ID: 86-5.12

TYPE: INTERPRETATION-NHTSA

DATE: 09/04/86

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood for Erika Z. Jones; NHTSA

TO: Mr. Binichi Doi

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Binichi Doi NSK Representative Office P.O. Box 1507 Ann Arbor, MI 18106

Dear Mr. Doi:

Thank you for your letters concerning the automatic safety belt warning requirements of Standard No. 208, Occupant Crash Protection. You explained in your letters and in conversations with Stephen Oesch of my staff that NSK-Warner is developing a motorized automatic belt system that would be equipped with an emergency release buckle. You also plan to provide voluntarily a manual lap belt with the system. I regret the delay in our response and hope the following discussion answers your questions.

You first asked whether you can use an automatic belt warning system for your motorized belt system which would activate an audible signal under the following conditions: (1) the vehicle ignition is moved to the "on" or "start" position (2) the motorized automatic belt is not fastened and (3) the motorized belt has not reached its locked protective position. As explained below, such a system is permissible, but is not required by the standard.

S4.5.3 of the standard sets forth the requirements for automatic belt systems. S4.5.3.3(b) requires a motorized automatic belt system to have a warning system that sounds an audible signal for between 4 and 8 seconds if the automatic belt latchplate is not fastened or the emergency release is activated and the ignition is in the "on" or "start" position. However, S4.5.3.3(b) does not require the audible signal to be activated until a motorized belt has reached its locked protective mode. Your system would activate the audible signal while the motorized belt is moving to its locked position and it would sound again once it has reached its locked position. Thus, NSK is voluntarily providing a warning that is not required by the standard. As stated in the preamble to the November 6, 1985 notice (50 FR 16063) adopting the new warning system requirements for automatic safety belts, a manufacturer is free to provide additional features as long as the features required by the standard still continue to comply with all the applicable performance requirements. Thus, as long as the warning system provides the warning required by S4.5.3.3(b), NSK may voluntarily provide additional warnings as well.

You also said that NSK is planning to provide an automatic belt warning system for both the driver's and right front passenger's seating position. S4.5.3.3(b) requires an automatic belt warning system only at the left front designated seating position. Thus, the agency would consider the passenger side warning system as a voluntary system, which you may install as long as the driver'a warning system will continue to meet all applicable requirements.

You also asked several questions about when and how long the audible and light warning are to be activated. Specifically you asked whether the warnings must be reactivated when the tongue of an emergency release buckle (referred to as an ERB in your letter) is inserted into the latch mechanism and then removed again within a few seconds. You also asked if the warnings can be de-activated by insertion of the tongue of the emergency release buckle before expiration of the 4-8 seconds specification for the audible warning and the 60 second specification for activation of the warning light. As explained below, if the emergency release buckle has been fastened and then unfastened after a few seconds, the warning does not have to be re-activated until after the ignition switch has been turned "off" and then turned again to the "on" or "start" position. Also if the warning begins to activate and then the emergency release buckle is fastened, the warning may immediately be cancelled and thus does not have to be activated for the full time period specified in the standard.

S4.5.3.3(b) provides that the audible warning and the warning light are to be activated only under certain conditions. Thus, the standard provides that the warnings are to be activated when condition A (the ignition switch is in the "on" or "start" position) exists simultaneously with one of the other conditions, such as condition B (the emergency release buckle not being fastened). Thus, if the emergency release buckle is unfastened and, at the same time, the ignition is in the "on" or "start" position, the warnings must activate. However, if the ignition is not in the "on" or "start" position and the emergency buckle is released, then the warnings do not have to be activated. The agency has previously said, such as in a June 17, 1981 letter to Chrysler, that the warning is not to activate if the safety belt is buckled. Thus, the warning may be cancelled once the emergency release buckle is fastened.

Again, I regret the delay in our response. If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

March 10, 1986

NHTSA Room 5219 400 Seventh Street, S.W.

Washington, DC 20590

Stephen L. Oesch Deputy Assistant Chief Counsel For Rulemaking

Subject: Questions Regarding FMVSS 208, 4.5.3.3(b).

Dear Mr. Oesch:

It was nice meeting with you the other day although I walked into your office without prior notice.

Below is a few questions NSK-Warner would like to ask your office, in addition to the previous request for interpretation of rules stated in my letter of February 4, 1986.

1. When conditions A and B exist simultaneously the audible and light warnings are activated. Under the existance of such conditions (say for two seconds), when a tongue of ERB is inserted into and removed from a buckle within a short time.

a) Are warnings (or one of two types of warning) required to be re-activated?

b) Are warnings required for the initially set time, that is, 4-8 seconds for audio-warning and not less than 60 seconds for light-warning after a tongue is inserted into and removed from a buckle during the initial warning activation time periods?

In other words, are the warning(s) needs to be re-activated for a certain length of time after a tongue is inserted into a buckle (this action would eliminate both types of warning) and removed immediately afterward as long as this sequence of events occurs within 4-8 seconds and not less than 60 seconds of initial activation of warnings?

Yet in other words, can the warnings be de-activated before expiration of 4-8 seconds and not less than 60 seconds by insertion of a tongue, for example, and not required to be reactivated at all until ignition switch is turned off once and turned on again?

2. NSK-Warner is considering the implementation of 'Condition B Warning' on the passenger side, also.

In such case, depending on the timing of anchor point reaching protected-mode at anchor-point, audible warning could last for a total of 16 seconds, 8 seconds on drivers side and 8 seconds on passenger side. Does this cause any rule-related problem?

I only hope that above questions sufficiently are clearly stated so that we can receive your kind consideration and response.

Very truly yours,

Binichi Doi NSK Representative

BD/mt

P.S. We would appreciate it if you could combine above with our previous set of questions for your consideration.

ID: 86-5.13

TYPE: INTERPRETATION-NHTSA

DATE: 09/05/86

FROM: AUTHOR UNAVAILABLE; S.P. Wood for Erika Z. Jones; NHTSA

TO: Mr. William Shapiro

TITLE: FMVSS INTERPRETATION

TEXT:

Sep 5 1986

Mr. William Shapiro Manager, Regulatory Affairs Volvo Cars of North America Rockleigh, New Jersey 07647

Dear Mr. Shapiro:

This responds to your letter concerning a newly designed Volvo child safety seat. You stated that this child safety seat can be certified as complying with Standard No. 213, Child Restraint Systems (49 CFR S571.213), when secured only by a vehicle lap belt, in the rearward-facing mode for infants and in the forward-facing mode for toddlers. In addition, you indicate that this child safety seat can be used in certain vehicle specific installations in Volvo vehicles, and that the vehicle specific installations "provide a higher level of protection." You asked this agency's opinion as to whether this new child safety seat is designed in due care to meet the minimum requirements of Standard No. 213 and whether it can be used in both the universal application (that is, secured by only a lap belt) and Volvo vehicle-specific modes.

With respect to your first question, the National Traffic and Motor Vehicle Safet Act (15 U.S.C. 1381 et seq.) provides no authority under which this agency can assure a manufacturer that its product has been designed in due care to comply with all applicable requirements or to otherwise "approve" it. The Act establishes a process of self-certification under which a manufacturer is not required to submit a product to the agency for approval before sale, but simply to provide a certification to dealers and distributors that it does meet all applicable Federal motor vehicle safety standards. If that product does not in fact comply, the manufacturer must notify and remedy the noncompliance according to the Act, and it is in presumptive violation of it (and therefore subject to civil penalties) unless it can establish that it did not have reason to know in the exercise of due care that the product was noncompliant. The statute thus provides an affirmative defense to the manufacturer, but it is a defense that does not arise until there is a violation of the Act, and the burden is upon the proponent to establish it.

Under the Act a product must comply at the time of sale to its first purchaser for purposes other than resale. This means that a manufacturer's responsibility to insure compliance does not end at the design stage, but extends through manufacture, distribution, and sale of the product. In this context whether a manufacturer has exercised due care in the design stage can be an irrelevant question if the noncompliance was caused by an error in the manufacturing process which should have been detected and corrected, for example. For these reasons we cannot provide the opinion that you seek.

With respect to your second question, Volvo can recommend its child seat for use with a lap belt in vehicles other than those manufactured by Volvo and for vehicle-specific uses in Volvo cars. The preamble to the 1979 final rule establishing Standard No. 213 included the following statement: "As long as child restraints can pass the performance requirements of the standard secured only by a lap belt, a manufacturer is free to specify other 'vehicle specific' installation conditions." 44 FR 72131, at 72136; December 13, 1979. Therefore, Volvo can provide the vehicle-specific installation conditions for its child safety seat in Volvo automobiles. Please note that section S5.6 of Standard No. 213 requires manufacturers recommending vehicle-specific installations to provide step-by-step instructions for securing the child restraint in those particular vehicles, as well as providing such instructions for securing the child restraint when it is used in vehicles for which no vehicle-specific installation is recommended.

Please feel free to contact me if you have any further questions or need more information on this subject.

Sincerely,

Erika Z. Jones Chief Counsel

April 9, 1986

Ms. Erika Jones Chief Counsel National Highway Traffic Safety Administration 400 Seventh St., S.W. Washington, D. C. 20590

Re: Request for Interpretation FMVSS #213 - Volvo Child Safety Seat

Dear Ms. Jones:

This will confirm the discussion of March 26, 1986 between Volvo ad NHTSA personnel regarding the Volvo child safety seat. Based on that meeting, we request the following be clarified. Volvo is deeply committed to the safety of all ages of the occupants of vehicles. For the past 10 years, we have marketed in Europe a vehicle-specific rearward facing Volvo child safety seat. We believe the rearward facing mode is a safer way to travel for children than forward facing. Its experience in Sweden has been excellent. However, due to the particular wording in FMVSS #213, we were unable to market it in the U.S.

During the past 1-2 years we have designed ad developed a new Volvo child seat. In the Thursday, December 13, 1979 F. R. V44N241, P. 72136 (Docket #74-9, Notice 6) NHTSA commented on vehicle-specific child seats.

"However, since vehicle specific child restraints can provide adequate levels of protection when installed correctly, NHTSA is not prohibiting the manufacture of such devices. The new standard requires them to meet the performance requirements of the standard when secured by a vehicle lap belt. As long as child restraints can pass the performance requirements of the standard secured only by a lap belt, a manufacturer is free to specify other 'vehicle specific' installation conditions."

Our development for the U. S. was based on this portion of the Federal Register. This seat is designed to be used by both infants (0-1 year) and toddlers (1-about 4 gears). The new Volvo child seat has universal application in automobiles. In addition, it has vehicle-specific modes for Volvo vehicles which provide yet a higher level of protection.

The Volvo child seat is desired to meet the performance requirements or FMVSS #213 when secured by a vehicle lap belt in the rearward racing mode for infants and the forward facing mode for toddlers. This is the universal installation. Because FMVSS #213 is a minimum performance standard, by fulfilling the requirements of FMVSS #213 in these modes we have fulfilled NHTSA intent as stated in the above mentioned Federal Register and believe this seat is designed in due care to meet the requirements of FMVSS #213.

The Volvo child seat in the vehicle-specific mode provides a higher level of protection than the universal application. This is accomplished by the use of an additional vehicle specific attachment strap and hardware. For both the infant and toddler Volvo vehicle-specific mode, the child rides rearward-facing in the vehicle.

We interpret that the new Volvo child seat, as described above, is designed in due care to meet the minimum requirements of FMVSS #213, and can be used in both the universal application and Volvo vehicle-specific modes. Your confirmation of that interpretation would be appreciated as soon as possible.

If there are further questions about the Volvo child safety seat, please contact me at your convenience.

Sincerely, VOLVO CARS OF NORTH AMERICA Product Planning and Development

William Shapiro, P.E. Manager, Regulatory Affairs WS:mc

ID: 86-5.14

TYPE: INTERPRETATION-NHTSA

DATE: 09/05/86 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: JOSEPH A. GIAMPAPA

TITLE: NONE

ATTACHMT: LETTER DATED 02/13/86, TO ERIKA Z JONES, FROM JOSEPH A GIAMPAPA, REGULATIONS, OCC-0202

TEXT: Dear Mr. Giampapa:

This responds to your letter dated February 13, 1986, regarding an auto body gauge which a client intends to manufacture. The accompanying material describes this device as "a gauge for aligning opposite points within opposite surfaces of a normally symmetric body." It could be used to align a vehicle body following damage in an accident or collision. You ask what Federal requirements are applicable to an auto body gauge. I regret the delay in responding to your letter.

This agency administers the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1391 et seq.). Under section 103 of the Act, NHTSA has issued Federal motor vehicle safety standards which are applicable to new motor vehicles and their equipment. The auto body gauge described in your letter would apparently be used by commercial automobile repair businesses when repairing and realigning damaged car bodies. In previous interpretations, NHTSA has said that items, such as wheel balancing machines, are "repair shop" equipment and not "motor vehicle" equipment. The reason is that, although their only use is with a motor vehicle, they are not intended to be used principally by ordinary users of motor vehicle equipment. Thus, we would not consider your client's product an item of motor vehicle equipment.

I hope this information is helpful to you.

Sincerely

ID: 86-5.15

TYPE: INTERPRETATION-NHTSA

DATE: 09/10/86 EST

FROM: JEFFREY S. JENSEN

TO: NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12/24/86 TO JEFFREY S JENSEN FROM ERIKA Z. JONES

TEXT: I was referred to your people by the National Transportation Safety Board out of Olympia, Wash.

I have come up with a way to inscribe lettering on the inside of car & truck tail light so that when the brakes are applied that the lettering is seen.

I had thought about going into this on a production basis and wanted to find out if there is any stipulations, conditions or laws, or regulations that have to be complied with. I realize there could be no $99[Illegible Word] words used, but I am not aware of any other limitations that may be imposed.

If you could please get back to me and let me know all the details as soon as possible, so that we could get going on the project right away.

ID: 86-5.16

TYPE: INTERPRETATION-NHTSA

DATE: 09/12/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: David M. Wise -- Gary Precision Products

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. David M. Wise Gary Precision Products 530 Old Post Road #3 Greenwich, CT 06830

This is in reply to your letter of August 7, 1986( asking if Federal Motor Vehicle Safety Standard No. 108, or any other Federal regulation applies to a plastic ice scraper with a reflector on it that you may manufacture.

Although the title of Standard No. 108 is "Lamps, Reflective Devices, and Associated Equipment," the reflective devices covered by the standard are those that are mounted on the rear and side of a motor vehicle, which are necessary for signaling and the safe operation of vehicles during darkness and other times of reduced visibility. It does not apply to ice scrapers. Nor does the other Federal motor vehicle safety standard dealing with reflectivity, Standard No. 125 "Warning Devices," or any other regulation of this Department.

I hope this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

August 7, 1986

Ms. Erika Z. Jones Chief Council National Highway Traffic Safety Administration Room 5219 400 7th St. S.W. Washington, DC 20590

Dear Ms. Jones:

Gary Precision Products manufactures a line of injection molded plastic ice scrapers and snow brushes . We are considering the manufacture of an ice scraper with a reflector on it. The reflector will be on the blade portion of the ice scraper.

We would like to know if there are any laws, rules or regulations governing the manufacture or sale of such a product. I specifically refer to U.S. Dept of Transportation Motor Vehicle Safety Standard # 108.

In my conversation with Mr. Taylor Vincent, the law only refers to motor vehicles themselves, not to portable automotive devices used on them.

We would like something in writing stating that there are no regulations or laws we need to comply with in manufacturing this product.

We thank you for your assistance in this matter.

Very truly yours,

GARY PRECISION PRODUCTS

David Wise

ID: 86-5.17

TYPE: INTERPRETATION-NHTSA

DATE: 09/12/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Davis Thekkanath

TITLE: FMVSS INTERPRETATION

TEXT:

SEP 12 86

Mr. Davis Thekkanath Oshkosh Truck Corporation P.O. Box 2566 2307 Oregon St. Oshkosh, WI 54903-2564

Dear Mr. Thekkanath:

This responds to your letter dated May 9, 1984, regarding the placement of the vehicle identification number (VIN) on heavy duty vehicles. You asked whether a heavy duty truck must have a VIN that meets the location requirement of S4.6 of the standard or whether the VIN for such a vehicle can be located on the vehicle certification plate. As discussed below, the VIN for a truck with a gross vehicle weight ratings (GVWR) of 10,000 pounds or more can be located on the vehicle certification plate.

Standard No. 115. Vehicle Identification Number - Basic Requirements, requires passenger cars, multipurpose passenger vehicles, trucks, buses, trailers, incomplete vehicles, and motorcycles to have a VIN. S4.5 of the standard requires the VIN to appear indelibly on a part of the vehicle which is not designed to be removed except for repair or upon a separate plate which is permanently affixed to the vehicle. S4.6 of the standard specifies the location of the VIN inside the passenger compartment for passenger cars, multipurpose passenger vehicles, and trucks of 10,000 pounds or less GVWR. However, the VIN location requirement of S4.6 does not apply to vehicles with a GVWR over 10,000 pounds.

As you correctly noted, Part 567, Certification, requires the VIN to be located on the certification label of motor vehicles. Since S567.4(b) requires the certification label to be permanently affixed to the vehicle, the agency considers providing the VIN in this location as complying with the requirement of S4.5 of Standard No. 115.

I hope this information is helpful to you.

Sincerely,

Erika Z. Jones Chief Counsel

May 9, 1986

Office of Chief Counsel National Highway Traffic Safety Administration 400 7th St. S.W. Washington. D.C. 20590

Subject: Placement of Vehicle Identification Number

Gentlemen:

We are manufacturers of heavy duty vehicles of GVWR of over 10,000 lbs. In our effort to find the exact federal requirement of the placement of the vehicle identification number, we scanned through FMVSS 115 for an answer. It specifically addresses in paragraph 4.6. vehicles of GVWR 10,000 lbs or less. Does this requirement apply for us also?

We currently have the certification label of which "VIN" is a part, placed inside the cab per 49 CFR 567 paragraph 4. Does this satisfy the "VIN" placement requirement? Does the regulation require that "VIN" be placed on any other part of the vehicle in addition to that on the certification label placed inside the cab?

We would appreciate your responding in writing to us as soon as possible.

Sincerely, OSHKOSH TRUCK CORPORATION

Davis Thekkanath Sr. Supervising Engineer

DT:ks

ID: 86-5.18

TYPE: INTERPRETATION-NHTSA

DATE: 09/12/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. John C. Hilliard

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. John C. Hilliard Chairman & Technical Director Combustion and Fuel Research, Inc. 857-9 South Wagner Road Ann Arbor, MI 48103

Dear Mr. Hilliard:

Thank you for your letter of July 1, 1986 asking how our regulations would affect the placement of the steering wheel on delivery vehicles You asked whether there are any State or Federal regulations which would prevent the installation of a right hand drive steering wheel. As discussed below, the National Highway Traffic Safety Administration (NHTSA) has not issued any safety standards that would prohibit the installation of a right hand drive steering wheel. As to State laws, I suggest you check with the Department of Transportation in the States where your client wants to use the vehicles.

Some background information about our agency and its standards may be of assistance to you. NHTSA has the authority to issue safety standards applicable to new motor vehicles and certain items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, the National Traffic and Motor Vehicle Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet our safety standards. The agency periodically tests vehicles and equipment items for compliance with the standards, and also investigates alleged safety-related defects.

We do not have any standards that prohibit the use of a right hand drive steering system. We have, however, issued two safety standards (Standard Nos. 203 and 204) that set performance requirements which apply to any steering system, whether left or right hand drive, installed in new passenger cars and light trucks, buses, and multipurpose passenger vehicles. A copy of each of these standards is enclosed.

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

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

July 1, 1986.

Mr. Stephen Wood Assistant Chief Council for Rulemaking NHTSA 400 7th Street SW Room 5219 Washington DC 20590

Dear Mr. Wood:

On the advice of Mr. Charles Fisher, of the Michigan Department of Transportation , I am writing for information on the following matter.

We have a specific inquiry with regard to placement of the steering wheel on delivery vehicles. As you know, many postal service vehicles and street utility vehicles are equipped, with steering wheels on the right--hand side.

One of our clients is exploring the possible manufacture of delivery vehicles where the driver has to leave the cab at regular intervals. Could you please tell us whether there are any state and/or federal regulations which would prevent the installation of a right hand drive steering wheel for a privately owned, delivery company?

We thank you for your assistance.

Sincerely yours,

John C. Hilliard Chairman & Technical Director

JCH:ph

ID: 86-5.2

TYPE: INTERPRETATION-NHTSA

DATE: 08/22/86

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood for Erika Z. Jones; NHTSA

TO: Mr. Charles J. Newman

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Charles J. Newman Vice-President, Engineering The Grote Manufacturing Company 2600 Lanier Drive Madison, Indiana 47250

Dear Mr. Newman:

This is in reply to your letter of December 10, 1985, asking for an interpretation regarding two proposed locations for clearance lamps. As you know, our response has been delayed because the original letter lacked one of the the drawings necessary for us to reply to your questions.

You have paraphrased S4.3.1.1.1 of Standard No. 108 as stating "in part that clearance lamps need not be mounted on the front or rear and at such a location need not be visible at 45 degrees inboard." That is not exactly what that section permits. It states that "Clearance lamps may be mounted at a location other than on the front and rear if necessary to indicate the overall width of a vehicle, or for protection from damage during normal operation of the vehicle, and at such a location they need not be visible at 45 degrees inboard." Your first request for an interpretation concerns a "fixed body with additional equipment mounted on the box," and depicts clearance lamps that are mounted on the front of a structure behind the cab, and yet are not visible at 45 degrees inboard. You have asked whether this meets the intent of S4.3.1.1.1. The plan view diagram in your letter indicates that the clearance lamps, if mounted on the front (i.e., the cab) would not be located to indicate the overall width of the vehicle. But when mounted on the structure behind the cab, they appear located so as to indicate the overall width of the vehicle. You have not mentioned mounting height, but we assume that they are "as close to the top as practicable" In accordance with the requirements of Table II of Standard No. 108. Therefore the exception permitted by S4.3.1.1.1 would apply.

Your second request covers a "side mounted clearance lamp," and states that "Because of box construction and box size, a side mounted clearance lamp is a better location." In this location, the inboard visibility requirements would not be met. You asked whether this would meet the intent of S4.3.1.1.1.

The intent of S4.3.1.1.1 is that the alternate location indicate the overall width of the vehicle. If we judge compliance by the plan view of the diagram, then the location on the second diagram is acceptable. But in this location the inboard angle of visibility would be even less than in the first diagram, and the overall width of the vehicle would be less apparent to an incoming driver. Given the fact that you have presented us with alternative means by which you may meet S4. 3.1.1. 1 we cannot conclude that the location shown in the second diagram complies with Standard No. 108.

Sincerely

Erika Z. Jones Chief Counsel

December 10, 1985

National Highway Traffic Safety Administration 400 Seventh St., S.W. Washington, D.C. 20590

Attn: Vincent Taylor

Re: Front mounted clearance lamps

Dear Mr. Vincent:

Due to a recent interpretation of FMVSS 108 and the construction of some truck bodies several of our customers have asked for recommendations on the mounting location of the front clearance lamps.

The vehicle manufacturer has in the past mounted five lamps on the top of the cab - three (3) indentification and two (2) clearance lamps-

Section "S4.3.1.1.1" of FMVSS 108 states in part that clearance lamps need not be mounted on the front or rear and at such a location need not be visible at 45o inboard.

This brings up several questionable mountings-

1. Fixed body with additional equipment mounted on the box.

(Please insert graphics)

We have outboard visibility and straight on visibility but do not have inboard visibility.

We would consider this mounting to meet the intent of S.4.3.1.1.1 of FMVSS 108.

Do you agree?

2. Side mounted clearance lamp-

(Please insert graphics)

Because of box construction and box size, a side mounted clearance lamp is a better location. We have outboard visibility and straight on visibility but do not have inboard visibility.

We would consider this mounting to meet the intent of S.4.3.1.1.1 of FMVSS 108.

Do you agree?

Sincerely,

THE GROTE MANUFACTURING COMPANY

Charles J. Newman Vice-President, Engineering

kp

ID: 86-5.20

TYPE: INTERPRETATION-NHTSA

DATE: 09/16/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Skip Maraney

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Skip Maraney National Star Route Mail Contractor Association 324 East Capitol Street Washington, DC 20003

Dear Mr. Maraney:

This responds to your telephone inquiry about whether our regulations would prohibit the installation of a right hand drive steering system in a motor vehicle. We do not have any standards that prohibit the use of a right hand drive steering system. We have, however, issued two safety standards (Standard Nos. 203 and 204) that set performance requirements which apply to any steering system, whether left or right hand drive, installed in new passenger cars and light trucks, buses, and multipurpose passenger vehicles. A copy of each of these standards is enclosed.

You also asked about the agency's regulations on the importation of motor vehicles. I have enclosed a copy of a publication, "Instructions Handbook for Complying with Regulations on Imported Vehicles," which will provide you with information about our importation regulations.

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

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

ID: 86-5.21

TYPE: INTERPRETATION-NHTSA

DATE: 09/16/86

FROM: JEROME A. CZARNOWSKI

TO: CARL CLARK -- INVENTOR CONTACT NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 06/04/87, TO JEROME A CZARNOWSKI FROM ERIKA Z. JONES, REDBOOK A30 (2), STANDARD 121

TEXT: Dear Dr. Clark,

Enclosed are copies of the un-edited and published versions of the article on the Emergency Air Reserve System (EARS) of which we spoke this morning. I retained copyright, while granting FIRE COMMAND one-time publication rights, which is our usual arrangement.

Basically, EARS is a separate high-pressure system intended to provide an emergency vehicle with enough air volume and pressure to charge the vehicle's integral system to operating pressure. Depending upon the volume of the integral system, this can be accomplished in four to ten seconds versus two to five minutes using the vehicle's air compressor from O PSI. In our business, cutting the response time in any emergency can mean life or death for the victim.

This system does not violate the integrity of the vehicle's system, since check-valves, a relief valve and one-way regulator are present. The components of the system are proven under the most demanding and abusive conditions.

The article points out other advantages to the system, and how some apparatus manufacturers are providing to solve the initial air-pressure problem. I doubt if some of the solutions I've seen (i.e., on-board diaphram compressors tied to the "wet tank") solve more problems than they create. I have also seen electrical air-selenoids on the discharge ports of air tanks to shut the tanks off when not in use (parked). Can you imagine the result if the electrical system fails while a fire engine is responding to a scene?

Thank you for your time in evaluating this device. As I stated over the phone, the Patent prospect looks favorable. However, I am more concerned with the safety for both the firefighter and the public.

Sincerely,