ID: nht91-7.49

DATE: December 18, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Masashi Maekawa -- Director, Technical Division, Ichikoh Industries, Ltd.

TITLE: None

ATTACHMT: Attached to letter dated 11-27-91 from Masashi Maekawa to Paul Jackson Rice (OCC 6714)

TEXT:

This responds to your letter of November 27, 1991, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it relates to a specific vehicle design.

Your letter depicts a combination tail/stop lamp that would be mounted on the deck lid ("Lamp B"), immediately adjacent to a combination tail/stop lamp that is mounted on the vehicle body ("Lamp A"). Each lamp complies with the requirement for effective projected luminous lens area, but neither complies with photometric requirements. You have asked whether, under S5.1.1.6 it is possible to consider the two adjacent lamps as one lamp for purposes of measuring the photometrics for tail and stop lamps, and, if so, whether the requirements for one or two lighted sections will apply.

S5.1.1.6 covers requirements for replacement stop lamps, and does not appear relevant to our question. We have, however, addressed before the question that you raise. It is not possible to consider the two adjacent lamps as one lamp for purposes of measuring the minimum photometrics required under Standard No. 108. We regard the lamp that is located on the body, Lamp A, as the lamp that must be designed to conform to all applicable requirements of Standard No. 108, including photometrics. In that location, Lamp A meets the requirement that stop/taillamps be located as far apart as practicable, whereas Lamp B would not. The requirements that would apply to Lamp A are those for lamps with a single lighted section. Since your letter indicates that Lamp A does not meet photometric requirements, Lamp A would be a nonconforming lamp. Lamp B is permissible as supplementary lighting equipment and need not meet the photometric or location requirements in order for the vehicle to comply with the standard. Thus, Lamp B would be permissible in its present state. (The sole restriction that Standard No. 108 imposes upon supplementary lighting equipment is that it must not impair the effectiveness of required lighting equipment; that possibility does not appear to exist in this design, where the two lamps are intended as complementary).

ID: nht92-8.47

DATE: February 21, 1992

FROM: Masashi Maekawa -- Director, Technical Division, Ichikoh Industries, Ltd.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: Re: Request for the interpretation of photometric output requirements for tail/stop lamps on passenger cars

ATTACHMT: Attached to letter dated 4/10/92 from Paul Jackson Rice to Masashi Maekawa (A39; Std. 108)

TEXT:

Thank you for your answering letter dated Dec. 18, 1991 to our questions concerning the interpretation of photometer output requirements for tail/stop lamps on passenger cars dated Nov. 27, 1991.

We had some questions as follows regarding positions stated in the letter from NHTSA.

1. NHTSA stated in the letter dated Dec. 18, 1991 as follows;

" It is not possible to consider the two adjacent lamps as one lamp for purpose of measuring the minimum photometrics required under standard No. 108."

But another letter from NHTSA dated June 28, 1985 addressed to Mazda (North America), Inc. stated as follows;

" We also discuss the implications of a stop lamp and tail lamp constructed so that a portion is fixed to the body of the vehicle adjacent to the decklid opening and the remaining portion is mounted on the outboard area of the decklid.

Compliance of a vehicle is determined with respect to its normal driving position, that is to say, with the tailgate, hatch, or decklid closed."

We realized the noticeable difference between those two letters. We have been designing and testing lamps until now according to the interpretation dated June 28, 1985.

2. As the interpretation of the testing method concerning photometer output requirements of lamps mounted onto both the moving vehicle part and the rigid vehicle part is not written in FMVSS No. 108, we have been designing those lamps to comply with photometer output requirements by using both lamps mounted onto the moving vehicle part (Lamp-B) and the rigid vehicle part (Lamp-A), in accordance with the sentence "The device shall be mounted in its normal operating position." of J (Photometry) of SAE J575e incorporated in FMVSS No. 108.

For the reason mentioned above, we would like to ask whether your stance concerning the interpretation of those lamps has been changed or not.

Kindly let us know your opinion concerning the above matters.

ID: nht90-2.65

TYPE: INTERPRETATION-NHTSA

DATE: 05/31/90

FROM: STEPHEN P. WOOD -- NHTSA ACTING CHIEF COUNSEL

TO: SUICHI WATANABE -- GENERAL MANAGER AUTOMOTIVE LIGHTING ENGINEERING CONTROL DEPARTMENT STANLEY ELECTRIC CO., LTD.

TITLE: NONE

ATTACHMT: LETTER DATED 03/19/90 FROM SHUICHI WATANABE TO ERIKA Z. JONES -- NHTSA; OCC 4549

TEXT: This is in reply to your letter of March 19, 1990, asking whether a new combination rear lamp is permitted under Motor Vehicle Safety Standard No. 108.

The lamp consists of three compartments. In its normal operating mode, when the taillamp and/or stop lamp are activated, all three compartments show a red light. Your question arises with respect to three different operating modes. The first occurs whe n the turn signal is activated; the red light in one of the compartments is replaced by an amber flashing one. The second occurs when the backup lamp is activated; the red light in another of the compartments is replaced by a white steady-burning one. The third occurs when both the backup lamp and turn signal are activated; in this event, the combination lamp would present an amber flashing light, a red steady-burning one, and a white steady-burning one. You have informed us that "the requirement of photometric and lighted area for each lamp function comply to FMVSS No. 108 and related comply with requirements for one and three compartment lamps when operating with one or three compartments (we assume that they would also meet the requirements for t wo compartment lamps).

The lamp appears to be intended to fulfill the requirements of Standard No. 108 for turn signal, stop, tail, and backup lamps. Thus, your question appears to be whether Standard No. 108 requires separate lamps or compartments dedicated to a specific pur pose, or whether your multiple purpose lamp is acceptable.

Standard No. 108 does not prohibit a combination of the functions that any chamber of your lamp provides. When a specific function is activated, the lamp will perform that particular function in a manner that appears to meet the minimum standard establi shed by Standard No. 108. Assuming that the CIE color definitions for white, amber, and red are met by the backup, turn, and stop/tail functions, the lamp appears to be permissible under Standard No. 108.

Sincerely,

ID: nht87-2.94

TYPE: INTERPRETATION-NHTSA

DATE: 09/17/87

FROM: WILLIAM E. LAWLER -- INDIANA MILLS AND MANUFACTURING INC

TO: ERICA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 10/14/88 TO WILLIAM E. LAWLER FROM ERIKA Z JONES, REDBOOK A32, STANDARD 208, STANDARD 209

TEXT: Dear Chief Counsel:

We are writing to you to request an official interpretation of portions of FMVSS 208 and 209 with regard to a Type 2 Seat Belt Assembly designed by a customer and ordered by him for installation at a static (non-suspension) driver's seat in a vehicle wit h a GVWR exceeding 10,000 pounds.

The proposed seat belt assembly incorporates an automatic locking retractor to be mounted at the left of the driver's seat and a free-sliding latchplate engineered to remain in view and easy reach when not in use. The webbing is continuous from the retr actor to the anchored end of the upper torso restraint which would be installed above, slightly behind and to the side of the seat occupant. The strengths of all components and the strength of the assembly itself comply with FMVSS 209.

The latter half of 49CFR 571.209 S5.2(i) deals with automatic-locking retractors and their tendency to cinch the seat belt assembly webbing against the occupant while riding on rough roads. In addition, 49 CFR 571.208 S4.2.2, S4.1.2.3, and S7.1, though dealing with lighter vehicles, seem to imply the intent of minimal upper torso restriction. These sections of FMVSS 208 and 209 have been discussed with our customer.

In our opinion, two modifications to the customer's design will convert the continuous webbing feature into separate lap belt and upper torso restraints which will allow his proposed design to comply with the sections of FMVSS 208 and 209 referenced abov e: 1. sew the latchplate to the webbing at a specified location in order to create a standard lap belt 2. place a manual adjusting device in the upper torso restraint.

Our customer has agreed to postpone the order on his original design and use the option we are suggesting until we have received an official opinion from The National Highway Traffic Safety Administration.

If you have further questions, please contact me.

Sincerely,

ATTACHMENT

[DRAWING OMITTED] ALR, 3PT. SYSTEM

ID: 09-001535 206

ID: 10932-2

Milford R. Bennett, Director
Safety Affairs and Safety & Restraints Center
General Motors Corporation
30200 Mound Road
Warren, Michigan 48090-9010

Dear Mr. Bennett:

This responds to General Motors' (GM's) May 19, 1995 letter asking whether a sunshade device is permitted under the 70 percent light transmissibility requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials. You describe the device as a screen-like device that is stowed in the back panel shelf area below the rear window and that can be electrically raised and lowered by a driver operated switch. The light transmissibility through the combination of the rear window and the raised sunshade is less than 70 percent. The short answer to your question is that the device is permitted.

Although you note earlier agency interpretations stating that windows with sunshades must still comply with Standard No. 205, you believe that the standard does not apply to your device. You state that those interpretations were distinguishable because the other shading devices were attached to the window, while your device is not.

You are correct in your assertion that installation of your sunshade would not cause a noncompliance with Standard No. 205. The purpose of the 70 percent light transmissibility requirements in Standard No. 205 is to ensure that the driver can see 70 percent of the incident light through the windows that are requisite for driving visibility, under all conditions of lighting. However, the test procedures do not incorporate an in-vehicle test. Instead, they contemplate testing only the glazing itself. Your mesh screen sunshade need not comply with the standard (because it does not meet the definition of glazing) or in combination with the rear window (because it is not attached).

Although our standards do not prohibit this device, we have some safety-related concerns with its use in inappropriate situations. NHTSA hopes that GM plans to take steps to minimize the likelihood that the sunshade will be raised in such situations.

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

Sincerely,

John Womack Acting Chief Counsel

ref:205 d:9/1995

ID: nht93-4.21

DATE: June 3, 1993

FROM: Richard Glover -- Director of New Product Development, Evenflo Juvenile Furniture Company, Inc.

TO: Deirdre Fujita -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 10/20/93 from John Womack to Richard Glover (A41; Std. 213)

TEXT:

I had attempted to call you concerning the possibility of including a bar code which could be automatically scanned at the bottom of the Car Seat Registration Card which consumers fill out. This bar code would contain model number, date of manufacturer, and serial number for the product that the card represents. We feel that by adding an automatically scanned bar code section to the card, that it will eliminate the possibility of mis- keying any of this information, in as much as the human element has been removed from the card. We would request a white section to be allowed in the portion of the card which is currently specified to be a 10 percent minimum gray scale background. I have sent you a mock up of the possible location that this bar code may reside in, for your consideration. We have noticed on the cards which are coming back to us at Evenflo so far, that if any postal damage has occurred to the card, that is very likely to occur on the bottom edge of the card. As a result of that, it may be more advantageous to move this white space into the area immediately below the area that the consumer fills in. It would be approximately the same width as the zone that the consumer fills in, and simply be a white space slightly further down into the card. It would leave the gray background around the outside perimeter of the card and would allow us space to openly print the model number, date of manufacture, and serial number in case there were any difficulties in bar code reading.

I would appreciate your consideration of this matter. Please advise us, as we are near the point of having to print additional cards at this time, and release printing lots to our printing company are at a rate of 500,000 cards per lot. If this will require a petition for a change in the current rules, please advise me so that we may petition as soon as possible. I remain,

Attachment (Child Restraint Registration Card) omitted.

ID: nht93-4.32

DATE: June 13, 1993

FROM: Charlie McBay -- Chief Engineer, Barrett Trailers, Inc.

TO: Office of Chief Counsel, NHTSA

TITLE: Conspicuity

ATTACHMT: Attached to letter dated 7-14-93 from John Womack to Charlie McBay (A41; Std. 108)

TEXT:

This letter asks that the Office of Chief Counsel review the enclosed drawings (Model 80MP6-DD & GNXS-207) for compliance of the upcoming conspicuity treatment.

As you can see, both models have "outside post" design and air gaps that run through the sides and rear of the trailer. Air gap quantity and locations vary with different designs.

2" red and white alternating pattern used on sides and rear. 2" white on upper rear corners.

Note: Location of side material as close to 4ft. off the ground as possible. In the center the location stays on the bottom rail (due to air gaps) and ranges from 14" to 20" off the ground.

Reflector material to be a 14" strip placed in center of each opening between side post. This length meets the 50% coverage requirements.

Note that post spacing throughout the length of the trailer is not the same. Evenly distributed material will be in most areas, but breaks between material vary. Will this suffice for evenly distributed? Also, if we have an area where a minimum 12" strip will not fit, can we install smaller material or must this area stay blank?

Note that white strips in upper rear corners do not meet. Must white be touching or can there be a gap between the strips? Our design makes it near impossible to make a nice continuous square corner. Installation of the white corners is also closer than 3" from red top rail lights. Is there any tolerance on the 3" dimensions? One full width red and white strip on rear of trailer on both models as close to 4ft. off the ground as possible.

Enclosed are drawings of proposed installation as close as we can get to meeting the requirements outlined. (The yellow hi-lited areas represent reflective Material)

I would welcome any comments and ask that our installation have your approval.

Attachments omitted:

Drawing of Model 80MP6-DD and drawing of GNXS-207.

ID: nht93-4.51

DATE: June 28, 1993

FROM: John Womack -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA

TO: Eddie Bernice Johnson -- U.S. House of Representatives

COPYEE: Washington Office

TITLE: None

ATTACHMT: Attached to letter dated 6-2-93 from Eddie Bernice Johnson to Art Neill (OCC 8736).

TEXT: This responds to your letter of June 2, 1993, to Art Neill of this agency on behalf of your constituent, Dr. Bill Way of Dallas. Dr. Way is concerned about the policy of the Department of Defense (DOD) to destroy M151 jeeps at the end of their useful military life because "for some reason the Department of Transportation has deemed (them) unsafe to be used on public roads." He finds this unusual "because if they are found to be unsafe on our roads, how can we consider these vehicles safe for use by military personnel?" Pointing out that used M151s could be sold for civilian use, he submits that "this is another waste of materials by the government."

As you know, it is the mission of the National Highway Traffic Safety Administration (NHTSA) to improve safety upon the public roads of the United States. Over 20 years ago, NHTSA became aware of allegations regarding the tendency of the M151 jeep to roll over during turning maneuvers. DOD was aware of these allegations and provided special handling instructions to M151 operators intended to minimize the possibility of roll overs. At that time, it sought NHTSA's advice as to the proper disposition of these vehicles at the end of their useful military life.

Because the suspension systems of the M151s could not be modified and because civilian operators would not have access to the same training in handling that was provided military drivers, NHTSA advised that surplus M151s should be rendered inoperable rather than sold to the public. DOD concurred, and formulated the policy that these vehicles should be destroyed at the end of their military life. This decision involved a balancing of the competing public interests of recovery of governmental funds and safety on the nation's highways, and the latter has been found to be the predominant public interest. In the years since DOD adopted this policy, it has been reviewed by both agencies from time to time and no compelling reason has been found to change it.

ID: nht95-1.2

TYPE: INTERPRETATION-NHTSA

DATE: January 2, 1995

FROM: Jim Cawse -- Principal Scientist; George Diehl -- Standards Engineer, General Electric

TO: Philip Recht -- Chief Counsel - NHTSA

TITLE: NONE

ATTACHMT: Attached to 2/6/95 letter from Philip R. Recht to Jim Cawse and Fred (George) Diehl (A43; Std. 108)

TEXT: Dear Mr. Recht:

As GE Plastics continues to develop and introduce new products for the Automotive Lighting marketplace, it is extremely important that we continue to adhere to the SAE testing protocol as delineated in SAE J576C, to ensure that our products meet the pass /fail three year natural weathering criteria in South Florida and Arizona. The Design of Experiment (DOE) approach we discussed with you in August and September, 1994, will enable us to generate a much wider spread of data utilizing dependent and indepe ndent variables including haze. Yellowness Index (YI), color shift, thicknesses, formulations, colors, color concentrations, and coatings. This will supply very meaningful results for us and our customers in that we will be able to extract more results from less testing.

As a result of our discussions with NHTSA, AAMVA (now AMECA), and the major automotive and automotive lighting players, we have modified our initial approach to incorporate the important concerns of all parties. These include:

* The thicknesses used in the study will be at least the three minimum as called out by SAE J576C (0.062, 0.125, and 0.250 inches). We have added the 0.040" thickness as well.

* The formulations (base material recipes) used in the study will be commercial formulations and the results of the study will be usable for only those formulations (i.e., no blends of two formulations).

* Each coating will be tested at least once on each formulation.

* Each color candidate will be tested in a low and high color concentration so that interpolations can be made from the test results for color concentrations that fall in between.

* The final list of coatings is being firmed up as of this writing, and actually is being expanded beyond the list presented in previous meetings.

We would appreciate your written affirmation of our approach so that we have a mutual understanding of our new testing directions, and so that our customers are assured of your concurrence.

Sincerely.