ID: 15938.ztv

Tadashi Suzuki, Manager
Automotive Equipment
Legal & Homologation Section
Stanley Electric Co., Ltd.
2-9-13, Nakameguro, Meguro-ku
Tokyo 153, Japan

Dear Mr. Suzuki:

This is in reply to your letter of August 29, 1997, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108 as it applies to two possible arrangements of a motorcycle tail and stop lamp, which has more than three lighted sections.

Attachment 1 to your letter depicts the two rear lamp configurations. Attachments 2 and 3 are copies of correspondence in 1985 between Stanley and this Office asking similar questions about a combination rear motorcycle lamp with more than three lighted sections.

Since Chief Counsel Berndt's letter to Stanley, dated March 1, 1985, SAE Standard J586 FEB84 has replaced SAE Standard J586c, August 1970, as Standard No. 108's specifications for stop lamps for motorcycles. However, there is no substantive change between the two standards that affect the 1985 interpretation. SAE Standard J585e, September 1977, remains the Federal specification for motorcycle taillamps. As before, both standards prescribe requirements for lamps with three lighted sections but are silent as to requirements for lighted sections greater than three.

We have reviewed the paragraphs 3.1 and 4 of SAE Standard J585e, paragraphs 5.1.5.2 and 5.4.1 of SAE Standard J586, and S5.1.1.6 and S5.1.1.26(b) of Standard No. 108. These are the appropriate references cited in your letter that apply to this interpretations. In 1985, we informed you that Stanley's design for a lamp with four lighted sections "would be acceptable provided that each of the four compartments meets the minimum value specified for test points in a section when there are three lighted sections." We affirm that that 1985 interpretation remains our interpretation in 1997.

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.10/20/97

ID: nht94-2.36

TYPE: Interpretation-NHTSA

DATE: April 12, 1994

FROM: Christopher A. Hart -- Acting Administrator, NHTSA

TO: Doug Bereuter -- U.S. House of Representatives

TITLE: None

ATTACHMT: Attached to letter dated 3/9/94 from Doug Bereuter to Howard Smolkin

TEXT:

Thank you for your letter concerning a rulemaking related to compressed natural gas (CNG) vehicle fuel systems and fuel containers. You express concern about the time it is taking to complete the rulemaking.

I fully understand your concern over this matter and want to assure you that the agency is working diligently to reach a final decision. The supplemental notice of proposed rulemaking we issued in December 1993 was an essential step toward permitting the use of CNG containers that employ new technologies. We have now reviewed the comments received on this notice and are preparing the final rule. As agency representatives explained when they met with you in December 1993, the final rule will be reviewe d by the Office of the Secretary and the Office of Management and Budget.

I hope this information is helpful and appreciate your patience in this matter.

ATTACHMENT 12/3/93

Dear Congressman Doug Bereuter:

This is in response to your November 22, 1993, letter regarding the actions of the National Highway Traffic Safety Administration in regulating the safe performance of compressed natural gas motor vehicles and fuel containers. I understand that represen tatives of the National Highway Traffic Safety Administration are scheduled to meet with you during the week of December 6 to discuss the points you raised in your letter. I think that they will be able to address your concerns at that time; however, I' d be happy to talk with you further about this if necessary.

Sincerely,

Federico Pena

ID: nht94-6.40

DATE: April 12, 1994

FROM: Christopher A. Hart -- Acting Administrator, NHTSA

TO: Doug Bereuter -- U.S. House of Representatives

TITLE: None

ATTACHMT: Attached to letter dated 3/9/94 from Doug Bereuter to Howard Smolkin

TEXT:

Thank you for your letter concerning a rulemaking related to compressed natural gas (CNG) vehicle fuel systems and fuel containers. You express concern about the time it is taking to complete the rulemaking.

I fully understand your concern over this matter and want to assure you that the agency is working diligently to reach a final decision. The supplemental notice of proposed rulemaking we issued in December 1993 was an essential step toward permitting the use of CNG containers that employ new technologies. We have now reviewed the comments received on this notice and are preparing the final rule. As agency representatives explained when they met with you in December 1993, the final rule will be reviewed by the Office of the Secretary and the Office of Management and Budget.

I hope this information is helpful and appreciate your patience in this matter.

ATTACHMENT

12/3/93

Dear Congressman Doug Bereuter:

This is in response to your November 22, 1993, letter regarding the actions of the National Highway Traffic Safety Administration in regulating the safe performance of compressed natural gas motor vehicles and fuel containers. I understand that representatives of the National Highway Traffic Safety Administration are scheduled to meet with you during the week of December 6 to discuss the points you raised in your letter. I think that they will be able to address your concerns at that time; however, I'd be happy to talk with you further about this if necessary.

Sincerely,

Federico Pena

ID: nht79-4.19

DATE: 03/30/79

FROM: AUTHOR UNAVAILABLE; Michael M. Finkelstein; NHTSA

TO: Rubber Manufacturers Association

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of March 19, you pointed out that the tire industry has printed tire lables and consumer information materials based on Figure 2 of the Uniform Tire Quality Grading (UTQG) Standards (49 CFR 575.104), as published in the National Highway Traffic Safety Administration's (NHTSA) Docket 25, Notice 24 (43 FR 30542; July 17, 1978). That notice contained a typographical error in the text of Figure 2, which was corrected in Notice 31 (44 FR 15721, March 15, 1979) by substitution of the word "are" in place of the word "of" in the first line of the third section of Figure 2.

The labels and other materials printed prior to the issuance of Notice 31 may be technically in noncompliance with the UTQG regulation. To avoid the waste which would result if use of these materials were prohibited, however, NHTSA will permit use of tread labels and information materials containing the Figure 2 text as stated in Notice 24, where orders for printing of these materials were submitted prior to March 15, 1979, the date of publication of Notice 31.

ID: nht75-6.13

DATE: 04/01/75

FROM: AUTHOR UNAVAILABLE; A.G. Detrick; NHTSA

TO: Matlock Truck Body & Trailer Corp.

TITLE: FMVSR INTERPRETATION

TEXT: This is to respond to your letter of February 11, 1975, to Mr. Wolfgang Reinhart, concerning your defect notification letter in NHTSA campaign # 74-0203.

You believe that the second sentence in your notification letter properly determined that the defect existed in Matlock Model trailers. That sentence read, "Matlock Truck Body and Trailer Corporation has determined that a defect which relates to motor vehicle safety exists in the brake shoes of Standard Forge axles with 12 1/4 and 7 1/2 brake shoes on Matlock Model MTE (electronic trailers)." The NHTSA has consistently viewed a determination stated in this manner as relating to equipment (brake shoes) and not specifically to the vehicle. Matlock's determination should have been that the defect had been determined to exist in the described vehicles. We are aware that the existing requirements (49 CFR S 577.4(b) (1)) are not worded as explicitly as they might be. However, a proposed amendment to Part 577 published November 25, 1974 (39 FR 41182), did attempt to clarify the intent of this section. Should you have need to issue defect notification in the future we would expect the statement of determination to be directed specifically at the vehicles you manufacture.

With respect to your second point, section 577.4(d) calls for the evaluation to mention the possibility of vehicle crash where that is a potential result of the defect. In that regard your notification was clearly deficient.

We hope that this clarifies our earlier letter to you. Please feel free to write again if you have questions regarding the interpretation or application of any NHTSA requirements.

ID: 7244

Mr. Al Twyford
Suite 1200
140 Mayhew Way
Pleasant Hill, CA 94523

Dear Mr. Twyford:

This responds to your letter of April 21, 1992, to the Federal Highway Administration, which has been forwarded to this agency for reply.

You wish to complain "about some makes of new cars that have two sets of headlights (4) which operate at the same time." If this agency plans to do nothing about it, you "plan to take this matter up with Congressmen and U.S. Senators."

You are not alone in your concern about headlamp glare created by new motor vehicles. Other citizens have brought the subject to the attention of Members of Congress. I enclose a copy of a recent letter from the Deputy Administrator of this agency to Senator Cohen of Maine which is representative of our views on this issue. You will see that a number of factors may be responsible for creating a perception of glare. We note that you have already been in touch with the Department of California Highway Patrol, and that California has no periodic motor vehicle inspection.

With respect to the specific comments in your letter, the agency does not "approve" specific headlamp designs. Standard No. 108 sets forth photometric performance requirements to be met on both the upper and lower beam, and does establish maximum limitations at some of the photometric test points. Further, in a four-headlamp system, the upper and lower beams may be provided by all headlamps. Headlamp manufacturers must ensure that their products meet these requirements, and certify that each headlamp complies by placing a "DOT" mark on the lamp. There is no requirement that a manufacturer obtain permission from this agency before introducing the lamps into the market.

We appreciate your concern.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosure ref:108 d:5/14/92

ID: nht95-2.97

TYPE: INTERPRETATION-NHTSA

DATE: May 25, 1995

FROM: Kenneth Zawlocki

TO: Chief Counsel

TITLE: Re: US DOT - NHTSA - FMVSS218

ATTACHMT: ATTACHED TO 8/29/95 LETTER FROM JOHN WOMACK TO KENNETH ZAWLOCKI (REDBOOK 2; STD. 218)

TEXT: It is my interpretation of FMVSS218 that the Helmet Penetration Test is for the outer shell of the helmet and the Impact Attenuation Test is for the inner proctectant. Of course the Retention Test is for the straps that hold the helmet on the head. I c annot find any specifications as to what kind or how much material is to be used in the manufacturing of said helmets. Also, there is no specific language to the effect the helmet may not be covered with materials such as wigs, caps, cloth, etc. Theref ore, would you please clarify the following points for me:

1. Is the Penetration Test (S7.2) for testing the penetration of the outer shell?

2. Is the Impact Attenuation Test (S7.14) for testing types of impact material to prevent head injuries?

3. Is the Retention Test (S7.3) for testing straps that retain the brim of the helmet onto the head?

4. Are there any specifications in FMVSS218 as to what type and how much material can be used in the manufacturing of helmets?

5. Are there any stipulations in FMVSS218 that you cannot decorate a helmet with any material (leather, cloth), wigs, flowers, decals, hats, etc.?

I look forward to your reply; thank you for your assistance in this matter.

ID: aiam5087

"Dear Mr. Mitchell: This responds to your letter asking about th hydraulic brake hose labeling requirements (S5.2) of FMVSS 106, Brake Hoses. You indicated that your current brake hoses have two stripes, on opposite sides of the hose. Each of the stripes is interrupted by a line of information. One line, which you call the 'DOT print line,' contains the information required by FMVSS 106. The other line, which you call the 'SAE print line,' contains certain information not required by FMVSS 106, including 'batch and shift' information. You asked whether it is permissible to place the batch and shift information (consisting of a mark such as 'AA') on the DOT print line. You stated that moving the batch and shift mark to the DOT print line would improve the legibility of the SAE print line. This is because better print materials could be used in the SAE print line if that legend did not contain a mark that must be updated on a daily or more frequent basis, such as the batch and shift mark. As discussed below, the batch and shift information may not be placed on the same line as the required information. NHTSA's longstanding position, stated in past rulemaking notice preambles (e.g., 39 FR 7425, February 26, 1974, 39 FR 24012, June 28, 1974), is that the DOT print line may only contain the required information. The striping requirement (S5.2.1) of FMVSS 106 states that one of the requisite stripes on a brake hose 'may be interrupted by the information required by S5.2.2, and the other stripe may be interrupted by additional information at the manufacturer's option.' We interpret this to mean that the stripe that is interrupted by the required information may not be interrupted by information voluntarily provided by the manufacturer. This conclusion is consistent with the preamble for the final rule establishing S5.2.1 (38 FR 31302, November 13, 1973), which refers to optional additional information as not being permitted in the legend that interrupts the first stripe. (That rule modified the labeling requirements to permit interruption of the second stripe with the optional information.) NHTSA did not permit optional information to be mixed with the required information because the mixture of optional and required labeling could obscure or confuse the meaning of the required information, or interfere with the appearance of complete labeling on some hose assemblies. For your information, we have enclosed the Federal Register documents cited above. Please contact Ms. Fujita of my staff at (202) 366-2992 if you have any further questions. Sincerely, Paul Jackson Rice Chief Counsel Enclosures";

ID: aiam3777

Dear Mr. Wuddel: This is in reply to your letter of September 23, 1983, to Augus Burgett of this agency with respect to an illuminated plate positioned between the right and left rear lamps. The plate would be illuminated by a separate light source, and would 'expose the manufacturer's name and the vehicle type.' You have asked if such a plate would be allowed on the rear of the vehicle.; Paragraph S4.1.3 of Federal Motor Vehicle Safety Standard No. 10 prohibits the installation of any motor vehicle equipment that impairs the effectiveness of lighting equipment required by Standard No. 108. Each lamp on the rear of a motor vehicle under Standard No. 108 serves an informational purpose, either to mark the vehicle (taillamps, license plate lamps, hazard warning signals) or to indicate vehicle action (stop lamps, turn signal lamps, backup lamps). It is imperative for purposes of safety that the function of each rear lamp be clearly understood by drivers following the vehicle. Addition of a light source or lamp other than that required by Standard No. 108 contains the potential either for confusion or to mask the effect of one of the required lighting devices. In general, the agency is opposed to any lighting devices on the rear of vehicles other than those required by the standard.; Sincerely, Frank Berndt, Chief Counsel

ID: nht95-6.43

TYPE: INTERPRETATION-NHTSA

DATE: September 18, 1995

FROM: Orlando Ferreira -- Orion Bus Industries Ltd.

TO: J. Medlin -- FTA

TITLE: Urban Bus, GVWR more than 10,000 LBS For NYCTA

ATTACHMT: ATTACHED TO 10/25/95 LETTER FROM JOHN WOMACK TO ORLANDO FERREIRA (A43; REDBOOK 2; STD 101)

TEXT: Dear Mr. Medlin,

This confirms our phone conversation of this afternoon.

The master switch (# 2 on page 12-Drivers side control panel) has 4 positions: Engine stop, Run, Lights and Park.

These positions are engraved so that a back light allow liability in might driving conditions.

My questions is to comply with FMVSS-101-Controls and Display these positions of the master switch have to be illuminated?

If yes, please indicate where this requirement is established?

Thank you in advance [Illegible Words] in this matter.

(Drawings omitted.)