ID: 21083-2.drn

[

        ]

Dear [           ]

This responds to your request for an interpretation of requirements for heating/venting/air conditioning controls specified in Standard No. 101, Controls and Displays. Our answers are provided below.

Your request for confidentiality is being addressed in a separate letter. However, in an e-mail exchange between [        ], your legal counsel and Dorothy Nakama of this office, it was agreed that the following description of the system can be made public:

The vehicle's instrument panel has a row of several push button switches, each of which has two positions. This same set of push button switches operates several different vehicle systems. The system to be operated by the switches at a given time is selected by the driver or passenger.

Above the push button switches is a video screen that shows an image of the switches. The video screen also shows the functions of the switches, which vary depending upon the system selected. There is a one-to-one correspondence between each switch and its image on the video screen.

One of the vehicle systems operated by the push button switches is the air conditioning system. In order to select this system, the driver or passenger pushes a separate button labeled "PUSH A/C." There are two such buttons, each of which is located away from the row of push button switches. There is an outer ring around each of these buttons which is used to adjust the interior temperature. This function is identified by blue and red lines on the buttons. The selected interior temperature is shown in digital format on the video screen. Rotating the outer ring (as indicated by blue and red lines on the buttons) raises or lowers the interior temperature. Each outer ring can be rotated to either the right or the left indefinitely. However, since there are limits on the extreme hot and cold interior vehicle temperatures which can be selected, rotating the button past certain points will have no effect on the selected temperature.

When the air conditioning system is selected, identification for the functions of the various push button switches is provided on the video screen, on the images of the switches and/or directly above the images of the controls. For example, the fan speed is controlled by one switch. The speed is increased by pressing the top of the switch and decreased by pressing the bottom of the switch. The four-bladed fan symbol appears on the image of this switch. An upward arrow appears on the image of the top of the switch, and a downward arrow appears on the image of the bottom of the switch. The relative speed of the fan is shown by illuminated bars on the screen above the switch. The fan speed is indicated by the number of bars that are illuminated.

In another case, a switch controls the opening of various vents. Certain identification is provided on the image of the switch, and a pictogram showing the vents relative to an occupant appears above the switch. As the switch is pressed, the pictogram changes to show the vents which are selected.

Your first question concerns whether the identification for the push button switches is considered "on or adjacent" to the controls, as required by S5.2.1(a) of Standard No. 101.

The answer is yes. The video screen that shows the images corresponding to the switches, and identification for the switches, is directly above the switches. Although there is a small unavoidable break between the video screen and the switches, no control, display or other potential source of distraction appears between the video screen and switches. For these reasons, we conclude that the proximity between the switches and the images/identification is so close that they are "adjacent" to each other.

Your second question concerns whether the system meets the requirement in S5.2.2 that identification be provided for each function of any heating and air conditioning control, and for the extreme positions of any such control that regulates a function over a quantitative range. So far as we can tell, it appears that identification is provided for each function of the various controls.

You asked about the requirement for identification of the extreme positions of any such control that regulates a function over a quantitative range in connection with the fan controls and temperature controls. We note that when this particular requirement was written, fan controls and temperature controls of the type provided in your system were not contemplated. While these controls regulate a function over a quantitative range, they do not have extreme positions in the traditional sense of a lever or button that moves only within a limited range, where the ends of the range represent the extreme positions. In the case of the two fan controls, the top of a switch is pressed to increase fan speed and the bottom of the switch button is pressed to decrease fan speed. A display indicates the relative fan speed, including the extremes. In the case of the temperature controls, a display indicates the selected temperature, including the extremes, but the outer rings can be rotated indefinitely.

Applying S5.2.2 to the type of control in your system, it is our opinion that the requirement to identify the extreme positions is met so long as there is a means by which the driver can know when the extreme positions have been reached. We believe your system provides such a means for both the fan and temperature controls. In the case of the fan controls, the driver can know when the extreme positions have been reached by viewing the display which indicates the relative fan speed. In the case of the temperature controls, the driver can know when the extremes have been reached by viewing the display of the selected temperature. When a driver rotates the outer ring of the temperature control to increase or decrease temperature, the selected temperature will increase or decrease up to the point where the extreme has been selected, at which point further movement of the outer ring in the same direction will not change the selected temperature.

Your third question was whether the identification of the heating/air conditioning system controls meets the requirement in S5.3.3 that means be provided for making controls and their identification visible to the driver under all conditions. You asked about this given the fact that identification of the heating/air conditioning controls may not be visible unless one of the knobs marked "PUSH AC" is pressed.

The answer to this question is yes. Standard No. 101 specifies at S5.3.3(a) that "means shall be provided for making controls ... and the identification of those items visible to the driver under all driving conditions." Although the images are not always displayed, the heating/air conditioning controls would meet this requirement because the images providing identification appear when the knob marked "PUSH AC" is pressed. ⁽¹⁾

I hope this information is helpful. If you have any further questions, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:101
ref.101
d.6/8/00

1. I note that for purposes of this answer,[          ] has confirmed that the brightness of the video screen can be adjusted by the driver "to provide at least two levels of brightness, one of which is barely discernible to a driver who has adapted to dark ambient roadway conditions."

[        ] also confirmed that the air conditioning control is illuminated at night.

ID: 2108y

Mr. Samuel Kimmelman
Product Engineering Manager
Ideal Division
Parker Hannafin Corporation
3200 Parker Drive
St. Augustine, FL 32084

Dear Mr. Kimmelman:

This is in reply to your letter to Taylor Vinson of this office. I regret the delay in responding. You express your understanding that Standard No. l08 "allows vehicles with combined function rear stop and turn signal/hazard lamps to operate in either of two modes when both the hazard switch and brake switch have been actuated." You have expressed these two modes as follows:

"l. The hazard switch is the major control for operation of the combined rear stop and turn signal/hazard lamps.

a. Actuating the hazard switch some period of time after actuation of the brake switch will cause the rear lamps to change from steady on, stop signal, to flashing, hazard signal.

b. Actuating the brake switch some period of time after actuation of the hazard switch will not change the flashing lamps, hazard signal, to steady on, stop signal.

2. The brake switch is the major control for operation of the combined rear stop and turn signal/hazard lamps.

a. Actuating the brake switch some period of time after actuation of the hazard switch will cause the rear lamps to change from flashing, hazard signal, to steady on, stop signal.

The front flashing hazard lamps will also become steady on.

b. Actuating the hazard switch some period of time after actuation of the brake switch will not change the rear steady on lamps, stop signal, to flashing, hazard, while the front hazard lamps go from off to steady on."

You ask for confirmation of your understanding, and if it is correct, whether NHTSA is presently considering rulemaking "to specify a specific signal from the combined function rear stop and turn signal/hazard lamps when both the hazard and brake switches are actuated."

Neither of these modes are correct, for the reasons discussed below. Initially we note that systems with combined-function lamps are those that use red lenses for the rear turn signals lamps, and not the amber lenses that Standard No. l08 allows. The second point we wish to make is that you may have confused hazard warning lamps with turn signal lamps. The basic Federal requirements for stop lamps are those of SAE Standard J586c Stop Lamps, August l970, which is incorporated by reference in Standard No. l08. Paragraph 4.2 of J586c states "When a stop signal is optically combined with the turn signal, the circuit shall be such that the stop signal cannot be turned on in the turn signal which is flashing." The identical provision is found in paragraph 4.4 of SAE Standard J588e Turn Signal Lamps, September l970, which is also incorporated by reference in Standard No. l08. This clearly means that a turn signal cannot be overriden by a stop lamp. In addition, you should note that regulations of the Federal Highway Administration's Bureau of Motor Carrier Safety forbid the optical combination of a stop lamp with a turn signal lamp unless the stop lamp function is deactivated when the turn signal lamp is activated (49 CFR 393.22(b)(2).

Assuming, however, that you meant hazard warning system lamps, there is no provision in Standard No. l08 for hazard warning system operation (those of SAE Recommended Practice J945 Vehicular Hazard Warning Signal Flasher, February l968, incorporated by reference in Standard No. l08) specifying priority of operation with respect to the stop lamp system. Because paragraph S5.5.4 of Standard No. l08 requires the stop lamps to be activated upon application of the service brakes, we interpret this as allowing the stop lamp system to override the hazard warning system. This opinion, of course, relates only to the rear lamps. The hazard warning system at the front of a vehicle must operate at any time the system is actuated.

In response to your question about the possibility of rulemaking, please note that the agency does not plan any rulemaking on this subject.

Sincerely,

Stephen P. Wood Acting Chief Counsel /ref:108 d:ll/l/89

ID: 8589

Dr. Thomas Lckemeyer
Dept VER/LB
SWF Auto-Electric GmbH

FAX 07142/73 28 95

Dear Dr. Lckemeyer:

As you have requested, we are responding by FAX to your letter of April 28, 1993, to Taylor Vinson of this Office. You have asked two questions with respect to the acceptability of a multiple rear turn signal lamp under Federal Motor Vehicle Safety Standard No. 108, and have enclosed a sketch of the lamp.

Your first question is:

"Is it allowed to split the turn signal lamp in two parts with the dimensions given in the sketch . . . where the bigger part (4.5 sq. in.) is on the body of the car. The distance does not exceed 22 in."

Your question indicates that the turn signal lamp array of two lamps that is illustrated in the sketch is intended for installation on passenger cars or other vehicles whose overall width is less than 80 inches. Standard No. 108 incorporates by reference the SAE standard applicable to such vehicles, J588 NOV84. Paragraph 5.1.5.2 of SAE J588 NOV84 permits the use of multiple rear turn signal lamps to meet the photometric requirements of Standard No. 108.

When multiple lamps are used to meet the photometric requirements of a rear turn signal lamp, paragraph 5.3.3 of SAE J588 NOV84 requires that the functional lighted lens area of each lamp shall be at least 22 sq. cm, provided the combined area is at least 37.5 sq. cm. Your sketch shows that the functional lighted lens area of one lamp is 23 sq. cm, and of the other, 30 sq. cm, with a combined area of 53 sq. cm. Therefore, Standard No. 108 permits you to use the turn signal lamp array shown in your sketch. Your second question is:

"Is it allowed to use the combination of the two lamps to meet the photometric requirements."

Because the distance between the two adjacent light sources in the array does not exceed 560 mm (the sketch indicates that it is less than 550 mm), paragraph 5.1.5.2 of SAE J588 NOV84 requires that the combination of the lamps be used to meet the photometric requirements for the corresponding number of lighted sections, two in this case. Sincerely,

John Womack Acting Chief Counsel

NCC-20:ZTVinson:mar:5/19/93:OCC 8589:62992 cc: NCC-0l Subj/Chron Interps. Std. 108; redbook (3) w/sketch 8589; ztv; U:\ncc20\interp\108\8589.ztv

ID: 8589r

Dr. Thomas Lckemeyer
Dept VER/LB
SWF Auto-Electric GmbH

FAX 07142/73 28 95

Dear Dr. Lckemeyer:

As you have requested, we are responding by FAX to your FAX letter of June 25, 1993, to Taylor Vinson of this Office.

Our FAX letter to you of May 28, 1993, provided an interpretation of SAE J588 NOV84, incorporated by reference in Federal Motor Vehicle Safety Standard No. 108. You mention the l990 SAE Ground Vehicle Lighting Manual which refers to SAE J588 September l970, and ask which is the correct SAE reference.

Standard No. 108 was amended with an effective date of December 1, 1990, to substitute "SAE J588 NOV84" for "SAE J588 September 1970" as the U.S. Federal requirement for turn signal lamps used as original equipment on passenger cars and other motor vehicles with an overall width of less than 80 inches overall width. Turn signal lamps may still be manufactured to the requirements of "SAE J588 September 1970" if they are intended to replace original equipment turn signal lamps that were manufactured in accordance with "SAE J588 September 1970." We understand that your earlier letter asked for an interpretation of Standard No. 108 as it related to the design of lamps for future production, and trust that this answers your question.

As you have requested, we are also FAXing a copy of Table III. Sincerely,

John Womack Acting Chief Counsel ref:108 d:7/8/93

ID: 8599

Mr. Frank Millar
1841 Shady Brook Drive
Thousand Oaks, CA 91362

Dear Mr. Millar:

This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 105, Hydraulic Brake Systems, and Society of Automotive Engineers (SAE) Recommended Practice J201. I apologize for the delay in our response. You asked about the significance of the two documents for manufacturers and consumers. You also asked whether you are correct in interpreting section S5.2.1 of Standard No. 105 as requiring the parking brake of a Toyota Camry with a standard (stick shift) transmission to hold the car stationary on a hill with a 30 percent grade in both forward and reverse directions for five minutes. Your questions are addressed below.

By way of background, the National Traffic and Motor Vehicle Safety Act authorizes the National Highway Traffic Safety Administration (NHTSA) to issue safety standards for new motor vehicles and items of motor vehicle equipment. All motor vehicles and items of motor vehicle equipment manufactured or imported for sale in the United States must comply with all applicable safety standards.

Standard No. 105 is one of the safety standards issued by NHTSA. The standard specifies requirements for hydraulic service brake systems and associated parking brake systems, for the purpose of ensuring safe braking performance under both normal and emergency situations. The standard applies to passenger cars, multipurpose passenger vehicles, trucks, and buses with hydraulic service brake systems. Manufacturers must ensure that each new vehicle complies with each applicable requirement of the standard. The standard specifies the specific test conditions under which each performance requirement must be met.

You asked the agency to confirm your understanding that section S5.2.1 of Standard No. 105 requires the parking brake of a Toyota Camry with a standard transmission to hold the car stationary on a 30 percent grade for five minutes in both forward and reverse directions. Section S5.2.1 reads as follows:

Except as provided in S5.2.2, the parking brake system on a passenger car . . . shall be capable of holding the vehicle stationary (to the limit of traction on the braked wheels) for 5 minutes in both a forward and reverse direction on a 30 percent grade.

Section S5.2.1 thus applies to all passenger cars, except as provided in S5.2.2. The alternative requirement set forth in S5.2.2 is only available for certain vehicles with a transmission or transmission control which incorporates a parking mechanism. Vehicles with standard transmissions do not typically have such a parking mechanism. Assuming that a Toyota Camry does not have a parking mechanism, it would be required to meet the requirements of S5.2.1.

I note that, even assuming that a vehicle meets the requirements of S5.2.1, it would not follow that the parking brake system would hold the vehicle stationary on a 30 percent grade under all real world driving conditions. As indicated above, Standard No. 105 specifies specific test conditions under which its performance requirements must be met. In the case of the standard's parking brake requirements, the specified test conditions include such things as control force and test surface. Also, the requirement only applies to the limit of traction on the braked wheels. Thus, if a 30 percent grade has a slippery surface, the vehicle might slide down the grade even though its parking brake system held the wheels locked. Finally, the requirement applies only to new vehicles and not used ones.

You also asked the significance of SAE J201 to manufacturers and consumers. The Society of Automotive Engineers is an independent, non-governmental group. In some cases, NHTSA has incorporated portions of that organization's recommended practices into its safety standards. Since the agency has not done so with SAE J201, that recommended practice does not have any significance to the Federal motor vehicle safety standards. NHTSA can only comment on the significance of its own standards and regulations and not on ones issued by other organizations or agencies. Therefore, we suggest that you contact SAE concerning the significance of SAE J201.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact David Elias of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:105 d:9/l/93

ID: 86-1.1

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/86 EST

FROM: MICHAEL M. FINKELSTEIN -- ASSOCIATE ADMINISTRATOR FOR RESEARCH AND DEVELOPMENT NHTSA

TO: CHARLES SCHAMBLIN

TITLE: NONE

TEXT: Dear Mr. Schamblin:

Your letter to Elizabeth Hanford Dale. Secretary of Transportation, was forwarded to me for response.

Thank you for sending the sample of the Flag-It Fluorescent Safety Signaling Device and the information that it is being manufactured in the United States. We share your concern with the problem of school bus safety and appreciate your efforts to develop a device to reduce the problem. However, as I am sure you can understand, government agencies cannot endorse commercial products.

Thank you, again, for your interest in improving highway safety.

Sincerely,

ID: 86-1.10

TYPE: INTERPRETATION-NHTSA

DATE: 01/24/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Robert Juckett -- Transglobal Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Robert Juckett Transglobal Industries, Inc. P.O. Box 98 Whitehall, New York 12887

This responds to your letter of September 9, 1985, regarding the applicability of Standard No. 121 to a partially used and partially new trailer. You asked whether your customer, who plans to purchase a trailer frame, air tank, and air valve from you, is responsible for compliance with Safety Standard 121. Your customer plans to mount on his newly purchased frame his own used suspension, wheels, brakes and axles.

By way of background information, this agency does not give approvals of motor vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to ensure that its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles and equipment comply with all applicable standards. The following represents our opinion based on the facts provided in your letter.

If your customer intends to use the trailer which he is assembling for his own use, then he is not governed by the Federal motor vehicles safety standards. Section 108(a) of the National Traffic Motor Vehicle Safety Act of 1966 provides:

(a) No person shall:

(1) Manufacture for sale, sell or deliver for introduction into interstate commerce or import into the United States, any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect under this rule unless it is in conformity with such standard,

Section 102(5) of that Act defines "manufacturer" as "any person engaged in the manufacturing or assembling of motor vehicles...for resale." Your customer is not covered by the Federal motor vehicle safety standards unless he is assembling the vehicle you mention for sale.

In the event that your customer is a manufacturer within the meaning of the Act, he may still be excepted from the requirements of Standard No. 121. You noted that your customer will mount a new trailer frame, air tank and air valve on his own used suspension, wheels, brakes and axles. 49 CFR Part 571.7(f) excludes from Standard No. 121 partly new and partly used trailers when the trailer running gear assembly (axle(s), wheels, braking and suspension) is not new and was taken from an existing trailer. In addition, the reassembled vehicle must use the same vehicle identification number as the original trailer and the original trailer must be owned or leased by the user of the reassembled vehicle.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones

Chief Counsel

09-09-85

Mr. Jeffery Miller Office of Chief Council N.H.T.S.A. 400 - 7th Street. S.W. Washington, D.C. 20590

Dear Mr. Miller,

We are a new trailer manufacturer and have a question reguarding F.M.V.S.S. 121. I recently spoke to Mr. Edward Glancy of your office and he suggested writing.

We have a customer requesting to purchase a trailer frame, air tank, and air valve from us. He has told us that he is going to mount his own old suspension, wheels, brakes, and axles on this frame.

Please inform me if my interpretation is correct.

As the owner is using his existing undercarriage, he is responsible for any F.M.V.S.S. 121 compliance, as with using his existing undercarriage the trailer retains its original Vehicle Identification Number.

Thank you for your assistance.

Sincerely yours.

Robert Juckett Engineering

ID: 86-1.11

TYPE: INTERPRETATION-NHTSA

DATE: 01/24/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: G. F. Kirchoff -- Special Project Manager, Morton Thiokol, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

G. F. Kirchoff Special Project Manager Morton Thiokol, Inc. 3350 Airport Road Ogden, UT 84405

Thank you for your letter of November 13, 1985, to Stephen Oesch of my staff asking how our standards would affect a diagnostic and sensor warning light for a self-contained airbag system you arc developing. You explained that the system would be mounted in the steering wheel and would have the diagnostic and sensor light located on the steering wheel horn pad.

Your warning light would be affected by Safety Standard No. 208, Occupant Crash Protection, S4.5.2 of the standard requires crash-deployed restraint systems, such as airbag systems, to have an indicator that monitors the readiness of the system, In addition, the indicator must be clearly visible from the driver's seat. Placing your diagnostic and sensor warning light in the center of the horn pad should ensure that it is visible to the driver.

If you have any further questions, please let me know. Sincerely,

Erika Z. Jones Chief Counsel

13 November,1985 U200-FY86-060

Mr. Steve Oesch, NOA-32 U. S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D. C. 20590

Dear Mr. Oesch:

Subject: Diagnostic and Sensor Light in Horn Pad

Morton Thiokol, Inc. is presently developing a self-contained airbag system for the automobile driver. As such, this system is planned to have a warning light in the steering wheel horn pad. It is an electrical system with the sensor and diagnostics, and capacitor power supply located in the driver module. The warning light for the diagnostics is planned to be either red or green. It would also appear to be desirable from an occupant attention standpoint to locate it on the horn pad.

We wish to insure that the placement of the warning light is in compliance with all NHTSA regulatory requirements and would appreciate your review and position on this. Thank you very much.

Sincerely,

G. F. Kirchoff Special Project Manager

ID: 86-1.12

TYPE: INTERPRETATION-NHTSA

DATE: 01/27/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Alan K. Simpson

TITLE: FMVSS INTERPRETATION

TEXT:

January 27, 1986 The Honorable Alan K. Simpson United-States Senate Washington, D.C. Dear Senator Simpson: Thank you for your letter on behalf of your constituent, Mr. W. S. Beaver, Superintendent of Schools for Sheridan County, concerning our requirements for school buses. We contacted your constituent to find out more about his concerns regarding the standard we issued for the identification of school buses. Mr. Beaver explained that he believed some allowance should be made in our regulation to permit a multipurpose passenger vehicle (MPV) that does not have school bus warning lights to be identified as a school vehicle when the vehicle travels on hazardous mountain routes. He further informed us that, although he has recently become aware that the issue he raises primarily involves State requirements, he would appreciate a clarification of our school bus regulations. We appreciate this opportunity to be of assistance. Our agency has two separate sets of regulations for school buses which we issued under different Acts of Congress. The first set, issued under the authority of the National Traffic and Motor Vehicle Safety Act of 1966, includes our motor vehicle safety standards for school buses. Those standards apply to the manufacture and sale of new motor vehicles, and requires sellers of new school buses to ensure that the vehicle they sell complies with our school bus safety standards. While new school buses must be equipped with a system of signal lamps under Safety Standard No. 108, there is no comparable Federal requirement for MPV's. Mr. Beaver understands that this is the case for MPV's and he has no argument with the nature of those requirements. The second set to regulations applicable to school vehicles was issued under the authority of the Highway Safety Act of 1966, and applies to Federal funding of State highway safety programs. Under the Act, we issued a series of highway safety program standards for State highway safety program standards for State highway safety programs, one of which is Highway Safety Program Standard (HSPS) No. 17, Pupil Transportation Safety. This "standard" is more in the nature of a guideline for State school vehicle usage laws, and it is with this standard that you constituent is most concerned. HSPS No. 17 contains recommendation for the manner in which school vehicles should be identified, such as the yellow color and "School Bus" signs. It recommends that MPV's used as school vehicles should either have the warning lights, yellow color and signing of a school bus or have none of those identifying features. Mr. Beaver was concerned that this was a Federal requirement which prohibited his MPV's from being identified as school vehicles since they do not have the school bus signal lights. As your constituent now knows, this was not an accurate understanding of HSPS No. 17's recommendations. The effect of HSPS No. 17's recommendation for school bus identification is dependent on State adoption. NHTSA does not require States to adopt each aspect of our highway safety program standards, and Wyoming has discretion in adopting some or all of HSPS No. 17's recommendations. Thus, the decision whether to permit an MPV to have a school bus sign alone, without the other identifying features of school buses, is within Wyoming's discretion. Mr. Beaver informed us that he is pursuing the matter with Wyoming State officials. I hope that this information is helpful, and that you or your constituent will not hesitate to contact us if we can be of further assistance. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 86-1.13

TYPE: INTERPRETATION-NHTSA

DATE: 01/30/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Commander, Naval Safety Center, Naval Air Station, Norfold, VA

TITLE: FMVSS INTERPRETATION

TEXT:

Commander Naval Safety Center Naval Air Station Norfolk, VA 23511-5796 Ref: 5100 Ser 42/5064

Thank you for your letter of December 5, 1985, following up on a number of phone conversations between your staff and mine, concerning the effective dates of the Federal standard requiring the installation of safety belts in motor vehicles. As requested by your staff, we have prepared the enclosed information sheet to be used as a guide by your security personnel in enforcing the safety belt use requirements on naval installations. If you have any further questions, please let me know. Sincerely, Original Signed By Erika Z. Jones Chief Counsel Enclosure