215, Exterio Protection, applicable to vehicles manufactured between September 1, 1972, and September 1, 1978, permitted the removal of trailer hitches prior to testing for compliance with the regulation (49 CFR S571.215, S6.1.5). Therefore, installation of a trailer hitch on such a vehicle would not be considered to have rendered the vehicle's bumper system inoperative.; Similarly, the Part 581 bumper standard, which replaced FMVSS No. 21 for vehicles manufactured on or after September 1, 1978, provides for removal of trailer hitches prior to testing (49 CFR S581.6(a)(5)). The installation of a trailer hitch which impairs the damage resistance performance of a bumper is then not prohibited by Federal bumper regulations.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam5335

Dear Mr. Freund: This responds to your letter addressed to th attention of Walter Myers of my staff in which you asked whether Table II of Federal Motor Vehicle Safety Standard (FMVSS) No. 119, New pneumatic tires for vehicles other than passenger cars, contains certain errors. You pointed out in your letter that Table I of FMVSS 119 specifies a plunger diameter of 5/16 inch for motorcycles, and 3/4 inch for 12-inch or smaller rims other than motorcycles. Table II, on the other hand, leaves blank the plunger diameter space in the motorcycle column, but lists 5/16 inch plunger diameter in the 12-inch or smaller rim column. You indicated your belief that the inconsistency is due to a typographical error in those columns of Table II and asked us to confirm your interpretation. Your observation is correct. A November 13, 1973 rule adopting Tables I and II (38 FR 31299) (copy enclosed) specifies the 5/16-inch diameter plunger for motorcycle tires, and the 3/4-inch diameter plunger for 12-inch or smaller tires and 17.5-inch or smaller light truck tubeless tires. Accordingly, the plunger diameter for the motorcycle column in Table II should read 5/16. Similarly, the 12-inch or smaller column in the current Table II is in error in specifying a plunger diameter of 5/16 inch. The correct plunger diameter for that column in Table II should be 3/4 inch to correspond with the plunger diameter specified for 12-inch or smaller rims in Table I. Thank you for bringing this error to our attention. The agency will issue a correction to avoid any further confusion. Sincerely, John Womack Acting Chief Counsel;