ID: nht93-7.7

DATE: October 1, 1993 Est.

FROM: Bob Carver

TITLE: None

ATTACHMT: Attached to letter dated 11/22/93 from John Womack to Bob Carver (A41; Part 571; Std. 217)

TEXT:

I'm an engineer at Wayne Wheeled Vehicles, a commercial and school bus manufacturing company. My job here is to see ensure compliance to FMVSS 217, effective May 1994. I have a question for you in which I need an official ruling concerning FMVSS 217 S5.5.3(c):

Each opening for a required emergency exit shall be outlined around its outside perimeter with a minimum 3 centimeters wide retroreflective tape, either red, white, or yellow in color, that when tested under the conditions specified in S6.1 of 571.131 meets the criteria specified in Table 1.

If an emergency roof exit is required, is it necessary to outline it with the retroreflective tape even though it is not visible unless the bus is tilted on its side? Also, Charles Hott at NHTSA said that the width requirement will be revised to 1 inch. Can you confirm this?

Thanks in advance for your prompt consideration and assistance concerning this matter.

ID: nht94-1.16

TYPE: Interpretation-NHTSA

DATE: January 10, 1994

FROM: Adam A. Freund -- Manager, Testing Services, Standards Testing Laboratories, Inc.

TO: Walter Myers -- Office of Chief Counsel, NHTSA

TITLE: Table II Minimum Static; Breaking Energy (inch pounds) D.O.T. 119

ATTACHMT: Attached to letter dated 4/12/94 from John Womack to Adam A. Freund (A42; Std. 119)

TEXT:

Further to our telephone conversation of this date, please find enclosed a copy of subject matter for your perusal. As we had discussed I believe there is a typo in the highlighted columns marked respectively MOTORCYCLE and ALL 12 INCH OR SMALLER RIM SI ZE. If I am correct the first column MOTORCYCLE should show a plunger diameter of 5/16" and the column marked ALL 12 INCH OR SMALLER RIM SIZE should show a plunger diameter of 3/4".

I would appreciate your qualifying my interpretation of above subject matter. If my interpretation is incorrect, please advise me how the respective columns should be marked.

Standards Testing Laboratories, Inc. would greatly appreciate any expedited consideration you may allow us on this request.

ATTACHMENT

(Table omitted.)

ID: nht72-1.33

DATE: 06/27/72

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

TO: Checker Motors Sales Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 25, 1972, asking whether you, as a selling dealer, may install steel-belted radial ply tires on an 8-passenger Checker taxicab. You state that the vehicle is normally delivered to you with tires having the "D" load range.

Federal Motor Vehicle Safety Standard No. 110 (49 CFR 571.110, copy enclosed) requires each passenger car to be equipped at the time of sale to a first purchaser with tires of certain minimum load carrying capacity, based on the weight of the vehicle. Any steel-belted radial ply tire that meets these load carrying requirements with respect to your vehicles may be installed by a selling dealer.

Radial tires of similar or related sizes, but of different manufacture, however, may have different load ratings. We suggest, therefore, that you contact Checker Motor Corporation for their recommendations as to which radial ply tires may be installed on these vehicles without adversely affecting the vehicle's conformity with Motor Vehicle Safety Standard No. 110.

ID: nht75-6.33

DATE: 07/10/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Cooney Equipment Company

TITLE: FMVSR INTERPRETATION

TEXT: Your letter of June 17, 1969, to Mr. Donald Morrison of the Bureau of Motor Carrier Safety, concerning switching arrangements for running lamps, has been transferred to this Office for consideration and reply.

Enclosed for your information is a copy of Federal Motor Vehicle Safety Standard No. 108 on lighting requirements for motor vehicles. This standard is applicable to new vehicles manufactured on or after the effective date of January 1, 1969. Special wiring requirements, such as lamp switching arrangements, are included in paragraphs S3.4 through S3.4.7 of the standard.

We do not completely understand your usage of the term "running lights." If you are referring only to tail lamps, your attention is invited specifically to paragraph S3.4.3 of the standard which is quoted as follows: "As a minimum the tail lamps shall be illuminated when the headlamps are illuminated except when the headlamps are being flashed." The switching arrangements for other "running lights," such as clearance lamps and identification lamps, are at the option of the vehicle manufacturer.

Thank you for writing.

ID: nht76-2.50

DATE: 02/09/76

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Gillig Brothers School Bus Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your request for information concerning methods of ensuring the compliance of school buses with the barrier crash test requirements of Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity.

Standard No. 301-75, while establishing minimum performance levels, does not specify any particular design requirements for school bus fuel systems. A manufacturer is free to design his vehicles in the manner that he believes most appropriate to ensure compliance. To this end, you may find helpful information in a study by Dynamic Science entitled School Bus Safety Improvement Program. The NHTSA cannot assure you, however, that following the suggestions contained in the study will guarantee that your school buses will comply with the standard.

The study is filed in the NHTSA's public docket as document number 75-03-GR1. Copies may be obtained by writing to:

Technical Reference Branch National Highway Traffic Safety Administration Room 5108 400 Seventh Street, S.W. Washington, D.C. 20590

You should refer to the following publication numbers: HS 801-615, -616, and -617.

ID: nht92-4.48

DATE: August 6, 1992

FROM: R.J. Misorski -- Director, Maintenance & Repair, Maersk Inc.

TO: Legal Council, NHTSA

COPYEE: A. Petrizzo, W. Drozd

TITLE: None

ATTACHMT: Attached to letter dated 8/21/92 from Paul J. Rice to R.J. Misorski (A39; Std. 108)

TEXT:

Attached is a copy of the Federal Register outlining your rule change that went into effect December 1, 1991.

The new rule now requires a minimum of 12 square inches of lens area for rear stop or turn signals on vehicles over 80" wide, regardless of the separation between lamps. We feel that equipment manufactured prior to December 1991 would be exempt from this ruling. Our interpretation of this new rule is that it only applies to equipment that is manufactured after December 1, 1991.

We would highly appreciate if you could confirm our understanding in writing in order that we may ensure compliance with our equipment fleet.

Attachment

Copy of page 20158 of the 5/15/90 Federal Register pertaining to 49 CFR Part 571, Federal Motor Vehicle Safety Standards; Lamps, Reflective Devices, and Associated Equipment (action: final rule). (Text omitted)

ID: nht91-5.51

DATE: September 17, 1991

FROM: Jeffrey P. Shimp -- Engineer, Fleet Engineering & Q.A., Transportation Department, Baltimore Gas and Electric

TO: Mary Versailles -- NHTSA, Office of Chief Counsel

TITLE: None

ATTACHMT: Attached to letter dated 10-9-91 from Paul Jackson Rice to Jeffrey P. Shimp (A38; VSA S108(a)(2)(A))

TEXT:

In order to better serve our customers, we have found it necessary to increase the size of our work crews from two men to three men in one of our departments. Due to the amount of material required for these crews, we have typically utilized (two passenger) cargo vans for this operation. In view of the above, we would like to install a third seat in our cargo vans (mini and/or short wheel base), which are delivered by the manufacturers as a certified completed vehicle.

We would greatly appreciate it if you could provide a written response advising us on this issue so that we can be in compliance with the Federal Motor Vehicle Safety Standards and any other governing regulations.

If I can be of any assistance to you, please feel free to contact me (301/281-3630).

ID: nht90-1.99

TYPE: Interpretation-NHTSA

DATE: April 5, 1990

FROM: Richard E. Portors -- Vice President and General Manager, Royale Limousine Manufacturers

TO: Zachary R. Fraser -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 8-30-90 from P.J. Rice to R.E. Portors (A36; Std. 108)

TEXT:

Please give me an advisory on my understanding of requirement 571.108 - S4.1.1.41 high mounted stop lamps section (a) projected area of not less than 4 1/2 square inches.

The 90 Cadillac stop lamps measure 6 sq. inches of area. When installing a boomerang TV antenna the shaft area displaces 1.125 sq. inch of area, this would leave an exposed area of 4 7/8" of light and would exceed the minimum requirements of section (a) . Also, section (b) would not be affected by the boomerang. Without window glazing, section (c) would not be affected either. I feel the boomerang antenna positioned properly would not affect the requirements of 571.108.

Please advise me on your findings as soon as possible.

Attached is a copy of the Federal Register, section 571.108, 49 CFR Ch. V (10-1-85- Edition), page 218 (text omitted)

ID: nht94-2.49

TYPE: INTERPRETATION-NHTSA

DATE: April 19, 1994

FROM: S. Greiff -- PARS, Passive Ruckhaltesysteme GmbH

TO: Chief Counsel -- US Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 6/8/94 From John Womack To S. Greiff (A42; Std. 208)

TEXT: Per Fax: 001/202-366-3820

Your "Laboratory Test Procedure For FMVSS 208/212/219/301"

Gentleman:

PARS is a company developing occupant restraint systems for the world wide automotive industry. One of our major topics is the development of airbag systems.

For development and validation of the restraint systems we own a Barrier Impact Test Facility which was built up in 1993 new.

Our runway is 80 m (260 feet's) long. The velocity tolerance up to 60 kph is +/- 0.1 kph.

In your Laboratory Test Procedure for FMVSS testing, a minimum runway length of 500 feet is requested.

We would like to ask you for an interpretation of your "500 feet requirement".

It would be much appreciated, if we could get an answer by fax.

Our fax no. is: 01149/6023/942-133

Thank you very much for your efforts in advance.

Sincerely yours

ID: nht94-4.53

TYPE: INTERPRETATION-NHTSA

DATE: October 14, 1994

FROM: Randal Busick -- President, Vehicle Science Corporation

TO: Mary Versailles, Esq. -- Office of the Chief Counsel, NHTSA

TITLE: Re: Request for interpretation of FMVSS 208 S7.1.2

ATTACHMT: Attached to 1/5/95 letter from Philip R. Recht to Randal Busick (A43; Std. 208; Std. 210)

TEXT: Dear Ms Versailles:

This is to request a clarification of FMVSS 208 S7.1.2. More specifically, would a seat belt system as shown on the attached drawing be in compliance with S7.1.2 as a so-called "semi-integrated" seat belt?

As shown on the drawing, the inboard lower FMVSS 210 anchorage, n1 is located on the seat frame and thus, as the seat moves fore and aft, the system allows a minimum of two seat belt adjustment positions and the distance between the two extreme adjustmen t positions of the system is more than 5 cm.

n1 The belt which holds the buckle is attached to this inboard anchorage.

We look forward to your response. If you have any questions, kindly contact the undersigned.

Sincerely

Enclosure

(Drawing omitted.)