ID: 16653.ztv

Mr. Filmore Bouldes
5607 High Ridge Drive
Ypsilanti, MI 48197

Dear Mr. Bouldes:

We have received your letter postmarked November 25, 1997, which asks the National Highway Traffic Safety Administration "if it's legal to use any other colors, on the front approach of your vehicle, other than yellow and clear/can you use blue, red etc. inside or outside of your vehicle?"

We assume that you mean the color of front lamps, such as headlamps, parking lamps, turn signal lamps, and fog or other supplemental lamps. The question of colors that you are permitted to use for lamps on the front of your vehicle must be answered under the laws of the states in which the vehicle will be licensed and operated. I am sorry that we are not conversant with state laws, but the Michigan Highway patrol will be able to furnish you an answer. However, we believe that most states restrict the use of blue or red front lighting to emergency vehicles.

This agency's motor vehicle lighting standard requires vehicles to be manufactured with front lamps that are white (headlamps), or amber (parking and turn signal lamps) in the color of light they emit. Federal law does not prohibit the owner of a vehicle from personally changing these colors, but state laws very likely will.

If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.1/13/98

ID: 1983-3.30

TYPE: INTERPRETATION-NHTSA

DATE: 12/05/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Duane W. Duvall

TITLE: FMVSS INTERPRETATION

TEXT:

Dear Mr. Duvall:

We have received your letter of October 27, 1943, informing us of your plans to provide a front-end replacement kit for 1971-77 Chevrolet Vegas. You have asked whether incorporating a 1973 bumper and mounting hardware will meet safety regulations. You have also asked for a copy of front lighting requirements, and for information on how you may certify your kit for national distribution.

As you have not provided us with a description of all equipment items in the kit, I can offer only general guidance. There are very few requirements for fabricators of kits intended to modify used vehicles. The Federal motor vehicle safety standards are of two types: those that apply to vehicle systems, and those that apply to individual equipment items. The so-called "bumper standard" is an example of a systems standard. Standard No. 215, Exterior Protection, which applied to passenger cars manufactured between September 1, 1972, and Sept. 1, 1978, did not directly apply to the bumper itself but established a level of damage resistance to be met by the vehicle in low-speed frontal impacts.

On the other hand, the vehicle lighting standard applies to both lighting systems and replacement lighting equipment. The primary statutory obligation of a kit supplier lies in this area--to determine if any item of equipment in the kit is covered by an equipment standard, and then to insure that the item meets the standard. For example, Standard No. 104, Lamps, Reflective Devices, and Associated Equipment, required 1971-77 Chevrolet Vegas to be equipped with sealed beam headlamps. Here unsealed European headlamps to be furnished as part of the kit, that sale would be in violation of the National Traffic and Motor Vehicle Safety Act. Other equipment standards cover brake hoses, tires, brake fluids, glazing, and seat belts. Usually the manufacturer of equipment items covered by standards will certify compliance with Federal requirements by marking them with the symbol "DOT". In that event, no recertification by the kit supplier is required. A further important obligation of a kit supplier is to insure that safety-related defects are absent, or do not develop, in any motor vehicle equipment that he fabricates. If such occur, he is required to notify purchasers and remedy the defects.

There is also a provision of the Safety Act that has some relevance to your operation. Although a vehicle owner may modify his car in any manner he chooses, a restriction is established on modifications by others. That restriction is that "no device or element of design" added to a vehicle enabling it to comply with a safety standard shall be "rendered inoperative in whole or in part." Thus, were a repair shop to remove the Vega front end and replace it with yours, the shop must insure that the Vega upon reassembly remains in compliance with the standards that originally applied to it. Although the kit supplier is not required under the Safety Act to insure that the Vega continues to comply with Standard No. 215, such insurance obviously assists the modifier in meeting its Federal responsibilities, and your incorporation of a 1973 bumper and attachments is helpful. The modified Vega must also continue to meet Federal lighting requirements, such as being equipped with front side marker lamps, and having no cover or other object over the headlamps when they are in use.

To assist you, I enclose copies of Standards Nos. 108 and 215 as they were in effect on October 1, 1977, the requirements were substantially the same for the other years in which you are interested. There is no charge and I am returning your check. If you have further questions, we shall be happy to answer them.

Sincerely, Original signed by Frank Berndt, Chief Counsel

October 27, 1983 Office of Chief Council 400 Seventh Street SW Washington, DC 20590

To Whom it May Concern:

A local agency referred me to this administration for some information that I need. Please send the proper pamphlets or publications.

I am designing a fiberglass front-end replacement kit for Chevrolet Vegas, years 1971-77. The rear will be unchanged, I plan to incorporate a 1973 bumper and mounting hardware, will this meet safety regulations?

I also need front exterior lighting regulations, and the procedure to certify this kit for national distribution.

Your prompt response is sincerely appreciated. I am enclosing $2 for any postage or duplication fees.

Thanks, Original signed by Duane W. Duvall (206) 766-6845 901 North Beach Rd.

Bow, VA 98232

ID: aiam4797

Dear Mr. Kadoya: This responds to your request for interpretations o several safety standards and the Bumper Standard, in connection with a planned 'active' suspension system. I regret the delay in responding to your letter. Your questions are responded to below. By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the statutes administered by this agency, it is the responsibility of the manufacturer to ensure that its vehicles and equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter. According to your letter, Mazda is concerned about the protocol of compliance testing of vehicles equipped with an active suspension system. This concern arises because many standards do not specify a suspension height that is to be used during compliance testing. As you noted, this has not been a concern for conventional suspension systems, since they do not provide for variable height. Mazda's planned active suspension system would be actuated by hydraulic fluid or compressed air, with control pressure being developed by a hydraulic pump or air compressor driven off the engine. Consequently the active suspension system would be operational only when the vehicle's engine is operating. At vehicle speeds in excess of 'z' mph, where z is greater than 35 mph, the suspension height would be lowered by 'x' mm from the nominal or design position for vehicle operation. If the engine/vehicle were not used for several consecutive days, pressure in the control system would fall such that the suspension height may be lowered from the nominal or design position for vehicle operation by 'y' mm, where y is greater than x. The suspension height would return to the nominal or design position for vehicle operation after such an extended period of inoperation almost immediately after starting the vehicle's engine. Before discussing your specific questions, I would like to discuss more generally the issue of how compliance is determined in situations where a standard down not specify a particular test condition. In issuing Federal motor vehicle safety standards, NHTSA attempts to specify all relevant test conditions. The agency does this as part of ensuring that its standards are objective and practicable. As a practical matter, however, it is not possible to specify every conceivable test condition. This is particularly true for ones which may only be relevant to as-yet-undeveloped technologies. In cases where a standard does not specify a particular test condition, we believe there are several relevant factors to consider in interpreting the standard. First, in the absence of specification of a particular test condition, we believe there is a presumption that the requirements need to be met regardless of such test condition, since the standard does not include any language which specifically limits applicability of its requirements to such test condition. For example, where a standard does not specify suspension height, its requirements may need to be met at all heights to which the suspension can be adjusted. Before reaching such a conclusion, however, we also consider the language of the standard as a whole and its purposes. Even if a standard is silent as to a particular test condition, the language of the standard or its purposes may indicate limitations on such test condition. Finally, in situations where a limitation on a particular test condition may appear to be appropriate, we also must consider whether the limitation is sufficiently clear, both with respect to justification and specificity, to be appropriate for interpretation. For example, in a situation where it may appear to be reasonable to limit a particular test condition but it is not obvious what particular limitation should be adopted, it would be inappropriate to select a particular limitation by interpretation. Instead, such a decision should be reached in rulemaking. I will now address the specific questions asked in your letter. Standard No. 108, Lamps, Reflective Devices, and Associated Equipment In asking about Standard No. 108, you stated the following: NHTSA has previously issued an interpretation of the requirements of FMVSS No. 108, at the request of a confidential applicant and dated February 12, 1985, with respect to active suspension equipped vehicles. This interpretation stated that the requirements of FMVSS 108 must be meet (sic), ...at any time in which...' lamps, reflective devices, and associated equipment are to be, '...operated for its intended purpose.' Consequently, headlamps, tailamps, stoplamps, the license plate lamp, and side marker lamps, must comply with the location requirements of FMVSS No. 108 whenever the vehicle's ignition is in the 'on' position. Conversely, reflex reflectors, and turn signal lamps that also function as hazard warning signal flashers must comply with the location requirements when the vehicle's ignition is in either the 'on' or 'off' position. However, it is Mazda's interpretation that hazard warning flashers are not intended to be operational for a period of days, but rather for a period of hours, at maximum, only. You then asked two questions, (1) whether Mazda's understanding of the subject NHTSA interpretation is accurate, and (2) whether Mazda's interpretation of the maximum intended operating duration of hazard warning signal flashers is correct. I note that the February 1985 interpretation was written in the context of a vehicle with a variable height system actuated by hydraulic fluid. In that particular system, the hydraulic pressure relaxed over a period of about three hours after the ignition was turned off, with the result that the vehicle assumed a lower height than it would have during driving. NHTSA stated the following: We believe that the minimum height requirement should be met for any lamp at any time in which it is operated for its intended purpose. Since vehicles at rest do not require use of headlamps, the minimum height requirement would be measured at the point after the ignition is on and when the car begins to travel (your letter implies that the time lag between turning on the ignition and restoration of a complying mounting height is a matter of seconds). On the other hand, the hazard warning signal lamps are frequently operated when the vehicle is stopped, and therefore the minimum mounting height of turn signal lamps, through which they operate, must be met with the ignition off, even if the system requires three hours to deplete itself and lower the vehicle to its minimum height. With respect to your question of whether Mazda's understanding of the interpretation is correct, I would like to note two points. First, while you state that 'the requirements of FMVSS 108' must be met at any time in which lamps, reflective devices, and associated equipment are to be operated for their intended purpose, out interpretation was limited to standard's minimum height requirement. While we are prepared, if asked, to address other requirements, out interpretations should be understood to be limited to their specific facts and conclusions. Second, while our interpretation only addressed headlamps and hazard warning signal lamps, you applied the interpretation for headlamps to tailamps, stoplamps, the license plate lamp, and side marker lamps, and the interpretation for hazard warning signal lamps to reflex reflectors. We concur with this application, with respect to Standard No. 108's minimum height requirement. We do not agree with Mazda's suggested interpretation of the maximum intended operating duration of hazard warning signal flashers. You would apparently like us to conclude that Standard No. 108's minimum height requirement for hazard warning signal flashers does not apply after a vehicle's ignition has been turned off for a matter of days. In addressing how Standard No. 108 applies in the absence of a specification for vehicle height, our February 1985 interpretation differentiates between situations where the vehicle is operating and where it is not. Looking at the purposes of the requirements in question, we believe it is obvious that the minimum height requirement for headlamps is only relevant in situations where the vehicle is operating, while the minimum height for hazard warning signal lamps is also relevant to situations where the vehicle is stopped and the ignition turned off. However, we believe that any determination that Standard No. 108's minimum height requirement for hazard warning signal flashers should not apply after a specified number of hours after the ignition has been turned off is one that would need to be addressed in rulemaking. It is therefore my opinion that the minimum mounting height of hazard warning signal lamps must be met at all heights with the ignition off, even if the system requires days to deplete itself and lower the vehicle to its minimum height. If you believe that a time limitation should be placed on this requirement, I note that you can submit a petition for rulemaking requesting such a change. Standard No. 111, Rearview Mirrors You requested an interpretation of section S5.1.1 of Standard No. 111, which generally requires a passenger car's rearview mirror to 'provide a field of view with an included horizontal angle measured from the projected eye point of at least 20 degrees, and sufficient angle to provide a view of level road surface extending to the horizon beginning at a point not greater than 200 feet to the rear of the vehicle...' You noted that since the specified procedures for determining the location of the driver's eye reference points are made referenced to point with the vehicle's cabin, your active suspension system would not affect these measurements. However, different vehicle heights would be relevant to whether there is a view of level road surface extending to the horizon beginning at a point not greater than 200 feet to the rear of the vehicle. You stated that, based on 'intended purpose,' Mazda's interpretation of Standard No. 111 is that the requirements of this standard are to be met when the vehicle's ignition is in the 'on' position as rearview mirrors are not intended to be used when the vehicle's engine is not operating. You then asked two questions, (1) whether Mazda's interpretation of the requirements of FMVSS No. 111 with respect to the state of the vehicle's switch is correct, and (2) for the purpose of compliance testing to the requirements of FMVSS No. 111, what means of maintaining the intended suspension height for a given speed and operating condition would be satisfactory to NHTSA. We agree that the field of view requirement specified in S5.1.1 for rearview mirrors need not be met for vehicle heights that only occur when the engine is not on, since the requirement is only relevant in situations where the vehicle is operating. However, the requirement would need to be at all vehicle heights that occur during vehicle operation, under the loading conditions specified in S5.1.1. With respect to the issue of how suspension height should be maintained for purposes of compliance testing, you note early in your letter that, for reasons of practicality and safety, a vehicle's engine is not actually operational during compliance testing. However, since the active suspension system derives its power from the vehicle's engine, the system's ability to maintain and regulate suspension height is only possible during engine operation. You therefore indicated that Mazda is seeking guidelines (for several standards) by which Mazda may be able to establish a means to maintain the intended suspension height for compliance testing purposes in the absence of engine operation. We are not able, in an interpretation, to specify a particular means for maintaining suspension height for compliance testing in the absence of engine operation. However, the basic principle that should be followed in selecting a means for maintaining suspension height is that is should not result in different test results than would occur if testing could be conducted with suspension height being maintained by engine operation, i.e., what would happen in the real world. This should be relatively straightforward for section S5.1.1 of Standard No. 111, since the test is static, For a crash test, it is important that a vehicle not be altered in any way that would change the vehicles's crash performance relevant to the aspect of performance being tested. Standard No.204, Steering Control Rearward Displacement In asking about Standard No. 204, you stated the following: Section S4 of this standard specifies the compliance parameter for this standard. Section S5 specifies the testing conditions to determine compliance with this standard. Section S5.1 specifies that the vehicle be loaded to its unloaded vehicle weight. Section S5.5 specifies that the vehicles fuel tank be filled with Stoddard solvent to any capacity between 90 and 95 percent of the total capacity of the tank. Mazda's interpretation of the requirements of this standard is that they are to be met when the vehicle's ignition switch is in the 'on' position only. Furthermore, Mazda interprets the vehicles suspension height pursuant to S5.1 and S5.5 to be the intended suspension height for the vehicle given the conditions of S4, i.e., 30 mph vehicle speed and steered wheels are positioned straight ahead. You then asked whether Mazda's interpretation of the requirements of FMVSS No. 204 are correct. As discussed below, we agree that Standard No. 204's requirements need to be met only at the suspension height that occurs at a 30 mph vehicle speed and with steered wheels positioned straight ahead. Standard No. 204 specifies requirements limiting the rearward displacement of the steering control into the passenger compartment to reduce the likelihood of chest, neck, or head injury. These requirements must be met in a 30 mile per hour perpendicular impact into a fixed collision barrier. While the standard specifies a number of test conditions, it does not specify suspension height. Looking at the Standard No. 204 as a whole, we believe it is clear that NHTSA explicitly decided to limit the standard's evaluation of steering control rearward displacement to how vehicles perform in a 30 mph perpendicular impacts, even though the requirements have relevance at lower and higher speeds. Therefore, we agree that the standard's requirements need to be met only at suspension heights that occur at a 30 mph vehicle speed and with steered wheels positioned straight ahead. With respect to Mazda's question concerning means of maintaining intended suspension height for compliance testing, please see our discussion provided with respect to Standard No. 111. THIS DATABASE WOULD NOT ACCEPT THE COMPLETE LETTER - DUE TO ITS LENGTH. THIS IS PART I. PART II IS ALSO DATED OCTOBER 2, 1990 AND COVERS QUESTIONS ON STANDARDS 208, 301 AND THE BUMPER STANDARD, PART 581. Sincerely, Paul Jackson Rice Chief Counsel;

ID: nht74-1.35

DATE: 06/06/74

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Committee on Transportation, Florida House of Representatives

COPYEE: W. R. EASON; NHTSA REGIONAL ADMINISTRATOR -- ATLANTA

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 7, to Dr. James R. Gregory, Administrator, National Highway Traffic Safety Administration, concerning the activation of headlamps during periods of reduced visibility, and the automatic illumination of vehicle headlights when the windshield wipers are activated.

The National Committee on Uniform Traffic Laws and Ordinances is the custodian of the Uniform Vehicle Code. Any revision of @ 12-201 relating to operation of headlights in line with the Florida law could be duly considered by its Subcommittee on Vehicles and Highways. Perhaps you may wish to submit a proposal to revise this section of the UVC to Mr. Edward F. Kearney, Executive Director, National Committee on Uniform Traffic Laws and Ordinances, 1776 Massachusetts Avenue, M.W., Washington, D.C. 20036. If you choose to do so, this would be a timely action since the various Subcommittees of the National Committee will be meeting in the next few months to consider pending proposals to revise various chapters of the UVC.

With respect to automatic illumination of headlights with the windshield wipers, the NHTSA has conducted, and will continue to conduct, considerable research on improved headlighting. This research will include evaluations of means and features which will enhance the safety of driving during inclement weather, at which time the driver would normally use his windshield wipers. The simultaneous activation of headlights and windshield wipers would ensure that the headlights are in use during adverse weather conditions. This feature would, however, result in unnecessary use of the headlights under fair weather conditions; for example, when the driver is operating his windshield washer or when the windshield wiper is used while the vehicle is parked. Illuminated headlights under fair weather conditions will also decrease the conspicuousness of the front turn signal lamps which are normally located near the headlights. These and other factors must be carefully considered in determining the true merits of a feature which would provide for automatic illumination of the headlamps when the windshield wipers are activated. Based on the information available to date, we are not in a position to justify proposing a Federal requirement for such a feature.

Furthermore, since paragraph S4.5 of Federal Motor Vehicle Safety Standard No. 108 establishes special wiring requirements (including simultaneous activation of taillamps, parking lamps, license plate lamps, and side marker lamps, with the headlamps), we would view differing State wiring requirements as preempted by Section 103(d) of the National Traffic and Motor Vehicle Safety Act, and hence invalid.

An alternative approach to ensuring the use of headlights during adverse weather would be the strict enforcement of State regulations requiring the use of headlights curing periods of reduced visibility, normally less than 500 feet.

This approach might be more cost-effective, since the cost of the automatic feature would be precluded.

Thank you for bringing your Bill HB 3135 to my attention. If I can be of any further assistance, please do not hesitate to contact me.

Sincerely,

NHTSA CONTROL NO. 1496

ATTACH.

FLORIDA HOUSE OF REPRESENTATIVES

COMMITTEE ON TRANSPORTATION

May 7, 1974

James B. Gregory, Administrator -- National Highway Traffic Safety Administration

Re: Uniform Vehicle Code (Rev. 1971) Chapter 12-201 "When lighted lamps are required"

Dear Mr. Gregory:

I call your attention to the above cited requirement of the U.V.C. compared to Florida's law, Chapter 316.217, Florida Statutes. I will agree that Florida requires lamps to be lighted one hour per day longer than the U.V.C. does as well as Florida enumerates the conditions during which time lamps shall be lighted and the U.V.C. does not. We can therefore agree that Florida's law is more stringent in its requirements than your recommendations in the U.V.C.

As you can see from my efforts to change our law, HB 3135 and a timely letter to the editor in the Miami Herald, copies enclosed, we are having our problems in educating the people about and enforcing the provision of the law which requires head lamps to be lighted when it is raining. Rain is not a safety hazard peculiar only to Florida. Perhaps the distinguished drafters of the Code should speak more specifically to this problem, require all states to conform to this law and even require the automobile manufacturers to install the mechanism referred to in Section 2 of my bill which when the windshield wipers are activated, the head lamps will automatically be activated without any additional action required of the operator.

I fully realize just how impractical it is for only one state to have such a requirement placed on the manufacturers of automobiles. However, this is my way of impressing you with the gravity of the situation and that it is within your power to reduce this specific safety hazard by requiring the manufacturers install the aforesaid mechanism. The cost to install such an item will be very nominal, less than $ 2.00, yet the benefits can be very large indeed in the saving of lives and the reduction of property damage.

Sincerely, Vernon C. Holloway -- CHAIRMAN

Enclosures

cc: NHTSA Regional Administrator, Atlanta; Miami Herald, Miami

(Regular Session 1974)

By Representative Holloway

A bill to be entitled

An act relating to the operation of head lamps and windshield wipers during unfavorable atmospheric conditions; arending section 316.217(1), F. S., requiring head lamps and windshield wipers be operated under certain conditions; amending section 501.125, F. S., adding subsection (3) thereto and renumbering (3) as (4); requiring certain automobiles have specific equipment attached before they are sold and licensed in the state; providing an effective date.

Be It Enacted by the Legislature of the State of Florida:

Section 1. Subsection (1) of section 316.217, F. S., is amended to read:

316.217 When lighted lamps are required. --

(1) Every vehicle upon a highway within this state at any time from sunset to sunrise, during fog, smoke, or rain, or atmospheric conditions, are such that there is inadequate light, shall display lighted lamps and illuminating devices as hereinafter respectively required for different classes of vehicles, subject to exceptions with respect to parked vehicles. Stop lights, turn signals and other signaling devices shall be lighted as prescribed for the use of such devices. Whenever conditions are present which require the use of windshield wipers, headlamps shall be activated.

Section 2. Section 501.125, F. S., is amended by adding a new subsection (3) thereto and renumbering (3) as (4) to read:

501.125 Warranty on sale and manufacture of automobiles; energy absorption system, windshield wipers and head lamps. --

(3) Every private passenger automobile manufactured on and after September 1, 1975, and sold and licensed in the state shall be sold subject to the manufacturer's warranty that it is equipped with a mechanism which when the windshield wipers are activated, the head lamps are automatically activated without any additional required action on the part of the operator.

(4) The warranty provisions of this section shall not be applicable with respect to any private passenger automobile as to which the manufacturer files a written certification under oath with the department of highway safety and motor vehicles, on a form to be prescribed by that department, that the particular make and model described therein complies with the applicable standards of this section.

Section 3. This act shall take effect October 1, 1977.

LEGISLATIVE SUMMARY

Requires automobile headlight operation when there is inadequate light, at any time from sunset to sunrise, during fog, smoke or rain. Requires windshield wiper use whenever conditions necessitate. Requires every private passenger automobile manufactured on and after September 1, 1975 and sold and licensed in the state to be warrantied by the manufacturer that it is equipped with a mechanism which automatically activates the head lamps when the windshield wipers are activated.

The Miami Herald

Monday, April 22, 1974

Enforce 'Lights On in Rain' Law

To The Editor:

Is there any law less frequently enforced than the law requiring headlights on during a rainstorm?

I realize that it requires the police officer to get out of his car in the rain, but if nobody is going to enforce it then get the law off the books -- or enforce it.

BOB RESNIZK

ID: 1983-2.28

TYPE: INTERPRETATION-NHTSA

DATE: 07/12/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Ezon Products Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Louis Gaia V.P. Purchasing Ezon Products, Inc. P.O. Box 18134 Memphis, Tennessee 38118

Dear Mr. Gaia:

In your letter of June 2, 1983, to the Office of Chief Counsel, you asked if there were "any D.O.T. requirements on miniature bulbs?"

We understand your question to refer to bulbs used in lighting devices other than headlamps. Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, imposes no performance requirements on individual bulbs used in lighting devices other than those used in replaceable bulb headlamps (an option permissible as of July 1, 1983). Other lighting devices must meet the photometric requirements of the standard with the bulb, chosen by the lighting device manufacturer, installed.

I hope that this answers your question.

Sincerely,

Frank Berndt Chief Counsel

June 2, 1983

National Hwy. Traffic Agency Office of Chief Councel 400 7th St. S.W. Washington, D.C. 20590

Dear Sir:

We were advised by Mr. Al Kazmierzak from the D.O.T. to write you concerning the following.

Are there any D.O.T. requirements on automotive miniature bulbs?

Please advise.

Awaiting your reply,

EZON PRODUCTS, INC.

Louis Gaia V.P. Purchasing

LG/dd

ID: nht76-1.2

DATE: 06/11/76

FROM: AUTHOR UNAVAILABLE; S. P. Wood; NHTSA

TO: British Leyland Motors Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of March 29, 1976, concerning the requirements of Federal Motor Vehicle Safety Standard No. 101, Control Location, Identification, and Illumination, for identification of the headlamps and taillamps control.

Your letter presented two symbols specified by the International Standards Organization as alternatives for identification of the master lighting switch. One of these appears in Column 4 of Table 1 of the standard and the other does not appear anywhere in the table. The headlamps and taillamps control (master lighting switch) is required by S4.2.1 to be identified with the word "Lights". The manufacturer may supplement this identification with a symbol, but only with a symbol that appears in Column 3 or Column 4 of Table 1. In issuing the amendment to the standard published July 29, 1975 (40 FR 31770, copy enclosed), the National Highway Traffic Safety Administration considered both ISO symbols and decided not to permit the one that does not appear in the table.

YOURS TRULY,

British Leyland Motors Inc.

March 29, 1976

Office of General Counsel National Highway Traffic Safety Administration U. S. Department of Transportation

RE: FMVSS 101

To commonize on switches used for master lighting controls worldwide, one of the Leyland Cars divisions would like to use the ISO light bulb symbol for master lighting switch.

We do not find this alternative provided in any recent proposals issued by NHTSA and we ask:

a) if you have considered this alternative symbol

b) if you have decided not to allow its use

c) would you consider its use.

Dianne Black Liaison Engineer

(Graphics omitted)

ID: nht68-2.39

DATE: 09/20/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: White Trucks, Division of White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 22, 1963, to Mr. David A. Fay, concerning a clarification of the requirements of paragraph S3.4.3 of Motor Vehicle Safety Standard No. 108.

As a truck-tracter manufacturer, your responsibility with respect to the requirements of paragraph S3.4.3 may be set by installing on your truck-tractors the switches, wiring and trailer electrical connectors that will, when properly mated with the wiring and electrical plugs on the trailern that are designed to be used with your particular electrical circuitry, cause the trailer tail lamps and the truck-tractor tail lamps to be illuminated when the truck-tractor headlamps are illuminated. If your truck-tractors are subsequently used to tow trailers that are not equipped with properly mated electrical plugs, connectors or circuitry, then you are not burdened with the responsibility of providing, for the resulting tractor-trailer combination, electrical circuitry that will cause the trailer tail lamps to be illuminated then the tractor headlamps are illuminated.

The trailer electrical connector that is installed on the tractor may be the 7-wire connector conforming to SAE 3560a, a 6-wire connector, or a special connector as specified by your customers. In this respect, we agree that your cannot ascertain at the time you build your truck-tractor the type of wiring system or electrical plugs that will be used on the trailer or trailer combinations that might, in the future, be tored by the truck-tractors.

Thank you for writing.

ID: 18033.ztv

Mr. Edward F. Dugan
President
Soda Fountain
FAX 908-322-3026

Dear Mr. Dugan:

This is in reply to your letter of May 14, 1998, to the New York Regional Office of this agency, with respect to a lighting device that you wish to offer to funeral directors. This device is a battery operated lamp, 3 inches in diameter, intended to be attached by a magnet or suction cup to the roofs of cars in funeral processions. The lamp, which emits a white color, flashes, with the intent of assisting drivers in the procession to stay together. You also note your belief that, with the advent of daytime running lamps, headlamps alone "are no longer a sufficient identifier of a funeral procession." You have asked if we have any objection to the use of these lamps.

The use of these lamps would not violate any Federal statute or regulation. They are subject to the laws of the State or municipality in which they will be used. Some jurisdictions may prohibit the use of flashing lights except on police or emergency vehicles. However, we are not conversant with local laws and are not able to advise you about them.

Because our interpretations are a matter of public record, I would like to explain briefly, without legal citations, how we reached our conclusion that the use of these lamps is not prohibited under Federal law. A flashing white lamp cannot be installed on a new motor vehicle, before its first sale, because all lamps must be steady burning, except for turn and hazard warning signals, school bus warning lamps, and headlamps that flash for signaling purposes. After the first sale of a vehicle, the lamp could not be attached by a manufacturer, dealer, distributor, or motor vehicle repair business because that would make inoperative the Federal lighting standard that applied to the vehicle when it was new. But this prohibition covers only the entities named, and installation of the flashing lamp by a person other than the entities named is not prohibited. That is to say, an employee of a funeral home or the owner of a vehicle in the procession can install the lamp without violating Federal law.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/24/98

ID: nht68-2.4

DATE: 05/16/68

FROM: ROGER H. COMPTON -- NHTSA; SIGNATURE BY DAVID A. FAY

TO: White Trucks, Division of White Motor Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 20, 1968, to Mr. Lowell Z. Bridwell, requesting clarification of paragraph S3.4.3 of Federal Motor Vehicle Safety Standard No. 109.

In your referenced letter you have asked two questions as follows:

"1. While we provide as standard on all tractor models built on or after January 1, 1968, a 7-wire trailer connection and cable, is it satisfactory to furnish the 3-wire cable and connector being requested by many customer? Would we still be considered as conforming to Standard No. 103 with such a cable and contector?

2. Upon customer request, will we still be considered as conforming to the requirements of Standard No. 103 if, in addition to providing the standard double pole double throw switch which would actuate the brown circuit for the tail, clearance and certain marker lights on the trailer, we also furnish a separate switch for the black circuit on the trailer which would illeminate the remainder of the running lights, provided the trailer was wired in accordance with SAE Recommended Practice J560A."

In answer to question No. 1, either the 7-wire or 6-wire trailer connection and cable may be used on truck-tractors, provided the wiring is such that trailer tail lamps will be illuminated when the truck-tractor headlamps are illuminated. It is also to be noted that Standard No. 105 does not specify the number of wires to be used in the trailer connector and cable.

In answer to question No. 2, on trailers wired in accordance with SAE Recommended Practice J560a, a seperate switch for the black circuit on the trailer is permitted under the provisions of Standard No. 103. Again, the wiring and switching for the brown circuit must provide illumination of the tail lamps when the headlamps are illuminated.

The above answer also appear to be responsive to the questions raised in your letter of March 14, 1963.

Thank you for writing.

ID: nht88-2.70

TYPE: INTERPRETATION-NHTSA

DATE: 07/14/88

FROM: SADATO KADOYA -- MANAGER, SAFETY -- ENGINEERING, MAZDA

TO: ERIKA Z. JONES -- OFFICE OF CHIEF COUNSEL, NHTSA

TITLE: REQUEST FOR INTERPRETATION - FMVSS 108; LAMPS, REFLECTIVE DEVICES, AND ASSOCIATED EQUIPMENT - AUXILIARY LAMPS

ATTACHMT: MEMO DATED 11-3-88, TO SADATO KADOYA, FROM ERIKA Z. JONES, STD 108; ALSO ATTACHED, MEMO DATED 7-14-88, RE: REQUEST FOR CONFIDENTIAL TREATMENT OF INFORMATION-49 CFR PART 512, CONFIDENTIAL BUSINESS INFORMATION

TEXT: Mazda is currently developing a lamp mechanism that features movable reflectors which can expand the area of illumination according to the driving steering angle on curved roads. The purpose of such a mechanism, when incorporated into the vehicle forwar d lighting system, is to better illuminate the forward curved path of the driver, and to therefore improve night-driving safety on winding roads.

To insure that such a system will be in compliance with all applicable safety standards, Mazda would like to confirm its interpretation of FMVSS 108; Lamps, Reflective Devices, and Associated Equipment.

In Mazda's proposed system, an electronic control unit adjusts an additional reflector's position to as much as thirty degrees to each side of the zero degree position in accordance with changes in steering angle. Automatic return of the reflectors t o the zero position occurs when the steering angle returns to zero degrees.

According to our interpretation of FMVSS 108, headlamps cannot be equipped with adjustable reflectors (S4.1.1.36). The only relevant provision applicable to fog lamps and cornering lamps is the requirement that they not impair the effectiveness of re quired vehicle lighting equipment (S4.1.3). Are we correct in concluding that although it will not be possible to introduce our adjustable reflector lamp as a headlamp, it may be possible to introduce it as a fog or cornering lamp, assuming the above pr ovision is met?

We would appreciate your interpretation of these issues at your earliest convenience. Please do not limit your discussion to the above regulations, but also address any other regulations and automotive safety considerations that might be pertinent.