ID: nht68-2.8

DATE: 05/15/68

FROM: JOSEPH R. O'GORMAN -- NHTSA SIGNATURE BY ANDREW K. NESS

TO: Cheetah Coaches

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 19, 1967, to the National Highway 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 by 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 by the enclosed Federal Register, Volume 33, No. 59.

Thank you for your cooperation and response to the Federal Highway Administration request regarding the certification requirement.

The label sample and information as to its location that you have 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 indentification 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.

ID: nht76-5.8

DATE: 12/03/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 3, 1976, in which you 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 Standard 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,

BLUE BIRD BODY COMPANY

November 3, 1976

Frank Berndt Acting Chief Counsel National Highway Traffic Safety Administration

SUBJECT: EMERGENCY DOOR MARKING - FMVSS 217

We are considering a change in early 1977 to a double faced decal made of 3 mil Mylar with a pressure sensitive adhesive which would be applied to the upper inside of the emergency door glass as shown in the enclosed photograph reproductions. We plan to use the designation "EMERGENCY DOOR" two inches in height with black letters on a metallic silver background. We would like to make a location change at the same time.

This type application would be visible from the inside and outside and, of course, would be protected from the weather because of inside application. The viewing angle for a person standing on the ground would be much improved since the decal would be 8" lower than if applied on the header above the emergency door.

Since we need to make a decision as soon as possible, we would appreciate a ruling on whether the above proposal meets FMVSS 217 section S5.5.3 at your earliest convenience.

Thanks

W. G. Milby Manager, Engineering Services Interior

Exterior

(Graphic omitted)

ID: nht94-4.69

TYPE: INTERPRETATION-NHTSA

DATE: October 28, 1994

FROM: Donald T. Hoy -- Senior Marketing Manager, Clean Air Partners

TO: Philip R. Recht -- Office of Chief Counsel

ATTACHMT: ATTACHED TO 2/27/95 LETTER FROM PHILIP R. RECHT TO DONALD T. HOY (REDBOOK 2; PART 303)

TEXT: The purpose of this letter is to obtain written confirmation on the issue of converting a school bus to run on a blended fuel of compressed natural gas (CNG) or liquefied natural gas (LNG) and diesel. During my conversation this morning with Mr. John Wo mack, I outlined our intention to convert school busses to run on a blended fuel of natural gas and diesel in Seattle, Washington. We fully intend to market this product in other states as well.

Basically, the Clean Air Partners, Inc. (CAP) CARB certified conversion system is designed to bolt on the original equipment manufacturer (OEM) diesel engine. The diesel fuel system remains intact and operates as designed during the duty cycle of the eng ine. Our conversion, during the dual fuel cycle, simply reduces the flow of diesel fuel to the engine and substitutes natural gas in its' place. Should your on board supply of natural gas be depleated, the system automatically reverts back to 100% diese l with no interruption in driveability.

With this brief description of our conversion system in mind, I would like to ask a few questions:

1. Are there any Federal Regulations preventing the conversation of a school bus from diesel to a "dual fuel" school bus?

2. With regard to vehicle certification, is there any significance as to when the conversion is installed on any school bus?

ID: nht94-1.44

TYPE: Interpretation-NHTSA

DATE: February 7, 1994

FROM: Jeffrey D. Shetler -- Manager of Government Relations, Kawasaki Motors Corp., U.S.A.

TO: Associate Administrator for Enforcement -- NHTSA

TITLE: Motorcycle Projector Beam Headlamps Interpretation of FMVSS 108

ATTACHMT: Attached to letter dated 5/6/94 from John Womack to Jeffrey D. Shetler (A42; Std. 108)

TEXT:

Kawasaki Motors Corp., U.S.A. is hereby requesting a interpretation from NHTSA regarding the application of a projector beam headlamp to a motorcycle and its compliance with FMVSS 571.108.

When reviewing FMVSS 108 we are not sure if our proposed application of a projector beam headlamp to a motorcycle will meet the specified requirements. Your response regarding the following questions would be greatly appreciated:

1. Table IV of FMVSS 108 specifies that if two (headlamps) are used they shall be symmetrically disposed about the vertical centerline.

Attached is a layout drawing which provides a general description of our proposed application of a projector beam headlamp. Our headlamp is not completely aligned symmetrically because the projector beam (lower beam) is located on the left side and the high beam is on the right side. However, the outer lens of the headlamp assembly is symmetrically positioned about the vertical centerline.

Question: Is our headlamp in compliance with the provision stated above?

2. Section S5.1.1.23 of FMVSS 108 indicates that instead of the headlamps specified by Table III, a motorcycle may be equipped with one half of any headlighting system specified in S7 which provides both a full upper beam and full lower beam, and where more than one lamp must be used, the lamp shall be mounted vertically, with the lower beam as high as practicable.

Question: Does this requirement mean our proposed projector beam shall be mounted on the upper half and the high beam shall be on the lower half when using one half of any headlighting system specified in S7? Or, is our proposed layout in the attachmen t acceptable?

Thank you in advance for your timely response to our questions. If further information is required, I can be reached at (714) 770-0400 ext. 2456.

ID: nht88-4.15

TYPE: INTERPRETATION-NHTSA

DATE: 11/24/88

FROM: MARTIN M. GINSBURG -- PROLINE DESIGNS

TO: ERICA JONES -- CHIEF COUNSEL U.S. DEPARTMENT OF TRANSPORTATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 07/27/89 FROM STEPHEN P. WOOD -- NHTSA TO MARTIN M. GINSBURG -- PROLINE DESIGNS; REDBOOK A33; STANDARD 126; STANDARD 302 LETTER DATED 05/08/88 FROM MARTIN M. GINSBURG TO ERIKA JONES -- NHTSA; OCC 2027

TEXT: Dear Ms. Jones:

I am requesting a legal interpretation concerning Motor Vehicle Standard No. 302 and whether or not my product must comply.

The product consists of interior window coverings for pick up truck shells. The shell is a segregated area from the cab. It is placed directly over the bed of the truck. There are no seats in the bed, and the shell is installed as an after market prod uct. The window coverings are made out of an apparel type material.

Am I required to comply with this regulation? Alternatively, if I have the product treated with California Health and Safety Code Standard No. 19, and if I send you a copy of the Standard, could you determine if I have met the No. 302 Standard.

Sincerely,

ID: nht89-3.34

TYPE: INTERPRETATION-NHTSA

DATE: NOVEMBER 7, 1989

FROM: JOSEPH PERRY

TO: STEPHEN P. WOOD -- OFFICE OF CHIEF COUNSEL, NHTSA

TITLE: IMPORTING A KIT CAR

ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO JOSEPH PERRY FROM STEPHEN P. WOOD; (A35; IMPORT REG.) TEXT:

I would like to inquire as to the rules and regulations pertaining to the importing of a kit car. I have been in contact with the manufacturer in England and have been told that they will supply certification that the windshield supplied with the kit wi ll be in accordance with the most recent DOT specification, I believe that it complies with SA1. The other problem area with kit cars appears to be the lights. I plan on using only parts which will be purchased in the U.S. The drive train: engine, clu tch and gearbox, as well as all other parts from a 1987 Ford Mustang which are required to meet EPA regulations will be installed on the car during assembly.

The body chassis unit, possibly two boxes of used and reconditioned suspension parts (Ford Cortina MK III or IV) and interior seats and trim in other boxes. I would like to know if it is acceptable to have all window glass and doors fitted to the body u nit before shipping to best assure its arrival in one piece. The doors which are used with this car are standard production Ford and are usually fitted at the factory on all kits sold.

I believe the question that I require answered is: Will fitting the windows and doors to the body unit be considered an acceptable assembly to import a car kit? As the interior, suspension, dash, wiring and steering and wheels will not be installed.

Thank you for any assistance and information that you might be able to give me.

ID: nht95-2.95

TYPE: INTERPRETATION-NHTSA

DATE: May 24, 1995

FROM: Denise Jones -- President/Co-owner, Nimi Manufacturing, Inc.

TO: Dee Fujita -- Office of the Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 6/30/95 LETTER FROM JOHN WOMACK TO DENISE JONES (A43; STD. 213)

TEXT: Dear Ms. Fujita:

As we discussed on the phone, attached is a xerox copy of the brochure describing our product. This pillow is designed specifically for use with booster car seats to provide support and comfort while the child is sleeping.

Approximately one year ago, I spoke with you on the phone regarding Federal regulations governing the flame retardancy of the fabric used to manufacture our product. At that time, your response was that there are no codes to govern this accessory.

We are now taking this product to the marketplace. Specifically, our local Wal-Mart store has purchased our pillow, however, we need to provide them with your response to us in writing. Would you please direct your reply to NiMi Manufacturing, Inc. so that we may provide retailers such as Wal-Mart with a copy. Their only concern was regarding the regulations of flame retardancy.

I certainly appreciate the time you have taken to talk with me, and the cooperation you have shown. NiMi is a very, very small business. Needless to say, your help and expediency is greatly appreciated, especially now that a major retailer is carrying our product. Perhaps we won't be small too much longer!

Please call me at (615) 636-5337 when you receive this. I'll be glad to answer any further questions you may have. Thanks again.

Attachment Brochure omitted.

ID: aiam1791

Dear Mr. Ham: This is in reference to your defect notification and remedy campaig (NHTSA No. 75-0004), concerning throttle cables on some 1974 Interceptors which may bind.; The letter which you have sent to the owners of the subject vehicle does not entirely meet the requirements of section 153 of the 1974 amendment to the National Traffic and Motor Vehicle Safety Act of 1966 and 49 CFR Part 577, 'Defect Notification.' The provisions of the amendment concerning notification and remedy requirements became effective on December 26, 1974. Unless mailing of the owner notification letters was begun prior to December 26, 1974, the provisions of section 153 should have been followed.; Your letter does not provide an adequate evaluation of the risk t motor vehicle safety reasonably related to the defect, as required by section 153(a)(2) and 49 CFR S 577.4(d). The possible consequences of a throttle sticking in the open position, such as vehicle crash, should have been given. Owners should also have been informed that they may write to the Administrator, National Highway Traffic Safety Administration, Washington, D.C. 20590, in the event that their dealer fails or is unable to remedy the defect without charge. This is required by section 153(a)(6). Finally, the last sentence in your third paragraph, beginning, '[H]owever, there have not been any reported instances . . .' must be deleted. We consider this statement to be a disclaimer and prohibited under 49 CFR S 577.6.; It is therefore necessary that you revise the notification letter an send a copy of the revised letter to this office and to each person registered under State law as the owner of an involved vehicle. Those owners whose vehicles have already been corrected at this time, however, need not be renotified. The revised letters should be sent by first class mail as specified by section 153(c)(1).; Copies of the 1974 amendment to the Act and 49 CFR Part 577 ar enclosed. If you desire further information, please contact Messrs. W. Reinhart or James Murray of this office at (202) 426-2840.; Sincerely, Andrew G. Detrick, Director, Office of Defect Investigation, Motor Vehicle Programs;

ID: 22310.ztv

Mr. Paul DeStefano
Optical Engineering Supervisor
Valeo Sylvania L.L.C.
1231 'A' Avenue North
Seymour, IN 47274





Dear Mr. DeStefano:

This is in reply to your letter of October 15, 2000, asking for an interpretation of S7.5(g) of Federal Motor Vehicle Safety Standard No. 108.

Paragraph S7.5(g) requires in pertinent part that the lens of a replaceable bulb headlamp be marked with the bulb marking designation provided in compliance with 49 CFR Part 564. In the hypothetical you present, the same headlamp lens would be used for two similar headlamp systems. The lower beam of one system would include a type H7 halogen bulb. The other system's lower beam includes a high intensity discharge (HID) D2S light source. You would like to mark the lens in front of the lower beam with both "H7" and "D2S," either one positioned above the other, or side by side. In a third variant, the marking could read "H7 or D2S." You state that it would not be possible to interchange the H7 and D2S light sources due to the different mechanical designs and electrical connections. You ask that we concur in your belief that this dual marking satisfies the intent of Standard No. 108.

We cannot concur. The lens marking must indicate only the light source that is behind the lens. The purpose of the marking is to ensure that there is a proper replacement for the light source if required. The aftermarket has begun to offer equipment that can convert filament lamps into HID lamps. This results in significant increases in intensity to the extent that the headlamps may no longer comply with the maximum candela restrictions of Standard No. 108. Dual marking of the lens could be interpreted as countenancing the replacement of an H7 filament type light source with a D2S HID type light source. In addition, local law enforcement officers are aware of the importance of complying lighting equipment to safety in their jurisdictions, and depend upon unambiguous lens marking to assist them in enforcing local lighting laws.

If you have any questions, you may phone Taylor Vinson of this office (202-366-5263).





Sincerely,

Frank Seales, Jr.
Chief Counsel

ref:108
d.1/19/01

ID: nht90-3.12

TYPE: Interpretation-NHTSA

DATE: July 11, 1990

FROM: Nelson Behar -- National Marketing Director, LooPo

TO: Steven Kratzke -- Office of Chief Consul, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-18-90 from P.J. Rice to N. Behar (A36; Std. 208); Also attached to information sheet dated 9-85 entitled Where to Obtain Motor Vehicle Safety Standards and Regulations (text omitted)

TEXT:

Thank you for the time you recently spent with me on the phone discussing NHTSA guidelines. As I explained, LooPo is a seatbelt slacking device available to motorists across the country.

Additionally, we have received and are in the process of responding to several state highway/safety agencies, that have asked whether the product falls within the current guidelines of NHTSA.

At your earliest convenience, may I have a letter from you stating that LooPo does keep within those guidelines? And in the future, would it be possible to keep me updated on any changes or alterations the committee might make regarding the NHTSA guidel ines?