ID: aiam2820

Dear Mr. Parsil: This responds to your inquiry concerning the steering wheel system on 1972 Plymouth Cricket. You ask whether Federal safety standards permitted non-collapsible steering columns on that vehicle model, whether the steering columns met all safety standards, and whether the vehicle manufacturer was exempted from Federal safety standards on the 1972 Plymouth Cricket because of hardship.; Federal Motor Vehicle SAfety Standard No. 203, *Impact Protection fo the Driver from the Steering Control System* (49 CFR 571.203), became effective for all passenger cars manufactured on or after January 1, 1968. Therefore, a 1972 Plymouth Cricket had to meet the performance requirements specified in that standard. I am enclosing a copy of Standard No. 203 for your information, and you should note that the standard does not specifically require 'collapsible steering columns. Rather, the standard limits the force loads that can be imparted by the steering column during a dynamic impact test.; Under Federal motor vehicle safety regulations, manufacturers ar required to determine for themselves that their vehicles are in compliance and to certify the vehicles as being in compliance. The National Highway Traffic Safety Administration only conducts compliance tests on a 'spot-check' basis for purposes of enforcement. Therefore, I cannot tell you whether the particular Plymouth with which you are interested was in fact in compliance with all safety standards. I can tell you that the agency has not made any determinations that the 1972 Plymouth Crickets failed to comply with Safety Standard No. 203.; Regarding your final question, no exemption from Standard No. 203 wa granted for the 1972 Plymouth Cricket.; please contact this office if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam3096

Dear Mr. Friberg: This is in response to your letter of February 5, 1979, and you telephone conversations with Mr. Schwartz of my office.; Section 4.5.2 of Federal Motor Vehicle Safety Standard No. 115 (Vehicl Identification Number) states that the second section of the vehicle identification number for passenger cars shall be decipherable into the vehicle's line, series, body type, engine type, and restraint system type. 'Line' is defined as 'a name which a manufacturer applies to a family of vehicles which have a degree of commonality in construction, such as body, chassis or cab type.' 'Series' is defined as 'a name which a manufacturer applies to a subdivision of 'line,' denoting price, size, or weight identification, and which is utilized by the manufacturer for marketing purposes.'; In Volvo's view, the only 'line' it markets in the United States in th '200-series.' Within this line, there are several models differentiated by body style and number of engine cylinders. Each model is offered in several different 'sales versions,' designated by a two- or three-letter suffix. Sales versions differ as to trim, upholstery, and other items which Volvo has designated as cosmetic. It is Volvo's desire not to encode the particular sales versions of the vehicle in its VIN.; Based on the facts presented, it is apparent that each 'sales version could also be designated a 'series' of Volvo desired. Nonetheless, the definition of 'series' makes clear that the responsibility for applying and utilizing the 'series' designation rests initially with the manufacturer. If a manufacturer chooses not to designate separate series for marketing reasons because of the superficiality of the differences between the potential series, the agency will not require such a designation.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam4719

Dear Mr. Rowghani: This is in reply to your letter of January 9, 1990 to Taylor Vinson of this Office. You have asked whether 'importation and sale of European doors (without reinforcement bars) is in accordance with the rules and regulations of the Department of Transportation.' Your question appears premised upon the fact that many European passenger cars achieve compliance with Federal Motor Vehicle Safety Standard No. 214 Side Door Strength by being equipped with doors incorporating reinforcement bars. However, this standard applies only to new vehicles, and does not extend to replacement parts for such vehicles. Thus, if damage to a vehicle is such that its original door must be replaced, and that door incorporated a reinforcing bar, there is no requirement that the replacement door restore the vehicle to a condition in which it continues to meet Standard No. 214. In short, the importation and sale of a replacement door that does not incorporate a reinforcing bar does not violate any of the statutes, standards, or other regulations administered by this agency. If the replacement door is intended for use on a passenger car line that is subject to the Federal Motor Vehicle Theft Prevention Standard that this agency administers, however, you should be aware that it must nevertheless be marked with the registered trademark of the manufacturer of the door, or unique identifier if there is no registered trademark, and the letter 'R'. I enclose a copy of the standard for your information, as this requirement is a relatively new one, and may not be clearly understood. This marking must be on the door before the door is imported into the United States. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure (Part 541);

ID: aiam3357

Dear Mr. Kuhns: This responds to your letter of August 10, 1980, in which you as whether your proposed urban transport vehicle would be classified as an automobile or a motorcycle.; The agency's definition of 'motorcycle' is given in 49 CFR S 571.3 which reads in part:; >>>'Motorcycle' means a motor vehicle with motive power having a sea or saddle for the use of the rider and designed to travel on not more than three wheels in contact with the ground.<<<; Based on our understanding of your drawings, your proposed vehicle ha more than three wheels. If our understanding is correct, your vehicle would be classified as a passenger car rather than as a motorcycle.; The requirements for passenger cars are more stringent than fo motorcycles. We have enclosed a pamphlet prepared by the agency which gives a brief summary of the requirements and applicability of each of the Federal motor vehicle safety standards (issued as of August 1978). However, because of the volume of these standards, we do not provide copies directly. We have enclosed an information sheet which explains how you can obtain up-to-date copies of our standards and other regulations.; This agency does not license any vehicles for street or highway use Licensing is handled by the States. We specify performance requirements, and any motor vehicle must be certified by its manufacturer as being in compliance with all applicable safety standards as of the date of its manufacture. If the vehicle complies with these requirements, we specify no further steps which must be taken.; The agency will provide confidential treatment for your letter an accompanying drawings.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam0905

Dear Mr. Burgess: This is in reply to your request of November 8, 1972, for informatio concerning the effects of governmental regulation on a decorative bumper that your client proposes to manufacture for sale in the automotive 'after-market.'; As far as Federal standards are concerned, your client's product is no a regulated item of equipment as long as it is installed after the vehicle has been sold to a customer for purposes other than resale. Although we have issued a standard to regulate the safety of bumpers on passenger cars (Federal Motor Vehicle Safety Standard No. 215, 49 CFR 571.215, effective September 1, 1972), the standard does not apply to the bumper as a separate item of equipment. Thus, a new car manufactured after the effective date of the standard must conform to the standard, but a bumper manufactured after the effective date and sold separately from the vehicle as a replacement part or add on, does not have to conform.; We strongly recommend, however, that any bumper system developed fo sale in the after-market be designed to conform to the performance requirements of Standard No. 215. If it should happen that significant problems are caused by the sale of inadequate bumpers, it may be necessary to expand the application of the standard to regulate the bumper as a separate item of equipment.; For your added information, state statutes with which we are familia also apply to new vehicles and would presumably not affect the installation of your client's product. However, you might find it advisable to ask the opinion of responsible state officials on this question.; If we can be of further assistance, please let us know. Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicl Programs;

ID: aiam1949

Dear Mr. Moss: #The President has asked me to reply to your letter o February 9, 1976, concerning the application of Federal Motor Vehicle Safety Standard No. 106-74, *Brake Hoses*, to replacement brake hoses for MG sports cars built from approximately 1945 to 1955. #All brake hose and brake hose end fittings manufactured on or after September 1, 1974, must meet the performance and labeling requirements of Standard No. 106-74. All brake hose assemblies manufactured on or after March 1, 1975, must meet those performance and labeling requirements in the standard that apply to assemblies and, with an exception noted below, must be constructed of conforming hose and end fittings. #The Federal motor vehicle safety standards are not applicable to classic or antique card in the following sense: a standard applies only to a motor vehicle or item of motor vehicle equipment that is manufactured after its effective date. Thus, for example, there is no requirement that MG's in question be retrofitted with conforming brake hose. However, any person manufacturing brake hose for use in such a vehicle must, on and after September 1, 1974, ensure that the hose conforms. #You may find some relief in S12 of the standard. To facilitate the depletion of inventories of hose manufactured before September 1, 1974, that conforms to all aspects of the standard except the labeling requirements, this provision permits the use of such hose in assemblies manufactured before September 1, 1976. #There are no Federal motor vehicle safety standards that apply to hydraulic brake system components other than Standard No. 106-74, *Brake Hoses*, and Standard No. 116, *Motor Vehicle Brake Fluids*. #Sincerely, Robert L. Carter, Associate Administrator, Motor Vehicle Programs;

ID: aiam4198

Dear Mr. Hilliard: Thank you for your letter of July 1, 1986, asking how our regulation would affect the placement of the steering wheel on delivery vehicles. You asked whether there are any State or Federal regulations which would prevent the installation of a right hand drive steering wheel. As discussed below, the National Highway Traffic Safety Administration (NHTSA) has not issued any safety standards that would prohibit the installation of a right hand drive steering wheel. As to State laws, I suggest you check with the Department of Transportation in the States where your client wants to use the vehicles.; Some background information about our agency and its standards may b of assistance to you. NHTSA has the authority to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the National Traffic and Motor Vehicle Safety Act establishes a 'self-certification' process under which each manufacturer is responsible for certifying that its products meet our safety standards. The agency periodically tests vehicles and equipment items for compliance with the standards, and also investigates alleged safety-related defects.; We do not have any standards that prohibit the use of a right han drive steering system. We have, however, issued two safety standards (Standard Nos. 203 and 204) that set performance requirements which apply to any steering system, whether left or right hand drive, installed in new passenger cars and light trucks, buses, and multipurpose passenger vehicles. A copy of each of these standards is enclosed.; If you have any further questions, please let me know. Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam5428

Dear Mr. Smith: This responds to your letter asking whether th National Highway Traffic Safety Administration (NHTSA) considers automotive and motorcycle braking systems to be 'safety devices.' As explained below, the agency considers such systems to be items of motor vehicle equipment. Please note that neither the National Traffic and Motor Vehicle Safety Act (formerly at 15 U.S.C. 1381 et seq. and recently codified in Title 49 of the U.S. Code) nor the agency's regulations in Title 49 of the Code of Federal Regulations use the phrase 'safety device.' Rather, the statute refers to 'motor vehicles' and 'motor vehicle equipment.' Specifically, motor vehicle equipment is defined, in relevant part, as any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory, or addition to the motor vehicle ... Under this definition, NHTSA would consider an automotive or motorcycle braking system to be an item of motor vehicle equipment. Please note that the Federal motor vehicle safety standards are issued to meet the need for safety. For example, the purpose of Standard No. 105, which regulates hydraulic brake systems of passenger cars and other specified vehicles, is 'to insure safe braking performance under normal and emergency conditions.' See S2 of Standard No. 105. Similarly, the purpose of Standard No. 122, which regulates motorcycle brake systems, is 'to insure safe motorcycle braking performance under normal and emergency conditions.' See S2 of Standard No. 122. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel;

ID: aiam4999

"Dear Mr. Twyford: This responds to your letter of April 21, 1992, t 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";

ID: nht68-1.35

DATE: 01/23/68

FROM: Howard A. Haffron; signature by Dowell H. Anders

TO: Thomas S. Foley; House of Representatives

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of January 8 to Congressional Liaison, Department of Transportation, in which you enclosed a letter of December 20 from your constituent James B. Mitchell of Spokane. Mr. Mitchell protests regulations then proposed and new adopted, promulgated jointly by the Department of Transportation and the Department of Treasury, which cover importation of motor vehicles subject to the National Traffic and Motor Vehicle Safety Act of 1966.

These regulations, in essence, implement section 108 of the Act and state that motor vehicles subject to the Federal motor vehicle safety standards (such as passenger cars including sports cars, but not including competition racing cars) cannot be imported into the United States unless they conform to all applicable standards prior to entry or are brought into conformity after entry. Consequently, any Ferrari manufactured on or after January 1, 1968, and intended primarily for use on the public roads will be admitted to the United States if it conforms to all applicable standards or, in the alternative, if it can be brought into conformity within 90 days after entry or such other period as the district director of customs of the port of entry may allow for good cause shown.