ID: aiam2452

Dear Mr. Milby: This is in response to your letter of November 3, 1976, in which yo ask whether the label Emergency Door' when placed on the glass near the top of a school bus emergency exit, complies with the requirements of Standard No. 217, *Bus Window Retention and Release*.; The positioning of this label will be regulated by S5.5.3 of Standar No. 217 in the case of school buses manufactured on or after April 1, 1977. That section, as it pertains to the location of the designation Emergency Door,' states in part that the designation shall be ...located at the top of or directly above the emergency exit...' The markings you describe, located at the top of the glass of the emergency door, would appear to be in compliance with the location requirements of S5.5.3 of Standard No. 217 (effective April 1, 1977).; Sincerely, Frank A. Berndt, Acting Chief Counsel

ID: aiam3565

Dear Mrs. Mitchell: The National Highway Traffic Safety Administration is pleased to lear that you want to install a high-mounted stop lamp on your 1978 Buick LaSabre. The two studies that the Administration funded, one with the Essex Corporation and the other with the Allen Corporation, indicated that rear end collisions could possibly be reduced by 50 percent with the use of a single high-mounted stop lamp. We do not know whether the States of New York or New Jersey will allow the use of these lamps. Our Office of Rulemaking contacted the American Association of Motor Vehicle Manufacturers (AAMVA) but the information we received was indefinite, and I would suggest that you contact your local State Police for a definitive answer. The agency has proposed that passenger cars be equipped with this system, and if the proposal is adopted, the lamps would be legal in all States.; As to where to locate these lamps on the car, our research showed tha a single lamp, placed on the rear vertical centerline of the vehicle and within the back window (either inside or outside) was the most effective position. Our research also included a system of two high-mounted lamps, mounted on either side of the rear window, apparently similar to the one you observed in upstate New York, however, this was not nearly as effective as the single lamp system in reducing rear end collisions.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0911

Dear Mr. Madigan: Your letter of October 30, 1972, to Mr. James H. Wakelin, Jr. regarding a flammability test cabinet, was forwarded to us for reply.; Federal Motor Vehicle Safety Standard (FMVSS) No. 302 specifies cabinet for flammability testing with the test specimens in a horizontal position. There is no FMVSS for a vertical test method. A copy of FMVSS No. 302 is enclosed.; Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: nht94-3.89

TYPE: INTERPRETATION-NHTSA

DATE: August 5, 1994

FROM: Bruce Monnie -- Senior Designer, ADVANCED DESIGN ASSOCIATES

TO: Chief Council, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO LETTER DATED 10/27/94 FROM PHILIP R. RECHT TO BRUCE MONNIE (A42; REDBOOK 6; STD. 208; STD. 209; STD. 213)

TEXT: We are going to be manufacturing a product that is used by consumers, to improve the security of childseats. I would like an interpretation from you, of Standards 209 and 213 or any other standards, that may apply. Below is a description of the how the product is to be used.

The product itself is one-piece steel construction, similar to the flat metal brackets included with some childseats already on the market. The bracket is installed on the seatbelt of the vehicle, to prevent slippage between the lap and shoulder port ions of the seatbelt and to tighten up slack in the lap portion of the seatbelt. It is a temporary installation that does not require any alterations to the vehicle, the seatbelt or the childseat. It does not render the seatbelt inoperative. It does n ot attach to the childseat nor does it interfere with the operation of the childseat. The consumer would be the user.

Our expectation is that this product does not fit the definitions as stated in 213, nor does it fall under 209. In the event that some other Standard may apply, I will give you additional information regarding the performance of the bracket. However , we cannot provide you with a drawing or picture of the product at this time.

Again, the bracket is one-piece with no moving parts. The design makes incorrect installation difficult; whether installed correctly or incorrectly, it cannot become a projectile. The strength required to remove the bracket is greater than the typic al 6 year old child would possess. There is no way for the bracket to be installed incorrectly that would impair or defeat the seatbelt. Incorrect installation would not increase slack in the seatbelt. The strength of the bracket itself, is engineered to withstand forces far beyond those occurring in vehicle accidents.

Furthermore, we will be submitting the product to actual crash-testing, to gather performance data. The results of the testing will be made available at a later date.

Please send me a letter stating your interpretation of Standards 209 and 213, as relating to the bracket. If you have any questions or if more information is needed for your interpretation, please contact me at (503) 235-9447. I am usually at my des k between 8am and 1pm, eastern time.

Thank you for your time in considering this request. Any effort on your part to expedite this matter would be greatly appreciated.

ID: aiam5152

Dear Ms. Dawson: This responds to your letter of March 5, 1993 askin if an exterior handle is required for emergency exit windows under the recent final rule amending Standard No. 217, Bus Window Retention and Release (November 2, 1992, 57 FR 49413). As explained below, the answer is no. The final rule added a new section S5.3.3.2 to Standard No. 217 which reads: each school bus emergency exit window shall allow manual release of the exit by a single person, from inside the passenger compartment (emphasis added). Thus, unlike doors and roof exits, a release mechanism is not required on the outside of emergency exit windows. 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, John Womack Acting Chief Counsel;

ID: aiam4051

Dear Senator Bentsen: Thank you for your recent letters to Administrator Steed on behalf o your constituent, Mr. Joe M. Rutland. I apologize for the delay in our response. Mr. Rutland asked why this agency requires safety warnings to be lithographically marked on brake fluid containers. He believes that this requirement causes undue hardship on small businesses that package brake fluid. I appreciate this opportunity to respond to Mr. Rutland's concerns and to clarify our requirements for brake fluid container labeling.; Some background information on NHTSA's authority to regulate in thi area might be helpful. The National Traffic and Motor Vehicle Safety Act of 1966 (the 'Vehicle Safety Act') authorizes us to promulgate motor vehicle safety standards for new motor vehicles and items of motor vehicle equipment, including brake fluid. Federal Motor Vehicle Safety Standard No. 116, *Motor Vehicle Brake Fluid* (49 CFR 571.116), has been in effect as a motor vehicle safety standard since the passage of the Vehicle Safety Act. In 1971, Standard No. 116 was amended to establish requirements for the labeling of brake fluid containers. The rule required certain safety information to be clearly and indelibly marked on each brake fluid container.; Brake fluid containers must be labeled with specific safety warnings in addition to other general information. The warnings serve as a safeguard against failures in hydraulic braking systems that might result from the use of improper or contaminated fluids. The warnings also help to prevent improper storage of the brake fluid which could contaminate the fluid or cause it to absorb moisture. Avoiding the absorption of moisture is extremely important since moisture in a brake system degrades braking performance and safety by lowering the brake fluid's boiling point, and increases possibilities of vapor lock and brake system component corrosion.; Thus, packagers of brake fluid have been required since 1971 to furnis the safety information clearly and indelibly on each brake fluid container. In response to a request for an interpretation of Standard No. 116 in 1984, NHTSA ruled that the use of labels affixed to brake fluid containers would not comply with the labeling requirements of the standard. However, Standard No. 116 does not mandate that lithography be used to mark the containers, as Mr. Rutland seems to believe. Any technology, whether lithography or otherwise, may be used if the resultant marking on a brake fluid container is clear and indelible and directly on the container itself.; The agency has recently been made aware of the concern that the 198 interpretation of Standard No. 116's labeling requirements may be causing undue hardship for packagers of brake fluid. In response to those concerns, we have been examining Standard No. 116 to assess its current labeling requirements.; I hope this information is helpful. Please contact my office if we ca be of further assistance.; Sincerely, Erika Z. Jones, Chief Counsel

ID: nht92-3.36

DATE: 09/30/92

FROM: EDNA SUTLIEF -- PROJECT CONCERN (ATCHISON, KANSAS)

TO: CHARLES GAUTHIER

TITLE: REQUEST FOR WRITTEN RESPONSE REGARDING USE OF SEATBELTS AND TIEDOWNS

ATTACHMT: ATTACHED TO LETTER DATED 11-13-92 FROM PAUL J. RICE TO EDNA SUTLIEF (A40; STD. 208; STD. 209)

TEXT: Mrs. Edna Sutlief at Project Concern in Atchison, Kansas has requested written response regarding the use of seatbelts and or the use of tiedowns in vans used for transporting disabled and senior citizens at Project Concern.

I spoke with Art Neill who confirmed for me that there are no Federal mandates which cover seatbelt use for handicapped Passengers in lift-equipped vans. Mrs. Sutlief would like something in writing stating this, because she has a driver who is refusing to drive a van unless all passengers are using seatbelts.

Since The state of Kansas mandates the use of seatbelts only in front seats, Mrs. Sutlief is concerned that she or the Project Concern staff will be in violation of Section 504 of the Rehabilitation Act if they insist on seatbelts or tiedowns for disabled passengers riding in the rear of vans. I suggested posting something in each van encouraging the use of belts for everyone, and agreed to speak with someone about her request for something in writing.

Because of ADA and increasing awareness of the need to treat all equally in facilities such as Project concern, calls of this nature will probably increase. The hotline staff should have more information on how to answer these

ID: aiam4369

Dear Mr. Faber: Thank you for your letter of April 16, 1987, concerning th requirements of Standard No. 208, *Occupant Crash Protection*. In particular, you asked for an interpretation of the requirements of S4.5.1 of the standard. I hope that the following discussion answers your question.; S4.5.1 of Standard No. 208 provides that each vehicle with a cras deployed occupant protection system must have a label setting out a manufacturer's recommended schedule for the maintenance or replacement needed to keep the performance of the occupant protection system at the level required by the standard. S4.5.1 further provides that 'the label shall be permanently affixed to the vehicle within the passenger compartment.' You explained that at the present time, you place the label for your air bag system on the glove box door. You further explained that you place all other important safety-related information, such as the certification label and tire information placard, on the latch post for the driver's door.; You stated that you want to relocate the air bag label from the glov box door to the latch post on the driver's side. You explained that one of the benefits of the new location is that it will establish a common location for the operator to quickly find important information. You said that the new location should remind vehicle operators of the replacement schedule since the tire pressure placard, which is routinely reviewed by the vehicle operator, is in the same location. Finally, you noted that dealership service personnel will be alerted to the replacement schedule since 'it is common practice for Service Writers to copy down the VIN from the certification label on the driver door latch post.'; NHTSA agrees that a label placed on the driver's latch post would mee the requirements of S4.5.1. The purpose of the location requirement is to place the replacement and maintenance schedule in a location that can be easily observed by the vehicle owner. Thus, the standard requires the label to be within the occupant compartment of the vehicle. The agency considers a label placed on the latch post, which is inside the exterior surface of the vehicle and is a part of the physical structure that constitutes occupant compartment, as meeting the location requirement. As you pointed out in your letter, the latch post is already used as a location for other important safety-related information about the vehicle.; If you have any further questions on this standard or need additiona information, please let me know.; Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam2998

Dear Mr. Black: This is in reply to your letter of March 12, 1979, to Mr. Vinson o this office asking for an opinion of whether a red rear fog lamp system would be permissible under Federal Motor Vehicle Safety Standard No. 108 as original equipment. This lamp system would be of the same intensity as the stop lamp system, installed in a separate compartment within the rear lamp assemblies. The system would have a separate switch and be operational only when the headlamp switch is in the 'on' position.; As you have noted, Standard No. 108 does not specify requirements fo either front or rear fog lamps. Lighting equipment supplementary to that required as original equipment may be provided at the manufacturer's option if it does not impair the effectiveness of any equipment installed in accordance with Standard No. 108 (S4.1.3). On the basis of your submission, we are unable to form an opinion whether your system would impair effectiveness with the meaning of S4.1.3. If it is Alfa Romeo's judgment that the red fog lamps will not impair the effectiveness of the taillamps, stop lamps, turn signal lamps or backup lamps, then you may have a reasonable basis upon which to install the fog lamp system and to certify compliance with S4.1.3.; Sincerely, Frank Berndt, Acting Chief Counsel

ID: aiam5405

Dear Herr Sandig: This responds to your FAX of June 6, 1994, to Mr. Va Iderstine of this agency, asking for an interpretation of Motor Vehicle Safety Standard No. 108. You present a drawing of a rear combination lamp incorporating one stop lamp and two taillamps. You have asked whether it is 'necessary that we must have the ratio 5:1/3:1 between the stop and the tail lamp measurements in this arrangement?' If the lamp is intended for use on narrower vehicles, the answer depends upon the distance between the optical axes of the stop and taillamp functions. SAE Standard J586 FEB84 Stop Lamps for Use on Motor Vehicles Less Than 2032 mm in Overall Width is incorporated by reference in Standard No. 108. Paragraph 5.1.5.3 of J586 is the source of the ratio: ' w hen a tail lamp is combined with the stop lamp, the stop lamp shall not be less than three times the luminous intensity of the tail lamp at any test point, except that at H-V, H- 5L, H-5R, and 5U-V, the stop lamp shall not be less than five times the luminous intensity of the tail lamp.' However, in a multiple compartment lamp such as yours, if 'the distance between optical axes for one of the functions exceeds the dimensions specified in paragraph 5.1.5.2 i.e., 560 mm the ratio shall be computed for only those compartments or lamps where the tail lamp and stop lamp are optically combined.' Although your combination lamp design combines the two functions, your drawing indicates that they are not optically combined, and the ratio will not apply if the optical axes are more than 560 mm apart. The ratio will apply if the distance between the optical axis of the stop lamp and that of either taillamp is 560 mm or less. SAE Standard J1398 MAY85 Stop Lamps for Use on Motor Vehicles 2032 mm or More in Overall Width is the standard incorporated in Standard No. 108 that applies to lamps used on wider vehicles. Its paragraph 5.1.5.2 establishes the same 5:3 ratio (though not including H-5L in the five times ratio), but does not provide an exception based upon spacing of optical axes. Thus, if your lamp is designed for wider vehicles, the ratio applies regardless of the spacing of the optical axes. Sincerely, John Womack Acting Chief Counsel;