ID: 1985-01.33

TYPE: INTERPRETATION-NHTSA

DATE: 02/12/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Nick Martz -- Regional Sales Manager, Isuzu Diesel of North America

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Nick Martz Regional Sales Manager Isuzu Diesel of North America 41169 Vincenti Court Novi, Michigan 48050

This responds to your letter asking about identification requirements applicable to water temperature, oil pressure and alternator instruments on bread delivery trucks. You asked whether the symbols specified by Standard No. 101, Controls and Displays, are required for such trucks and, if so, whether it is permissible to use transparent decals with the proper symbols on the lenses. You also asked whether waivers can be issued. The answers to your questions are provided below.

Federal Motor Vehicle Safety Standard No. 101, Controls and Displays, specifies requirements for the location, identification, and illumination of motor vehicle controls and displays. Water temperature, oil pressure and alternator instruments are displays. While the standard's requirements for controls apply to all trucks, the standard's requirements for displays are only applicable to trucks with a gross vehicle weight rating of less than 10,000 pounds. See section S5.

Assuming that your bread trucks do have a gross vehicle weight rating of less than 10,000 pounds, the instruments must be identified by the symbols specified by Standard No. 101. Section S5.2.3 provides in relevant part:

Except for informational readout displays, any display located within the passenger compartment and listed in column 1 of Table 2 that has a symbol designated in column 4, shall be identified by that symbol. Such display may, in addition be identified by the word or abbreviation shown in column 3. . . . Additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity. The identification required or permitted by this section shall be placed on or adjacent to the display that it identifies. The identification of any display shall, under the conditions of S6, be visible to the driver and appear to the driver perceptually upright.

The displays described by your letter are conventional guages rather than informational readout displays. (Informational readout displays are defined by the standard to be displays using light-emitting diodes, liquid crystals, or other electro illuminating devices where one or more than one type of information may be displayed.) Table 2 specifies symbols for, among other displays, oil pressure gauges, coolant temperature gauges, and electrical charge gauges. Therefore, under S5.2.3, the displays must be identified by the specified symbols.

Standard No. 101 does not specify the nature of the material to be used in identifying displays, i.e., paint, decals, etc. Therefore, it is permissible to use decals.

You also asked whether waivers can be issued. In a telephone conversation with Edward Glancy of this office, you indicated that some trucks have been produced using words rather than symbols to identify the gauges discussed above. 49 CFR Part 556 sets forth procedures for petitioning for exemption from the notification and remedy requirements of the National Traffic and Motor Vehicle Safety Act due to the inconsequentiality of a noncompliance with a safety standard as it relates to motor vehicle safety. I have enclosed a copy of Part 556 for your convenience, as well as a copy of Standard No. 101.

Sincerely, Frank Berndt Chief Counsel Enclosures

Lyall F. (Nick) Martz Zone Sales Manager Isuzu Diesel of North America 41169 Vincenti Court Novi, Michigan 48050-2689 (313) 474-8000

November 1, 1984 National Highway Traffic Safety Assoc. Office of Chief Counsel 400 7th Street S.W. Washington D.C. 20590

Re: Engine Instruments

Gentlemen:

We need your advice on water temperature, oil pressure, and alternator instruments in 1984 bread delivery trucks. We have had to change the above mentioned gauges since the original instruments in the vehicle are not compatible with our diesel engine.

The gauges we installed in the vehicle in an accessory panel are 2-inch dials with illumination lights.

The new oil pressure gauge manufactured by F. W. Murphy has a black dial with white numbers and pointer and is calibrated in PSI and K/CM3 but has no ISO symbol.

The water temperature gauge manufactured by VDO has the same type dial and is calibrated in Fo and Co. This gauge has an ISO symbol like the one used in SAE J-298 for industrial applications.

The alternator light has Alt. between the red 1/2" diameter lense and the light. This light is illuminated in the accessory position and crank position but goes out when the engine is running.

We have contacted V.D.O. and Murphy Mfg. and they informed us they do not make gauges with the FMVSS 101 symbol on them.

The problem we have is that the 96 vehicles with these gauges are now ready for delivery, but the missing ISO symbols will delay delivery to the customer. The gauge manufacturer says it will take 12 weeks to develop the proper symbol.

Is it necessary to use Automotive ISO symbols on E-350 delivery trucks, or can a waiver be issued? If symbols are necessary, is it acceptable to use transparent decals with the proper symbols on the lense?

I would appreciate your prompt attention and answer on this matter since time is critical.

Please call at your earliest opportunity.

Regards, Nick Martz Regional Sales Manager Enclosures

ID: 1985-01.34

TYPE: INTERPRETATION-NHTSA

DATE: 02/12/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Ms. Rose Marie Sigismondo

TITLE: FMVSS INTERPRETATION

TEXT:

Ms. Rose Marie Sigismondo Star Route Box 346 Dingman's Ferry, PA 18328

This responds to your letter asking whether our agency has any authority under current law to require school bus drivers to wear safety belts immediately. Practically speaking, the answer is no. Our authority over school transportation is indirect and can be effectuated only through the States. Let me explain.

The regulations on school transportation were issued by our agency under the Highway Safety Act (Public Law 89-564). The Highway Safety Act deals with the safety of vehicle operation through a grant program to the States. The standard to which you refer in your letter, Highway Safety Program Standard No. 17, Pupil Transportation Safety (hereafter HSPS 17), was issued under the authority of that Act. You are correct that section IV.C.d. (4) of this standard provides that drivers of school vehicles equipped with lap belts shall wear the belts whenever the vehicle is in motion. We issued this provision because we believe that safety belts protect school bus drivers in the event of an accident and assist to avoid accidents by helping drivers maintain control of their vehicles.

The great majority of the States have recognized the importance of requiring school bus drivers to wear safety belts, and have issued appropriate requirements either by law or through regulations issued by State agencies. It is the States' responsibility to require the use of safety belts by bus drivers. We have no authority to displace the States and issue regulations directly applicable to drivers. It is up to Pennsylvania to adopt regulations or legislation to require that school bus drivers wear their safety belts and to enforce its law.

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

Sincerely,

Frank Berndt Chief Counsel Star Route Box 346 Dingman's Ferry, Pa., 18328 November 5, 1984 NHTSA 400 Seventh Street, S.W. Washington D.D., 20590

Attn: Mr. Brundt

Dear Sir:

I have spent the last 8 weeks examining many aspects of school bus safety, especially seat belts on school buses. While researching I came across: a) Standard 17 amended 5/73 - Drivers of School Vehicles equipped w/ lap belts shall be required to wear them whenever the vehicle is in motion.

b) Pa. Equip and Safety Standards of School Buses and School Vehicles Ch. 171 9/1/83 Pg. 25 171.68 - Seat belt for driver. A seatbelt meeting the requirements of FMVSS 209 shall be provided for the driver. c) Pa. School Bus Operators Manual Dept of Trans. Pub #117 rev. 1978 Pg 48 - Adjust your seatbelt to provide firm yet comfortable support. Pg 56 Daily Inspection Form-Inside Bus-Seat belt adjustment.

It is obvious that Pa. complies w/ standard 17 in as far as requiring a belt for the driver. Most of our drivers do not wear their belts. I have called our state troopers asking for info on written warnings or citations that the drivers or contractors would receive when breaking this law.

When I couldn't get a firm answer I called Mr. Robert William who referred me to David Soule. after some discussion he referred me to Elana West Penn DOT 717/787-6453 her office referred me to Mr. William Hilton, 717/787-2895. Mr. Hilton explained that seat belts are required in driver positions although there is no law mandating the driver to use the belt, even when his operators manual tells him to do so. Mr. Hilton said that regulation will be written, it will take 3 mos. to a year for law to be passed.

I hope that your dept can do something in the way of mandating drivers to wear belts. Pa. complies w/ standard 17 on paper yet the most important factor isn't there, the penalty or incentive to wear the belt. I am confident that Mr. Hilton will do all he can to rectify this, but can't help to wonder how many other states are in the same position. As good as standard 17 is, it doesn't mean a thing when not enforced in real life.

I am writing you with hope that you can guide us in the proper direction in enforcing standard 17. Is there anyway presently to interpret current law so that the drive is will have to wear their belts immediately.

Sincerely yours,

Rose Marie Sigismondo

cc: Mr. John a Pachuta Director Bureau Motor Vehicles Pa. Judy Dranov Nat. Coalition for Seatbelts on School Buses Rep. William S. Foster Senator Frank O'Connell Senator H. John Heinz Congressman Joseph McDae Senator Arlen Spector Rep. Peter Nostmayer Senator Stewart Greenleaf Doctor G. Strock Superintendent. Delaware Valley School District

Dingmans PTA debates school bus seat belts

[Text Omitted]

ID: 1985-01.35

TYPE: INTERPRETATION-NHTSA

DATE: 02/22/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: John Humphrey -- Fleet Maintenance Division, U.S. Postal Service

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. John Humphrey General Manager Fleet Maintenance Division Office of Fleet Management United States Postal Service Delivery services Department 475 L'Enfant Plaza, SW Washington, D.C. 20260-7200

This is in response to your letter of January 15, 1985, to Taylor Vinson of this office asking for a waiver of the maximum height requirement so that the Postal Service may install center stop lamps on its new delivery trucks mounted from 75 to 83 inches above the road surface.

You do not need an exemption in order to install the lamp at the height you desire. First, Standard No. 108 requires the installation of a center high mounted stop lamp on passenger cars only, and not on trucks. Secondly, the 72-inch limitation on stop lamp mounting height imposed by Standard No. 108 for stop lamps applies only to the stop lamps that are mounted on either side of the vertical centerline. There is no limitation on the mounting height of the center lamp, when required on a vehicle, or prohibition against mounting it above 72 inches on a vehicle that is not required to have it.

We appreciate the interest of the Postal Service in reducing rear end accidents but would like to point out that the efficacy of the lamp on vehicle other than passenger cars is unknown. Our studies showed that the lamp was most effective at the approximate eye height of the driver in a following vehicle, and also as an alert to the driver behind who saw the highmounted light through the intervening car. Thus, the Postal Service with its lights mounted above the rear door should not expect its vehicles in service necessarily to replicate this agency's test experience.

Sincerely,

Original Signed By

Frank Berndt Chief Counsel

January 15, 1985

Mr. Taylor Vinson, Legal Counsel Room 5219 - FMVSS - 108 NHTSA - U.S. Department of Transportation 400 7th Street, S.W. Washington, D.C. 20590

Dear Mr. Vinson:

The U.S. Postal Service is in the process of testing and procuring a new Long Life Vehicle (LLV). These vehicles are light delivery trucks and will be used primarily for residential mail delivery and collection and will replace the vehicle (Jeep) presently used for this function.

In the interest of safety we have required a high center mounted brake light on these units. Since the units will be slightly larger than the current vehicle the high mounted brake light will exceed the maximum of seventy-two (72) inches from the roadway as required by Federal Motor Vehicle Safety Standards, Part 511, 108 Table IV Location of Required Equipment.

Due to the configuration of the proposed LLV the center mounted stop lamp will be between 78 and 83 inches from the roadway at curb weight. I have enclosed a photo of the three units we are currently testing, so that you might have a better understanding of the stop lamp location.

We are requesting a waiver to this requirement to permit placement of a center mounted stop lamp on these vehicles. Your assistance will be appreciated.

Sincerely,

Mr. John Humphrey General Manager Fleet Maintenance Division Office of Fleet Management

ID: 1985-01.36

TYPE: INTERPRETATION-NHTSA

DATE: 02/26/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Bernt Svensson -- Marketing Director, Viskafors Gummifabrik AB

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Bernt Svensson Marketing Director Viskafors Gummifabrik AB Box 2059 S-515 02 Viskafors SWEDEN

This responds to your letter to Ms. Kathleen DeMeter of my staff, asking for information on how to get a new temporary spare tire size included in the tire tables following Standard No. 109 New Pneumatic Tires --Passenger Cars (49 CFR S571.109). The agency rescinded tire tables in Standard No. 109 in a final rule published at 46 FR 61473; December 17, 1981. I have enclosed a copy of that rule together with a current copy of Standard No. 109 for your records.

Section S4.4.1 requires tire manufacturers to provide a listing of the rims that may be used with each tire size it produces. Section S4.2.1(c) requires a tire's load rating to be the load rating for that size specified in a submission under S4.4.1. This may be provided by the manufacturer in a document furnished to each of the manufacturer' s dealers, to this agency, and to the public upon request. Alternatively, the manufacturer may use the data for that tire size shown in a current publication of one of the standardization organizations listed in S4.4.1(b). Your company will have to use one of these two means of complying with this requirement, instead of relying on the tire tables, as was formerly done.

The current publication of the American standardization organization (the Tire & Rim Association) shows no listing for the tire size about which you inquired. It is possible that the size is listed by one of the other standardization organizations. If not, you should either get the size listed by the standardization organization of your choosing or submit the data directly to this agency, all your dealers and the public, upon request.

Should you have any further questions on this matter, please contact Mr. Stephen Kratzke of my staff at this address.

Sincerely,

Frank Berndt Chief Counsel

Enclosures

1985-02-01 U.S. Department of Transportation M/MA2 National Highway Traffic Safety Administration 400 Seventh St. S.S. WASHINGTON, D.C. 20590 U S A

Att.: Mrs. Kathleen DeMeter

Dear Mrs. DeMeter,

From your files you may record that we are a producer of tires having the plant code VV.

We are in the process of manufacturing a spare tire for one of our clients in Sweden and would kindly ask for your advice and information as to the following points:

In the MVSS 109 regulation there are several sizes listed under the heading "T-series" 60 psi tires.

Due to various technical reasons we are considering one particular size which as far as we know is not listed namely T 125/90 R 15. (We understand that "D"-bias and "R"-radial are equal alternatives.

In connection with this we have the following questions:

Is T 125/90 "D" alt. "R" 15 now recorded in the latest edition of MVSS 109. If so could you please send us this edition showing all required data or alternatively the specific data for this tire as a complement to the MVSS 109 needed to consider and meet the USA legal requirements.

If you are not familiar with this particular size in the "T-series" range could you please advise us how we should proceed to have this tire recorded and recognized.

We would appreciate your consideration of this matter and look forward to your early response.

Very truly yours, VISKAFORS AB

Bernt Svensson Marketing Director

ID: 1985-01.37

TYPE: INTERPRETATION-NHTSA

DATE: 02/26/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Giorgio Kirchner Federazione Italiana Fuoristrada

TITLE: FMVSS INTERPRETATION

TEXT:

AIR MAIL

Mr. Giorgio Kirchner Segreteria Generale Federazione Italiana Fuoristrada 20131 Milano Via Capranica, 4 ITALY

Dear Mr. Kirchner:

This responds to your letter asking for information about U.S. Federal laws covering tires. For your information, I have enclosed a copy of a letter I sent to a Brazilian tire manufacturer last year, explaining all of the requirements which must be satisfied by a foreign manufacturer selling tires in the United States and enclosing copies of the pertinent regulations.

You stated that you were particularly interested in knowing the meanings and the corresponding values of identification symbols required to appear an sidewalls of tires subject to Standard No. 119. You listed as examples of symbols you were interested in load range and "P.R."

The load range is a letter between "A" and "N", with an A being the lowest load range and N being the highest. Load ranges are designed to tires for use on motor vehicles other than passenger cars because such tires may have identical physical dimensions and, therefore, identical size designations, but widely differing load-carrying capabilities. To ensure that these tires are used only in situations where their load-carrying capability is sufficient, section S6.5(j) of Standard No. 119 requires a letter designating the load range to appear on the sidewall of each tire for use on motor vehicles other than passenger cars. If you are interested in learning the load-carrying capability of the load ranges assigned to a particular tire size, you should contact one of the standardization organizations listed in section S5.1(b) of the enclosed copy of Standard No. 119.

I believe that the symbol "P.R." refers to the ply rating for a tire. The ply rating is an older system which performed the same function now served by the load range. Under the ply rating system, tires were rated from 2 to 24 plies, with the lower numbers indicating a lesser load-carrying capability. Standard No. 119 does not require that a ply rating appear on the sidewall of tires. I have enclosed a copy of a page from the most recent yearbook published by the American standardization organization, the Tire a Rim Association, which shows how to convert a ply rating to the appropriate load range.

If you need further information or have any questions on the enclosed materials, please feel free to contact me.

Sincerely,

Original Signed By

Frank Berndt Chief Counsel

Enclosures

U.S. DEPARTMENT OF TRANSPORTATION 407 7th St. S.W. WASHINGTON D.C. 20580 (Stati Uniti)

Milano, 27.12.84

Re : U.S. Federal Laws covering Tires

Dear Sirs,

We should like to receive information covering the above mentioned U.S. Federal Laws and the one named FMVSS119.

We are particularly interested in knowing the readings (and the corresponding values) of identification symbols carried on tire sidewalls, i.e.:

Load Range, P.R., etc.

We thank you for your assistance.

We remain Yours faithfully Federazione Italiana Fuoristrada Segreteria Generale Giorgio Kirchner

ID: 1985-01.38

TYPE: INTERPRETATION-NHTSA

DATE: 02/27/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. H. Horiyoshi Mazda (North America), Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. H. Horiyoshi Executive Vice President and General Manager Mazda (North America), Inc. 24402 Sinacola Court Farmington Hills, MI 48018

Dear Mr. Horiyoshi:

This is in reply to your letter of November 21, 1984, asking for an interpretation of Motor Vehicle Safety Standard No. 108 as it would apply to a contemplated parking lamp system.

Usually passenger cars are designed with two parking lamps, one on each side of the vehicle front. Mazda would have two such lamps on each vehicle side, each of the two lamps flanking the headlamp. You have asked whether, in determining the H-V axis, one takes the axis as the center of each lamp, or should one consider the pair a single device and place the H-V axis at the midpoint between them.

Standard No. 108 requires passenger cars to be equipped with a minimum of two parking lamps, located "as far apart as practicable." Therefore, the outermost parking lamp, (the one located between the turn signal lamp and the headlamp) is the lamp that must meet the parking lamp requirements of Standard No. 108, and the H-V axis for purposes of compliance would be determined at the center of the lens of that lamp. Supplementary lighting equipment is permissible under Standard No. 108 and does not have to meet the standard's requirements, but it must not impair the effectiveness of the lighting equipment required by the standard (paragraph S4.1.3). Because of the difference in candela between parking lamps and headlamps, information available to us does not indicate that your supplementary parking lamp would have this effect, and consequently, the design would be permitted.

I hope that this answers your questions.

Sincerely,

Original Signed By Frank Berndt Chief Counsel

ID: 1985-01.39

TYPE: INTERPRETATION-NHTSA

DATE: 03/01/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Hiroshi Shimizu

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of December 19, 1984, concerning the requirements of Federal Motor Vehicle Safety Standard No. 209, Seat Belt Assemblies. You noted that section S4.1(e) of the standard provides that "A Type 1 or Type 2 seat belt assembly shall be provided with a buckle or buckles readily accessible to the occupant. . . ." [Emphasis added]. You asked whether the standard would permit a seat belt assembly with two buckles as shown in the schematic attached to your letter. The answer is that while Standard No. 209 would permit such an assembly, whether such an assembly can be installed in a particular vehicle is determined by Standard No. 208, Occupant Crash Protection.

Standard No. 208 specifies performance requirements for the protection of occupants in a crash. Section S4.1.2.3.1 provides that Type 2 lap and shoulder belt systems used in passenger cars must have a nondetachable shoulder belt. Likewise, S4.2.2 provides that certain trucks and buses with Type 2 belts must have a nondetachable shoulder belt. The belt system you illustrated in your diagram consists of one continuous loop of webbing which serves as both the lap and shoulder belt. However, your design provides a separate buckle for the shoulder anchorage and thus an occupant could release the shoulder buckle and use the belt solely as a lap belt. Thus, we would not consider your design to have a nondetachable shoulder belt.

In addition, section S7.2 of the standard sets requirements for the latch mechanism of non-automatic seat belt assemblies used in passenger cars and certain trucks and buses. Section S7.2(c) requires that the latch mechanism used in those vehicles must release at a single point. Therefore, a two buckle system could not be used in those vehicles.

I hope this answers your question.

Sincerely,

ATTACH.

December 19, 1984

Diane Steed -- Administrator, National Highway Traffic Safety Administration

Dear Sirs:

This is to ask for your confirmation that a design of seat belt assembly having two buckles is allowed by Federal Motor Vehicle Safety Standard 209.

Section S4.1(e) of the standard sets forth "A Type 1 or Type 2 seat belt assembly shall be provided with a buckle or buckles readily accessible to the occupant . . . . .". Based on that provision, we believe that FMVSS 209 permits such a seat belt design as shown in the schematic enclosed as long as they meet all the applicable provisions in the regulation.

We should appreciate your confirmation letter.

Very truly yours,

TOKAI RIKA CO., LTD.;

Hiroshi Shimizu, Asst. Manager -- Overseas Operations Dept.

Encl.

(Graphics omitted)

Schematic of Seat Belt Assembly having Two Buckles

ID: 1985-01.4

TYPE: INTERPRETATION-NHTSA

DATE: 01/03/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: The Honorable Robert S. Walker

TITLE: FMVSA INTERPRETATION

TEXT:

Jan. 3, l985 The Honorable Robert S. Walker House of Representatives Washington, D.C. 20515

Dear Mr. Walker: This is in further response to your letter on behalf of your constituent, Mr. Curtis L. Rohm, the Superintendent of Schools n the Solanco School District. We have recently replied to Mr. Rohm by letter dated December 28, l984. Enclosed you will find a copy of our response to Mr. Rohm and your constituents correspondence. If you have further questions, please do not hesitate to contact my office.

Sincerely, Frank Berndt, Chief Counsel Enclosures

ID: 1985-01.40

TYPE: INTERPRETATION-NHTSA

DATE: 03/01/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: T. Chikada, Manager, Automotive Lighting, Engineering Control Dept., Stanley Electric Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Chikada, Manager Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

This is in reply to your letter of January 11, 1985, to Mr. Vinson of this office, asking for a clarification of certain terminology relating to the definition of a standardized replaceable light source in Motor Vehicle Safety Standard No. 108.

We are aware of the problem underlying your question, i.e., that the standard contemplates testing of the bulb with its base but the photometrics specified are appropriate for the capsule portion alone. Our Rulemaking staff is reviewing this issue. The agency will inform you of the results of that review. If appropriate, the issue will be addressed through an appropriate interpretation or amendment of the standard.

Sincerely,

Frank Berndt Chief Counsel

January 11, 1985

Attn: Mr. Taylor Vinson Lawyer

Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U. S. A.

Dear Mr. Vinson,

We are a little bit confused with your wordings in a current FMVSS 108 particularly on S3 "Definition" of specifying "Standardized Replaceable Light Source".

By the S3, Definition of Standardized Replaceable Light Source, it specifies that it is an assembly of a headlamp bulb, base and terminals as described in Fig. 3.

From the above S3 Definition, it can also be interpreted that the means a halogen capsule alone without base as described in Fig. 3 -5.

The lumen values specified in a (b) (1), the general specification of the bulb shall be: for standardized replaceable light source required in S4.1.1.38 of FMVSS 108, can we take that values measured from a halogen capsule alone, without base? Because the wordings are very ambiguous. Please refer the wordings and words underline in the attached.

What is more, at the (b) in S4.1.1.38 says, the bulb portion of the standardized replaceable light source, this bulb portion and the bulb in the (b) (1), the general specification of the bulb shall be: you are talking the same thing, Bulb only (means capsule) without base, we presume.

We would appreciate it very much if you would clarify the each meaning of the word, "Bulb" colored in blue and assembly, light source and the relation between the above words and standardized replaceable light source in the attached.

Sincerely,

Stanley Electric Co., Ltd.

T. Chikada, Manager Automotive Lighting Engineering Control Dept.

Encl. Copies of FMVSS 108 (5) KW/es

Federal Motor Vehicle Safety Standard No.108

Lamps, reflective devices, and associated equipment

S1. Purpose and scope

This standard specifies requirements for original and replacement lamps, reflective devices, and associated equipment necessary for signaling and for the safe operation of motor vehicles during darkness and other conditions of reduced visibility.

S2. Application

This standard applies to passenger cars, multipurpose passenger vehicles, trucks, buses, trailers (except pole trailers and trailer converter dollies), and motorcycles, and to lamps, reflective devices, and associated equipment for replacement of like equipment on vehicles to which this standard applies.

S3. Definitions

"Headlamp test fixture" means a device designed to support a replaceable bulb headlamp in the test position specified in the laboratory tests in S4.1.1.36(d), and whose mounting hardware and components are those necessary to operate the headlamp as installed in a motor vehicle.

"Replaceable bulb headlamp" means a headlamp comprising a bonded lens and reflector assembly, and a standardized replaceable light source.

"Seasoning" means a process of energizing the filament of a headlamp, at design voltage, for a period of time equal to 1 percent of average rated laboratory life.

"Standardized replaceable light source" means an assembly of a headlamp bulb, base, and terminals, as described in Figure 3.

S4. Requirements S4.1 Required motor vehicle lighting equipment

S4.1.1.38 Each standardized replaceable light source shall conform to the following requirements: (a) A silicone O-ring shall be provided. (b) The bulb portion of the standardized replaceable light source shall meet the requirements in paragraphs (b)(1) through (b)(6) of this section.

(1) The general specifications of the bulb shall be:

Low beam High beam Maximum power, watts at 2.8V (design voltage) 50 70

Lumens (without black cap) at 12.8 V design voltage 1.067 + 10% 1.738 + 10%

Average life at 14.0 V rated voltage (life testing 320 hrs 150 hrs as conducted in a finished headlamp assembly placed in the normal operating attitude)

(2) The bulb filaments shall be subject to seasoning prior to wattage and lumens measurement. (3) Wattage and lumens measurements shall be made with the direct current test voltage regulated within one quarter of one percent. (4) Except for reference dimensions, and unless otherwise specified, a general tolerance of +0.004 in. (0.10 mm) shall apply to all linear dimensions and +1o.00' shall apply to all angular dimensions. (5) Bulb, lead wires and/or terminals shall be installed in the base so as to provide an airtight seal. (6) After a bulb deflection test conducted in accordance with S7, the permanent deflection of the glass envelope of each standardized replaceable light source shall not exceed 0.005 inch (0.13 mm) in the direction of the

ID: 1985-01.41

TYPE: INTERPRETATION-NHTSA

DATE: 03/01/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Andrew P. Kallman -- Kallman Marketing

TITLE: FMVSS INTERPRETATION

ATTACHMT: 10/28/88 letter from Erika Z. Jones to Andrew P. Kallman (A32; Std. 205; Std. 212); 2/8/88 letter from Andrew P. Kallman to Erika Z. Jones and Susan Schruth (ACC 1569)

TEXT:

Mr. Andrew P. Kallman Kallman Marketing 205 W. Saginaw Lansing, MI 48933 Dear Mr. Kallman:

This responds to your letter of January 14, 1985, concerning what regulations affect a process you intend to market for new and used cars. The process consists of grinding two parallel grooves into the lower portion of the windshield. The grooves are 2mm wide, 0.1-0.3mm deep, and are 2mm from each other. You stated that the purpose of the grooves is to improve the efficiency of the wipers and increase their life expectancy. The following discussions address the effect of our regulations on the process you described.

First, let me explain how our regulations apply to a new vehicle or to a new windshield sold as an item of replacement equipment. Our agency has issued Standard No. 205, Glazing Materials, which sets performance requirements for glazing materials used in new vehicles or sold as items of replacement equipment. I have enclosed a copy of the standard. If, before they are sold, the safety grooves are ground into either the windshield of a new vehicle or into a new windshield sold as an item of replacement of equipment, the person making the grooves would have to certify that the glazing continues to be in compliance with all of the requirements of Standard No. 205 for windshields. I note that the test results enclosed with your letter do not address whether the glazing would continue to comply with the requirements after it has had the safety grooves ground into it. In particular, we would urge you to determine whether the glazing would continue to comply with the requirements regarding impact and penetration resistance, optical deviation and visual distortion after the grooves have been ground into the windshield. Purchasers of a new vehicle may alter the vehicle as they please, so long as they adhere to all State requirements.

If the safety grooves are ground into the windshield of a used vehicle, then Section 108 (a)(2)(A) of the National Traffic and Motor Safety Act may apply. That section provides that no manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative any device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard. Thus, none of those persons may knowingly grind the grooves into a vehicle's windshield if by so doing they would render inoperative the compliance of the vehicle's glazing with Standard No. 205. Violation of this section can result in Federal civil penalties up to $1,000 for each violation.

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

Sincerely,

Frank Berndt Chief Counsel

Enclosure

205 W. Saginaw Lansing, M 4d833 (517) 484-0699 TLX. 517360

January 14, 1985

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

Gentlemen:

Please find enclosed a brochure, technical results, and other testimonials on a new Product called "Turvaura" in Finnish, which being translated means "saftey grooves". Safety grooves consist of two Parallel grooves ground into the windshield on the lower part of the windshield. The grooves are 2 mm wide, 0.1-0.3 mm deep and at a distance of 2 mm from each other.

In the enclosed literature you will find the following points expanded upon:

1. The saftey grooves are an acknowledged Finnish invention (Pat. No. 50229).

2. The saftey grooves increase the efficiency of the wipers improving the wiping result and reducing glare.

3. The saftey grooves reduce the scratching effect of dirt particles on the windscreen and also reduce the amount of washing liquid used due to the increased efficiency of the wiper blades.

4. The saftey grooves increase the wiper blade life expectancy.

5. The saftey grooves do not weaken the strength of the windshield. (See also the enclosed report from the Technical Research Centre of Finland).

6. The saftey grooves need no maintenance and are permanently grooved into the windshield.

Our corporation has obtained from the producer in Finland the national marketing rights for all of the U.S. for both the new and aftermarket applicatlon of these grooves. We would appreciate a response from you regarding the process necessary to obtain approval or waiver in respect to any vehicle saftey standards applicable to this product.

In advance, thank you for your assistance.

Very truly yours,

Andrew P. Kallman Director [Enclosures Omitted)