ID: aiam2931

Dear Mr. Gerth:#This is in response to your letter of November 27 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, *Controls and Displays*. Specifically, you asked whether it is permissible to use symbols for the parking lamp functions of the headlamp switch, in addition to the headlamp symbols required in Table I of the Standard.#The answer to your question is yes. Section 5 of the standard states that each passenger car 'with any control listed in S5.1 or in column 1 of Table 1, ... shall meet the requirements of this standard for the location, identification, and illumination of such control or display.' Since no symbols or other designations are required under the standard for parking lamps where their control is not combined with that for headlamps or for 'lamps-off' positions on controls, it is up to the manufacturer whether to label these additional functions and whether to use words or symbols. Footnote 2 of Table 1 of the standard does provide that a manufacturer must use the single headlamp symbol to designate several functions when clearance, identification, parking and/or side marker lamps are all controlled with the headlamp switch. This footnote was not intended to preclude additional symbols for these other functions, however. In fact, S5.2.1 provides that 'additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity.'#Regarding your drawings, clearance lamps are listed in paragraph S5.1 and in column 1 of Table 1 of the standard. Therefore, they must be identified by the symbols shown in column 3 of Table 1 or by the words 'Clearance Lamps' or 'Cl Lps'. The 'parking right and left' symbol shown on the drawing submitted with your letter would not satisfy the requirements for clearance-lamp designations. However, the symbol labeled 'Clearance Lamps' that appears on the drawings which Mr. Gebhard M. Hespeler and Mr. Craig Jones submitted on December 20, 1978, would conform with the requirements. I have enclosed a copy of that drawing.#If you have any further questions, please do not hesitate to write.#Sincerely, Joseph J. Levin, Jr., Chief Counsel;

ID: aiam0768

Dear Mr. Petler: This is in response to your letter of July 11, 1972, asking whethe Suzuki switches 577-2 and 577-5 comply with the headlamp beam operational requirements of Standard No. 123.; We assume that the letters 'L' and 'H' on each switch means 'low beam and 'high beam' respectively. Each switch has two positions, the upper on each marked 'L' and the lower marked 'H'. Standard No. 123, as you have noted, requires that a headlamp beam control switch provided an upper beam by pushing up, and a lower beam by pushing down. You have commented that 'in their current state of design these headlamp beam switch functions are the opposite as specified in Standard No. 123.'; Thus, as you appear to have surmised, switches 577-2 and 577-5 do no meet the headlamps beam operational requirements of Standard No. 123.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam0064

Dear Mr. Tate: Thank you for your letter of December 19, 1967, to the National Highwa Safety Bureau, in which you request information governing vehicle width and safety glass installation requirements on the vehicles you manufacture.; Regarding your question on vehicle width, Safety Standard No. 108 relative to lamps, reflectors and associated equipment, for specified vehicles 80 or more inches wide overall, defines the term 'overall width' as the nominal design dimension of the widest part of the vehicle, exclusive of signal lamps, marker lamps, outside rear view mirrors, flexible fender extensions and mud flaps, determined with doors and windows closed and the wheels in the straight ahead position. Therefore, if your vehicle measures less than the Safety Standard No. 108 requires, compliance is not required.; Your question regarding installation of safety glass as specified b Safety Standard No. 205, relative to Glazing Materials, can be answered by directing your attention to Standard No. 205. It specifies adherence by a multi-purpose Passenger Vehicle, a category into which your pick-up campers fall. A copy of the Federal Register, Volume 32, No. 23 and amendment to this regulation, Volume 32, No. 131, is enclosed for your information.; The application of Safety Standard No. 205 to pick-ups, is covered b the enclosed Federal Register, Volume 33, No. 59.; Thank you for your cooperation and response to the Federal Highwa Administration request regarding the certification requirement.; The label sample and information as to its location that you hav provided will be very useful to us, however, in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with the serial identification system in order that vehicles manufactured (completed) after January 1, 1968, can be identified.; Your interest in the safety program of the Bureau is appreciated. Sincerely, Joseph R. O'Gorman, Acting Director, Office of Performanc Analysis, Motor Vehicle Safety Performance Service;

ID: aiam3116

Dear Mr. Pepe: This responds to your recent letter concerning the testing procedure specified in Safety Standard No. 209, *Seat Belt Assemblies*. Specifically, you ask about the proper sequence of requirements and testing procedures provided in paragraphs S4.3(j), S4.3(k), S5.2(j) and S5.2(k).; Paragraph S4.3(j) provides that a retractor must meet certai requirements when tested in accordance with S5.2(j). Compliance with this paragraph should be determined initially. Then, paragraph S4.3(k) provides that the same retractor must be able to comply with S4.3(j) after being tested in accordance with S5.2(k), except that the retraction force is only required to be 50 percent of its original value. This original value was determined, of course, during the compliance procedure of S5.2(j). Therefore, the first interpretation included in your letter is correct.; Sincerely, Frank Berndt, Chief Counsel

ID: nht68-1.6

DATE: 10/23/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: FWD Corporation

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of October 4, 1968, in which you inquired about the acceptability of affixing a "paper type nameplate" to the cab door glass of partially completed chassis-cab trucks.

I assume that you are referring to the requirement for certification of conformity with Federal Motor Vehicle Safety Standards under the National Traffic and Motor Vehicle Safety Act of 1966. The Federal Highway Administration has recently issued a notice of proposed certification regulations, a (Illegible Words) of which is enclosed. While of course this proposal may be (Illegible Word) 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 question, the proposed regulations do specify in @ 275.5 that a label be affixed to a window of a chassis-cab. No material is specified, so paper or similar material will be satisfactory under this proposal. You will note that the proposed requirements differ in several respects from the drawing that you submitted with your letter. At least twelve-point type is required, which has capital letters of approximately 1/8 inch; the place of manufacture must be specified; and the statement restricting use must conform substantially with item (e) of that section.

We are pleased to be of assistance.

ID: aiam5282

Dear Ms. Norris: This is in reply to your letter of December 1, 1993 to Robert Hellmuth of this agency. You have written us questioning the disconnection of your original equipment center highmounted stop lamp when an aftermarket spoiler with lamp was installed on your Honda. American Honda has referred you to us, referencing an interpretation by our former Chief Counsel, Paul Jackson Rice. I enclose a copy of Mr. Rice's letter of August 31, 1990, to David Holscher which sets forth the agency's views on this subject. These views remain our position. The disconnecting of your lamp appears permitted under Federal Motor Vehicle Safety Standard No. 108 according to this interpretation. Because Federal authorities do not interpret the laws of the individual States, we are unable to comment on the Louisiana provisions that you paraphrase, except to note that 'tail lights', as you refer to them, are not 'stop lamps' under Standard No. 108. Taillamps are another item of lighting equipment and have no relevance to the wiring of the center highmounted stop lamp. Sincerely, John Womack Acting Chief Counsel Enclosure;

ID: nht71-4.13

DATE: 09/18/71

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

TO: Meiji Rubber & Chemical Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: RE: HYDRAULIC BRAKE HOSE ASSEMBLIES

This is in reply to your letter of September 3 asking questions about compliance of hydraulic brake hose assemblies with Federal Motor Vehicle Safety Standard No. 106.

With respect to your first two questions, the National Highway Traffic Safety Administration does not require that you demonstrate compliance with Standard No. 106 prior to supplying Japanese car manufacturers with brake hose assemblies to be installed on cars intended for export to the United States. If the Japanese vehicle manufacturers request proof of compliance from you (apparently in the form of a certification from the Commonwealth of Pennsylvania based upon test reports from only one of two test laboratories) such a request is solely a business matter between you and the vehicle manufacturer.

Your third question points out that proposed Standard No. 106 (Docket No. 1-5, Notice 7) would eliminate the specification of braid material for hydraulic brake hoses and asks whether you may implement this "revision" at the present time. Notice 7 is a proposal only, and the current requirements specifying braid material remain in effect until a formal amendment of Standard No. 106 occurs. The brake hose manufacturer's code number, the subject of your fourth question, is also a proposal which may or may not be adopted in the final rule.

ID: nht76-1.43

DATE: 06/23/76

FROM: AUTHOR UNAVAILABLE; T. W. Herlihy for S. P. Wood; NHTSA

TO: Little Dude Trailer Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your March 26, 1976, letter concerning the certification label requirements in S5.3 of Federal Motor Vehicle Safety Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.

You have pointed out that the example shown in S5.3 presents rim, inflation, and maximum speed information after the Gross Vehicle Weight Ratings (GVWRs) as well as after the Gross Axle Weight Ratings (GAWRs). You have suggested that the text of S5.3 merely requires such information to appear after the GAWRs and urged such an interpretation. It appears that you have misunderstood the text.

In its present form, S5.3 requires each listed GVWR and GAWR to be followed by the information specified in paragraphs S5.3(a) through (d). Paragraph (a) is divided into subparagraphs (a)(1) and (a)(2) in order to specify different items to follow GVWR and GAWR, respectively. Paragraphs (b) through (d) (which specify rim, inflation, and maximum speed information) are not subdivided because the same items are intended to follow GVWR and GAWR.

Several petitions for reconsideration of the standard have requested an amendment of S5.3 to eliminate the requirement that tire and rim information appear after the GVWR. Your suggestions on this matter, as well as the other suggestions in your letter, are being considered by the National Highway Traffic Safety Administration in the preparation of its response to those petitions.

Please note that the effective dates of several of the standard's requirements, including that of S5.3, were delayed in a Federal Register notice published on May 6, 1976 (41 FR 18659; Docket No. 71-19, Notice 4). A copy of that notice is enclosed for your convenience.

YOURS TRULY,

little dude TRAILER COMPANY, INC.

March 26, 1976

James B. Gregory Administrator National Highway Traffic Safety Administration Department of Transportation

Re: Safety Standard 120

We have some questions and comments regarding the subject standard. On page 3480 (S5.3) you cover the requirements of the certification label. Part (a) (1) states, "After GVWR, the size designation of tires appropriate as a minimum for the GAWR's corresponding to that GVWR." Paragraph (a) (2) then goes into GAWR which is to be followed by (b), (c), and (d) as well as the appropriate tire size. On the surface, it appears that the GVWR is to be followed only by tire size; yet, your example shows it (GVWR) followed by everything, even though it is a duplication, that follows GAWR. Which is correct? If the example is correct, why should rim size, cold inflation, and maximum speed be repeated since they obviously must be the same?

Now, as to your discussion of the comments. On page 3478, 3rd column, 2nd paragraph, you state that the commentors pointing to the large number of possible combinations making the decal too large and confusing are not correct because they fail to fully understand the rule. We have no doubt that this is true on the comprehension part; but we cannot possibly see how rim designation, tire inflation, and maximum speed can be of any possible use to the consumer when the tires on the vehicle need not be listed. We hope that people do not apply this info in servicing, driving, or replacing a larger size tire than appears on the decal. The obvious question is, if these items don't have to apply to the tires on the vehicle, what good are they?

We feel that the comments about the size of and confusion on the decal definitely are pertinent to boat trailers even if not pertinent to cars and trucks. We are limited in size (3" to 5") for vertical decal expansion; consequently, we can only go horizontally to add the new information. Since some decals encompass as many as 4 GVWR's and GAWR's (8 on a tandem) we could very easily have one whole side of the trailer which would require no paint. What you failed to realize in your comment interpretation is that 99% of the changes in tires on boat trailers are made to change capacities; therefore, your answer that the law does not require the listing of more than one tire size is just not applicable to trailers. The changing of tires changes both the GVWR and the GAWR which adds all of your additional information in as much as fourfold for GVWR and up to eightfold on GAWR for a tandem. Some trailer manufacturers even go as far as 3 axles. The only alternative to this horrendous decal that no one could read or understand is a separate one for each capacity trailer. This alternative would be utter chaos for the Marine Industry and any other trailer shipped in a knocked down condition. When the same frame has up to 4 different running gear and load capacity combinations there is no assurance that our assembly people will be able to distinguish which decal goes with which running gear. Needless to say, the people putting trailers together for a dealer will never get them right or even care. The inventory duplication will be impossible for the manufacturer and his customers.

For once, why can't trailers be excepted from the laws governing cars and trucks? They are entirely different both in type and use. Between the lighting, decal, new warranty requirements, and cutting of tire capacities, we are fast protecting the consumer fully. Since all these costs must be passed on, the consumer will soon be unable to afford a trailer; hence, full protection because no one will have one.

No Marine Dealer or consumer that we have talked to knows or cares what GVWR and GAWR means. Furthermore, most trailer manufacturers buy their wheels and tires mounted. The rim information is to be on the wheel, capacity and inflation pressure are on the tires, and the over-the-road speed limit is 55 MPH. Aren't these items enough? They are certainly a safer guide than the decal information which you admit may or may not apply to the tires on the trailer. The only problem would be a disreputable tire or trailer manufacturer mounting a high capacity tire on a lower capacity rim. The trailer manufacturers that would do this aren't legal on lights and decal (some don't even have one) now; so, they won't be affected anyway, and the tire companies simply can't afford to run that kind of risk. This will be just another means of making reputable manufacturers less competitive with our already illegal "backyard" competitors. They never even paid their excise tax and certainly aren't worried about a decal.

Please advise:

1. Whether the example or the language is correct,

2. If we have misinterpreted anything,

3. If there is any way trailers, can be excluded from the new decal requirements.

Richard L. Rogers President

cc: CHUCK VERRILL; JEFF NAPIER

ID: aiam0022

Dear Mr. Phelps: In response to your letter of May 12, 1967, regarding th classification of your Blue Bird Wanderlodge, I have enclosed a copy of the Initial Federal Motor Vehicle Safety Standards. On page 2408 of this document, 'Bus' is defined as a motor vehicle with motive power, except a trailer, designed for carrying more than 10 persons. With the assumption that your Wanderlodge does have seating capacity for more than 10 people, it would therefore be classified as a bus.; Thank you for your interest in the motor vehicle safety program of thi Bureau.; Sincerely yours, George C. Nield, Acting Director, Motor Vehicle Safet Performance Service;

ID: 7763

Ms. Mindy Lang
Division Manager
Huntleigh Transportation Services Inc.
#12 Millpark Court
Maryland Heights, MO 63043

Dear Ms. Lang:

This responds to your letter of September 12, 1992, requesting information on regulations concerning bus conversions. Your company converts the interior of buses by installing such materials as carpets, wall coverings, and blinds. In particular you asked for information on regulations concerning the attachment of seats to vehicles and the material used for the construction of seats. I am pleased to have this opportunity to explain our law and regulations to you.

The National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1381 et seq.) authorizes this agency to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) prohibits any person from manufacturing, introducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

NHTSA has exercised its authority to establish one safety standard relevant to seating, Standard No. 207, Seating Systems, which establishes strength and other performance requirements for vehicle seats. However, this standard excludes passenger seats on buses from these performance requirements. There is one other safety standard that could be affected by the work your company performs. Standard No. 302, Flammability of Interior Materials, specifies burn resistance requirements for materials used in motor vehicles, including buses.

If your company converts previously certified buses, it could be considered an alterer under our regulations. Under 49 CFR Part 567, Certification, an alterer is defined as:

A person who alters a vehicle that has been previously certified ... other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, ... before the first purchase of the vehicle in good faith for purposes other than resale ....

If considered an alterer, your company would be subject to the certification requirements of 49 CFR 567.7. These requirements include provisions that the alterer supplement the original manufacturer's certification label, which must remain on the vehicle, by affixing an additional label. The label must state that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards, including Standard No. 302. The label must also state the name of the alterer and the month and the year in which the alterations were completed.

Your company would not be subject to the certification requirements of 49 CFR 567.7 if the modifications involve only readily attachable components. However, the modifications would still be affected by section 108(a)(2)(A) of the Safety Act. That section provides that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle . . . in compliance with an applicable Federal motor vehicle safety standard.

Any violation of this "render inoperative" prohibition would subject the violator to a potential civil penalty of up to $1,000 for each violation.

I hope you find this information helpful. I have enclosed an information sheet for new manufacturers of motor vehicle equipment that briefly explains the responsibilities imposed on manufacturers, and tells how to get copies of the relevant laws and regulations. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosure ref:#207,#301 d:10/20/92