ID: nht81-1.46

DATE: 03/17/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Eidal International Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

M. William E. Medcalf Engineering Manager Eidal International Corp. P.O. Box 2087 Alburquerque, NM 87103

Dear Mr. Medcalf

This is in response to your letter forwarding your firm's vehicle identification numbering system and requesting confirmation that it complies with Federal Motor Vehicle Safety Standard No. 115 -Vehicle identification number.

The National Highway Traffic Safety Administration (NHTSA) does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed system. Based on our understanding of the information which you have provided, your system apparently complies with Standard No. 115.

Sincerely,

Frank Berndt Chief Counsel

November 7, 1980

National Highway Traffic Safety Administration 400 South Street, S.W. Washington, D.C. 20590

Attention: VIN Coordinator

Dear Coordinator:

Pursuant to the requirements of 49 CFR 575.115, as revised and amended per Docket No. 1-22, please find enclosed the information required to decipher the characters contained in VIN's to be assigned by the Eidal International Corporation (EIC).

Additionally, EIC petitions for a waiver of the sixty (60) day advance filing requirement, as it applies to the attached character decipher information. Our small firm was not made cognizant of this new requirement until late September 1980, and has proceeded with all possible deliberation to develop the attached character codes.

EIC is a small, low volume (less than 500 trailers per year) manufacturer of transportation equipment. Our products, with few exceptions are custom designed to meet the needs of our customers in the heavy-haul, oilfield, and military equipment markets. Accordingly, the Society of Automotive Engineers has assigned the codes 1E9 and 015 for EIC use in VIN positions 1-3 and 12-14, respectively, of the complete 17 digit VIN.

It is our belief that the enclosures, which are preceeding completion of our procedure, fully explain the method of encoding the required information. A copy of the finalized procedure will be filed as soon as it becomes available. If additional information is required, please do not hesitate to contact me.

Sincerely,

EIDAL INTERNATIONAL CORPORATION William E. Medcalf Engineering Manager

dw

Enclosure

ID: nht94-2.37

TYPE: Interpretation-NHTSA

DATE: April 13, 1994

FROM: Richard Kreutziger -- Executive Director, New York State Bus Distributors Ass'n.

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/25/94 from John Womack to Richard Kreutziger (A42; Std. 108)

TEXT:

I VERY MUCH APPRECIATE YOUR RESPONSE TO MY QUESTIONS FAXED TO YOU ON 1/12/94 AND 2/14/94. THE "APPENDIX" PROVIDED HAS AND I AM SURE WILL PROVIDE MUCH MORE BENEFIT IN TIME.

I AM FACED, NOW, WITH A NEW QUANDARY. I CERTAINLY DO NOT MEAN TO IMPOSE ADDED WORK LOAD, AND I ASSURE YOU THAT I HAVE READ AND REREAD FMVSS 571.108 - LAMPS, REFLECTIVE DEVICES, AND ASSOCIATED EQUIPMENT, FOR MY ANSWER.

IN 571.108 SECTION S5.5.7 - REFERENCE TO VEHICLES INCLUDING BUSES, OF LESS THAN 80 INCHES OVERALL WIDTH - HAVE VERY DEFINITE WIRING PROGRAMS INCLUDED, PART (a) AND (b) - IN BOTH SUB-SECTIONS THE "MAKER LIGHTS" ARE REFERRED TO - WHICH HAVE TO BE ACTIVATED WHEN THE PARKING OR HEADLIGHT SWITCH IS ACTIVATED.

MY "QUANDARY" IS - I CAN FIND NO LIKE OR SIMILAR SECTION REQUIRING THE ACTIVATION OF SPECIFIC LIGHTS ON VEHICLES OF MORE THAN 80 INCHES IN OVERALL WIDTH.

ANY HELP AND/OR KNOWLEDGE OF A SIMILAR POSITION/FACTOR ON VEHICLES OF MORE THAN 80 INCHES IN WIDTH AS THOSE OF 80 INCHES OR LESS WILL BE GREATLY APPRECIATED.

ID: aiam1620

Dear Mr. Louis:#This is in response to your letter of September 13 1974, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101.#You ask confirmation that your proposed vertically lettered identification for windshield wiper and hazard warning switches will meet the requirement of Standard No. 101, S4.2.1, that the identification 'shall appear to the operator in an upright position.'#Both horizontally and vertically lettered identifications are acceptable, as long as their appearance is upright. We have no objection to your use of the proposed designations.#Yours truly, Richard B. Dyson, Acting Chief Counsel;

ID: aiam1862

Dear Mr. Steenbock: This responds to your March 11, 1975, question whether the exceptio category of 'no cargo-or passenger-carrying capacity' found in S3 of Standard No. 121, *Air brake systems*, includes a vehicle designed to carry a driver and a second person to operate the vehicle's specialized equipment.; The answer to your question is yes. We use the word 'passenger' in thi context to mean a person who does not help to operate the vehicle or its equipment, *i.e.*, who is not part of an operating crew. Positions for the crew necessary to operate a vehicle's specialized equipment would not disqualify a vehicle under the passenger-carrying criterion.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: nht94-4.7

TYPE: INTERPRETATION-NHTSA

DATE: August 19, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jerry Miller -- Director of Operations, Associated Leasing Handicapable Vans

TITLE: None

ATTACHMT: Attachment Dated 5/31/94: Letter From Jerry Miller to Chief Console

TEXT:

This responds to your letter of May 31, 1994, requesting confirmation that "there are no rules or regulations on wheelchair tie downs for vehicles other than school buses."

You are correct that Federal motor vehicle safety standard No. 222, School Bus Passenger Seating and Crash Protection, which includes requirements for wheelchair securement devices, applies only to school buses. However, while none of the safety standar ds apply to wheelchair securement devices for vehicles other than wheelchairs, the manufacturer of the product is subject to federal requirements concerning the recall and remedy of products with defects related to motor vehicle safety (49 U.S.C. 30118-3 0121). The agency does not determine the existence of defects except in the context of a defect proceeding.

You should also be aware that the Department of Transportation has issued a final rule implementing the transportation provisions of the Americans with Disabilities Act. This final rule includes requirements for wheelchair securement devices installed i n vehicles required to be accessible by this rule. A copy of the final rule is enclosed with this letter. If you have further questions on these regulations, please contact Mr. Irv Chor of the Federal Transit Administration. Mr. Chor's card is attached to the final rule.

I hope you find this information helpful. If you have any other questions concerning NHTSA regulations, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Enclosure

ID: 20271.ztv

Mr. Gary Starr
Zap Bikes
117 Morris Street
Sebastopol, CA 95472

Dear Mr. Starr:

This is in reply to your email of July 7, 1999, to the National Highway Traffic Safety Administration (NHTSA) Webmaster asking two questions.

You first asked "What distinguishes electric powered toys such as ride on Perego and Power wheels from motor vehicles?"

We are not familiar with "electric powered toys such as ride on Perego and Power wheels." In brief, our principal safety statute defines a "motor vehicle" in pertinent part as a vehicle that is driven by mechanical power and manufactured primarily for use on the public streets, roads, and highways (see 49 U.S.C. 30102(a)(6)). Manufacturers of children's wheeled powered toys do not manufacture them for on-road use, nor do states license these toys for on-road use. In contrast, powered bicycles are intended by their manufacturers intend to be operated on the public roads and are licensed by states for on-road operation. These powered bicycles are "motor vehicles," as we have previously advised you. We would be pleased to advise you further if you wish to provide us with a fuller description of the vehicles about which you have asked.

Your second question is "What do electric powered mobility scooters that are used for the disabled come under? Are these toys? Or motor vehicles?"

We do not consider single-seat low-speed electric powered mobility vehicles to be manufactured primarily for use on the public roads within the meaning of the statutory definition of motor vehicle. Because they are not motor vehicles, they are not subject to our jurisdiction. This means that the Consumer Product Safety Commission has jurisdiction over mobility vehicles.

I hope that this answers your questions.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:571
d.8/19/99

ID: nht93-9.26

DATE: December 27, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA; Signature by Kenneth Weinstein

TO: Lisa A. Norris

TITLE: None

ATTACHMT: Attached to letter dated 12/1/93 from Lisa A. Norris (OCC-9427) and letter dated 8/31/90 from Paul Jackson Rice to David Holscher (Std. 108)

TEXT:

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 form 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.

ID: nht94-8.12

DATE: February 14, 1994

FROM: Lawrence A. Beyer -- Attorney at Law

TO: Z. Taylor Vinson -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 3/7/94 from John Womack to Lawrence A. Beyer (A42; Std. 108)

TEXT:

This letter requests an opinion letter from your office concerning the re-importation of a certified vehicle.

My client wishes to re-import vehicles which were certified by the original manufacturer and purchased in the U.S. These vehicles would then be modified and sent back to the U.S. The vehicles in question are motorcycles which would then have a shell placed around it. The frame would be slightly modified and seating lowered to incorporate the design. However, my client would not knowingly render inoperative wholly or in part any device or element of design installed in accordance with the FMVSS.

On November 16, 1992, your office issued a letter regarding this matter. Please advise me if this letter is still your interpretation.

ID: nht76-3.4

DATE: 03/11/76

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Inertia Switch, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: I am writing in response to your March 9, 1976, telephone conversation with Mark Schwimmer of this office concerning the meaning of "GVWR" as it appears in Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity.

"GVWR" or "Gross vehicle weight rating" is defined in 49 CFR 571.3 as:

the value specified by the manufacturer as the loaded weight of a single vehicle.

One constraint on this specification is found in @ 567.4(g)(3) of 49 CFR Part 567, Certification, which requires that the GVWR shall not

be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity. . . .

An information sheet entitled "Where to Obtain Federal Motor Vehicle Safety Standards and Regulations" is enclosed for your convenience. If you have any further questions, please do not hesitate to write.

ID: nht76-5.22

DATE: 03/11/76

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Hardings Lane

TITLE: FMVSR INTERPRETATION

TEXT: I am writing in response to your March 9, 1976, telephone conversation with Mark Schwimmer of this office concerning the meaning of "GVWR" as it appears in Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity.

"GVWR" or "Gross vehicle weight rating" is defined in 49 CFR 571.3 as:

the value specified by the manufacturer as the loaded weight of a single vehicle.

One constraint on this specification is found in @ 567.4(g)(3) of 49 CFR Part 567, Certification, which requires that the GVWR shall not

be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity. . . .

An information sheet entitled "Where to Obtain Federal Motor Vehicle Safety Standards and Regulations" is enclosed for your convenience. If you have any further questions, please do not hesitate to write.