ID: 1983-1.9

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Velvac, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Jan 28 1983

NOA-30

Mr. Robert R. Brester Velvac, Inc. 2900 South 160th Street New Berlin, Wisconsin 53151

Dear Mr. Brester:

This responds to your November 18 letter to Roger Fairchild of this office. In that letter, you asked whether certain heavy duty trucks may have installed on each side of the vehicle two mirrors each of 25 square inches surface area. The dual mirrors would be mounted in a common bracket with a gap between the mirrors.

The language of FMVSS 111 clearly envisions that there shall be a single mirror of at least 50 square inches of surface area on each side of the vehicle. Section 7.1 of the standard provides that such trucks must have exterior mirrors "each with not less than 50 in2 of reflective surface...." (Emphasis added.) Further, the agency questions whether the performance of the dual mirror would be equivalent to that of a single mirror. For example, images could temporarily be lost in the gap between the two mirrors, potentially presenting a hazard to the driver. Further, the mirrors could have slightly different orientations in the common mounting, possibly misleading the driver as to the speed and location of an object viewed in the mirrors. Therefore, we conclude that the split system does not comply with FMVSS 111.

If you have further questions on this matter, please feel free to contact us.

Sincerely,

Frank Berndt Chief Counsel

November 18, 1982

Mr. Roger Fairchild National Highway Traffic Safety Administration Federal Motor Vehicle Safety Standard No. 111 Room 5219 United States Department of Transportation 400 Seventh Street SW Washington D.C. 20590

Dear Mr. Fairchild,

I am writing you this letter in response to a phone conversation I had with Mr. Kevin Cavey, Office of Vehicle Safety Standards in regards to compliance with F.M.V.S.S. 111 using a flat mirror split system.

Specifically, I addressed the question to Mr. Cavey, "Will two flat mirrors mounted on a common bracket with a combined square area meeting current F.M.V.S.S. specifications be equivalent to a single flat mirror?" (see example).

FLAT MIRROR

**INSERT** Would this be acceptable under the current FMVSS 111?

Mr. Cavey said he is not in the position to comment on this matter verbally and that I should contact you in writing.

Please give this matter your prompt attention as we have a customer desiring to purchase this split system to eliminate a blind spot that is caused by one large mirror.

If you have any questions regarding this matter please contact me at 1-414-786-0706.

Sincerely,

Robert R. Brester-Chief Engineer

c.c. W. Sandham R. Hosmer

ID: 1983-2.1

TYPE: INTERPRETATION-NHTSA

DATE: 05/04/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mohawk Rubber Company -- T.J. Brown

TITLE: FMVSR INTERPRETATION

TEXT:

Mr. T.J. Brown Mohawk Rubber Company Roanoke, Virginia 241017

Dear Mr. Brown:

This is in response to your March 28, 1983, letter to Roger Fairchild of this office, requesting confirmation of your understanding of the effective dates for the recent suspension of treadwear grading under this agency's Uniform Tire Quality Grading Standards.

Your understanding of the effective dates is correct. Tires produced in molds manufactured on or after August 8, 1983, must have the new grading format which excludes treadwear information. Tires produced in molds manufactured before which includes treadwater information. We encourage manufacturers to use the new format as soon as feasible, to minimize the dissemination of misleading information with regard.

With regard to labels, the requirement that such labels must contain information regarding treadwater grades was suspended effective February 7, 1983. The preamble to the final rule states that manufacturers will be permitted to exhaust inventories of labels which were in existence as of the date of the suspension. Thereafter, manufacturers should begin using labels without treadwear information.

If you have further questions on this matter, please feel free to contact us.

Sincerely,

Frank Berndt Chief Counsel

March 28, 1983 Mr. Roger Fairchild Re: 49 CFR Part 575, Docket No. 25, Notice 52

Dear Mr. Fairchild:

Mr. C.D. Frame of Mohawk contacted you on March 28 pertaining to the ruling included in the Federal Register dated Monday, February 7, 1983.

Our particular concern is in interpretation of the treadwear stamping to be included, or not included, in the tire mold. We understand the ruling to state that tires which are produced after August 8, 1983, are not to have the treadwear information only if the molds themselves were manufactured after this date.

On tires produced in molds which were manufactured prior to August 8, 1983, the treadwear information is permitted on the molded tire. It is further our understanding that tire label are to have the treadwear grade and the explanation as to how it was obtained removed from them as new labels are procurred after the date of February 7, 1983. Existing inventories of labels containing he treadwater information are permitted to be used until such time as thi inventory is depleted.

We would appreciate a letter from you in response to our interpretations as to whether they are indeed correct.

Very truly yours

MOHAWK RUBBER COMPANY

T. J. Brown General Manager, Product Services

ID: 1983-2.10

TYPE: INTERPRETATION-NHTSA

DATE: 05/20/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Champ Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

May 20, 1983 NOA-30

Mr. Mike M. Simovich Champ Corporation El Monte, California 91733

Dear Mr. Simovich:

This is in response to your March 23, 1983, letter to Roger Fairchild of this office, regarding the applicability of Federal Motor Vehicle Safety Standard No. 115 (Vehicle Identification Number) to construction type forklift trucks. As you state in your letter, these vehicles are principally designed to operate on a construction site, such as by lifting building materials to upper levels in a building project. The trucks would apparently remain at construction sites for two to twelve months, then move to the next job site. Some models of the trucks have special equipment to facilitate being towed between job sites. While all models presumably could be driven between job sites, none are capable of achieving open highway speeds.

Standard 115 applies only to vehicles manufactured "primarily for use on the public streets, roads, and highways." NHTSA has interpreted this language to exclude mobile construction equipment which use the highways only to move between job sites and which typically spend extended periods of time at a single job site. In such cases, the on-highway use of the vehicle is merely incidental, not the primary purpose for which the vehicle was manufactured. Based on the information provided in your letter, your fork-lift trucks would therefore not be subject to Standard 115.

You should be aware that this interpretation applies only to Federal requirements; individual States may establish their own numbering requirements for vehicles outside this agency's jurisdiction (e.g., off-road vehicles). Thus, even though Federal requirements do not apply, it may be that State requirements do apply to your fork-lift trucks.

If you have further questions on this matter, please contact us.

Sincerely,

Frank Berndt Chief Counsel

March 23, 1983

Mr. Roger Fairchild Office of Chief Council National Highway Traffic Safety Administration Department of Transportation Washington, D.C. 20590

Ref: Federal Motor Vehicle Safety Standard Number 115

Dear Mr. Fairchild:

This Company has been notified by the California Department of Motor Vehicles that we must adhere to the above safety standard to register our forklift trucks, unless we receive exemption from the National Highway Traffic Safety Administration.

This letter is directed to you at the suggestion of Mr. Nelson Erickson of the National Highway Traffic Safety Administration, Department of Transportation, Washington, D.C.

This Company manufactures Champ rough terrain construction type forklift trucks, having originated the concept in 1947.

The Champ lift truck is principally designed to operate on the construction site, lifting building materials to second and third story levels and to move building materials about the construction site in place for use by the installing personnel.

The site may be a commercial, residential, oil field, agricultural or plant site - the requirement is still an off-the-highway application. Because this type of application requires extra large flatation tires, Champ has been able to provide towing facilities on some models to move the vehicle from site to site at the completion of projects when applicable.

Since most construction projects average two to twelve months and the next site is usually limited to a very few miles, the time the Champ is being towed on the highway is insignificant. The lift truck is not used to carry a load-on the highway.

To our knowledge, only California and Washington States provide provisions for registering these vehicles to provide identification in case of theft and to assure a simple means to provide taxation in lieu of property taxes. No weight fees are assessed since the vehicles do not carry a load on the highways nor do they perform a "for hire" function.

Since the original correspondence in late 1981, no further instructions or directions have been received and it was therefore assumed the requirement for a seventeen character identification number for forklift trucks was exempt. We have contacted other similar forklift manufacturers who are not even aware of the proposed regulation and therefore were further convinced the requirement did not apply to forklift trucks.

In view of the foregoing, we sincerely believe that the regulation applying to transportation and regular highway going vehicles operating on the highways for hire should not apply to off-the-road forklift trucks performing their designated tasks on construction and farm sites.

We sincerely request that the concerned facility review this matter and offer an exemption for the seventeen character vehicle identification for lift trucks. New 1983 Champ lift trucks are already in operation throughout parts of the country which could result in duplication of identifications.

Champ is most happy to work with the Department of Transportation and welcomes the opportunity to cooperate toward any practical resolution.

The enclosed brochures and photo are submitted for better identification of the product.

Please call or write as soon as possible so that we may resolve the problem without further undue complications.

Very truly yours,

CHAMP CORPORATION

Mike M. Simovich President

Enclosures

ID: 1983-2.11

TYPE: INTERPRETATION-NHTSA

DATE: 05/20/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: The Goodyear Tire and Rubber Company -- Tom Caine, Law Dept.

TITLE: FMVSS INTERPRETATION

TEXT:

Tom Caine, Esq. Law Department The Goodyear Tire & Rubber Company Akron, Ohio 44316

Dear Mr. Caine:

This responds to your recent letter in which you asked for an interpretation concerning the status of tires which are manufactured by applying new tread to a new casing. Specifically, you ask whether such tires should be considered retreaded tires or new tires subject to the applicable Federal motor vehicle safety standard.

Any tires manufactured by applying new tread to new casings would be considered new tires rather than retreaded tires, and would be subject to the same requirements as any other new tires.

Standard No. 117, Retreaded Pneumatic Tires (49 CFR 571.117), defines the term "casing" as follows: "Casing means a used tire to which additional tread may be attached for the purpose of retreading." In the situation you described in your letter, the casing is not a used tire. It is simply a new tire which has never had any tread attached to it. That casing would not be considered a used tire until the casing and the new tread attached to it had been used on the highway and the remainder of the tread then buffed off the casing to allow the application of another new tread. With the addition of the new tread, the used tire would become a retreaded one.

I would appreciate it if you would forward any factual information you have about the proposed importing of new casing to this agency's office of Vehicle Safety Compliance. This will help us ensure that all imported new casings with new treads attached to them are subjected to the new tire performance tests.

Sincerely,

Frank Berndt Chief Counsel

Dear Mr. Berndt:

I have been advised that it has been proposed to import into the United States new (unused) tire casing - both auto and truck casings which will then have new treads applied to the casings in a manner similar or identical to existing retreading processes.

If the casing in question are in fact new (unused) and a new tread is applied to the casing, it would seem to me that the finished product is a new tire, not a retread, and subject to the testing and certification requirements of the applicable Federal Motor Vehicle Safety Standard. It would also seem to follow that the person or company producing such a finished product for sale to the public would be required to comply in all respects with Part 574 of Title 49 CFR including the obtaining of a new tire manufacturer's identification mark.

Will you please advise as to whether the application of a new tread to a new (unused) tire casing constitutes the manufacture of a new or a retreaded tire.

Sincerely, T. D. Caine Attorney

ID: 1983-2.12

TYPE: INTERPRETATION-NHTSA

DATE: 05/24/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Stephen E. Parmeter

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 24 1983 NOA-30

Mr. Stephen E. Parmeter Route 4 Potsdam, New York 13676

Dear Mr. Parmeter:

This responds to your recent letter concerning the process of repairing breaks in automobile windshields. You ask whether such repairs would conflict with any present Federal motor vehicle safety standards.

The National Highway Traffic Safety Administration has issued Federal Motor Vehicle Safety Standard No. 205 which specifies performance and location requirements for glazing materials used on motor vehicles (copy enclosed). This standard would not apply to a repair process such as you describe, however. There is no Federal regulation which would prohibit the use of a product or process in the repair of windshields which have previously been installed in vehicles and damaged in use.

Please note, however, that using such a material or process in a new windshield which may require repair (as a result of damage sustained, for example, in shipment) could cause the windshield to fail to meet the performance requirements of Safety Standard No. 205, or could fail to bring a noncomplying windshield back into compliance. Either case of noncompliance would be the responsibility of the person selling the windshield (49 CFR 567.7, copy enclosed). Therefore, we do not recommend use of windshield repair processes prior to the first purchase of a new windshield by a consumer.

You will have to contact a private attorney to determine your liability under civil law with regards to such a business.

Please contact Hugh Oates of my staff if you have any further questions.

Sincerely, Frank Berndt Chief Counsel

Enclosures

ID: 1983-2.13

TYPE: INTERPRETATION-NHTSA

DATE: 05/27/83

FROM: AUTHOR UNAVAILABLE; S. P. Wood for F. Berndt; NHTSA

TO: Volvo White Truck Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 27 1983 NOA-30

Mr. J. W. Lawrence Manager, Compliance and Recall Volvo White Truck Corporation P.O. Box D-1 Greensboro, NC 27402-1200

Dear Mr. Lawrence:

This responds to your letter concerning Safety Standard No. 101, Controls and Displays. You asked whether standard's identification and illumination requirements are applicable to an optional windshield wiper control you are planning to make available on some heavy duty trucks.

By way of background information, the agency does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is up to the manufacturer to assure that its vehicles and equipment comply with applicable Federal motor vehicle safety standards. The following interpretation represents our opinion based on the facts provided in your letter. It also takes into account information provided in a follow-up telephone conversation with Edward Glancy of this office.

The standard wiper controls for the vehicles in question consist of two knobs which independently control the left and right wipers. These controls provide both the on-off function and variable speed. According to your letter, these controls are identified and illuminated as required by the standard.

The proposed optional control, the specific subject of your letter, would provide a time delay for windshield wiper operation during light mist conditions. The control would be a knob which, if turned to the left, would provide no pause, and if turned toward the right, would offer a variable time delay.

We are unable to agree with your suggestion that the control is not covered by Standard No. 101. As discussed below, Standard No. 101 requires that this control, like the standard controls, be identified and illuminated in accordance with the standard's requirements. Additional words or symbols may be provided for the purpose of clarity.

Section S5 of Standard No. 101 requires, among other things, that each truck manufactured with any control listed in S5.1 or in column 1 of Table 1 meet the requirements of the standard for the location, identification, and illumination of such control. One of the controls listed by S5.1 is "windshield wiper." Also, "windshield wiping system" is among the controls listed in column 1 of Table 1. The issue raised by your letter is therefore whether an optional control for intermittent wiper operation is within the meaning of "windshield wiper" control and/or "windshield wiping system" control. It is our interpretation that such a control is within the meaning of both terms.

Neither the term "windshield wiper" control nor "windshield wiping system" control is limited to specific wiper functions, such as on-off, variable speed, etc. Since a control for intermittent wiper operation controls one function of windshield wipers, it is a "windshield wiper" control or "windshield wiping system" control. Such a control is therefore subject to the standard's requirements for location, identification and illumination.

We would note that while section S5.2.1 and Table 1 require such a control to be identified by the symbol specified for windshield wiping system controls, additional words or symbols may be used at the manufacturer's discretion for purposes of clarity. Since your vehicles would have three windshield wiper controls, you may wish to provide such additional words or symbols to explain the function of each.

Sincerely,

Frank Berndt Chief Counsel

March 30, 1983

Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D. C. 20590

Subject: Request for Interpretation FMVSS-101 Controls and Displays

Volvo White Truck Corporation of Greensboro, North Carolina, a manufacturer of heavy duty trucks 26,000 lbs. and greater GVWR, requests an interpretation of FMVSS-101 as it applies to these classes of vehicles. In specific, we request an interpretation of S 5.3.1 and Table 1 for an optional windshield wiper control available on some of our vehicles.

Volvo White's standard wiper controls are identified and illuminated as required by S 5.3.1 and Table 1 of the Standard. We also are making available an additional control that allows the driver to "time" the wiper sweep by delaying the wipe cycle for vehicle operation during light mist conditions. The control is separate from the wiper control and selects only the desired time delay for the intermittent wiper operation.

Considering that this control operates the time delay feature only but is similar to a wiper control, Volvo White considers it should be identified as follows:

1. The control is not covered by Standard 101, therefore, the identification is at the discretion of the manufacturer.

2. Standard 101 does not prohibit the use of the symbols in Table I for similar type controls. Volvo White may use the symbols and/or words in Table I or other appropriate identification.

3. The control, when mounted on the instrument panel may, but need not, be illuminated.

Volvo White would appreciate, at your earliest convenience, confirmation or clarification on the three issues noted above.

Very truly yours,

J. W. Lawrence Manager, Compliance and Recall

ID: 1983-2.14

TYPE: INTERPRETATION-NHTSA

DATE: 06/06/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Western Bus Sales, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

June 6, 1980 NOA-30

Mr. Dean A. Fialka Western Bus Sales, Inc. 311 N.E. 2nd Gresham, Oregon 97030

Dear Mr. Fialka:

Ms. Lauretta Carlson of our Regional Office in Seattle has forwarded to us a copy of a letter to you dated April 21, 1983, from the Motor Vehicles Division, Department of Transportation, Oregon, with reference to the "Conspicuity Package" on school buses. Oregon appears not to approve the white reflectors in this package. Ms. Carlson has asked us to respond directly to you.

The portions of the conspicuity package that trouble Oregon are the eight white reflex reflectors on the rear (installed on the extreme edge of the vehicle to define its height and width), and the seven white reflex reflectors on each side (defining the overall length and height of the bus). The Oregon letter says that the laws of that State allow only red and yellow reflectors to the rear and sides of the vehicle and that it finds "no indication that the white reflex reflectors are approved by the federal code."

Paragraph S4.1.3 of Federal Motor Vehicle Safety Standard No. 108 permits the installation as original equipment of other lamps and reflectors not specified by the standard provided that the additional equipment does not "impair the effectiveness" of lighting equipment required by Standard No. 108. The agency therefore has no present basis for concluding that white reflectors "impair the effectiveness" of red and yellow reflectors and lamps required by Standard No. 108. Thus, under Federal law, a school bus may be manufactured and sold with the white reflectors.

Further, use of white reflectors may aid safety. Although the National Highway Traffic Safety Administration has not conducted research on improving the conspicuity of school buses, it has contracted for a study of that issue with respect to large vehicles of similar sizes such as trucks and tractor-trailer combinations. The preliminary results indicate that outlining the sides and rear of large vehicles with red and white reflex striping is the best way to improve conspicuity; verification awaits field tests which have not been scheduled to date. Use of white reflectors, while not as effective as red and white striping, probably enhances conspicuity.

The use of a bus with these reflectors, however, is subject to Oregon law. Although under Federal law a State may not have a vehicle safety standard covering the same aspect of performance as a Federal vehicle safety standard unless is identical to it, the white reflectors are not required by a Federal standard and are thus subject to regulation by any State in which the school bus is registered.

I hope that this letter provides a satisfactory clarification.

Sincerely,

Frank Berndt Chief Counsel

cc: Lauretta Carlson Region X

April 21, 1983

Western Bus Sales, Inc. 311 NE 2nd Gresham, Oregon 97030

Attn: Dean A. Fialka

Gentlemen:

Your inquiry regarding the use of a special "Conspicuity Bus" package on school buses has been carefully reviewed. You advise the package contains all lighting and reflex reflectors required by federal standards, and in addition, white reflectors designed to be placed to outline the height and width of the bus from the rear and sides.

Oregon laws only allow the red and yellow or amber reflectors and lights to the rear and sides of a vehicle. (The only exception would be the white license plate light.)

Also, we find no indication that the white reflex reflectors are approved by the federal code. We will forward a copy of your letter to Lauretta Carlson, who is the area director for the National Highway Traffic Safety Administration. Possibly she will be able to advise you further on the federal regulations. You may wish to call her at (206) 442-5935.

Photocopies of the Oregon laws pertaining to use of reflectors and the allowable colors are enclosed for your information.

If we can help further, please advise.

Very truly yours,

Wayne Ivie Manager, Support Units Telephone 378-2057

AO:bef

cc: Lauretta M. Carlson, Highway Safety Program Area Director, N.H.T.S.A., 3140 Federal Bldg., Seattle, Washington, 98174

March 15, 1983

Mr. Wayne Ivie Motor Vehicle Division 1905 Lana Ave NE Salem, OR 97314

Dear Wayne,

Enclosed are copies of two magazine articles covering the "conspicuity package" I briefly described to you over the phone. We have approached some school districts about including this package on their new buses and everyone is concerned with the legality of the color of the reflectors. As the articles state these white reflectors are in addition to those required by FMVSS 108.

To properly market this reflector option we need a determination in writing from your Division stating whether this package would be permissible under Oregon law. This package is of particular interest because the increased visibility would be a tremendous positive safety factor after dark, especially on rainy nights when visibility is reduced. The longer of the articles demonstrates the effectiveness of this new reflector package.

We sincerely appreciate the time taken out of your busy schedule for our request.

Thank you for returning my phone call last Friday; if you have any questions please do not hesitate to call me.

Very truly yours,

WESTERN BUS SALES, INC.

Dean A. Fialka Sales Manager

DAF:pb encl

ID: 1983-2.15

TYPE: INTERPRETATION-NHTSA

DATE: 06/06/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Fiat Motors of America Inc. -- Alberto Negro, Fiat Research and Development

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Alberto Negro Fiat Research & Development - USA Branch Fiat Motors of North America, Inc. Parklane Towers West, Suite 1210 Dearborn, Michigan 48126

Dear Mr. Negro:

This is in reply to your letter of May 9, 1983, to Mr. Vinson of my staff with respect to conformance of a planned stop lamp design with Federal Motor Vehicle Safety Standard No. 108, Lamps Reflective Devices, and Associated Equipment.

The design comprises two compartments separated by a reflex reflector. One of the compartments will meet the photometric requirements for a stop lamp, in your judgement. The other will not, but in conjunction with the first compartment "the requirements can be met." You have asked if this arrangement is acceptable pursuant to paragraph S4.1.1.6 which allows photometric requirements to be met by a combination of compartments or lamps.

Paragraph S4.1.1.6 is intended to cover replacement stop lamps for vehicles manufactured between January 1, 1973, and September 1, 1978, when the SAE J586b, September 1966. As such, its requirements are not relevant to your concerns.

However, SAE J586c, August 1970, whose requirements do apply to stop lamps, appears to permit your design. Under paragraph 3.1, where the distance between filament centers of two stop lamps does not exceed 22 inches (presumably your design) the photometric readings of both lamps must be combined to meet the photometric requirements of Table 1 of J586c applicable to two lighted sections. However, the combined candela must not exceed the specified total of 360 for two lighted sections.

I hope this answers your questions.

Sincerely,

Frank Berndt Chief Counsel

May 9, 1983

Mr. Taylor Vincent Office of Chief Counsel Department of Transportation NHTSA 400 7th Street, S.W. Washington, D.C. 20590

Subject: FMVSS 108 Combination Tail Light Assembly

Dear Mr. Vinson:

Please find enclosed a drawing of a combination rear taillamp assembly that Ferrari would like to use on a model to be imported into the United States beginning with model year 1985 or 1986. Since this assembly is a departure from the round light assemblies customarily seen on the rear of the Ferrari vehicles, there is some minor concerns regarding the stop light portion of this assembly.

The lower left compartment of the assembly which is labeled "Sector II" and outlined in red is a stop light with a 32 candle power lamp. This sector by itself will meet the photometric requirements for a stoplamp. The lower right compartment which is labeled "Sector I" and having a 4 candlepower lamp while the second lamp is a dual filament lamp used as a parking/stop light. The parking light has a 32 candlepower rating. This sector of the assembly will not meet the photometric requirements by itself but in conjunction with "Sector II" the requirements can be met.

We have reviewed paragraph S4.1.1.6 of FMVSS 108 which states impart "the photometric requirements may be met by a combination of compartments or lamps" (emphasis added) and, therefore, we have concluded that Ferrari would be in compliance with the stop light requirements of Standard 108.

We are kindly requesting that NHTSA review the drawing and our interpretation of paragraph S4.1.1.6 and notify us if our conclusions that Ferrari would be in compliance with the stop light requirements of Standard 108.

We are kindly requesting that NHTSA review the drawing and our interpretation of paragraph S4.1.1.6 and notify us if our conclusion that Ferrari would be in compliance with Standard 108 is correct.

Sincerely yours, Alberto Negro

ID: 1983-2.16

TYPE: INTERPRETATION-NHTSA

DATE: 06/13/83

FROM: AUTHOR UNAVAILABLE; Diane K. Steed; NHTSA

TO: Ford Motor Company -- Roger E. Maugh, Director, Automotive Safety Office

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Roger E. Maugh Director, Automotive Safety Office Ford Motor Company The American Road Dearborn, Michigan 48121

Dear Mr. Maugh:

This responds to your letter of June 2, 1983, regarding Ford's desire to equip 2,500 of its vehicles with Securiflex windshields to obtain field data regarding glass-plastic glazing. You state that such a test fleet would provide Ford with information regarding concerns it has about in-plant handling, vehicle assembly, mirror attachment, haze, scratching, delamination, durability, and performance in accidents.

As you are probably aware, General Motors made a similar request regarding a test fleet of Securiflex windshields last fall. We can give Ford the same assurances that were given to General Motors in response to their request. Under the limited and special circumstances of the field test described in your letter, the agency can firmly state that it would not enforce the abrasion requirement of Safety Standard No. 205 as it now stands since it does not appear to be appropriate for technology like the Securiflex windshield (Securiflex apparently cannot pass the existing abrasion requirements). That technology was developed after the standard was originally issued, and the standard did not contemplate asymmetrical glazing of this type. Equally important, the agency notes that all current information indicates that glass-plastic glazing does have a great potential for reducing lacerative injuries in accidents. The experimental use which you propose should provide valuable information regarding injury reduction and some of the remaining problems which do appear to exist with regards to this type windshield. We also note your statement that the Securiflex windshield you plan to install on the test fleet would comply with the proposed requirements for glass-plastic glazing issued by the agency March 10, 1983 (48 FR 10097).

In light of the agency's policy decision to foster the use of new safety technology by permitting the field test you propose, the agency expects your company to monitor closely the test fleet and to rectify any problems that may develop. Ford would, of course, remain responsible for meeting its obligation under the Vehicle Safety Act regarding any safety related defects. The agency also expects to be apprised of all information that Ford obtains from this field test.

Sincerely, Diane K. Steed Acting Administrator

ID: 1983-2.17

TYPE: INTERPRETATION-NHTSA

DATE: 06/14/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mack Trucks, Inc. -- S. Robson, Sr. Project Engineer - Vehicle Regulations

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. S. Robson Sr. Project Engineer - Vehicle Regulations Mack Trucks, Inc. P.O. Box 1761 Allentown, Pennsylvania 18105

Dear Mr. Robson:

This responds to your recent letter requesting an interpretation concerning the test procedures of Safety Standard No. 207. You ask whether a seat in a heavy duty truck must remain in its adjusted position when tested with a load of 20 times the weight of the entire seat, if the seat has been tested and remains in its adjusted position when subjected to a load of 20 times the weight of the adjustable upper section of the seat.

This question arises because of the configuration of some heavy-duty truck seats which include suspension fixtures (pedestal structures) on which the upper seat section rests. Safety Standard No. 207 requires seats to withstand a load equal to 20 times their weight and requires the seats to remain in their adjusted position during the required loading (paragraph S4.2). The upper seat sections and adjusters of your truck seats are tested on rigid test beds by the seat manufacturer and reportedly comply with the adjuster provision of S4.2. However, when you test these seats in the actual vehicle (applying 20 times the weight of the entire seat, including pedestal), the center of gravity falls on the seat adjuster and the seat does not always stay in its adjusted position during loading.

In answer to your specific question, the seat must remain in its adjusted position when tested to 20 times the weight of the entire seat, as required by paragraph S4.2 of the standard. We would agree with you, however, that with a seat configuration such as you describe, the adjusters and upper seat section would never experience a loading of 20 times the weight of the entire seat in an actual crash. Your problem appears to arise because the center of gravity of this seat happens to fall on the seat adjusters and the standard requires the loading to be applied through the center of gravity. The purpose of this loading requirement, however, is to ensure the integrity of the entire seat as it is attached to the vehicle structure.

Therefore, it is our opinion that for a pedestal seat such as you describe, a manufacturer could establish due care through a combined test procedure which would load the seat adjusters and upper seat section to only 20 times the weight of those components to determine if the seat would remain in its adjusted position, and which would load the seat as anchored to the vehicle structure to 20 times the weight of the entire seat, including the pedestal.

Please contact Hugh Oates of my staff if you have any further questions (202-426-2992).

Sincerely,

Frank Berndt Chief Counsel

April 29, 1983

Office of General Council, NHTSA

Gentlemen:

Subject: Clarification of Seat Testing Procedure FMVSS 207

Mack Trucks, Inc., a major manufacturer of heavy duty trucks is requesting an interpretation and clarification of the seat test procedure appearing in Sections 4 and 5 of 49 CFR Part 571.207 -Standard No. 207; Seating Systems.

The typical structure of the vast majority of seats used in heavy duty trucks is considerably different than those used in passenger cars. Note the comparisons on the attached sheet. In a passenger car, the fore/aft (longitudinal) adjuster is typically at the bottom of the seat between the seat and the floor of the vehicle body (see Figure 1). In a heavy duty truck, the adjuster is typically above the suspension mechanism of the seat and below the upper seat section (see Figure 2). In an actual 20g acceleration, the adjuster on the typical passenger car seat would experience the force of the mass of the entire seat being accelerated (or decelerated). However, on a typical heavy duty truck seat the adjuster would experience the force of only the upper seat section (perhaps about 40% of the total seat weight) being accelerated (or decelerated) at 20g.

Mack Trucks, Inc. is not a manufacturer of the seats used on our vehicles; they are manufactured by outside vendors. These outside vendors test and certify the seats supplied to Mack Trucks, Inc. for compliance with FMVSS's 207, 210 and 302.

However, these certifications are made with the seats mounted to rigid test beds, not in an actual cab. Mack Trucks, Inc., in exercising due care in its installation of seats, performs its own compliance testing of each new seat or seat belt mounting in an actual truck cab. Because of the basic difference in seat structure between a passenger car seat and a truck seat, it is necessary that a fixture be welded to the seat as close as possible to the actual vertical c.g. (center of gravity) of the entire seat. This fixture is used to attach the hydraulic mechanism necessary to apply the 20g load to the seat. In many instances, the vertical c.g. of the seat is approximately at the same height as the seat adjusters. When attaching this fixture to the seat, it quite often becomes necessary to attach it to brackets that are part of the upper seat section. In doing so, the 20g load for the entire seat is being transmitted through the fore/aft adjusters. As mentioned earlier, the fore/aft adjusters would not "see" this much load in an actual 20g acceleration (or deceleration). It would "see" only 20 times the weight of the upper seat section. Therefore, in testing the seat with the fixture attached to the upper seat section, the adjusters would be greatly overloaded from their design load and may not remain in their adjusted position.

The question that Mack Trucks/ Inc. poses to the NHTSA is this: Would it be considered as not meeting the test requirements of FMVSS 207 if a seat, when tested with a load of 20 times the weight of the entire seat being applied through the adjusters for the upper seat section, does not remain in its fore/aft adjusted position, even if the adjusters have been tested and certified from the vendor for compliance when subjected to the load of 20 times just the weight of the adjustable upper section of the seat?

As you can appreciate, the answer to this question will affect our current test procedures and therefore, we request a timely response. If additional information is required or you wish to discuss the problem further, please contact this office.

Very truly yours,

MACK TRUCKS, INC.

S. Robson Sr. Project Engineer - Vehicle Regulations

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Attachment Omitted.