ID: nht73-5.2

DATE: 08/30/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Multinational Industries

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 12, 1973, concerning gas tank caps. You state that you are considering marketing imported gas tank caps for trucks, and you want to know whether there is a Federal standard to which such caps must conform. The answer is that there is not.

Multinational Industries

July 12, 1973

National Highway Traffic Safety Administration

Attention: Chief Counsel, Lawrence Schneider

We are considering the marketing of Gas Tank caps manufactured in Japan for use on trucks in the United States.

As there may be some problems importing these items, I would like your opinion on the following questions:

Is there any current Federal Standard to which gas tank caps must conform?

If so, how is such compliance established?

Must the gas tank cap bear any symbols mentioning this compliance?

If so, please be specific.

Thank you for your valuable time.

Richard Kuskin, President

ID: nht73-5.20

DATE: 01/15/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 14, 1972, concerning the acceptability, under S7.4 of Standard 208, of a time delay device in a belt interlock system.

As described in your letter, the delay device would permit an occupant who has operated the belt in the correct sequence to lift off the seat while buckled for a brief period before attempting to start the vehicle. Under S7.4 as presently constituted, this action by the occupant would result in the belt's being buckled before the seat is occupied. The occupant would therefore have to unbuckle the belt and rebuckle before starting the car. A time delay device, in short, would not be allowable.

We make no comment that this situation is desirable or undesirable, but it is, however, required by the language of S7.4.

NISSAN MOTOR CO., LTD.

December 14, 1972

Lawrence R. Schneider National Highway Traffic Safety Administration

This is to request your interpretation of MVSS 208, S7.4, Belt Interlock System.

QUESTION 1

Would a belt interlock system utilizing a time delay device, which works as shown in the enclosed illustration, in order to avoid the following situation meet MVSS 208, S7.4?

SITUATION

If a front seat occupant, after buckling his seatbelt, were to move in such a way as to lift himself from the seat for any reason before starting the engine, that person would be required to unbuckle and rebuckle in order to start the engine. This situation is not only inconvenient to the customer but also may alarm him as he may not realize why the engine does not start although he has done the proper process.

QUESTION 2

Should the abovementioned interlock system meet MVSS 208, how many seconds (3 or 5) delay ("t" see illustration) will be acceptable?

Due to a very short lead time a prompt reply would be greatly appreciated.

Satoshi Nishibori Engineering Representative Liaison Office in USA

FUNCTION OF TIME DELAY DEVICE

(Graphics omitted)

ID: nht73-5.21

DATE: 09/19/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Pundalik K. Kamath

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of August 7 and August 23, 1973, concerning the conformity to Standard No. 121 of certain features in air brake systems submitted to you by suppliers.

Your first question is whether the volume of a supply reservoir that lacks a check valve is to be included in arriving at the required reservoir volume of 12 times the full-travel service brake chamber volume. Our reply is that S5.1.2.1 includes the volume of all service and supply reservoirs, regardless of valving, and that the volume of the supply reservoir in question would therefore be included in the combined reservoir volume.

You next ask whether a system that has no isolated emergency reservoir can rely on its service reservoirs to provide air for the two emergency stops proposed as S5.7.3 by Docket No. 73-13, Notice 1 (38 F.R. 14963). Under this proposal, the stops would have to be accomplished with a single failure of a part (other than a common valve, manifold, brake fluid housing or brake chamber housing) designed to contain compressed air or brake fluid. If the system is designed so that no single failure, other than a valve, manifold, or housing failure, will cause a loss of air in both tanks, it would seem to be capable of meeting the proposed requirement even though it does not have an isolated emergency reservoir. However, if a single failure in a brake line would deplete the air in both service reservoirs, the system would be unable to meet S5.7.3 unless an emergency isolated reservoir were provided.

2

In answer to your last question, the emergency stops proposed in S5.7.3 would be conducted from an initial pressure in excess of the compressor cut-in pressure. The reservoirs would not be depleted by prior stops.

Yours truly,

August 7, 1973

Lawrence Schneider Chief Counsel National Highway Traffic Safety Administration

Enclosed are schematic copies of air brake systems provided to OTC by Berg Manufacturing Company and Bendix-Westinghouse Air Brake Division which illustrate air brake systems incorporating provision for secondary brakes per the Notice of Proposed Rulemaking, Docket 73-13, Notice 1.

Our concern is if these systems, which are essentially the same, will meet the proposed change to FMVSS 121 when effective, particularly paragraph S5.7.3 as proposed? While we see no reason they would not OTC would like an opinion from your office before we adopt either system.

We would like said opinion as soon as conveniently possible to assist in our brake program execution. Thank you.

OSHKOSH TRUCK CORPORATION

Pundalik K. Kamath Senior Safety Engineer

Enclosures

August 23, 1973

Lawrence Schneider Chief Counsel National Highway Traffic Safety Administration

With reference to my letter dated, August 7, 1973, regarding compliance of the air brake systems proposed by Berg Manufacturing Company and Bendix-Westinghouse Air Brake Division with FMVSS 121 per Proposed Rulemaking, Docket 73-13, Notice 1, particularly with respect to the following questions, I would like to receive clarification from you.

1. Is it correct to use the supply reservoir volume, which is not protected by a check valve, when calculating the total volume of twelve times full stroke chamber volume? Our assumption is that this is acceptable however, we would like confirmation.

2. These systems have no isolated emergency reservoir and rely on air pressure from one of the two service reservoir sources, assuming a failure in the other service reservoir source, for the minimum two stop capability in modulated emergency mode. This implies a single failure affecting only one service reservoir system, it is our understanding that this is acceptable practice per the proposed standard. Please confirm.

3. We understand that a modulated emergency stop condition implies a fully charged service reservoir, that is 100-110 psi in the functional reservoir, that no normal stops which temporarily drop this pressure to 80-90 psi immediately prior to the failure condition are considered. In the latter case two modulated emergency stops may not be obtainable due to the lowered pressure. Please confirm that the baseline condition assumes at least one service reservoir is normally charged to 100-110 psi before simulating failure.

We would appreciate your reply to these questions, as soon as conveniently possible.

OSHKOSH TRUCK CORPORATION

PUNDALIK K. KAMATH Senior Safety Engineer

ID: nht73-5.22

DATE: 09/19/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: International Bicycle Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 21, 1973, to Dr. Gregory concerning your wish to import and sell an "electric moped".

Although you did not enclose a pamphlet on the Electra, we are familiar with the conventionally powered mopeds. Two-wheeled powered vehicles are "motorcycles" for purposes of the Federal motor vehicle safety standards and must comply with standards applicable to that category. In addition to Standard No. 108, standards applicable to motorcycle controls (No. 122) and brake systems (No. 123) became effective January 1, 1974 and September 1, 1974, respectively. The standards are found in Table 49 Code of Federal Regulations Part 571.

The manufacturer of the vehicle, or the importer as a statutory manufacturer, certifies on the basis of his own tests or other engineering information that the vehicle meets all applicable Federal standards at the time of its manufacture. The regulation for this requirement is Part 567 of Title 49. It is a self-certification procedure, subject to penalties for noncompliance, and no "approval" is obtained from this agency.

Part 555 of Title 49 Sets forth the procedures for applying for temporary exemption from any standard on one of four grounds. Of interest to you will be the exemption procedure for hardship and facilitation of development of low-emission vehicles.

I enclosed an information sheet telling you where you may obtain these materials.

ENC.

International Bicycle Corporation

August 21, 1973

Dr. James Gregory Administrator National Highway Traffic Safety Administration

We are enclosing a pamphlet on an electric moped sold on the East Coast as the Solo Electra, and intended to be sold on the West Coast as the International Electra. The units will be identical.

With the help of the California Motor Vehicles Department, we licensed our demonstrator model, only to find out later from the Highway Patrol that more requirements must be met.

We now understand that we must obtain certification that the Electra meets Federal Motor Vehicle Safety Standards, and also that it must conform to Federal Standard 108. We need to know what is involved in obtaining this certification. In addition, we were informed that the lights must be on the California approved list, which is a minor problem we can look after without difficulty.

In our opinion, an inexpensive electrically powered commuter vehicle replacing some use of automobiles is very desirable from many points of view. However, we do not feel that it will become a volume item for some time, and doubt that 1000 annually will be sold for the next few years. Therefore, while we would like to import and sell these Electras, we are not in a position to go to a great deal of expense in meeting standards which Honda, and other major manufacturers can handle without difficulty.

We would appreciate knowing what must be done so that we can weigh the costs against sales potential, and drop this project if it appears to be too difficult or too expensive.

A. E. Davies Vice President

ID: nht73-5.23

DATE: 09/20/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Auto Safety Research Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 27, 1973, which requests information on the requirements of Standard 206, Door Locks and Door Retention Components, and suggests that door locking mechanisms should prevent operation of the inside and outside handles latch release controls) of both front and rear doors.

The standard presently requires that engagement of the front-door locking mechanism on passenger cars, multi-purpose passenger vehicles, and trucks render the outside door handle (latch release control) inoperative. On passenger cars and multipurpose passenger vehicles, engagement of the rear-door locking mechanism must render both inside and outside handles inoperative. Your suggestion that inside front door handles also be rendered inoperative was proposed in 1967 as an initial standard, but it was determined at that time that ease of escape in the event of accident made one-step operation of the door more desirable. It was concluded that the vehicle operator would have sufficient control over children in the front seat to permit such override operation.

We are still interested in the best arrangement of locking mechanisms and override at the various seating positions. At the moment, available accident data does not justify further rulemaking. Your comments will be fully considered in the event we decide to take further action.

AUTO SAFETY RESEARCH CENTER

June 27, 1973

U.S. Department of Transportation

Dear Sir;

We were under the impression that, since about 1968, an automobile door, once locked, could not be opened from either the outside or inside, unless it was subsequently unlocked, and that there were Federal regulations to this effect. However, at least on some 1973 cars, the doors can be opened from the inside, even while locked, and a number of people have come to us both surprised and concerned that children and others can open a supposedly locked door.

Please advise us if there is indeed a Federal regulation concerning door lock operation. If there is no regulation to the effect that the door handles, both inside and outside, are rendered inoperative when the door is locked, then may we suggest that, from a safety standpoint, such a regulation should be adopted as soon as possible.

Sincerely,

Delbert A. Russell, Jr. Director

ID: nht73-5.24

DATE: 09/21/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. John Holzer

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 7, 1973, requesting information concerning possible regulatory action involving plastic or gas filters.

Although we have no regulation concerning gasoline filters, the law under which our regulations are promulgated requires that where possible, our standards be based on performance rather than design requirements. This gives the automotive manufacturers maximum flexibility in conforming with the requirements and provides freedom to select whatever design he prefers in order to meet the requirements of the standard.

Our current fuel system requirements are contained in Federal Motor Vehicle Safety Standard No. 301, Fuel Tank Filler Pipes and Fuel Tank Connections, which was effective January 1, 1968. A copy of this standard is enclosed for your information. We have recently issued an amendment to the standard and a proposed amendment which are intended to substantially upgrade fuel systems of motor vehicles between September 1, 1975 and September 1, 1977. Copies of these rulemaking actions are enclosed for your information (38 F.R. 22397 and 22417).

Motor vehicle manufacturers are free to choose the components and designs which they consider most appropriate to their performance requirements. It is quite possible that certain components cannot be used as original equipment because of periodic regulatory actions; for example, a manufacturer may consider a glass fuel filter hazardous when he is attempting the preservation of fuel system integrity incidental to a 30 mile-per-hour, fixed barrier collision.

We would suggest that contact be made with the automotive manufacturers and original equipment manufacturers for a more complete answer to your question.

If we can be of any further assistance, please do not hesitate to contact us.

Sincerely,

September 7, 1973

Department of Transportation National Highway Traffic Safety Administration

Dear Mr. Secretary,

I would like to know if your department has or will propose any motor vehicle safety standards in the area of plastic or glass gas filters.

I am a distributor of these products and I have heard they will be outlawed or restricted in use in 1974. My name and address are,

John Holzer 217-18 64th Ave. Bayside, New York 11364 Sincerely yours,

John Holzer

ID: nht73-5.25

DATE: 10/14/73

FROM: AUTHOR UNAVAILABLE; E. T. Driver for R. L. Carter; NHTSA

TO: R. Debesson - E.T.R.T.O.

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your(Illegible Words) 71, dated September 14, 1973,(Illegible Word) that the(Illegible Words) designation in incorrectly stated in Appendix A of Standard No. 109, Table(Illegible Words) will be changed to(Illegible Words) will make the necessary correction in the next quarterly(Illegible Word)

The National Highway Traffic Safety Administration(Illegible Words)(Illegible Lines) on or about October(Illegible Words) April 1, and July 1 of each year. It is anticipated that your(Illegible Words) will be published in the Federal Registra on or about January 1, 1974.

The addition of(Illegible Words) designations to the table is accomplished through(Illegible Words) publication in the(Illegible Words)(Illegible Line)(Illegible Lines) pursuant to(Illegible Words) motor vehicle standards will be considered.

ID: nht73-5.26

DATE: 10/11/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Robertson Tank Lines, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 30, 1973, requesting a DOT code number for retreaded tires you manufacture. It appears from your letter that the tires you retread are truck tires intended solely for your company's own use.

Any tires retreaded by and solely for use by Robertson Tank Lines are exempt from NHTSA recordkeeping requirements and a code number is not required. As truck retreads are not subject to any Federal motor vehicle safety standard, you are also not required to place a "DOT" symbol on them. If you retread passenger car tires, however, you are required to place a "DOT" symbol on the tire sidewall (indicating conformity to Federal Motor Vehicle Safety Standard No. 117).

ROBERTSON TANK LINES INC.

August 30, 1973

Tire Identification and Recordkeeping Dept. National Highway Traffic Safety Administration

Dear Sir:

The attached form is our request for a tire retread D.O.T. number. Tires produced in our shop will be for our fleet use, with no resale of our tires or services.

Our main office address is:

Robertson Tank Lines, Inc. P.O. Box 1505 Houston, Texas 77002

Retread shop address:

Robertson Tank Lines, Inc. Maintenance Terminal 2401 Battleground Rd. Deer Park, Texas 77536

Thank you for your consideration in handling this matter.

Best Regards,

Donald Gary Hayes

cc: Bob Partain

Date: August 29, 1973

Tire Identification and Recordkeeping National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Gentlemen:

I hereby apply for a Retread Tire Identification Code Mark as a manufacturer of retread tires.

The following information is offered:

Retread Plant

Name:(Illegible Words)

Street:(Illegible Words)

City & State: DEERPARK(Illegible Word)

Zip Code: 77536

Telephone No. 479-3451 EXT 52

Main Office

Name:(Illegible Words)

Street:(Illegible Words)

City & State: Houston, Texas

Zip Code:(Illegible Word)

Telephone No: 623-0000

Types of Tires Retreaded

Truck:

Applicants Signature:(Illegible Words)

ID: nht73-5.27

DATE: 10/18/73

FROM: AUTHOR UNAVAILABLE; R. B. Dyson for L. R. Schneider; NHTSA

TO: Schultz, Evans and Burns

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 28, 1973 to Secretary Brinegar, concerning outside rear view mirrors.

The existing standard (No. 111) on Rearview Mirrors, is found in Title 49, Code of Federal Regulations @ 571.111. Paragraph S3.2 establishes requirements for outside mirrors. This standard applies to all passenger cars and multipurpose passenger vehicles manufactured since January 1, 1968, and establishes requirements for original equipment mirrors. It does not apply to mirrors manufactured for the aftermarket.

SINCERELY,

SCHULTZ, EWAN AND BURNS

September 28, 1973

Claude S. Brinegar, Secretary of Transportation

Dear Sir:

I am anticipating a possible suit against one of the American automotive manufacturers. The basis of this suit would be the dangerous design and manufacture of an outside side view mirror.

Pursuant to the Federal Traffic and Motor Vehicle Safety Law Chapter 38 USCA @ 1392(a), your office is to establish motor vehicle safety standards. I would greatly appreciate all standards promulgated by your office pertaining to side view mirrors which were in effect for the 1973 model year.

Yours truly,

William C. Burns

ID: nht73-5.28

DATE: 03/05/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Sekurit-Glas Union GmbH

TITLE: FMVSR INTERPRETATION

TEXT: We have received your letter of February 22, 1973, submitting material to our Docket 70-7, Fields of Direct View.

Under our procedural regulations 49 CFR @ 553.21, all submissions to a regulatory docket must be in English. We are placing your letter in the docket, but if you wish to have your report entered we must receive an English translation.

YOURS TRULY,

U.S. DEPARTMENT OF TRANSPORTATION National Highway Traffic Safety Administration

February 22 1973

Gentlemen:

We apologize for replying so late to your letter dated September 26th 1972 about our comments to Docket 70-7 (Notice 2).

Most of the tests which are mentioned in details in our comments have been realized by our company and have therefore no official signification. Concerning this matter detailed investigations have been conducted by the Medical Superintendent of the "Augenabteilung und der verkehrsmedizinisch-ophthalmologischen Untersuchungsstelle am(Illegible Word) Krankenhaus Othmarsche (Hamburg)" Priv.-Doz. Dr. Gramberg-Daniclsen. Owing to printing and editing reasons these investigations will be published in April 1973 only, in the "Klinische Monatsblatter fur Augenheilkunde" by Ferdinand Enke. In order to avoid a further waste of time we send you, enclosed, a copy of this manuscript, which shows that the thickness of the wires does not affect the driver.

We hope that this information will be helpful in your analysis of comments to the above mentioned Docket.

Sincerely, SEKURIT-Glas Union GmbH.

Encl.