ID: nht71-5.56

DATE: 05/12/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Herbert A. Strum; P. E.

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of April 20, 1971, to Robert L. Carter you ask for copies of regulations governing "the construction, equipping, and operation of private motor coaches." It is our understanding that you wish to construct a vehicle for your own use upon a standard Dodge M-300 motor coach chassis.

A motor coach is categorized as a "multipurpose passenger vehicle" under the Federal motor vehicle safety standards. I enclose copies of the following safety standards which would apply to the motor coach body that you wish to construct, and with which you, as a "manufacturer" of a motor vehicle, must ensure compliance.

102 - Transmission Shift Lever, etc. (Note S3.2)

103 - Windshield Defrosting and Defogging Systems

104 - Windshield Wiping and Washing Systems

107 - Reflecting Surfaces

108 - Lamps, Reflective Devices, and Associate Equipment

111 - Rearview Mirrors

205 - Glazing Materials

206 - Door Locks and Door Retention Components

208 - Seat Belt Installation (effective July 1, 1971)

209 - Seat Belt Assemblies (effective September 1, 1971; the requirements in effect until then apply only to equipment manufacturers)

This agency has no regulations governing the "operation" of a private motor home; however, Michigan may have special provisions as a prerequisite to the registration of a motor home.

Sincerely,

Enclosures

April 20, 1971

Robert L. Carter, Motor Vehicle Programs, Nat'l Highway Traffic Safety Administration,

Re: Construction and Equipment Requirements Motor Coaches - Recreational Vehicles.

Would you kindly send me the regulations which govern the construction, equipping and operation of private motor coaches? I am proposing to construct such a coach for my own use, starting with a standard Dodge M-300 motor coach chassis designed for the purpose, and presumably meeting all current regulations which apply to the chassis and drive-train, etc. My concern thereafter, is with the requirements governing the body dimensions, clearance lighting, etc.

Your prompt attention will be appreciated.

(Herbert A. Strum) P. E.

ID: nht71-5.57

DATE: 05/12/71

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mercedes-Benz of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 20, 1971, regarding an interpretation for seat belt assemblies required by Federal Motor Vehicle Safety Standard No. 208 - Occupant Crash Protection.

It is our intent that an integral (3-point) lap and shoulder belt system, with a sliding attachment, could meet the requirements of the subject standard. Since paragraph S7.1.1 requires automatic adjustment by means of an emergency-locking retractor for this type of integral system (see S7.1.1.3), the sliding attachment friction could not unduly restrict adjusting movements of the belt, however, a nominal friction is permissible and is expected.

The seat belt assembly which you submitted to Mr. Clue Ferguson's Office of Crash Worthiness has been placed in Docket 69-7. This system would appear to have a nominal friction at the sliding adjustment, however, an actual vehicle installation is necessary to enable a full evaluation.

MERCEDES-BENZ OF NORTH AMERICA, INC.

April 20, 1971

Doug W. Toms, Director National Traffic and Highway Safety Administration

Subject: Seat Belt Assemblies According to FMVSS 208

The Motor Vehicle Safety Standard 208 which will be effective January 1, 1972, requires that seat belt assemblies shall adjust to fit the occupant by means of an automatic or emergency locking retractor. The seat belt assembly being considered for installation in our vehicles has been designed to comply with the subject Safety Standard. We would, however, appreciate receiving your confirmation that the design complies with the aspect of performance described in S7.1.1 of the Standard prior to equipping our vehicles.

The subject assembly consists of a single piece of webbing permanently attached at the outboard floor anchorage, with the release/fastening mechanism at the inboard anchorage forming the pelvic restraining loop and a third anchorage behind the shoulder forming the upper torso restraint. The webbing is fed during extension by an emergency locking retractor through the upper shoulder restraint anchorage to provide freedom of movement for the occupant.

Application of this assembly around the occupant is achieved by pulling the "tongue" portion of the attachment hardware from its fully retracted position at the "3" pillar, across the occupant down to the fixed buckle or receptable at the inboard anchorage. The webbing passes loosely through a slot in the tongue to provide a sliding adjustment during this application.

We are requesting your confirmation that this sliding adjustment specifically, will not be considered in non-compliance with your requirement for adjustment by the retractor because of the small amount of friction occuring at the webbing and tongue. It is our opinion that the friction is adequately overcome by the retractor force to provide proper adjustment. Additionally, the assembly when extended for use, will be drawn across the occupant, thus a snug fit across the pelvic region will be provided upon application thereby minimizing the need for further automatic adjustment by the retractor.

A sample of an assembly incorporating this design has been left at Mr. C. Ferguson's office for further evaluation by your staff. Upon receipt of your evaluation of this design we will advise our parent company accordingly.

H. W. Gerth General Manager Product Engineering and Service

cc: Mr. Wilfert Dr. Reidelbach

ID: nht71-5.58

DATE: 04/30/71

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Rolls-Royce Limited

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 14, 1971, in which you repeat Rolls Royce's requests for interpretation of Standards No. 207 and 208.

The request for interpretation of the seat adjustment requirement of Standard No. 207 was initially made in your petition for reconsideration of that standard. Our response to the petitions on Standard No. 207 was published or April 20, 1971. Your petition was denied to the extent that it requested that the requirement be amended to permit 2 inches of travel. However, it is recognized that continuously adjustable seats may have a certain small amount of travel that would not be harmful, and the notice accordingly indicates that they are considered to remain in their adjusted position despite such motion.

We expect that you have by now received our reply to your questions on Standard No. 208. Your inquiry first reached us through your Washington counsel and we accordingly sent our reply by the same route. Please advise us if further clarification is needed.

ID: nht71-5.59

DATE: 12/29/71

FROM: WALTER T. COX -- V. P., THEODORE BERGMAN COMPANY

TO: Recreational Vehicle Institute Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter to Frank Armstrong, Director of the Office of Standards Enforcement, National Highway Traffic Safety Administration, concerning the responsibilities of recreational vehicle manufacturers for whom the Bargman Lock Company is conducting a defect notification campaign.

The primary responsibility for conducting the defect notification campaign rests with the vehicle manufacturer. While, in this case, the campaigns are being conducted by the Bargman Lock Company on behalf of the various recreational vehicle manufacturers, it is the responsibility of the vehicle manufacturer to (1) assure that the Bargman Company is supplied a list of customers who purchased vehicles with non-complying door locks, and (2) make sure that the customer is, in fact, notified of the defect.

Since we have received samples of the defect letters the Theodore Bargman Company is sending the vehicle purchaser and the vehicle dealer, it is not necessary for the recreational vehicle manufacturers to send the National Highway Traffic Safety Administration copies of the defect notification letters as required under section 113(d).

Concerning the requirements of the Defects Reports Regulation (49 CFR 573), you are correct in your understanding that the regulation would not be applicable to the Bargman defect notification because the defect involved was determined to be safety-related prior to the effective date of the regulation.

ID: nht71-5.6

DATE: 11/22/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Trike Motor Company

TITLE: FMVSR INTERPRETATION

TEXT: You wrote some time ago to request information concerning the application of various motor vehicle safety standards to passenger cars with curb weights of less than 1,000 pounds. Contrary to the information you obtained from Motor Trend, this category of passenger cars is still exempt from the standards. There is a possibility that at some future date the exemption granted by 571.7(a) will be changed or revoked, but any such action can be taken only after opportunity for public comment.

Please advise us if you feel it necessary to have your remaining questions answered.

ID: nht71-5.60

DATE: 09/14/71

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Cabot Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of March 10 and July 1, 1971, requesting an exemption from Motor Vehicle Safety Standard No. 117 for experimental tires that you manufacture by buffing off the tread of new tires and then recapping the tires with different compounds. You state that you use these tires for testing carbon blacks by testing the tires on the public highways and on private test tracks.

We do not consider tires manufactured by the method you describe to be retreaded tires within the scope of Standard No. 117 because they are not manufactured from used tires. However, we do consider them to be new pneumatic tires, and subject to the requirements of Motor Vehicle Safety Standard No. 109. We regret that an earlier letter to you of April 7, 1971, may have been misleading in that regard.

Section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1397(a)(1)) provides that no person shall --

"manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce . . . any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect . . . unless it is in conformity with such standard."

We consider the testing of these tires on the public roads to be an introduction of them in interstate commerce, and prohibited by section 108(a)(1) unless the tires conform to Standard No. 109. The tires need not be manufactured for sale to the general public

in order for violations of section 108(a)(1) to occur. However, if the testing of these tires is confined to the laboratory or to private roads, the prohibition of the section 108(a)(1) will not apply to them.

A copy of the Act and Motor Vehicle Safety Standard No. 109 is enclosed for your information.

Enclosures

ID: nht71-5.61

DATE: 09/15/71

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: E. R. Buske Mfg. Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of September 3, 1971, to the Bureau of Motor Carrier Safety concerning the mounting of lamps on a body backplate has been referred to this Office for consideration and reply.

Federal Motor Vehicle Safety Standard No. 108 requires that lamps meet the applicable SAE Standards (including the photometric specifications) when tested as mounted on the vehicle. (See SAE J575c, Paragraph J.) The maximum angle from a line perpendicular to the longitudinal centerline of the vehicle that a lamp can be mounted and meet the applicable requirements depends upon the design and configuration of the lamp. We therefore recommend that you contact the manufacturer of your lamps for this maximum angle information.

ID: nht71-5.62

DATE: 11/11/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Tire Review

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 10 and October 6, 1971, concerning the size requirements for retreaded tires as specified in Federal Motor Vehicle Safety Standard No. 117. Your letter of August 10 enclosed a draft article that you requested we examine.

I have enclosed a copy of the Administration's action on the petitions for reconsideration that were received in response to the standard as published April 17, 1971 (36 F.S. 7315). This action amends the size requirements of 25.12 of the standard by allowing a minus 3 per cent deviation from the section width specified in Table 1 of Appendix A of Standard No. 109 in addition to the plus 10 per cent deviation previously allowed. With reference to your draft article, its discussion of the size requirements, apart from the changes made by the amendments, is accurate.

The copies of Appendix A or Standard No. 109 that you were furnished on August 20 have been supplemented, and a copy of the additional material is also enclosed.

WE ARE PLEASED TO BE OF ASSISTANCE.

ENCLS.

ID: nht71-5.63

DATE: 10/14/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: FWD Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of November 11, 1971, concerning the application of GVWR and GAWR (49 CFR Parts 567, 568) to semitrailers.

Your position is that the term "gross vehicle weight rating" is not meaningful when applied to semitrailers because the amount of cargo a semitrailer can carry depends upon the tractor that pulls it. You request that a different expression, "rating based on load-carrying capability" be used "for purposes of certification" (assumedly on the certification label). If that alternative is found unsatisfactory you request our concurrence with the following: "For semitrailers, GVWR shall be taken to mean the structural capability of the vehicle when supported by the king-pin and axles with the load uniformly distributed throughout its length." You also mention that gross vehicle weight rating has particular industry meaning and note that confusion "will certainly arise when state and Federal governmental authorities are using the same term to mean two different things."

As we indicated in our meeting with you of November 4, 1971, we do not agree that the concept of GVWR is meaningless when applied to a semitrailer. The definition of GVWR, "the value specified by the manufacturer as the loaded weight of a single vehicle" (49 CFR @ 568.3), can be applied to a semitrailer without considering the load-carrying ability of a tractor. The fact that certain tractors should not be attached to a particular semitrailer loaded to its GVWR does not mean that the trailer cannot be so rated.

With regard to your first question, "rating based on load-carrying capability," while we do not grant your request that this language be substituted on the label, we believe that a GVWR based on operational load-carrying capability, as long as the weight of the vehicle is included, would be within the definition of GVWR in

49 CFR 568.3. Similarly, your other statement, "For semitrailers, GVWR shall be taken to mean the structural capability of the vehicle when supported by the king-pin and axles with the load uniformly distributed throughout its length" is likewise consistent with the definition of GVWR. With reference to your claim concerning confusion of State and Federal regulation, we believe that if problems in this regard are properly presented to a State government, any ambiguities can be satisfactorily resolved.

You also ask, with reference to Gross Axle Weight(Illegible Word) whether speed limitations can be included on the certification label. The regulation does not allow such weight limitations to be included within the listing of the required information, although it may be placed on the vehicle in any other location.

ID: nht71-5.64

DATE: 10/14/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Truck Equipment & Body Distributors Association

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of September 8, 1971, you ask whether final-stage manufacturers may use the new vehicle certification label required as of January 1, 1972, before that date.

Your members may use the new label before January 1, 1972. Since the two vehicle weight ratings are not required until that date, there is no legal objection either to leaving the appropriate space blank, or to typing the phrase "NOT REQUIRED UNTIL 1/1/72" in the space provided.