ID: nht76-2.18

DATE: 11/15/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Gillig Bros.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of September 13, 1976, in which you ask whether Standard No. 222, School Bus Passenger Seating and Crash Protection, requires that the 20-inch maximum separation between the seating reference point and the rear surface of the restraining barrier be measured at the point of greatest distance between the two.

The restraining barrier you describe has padded tubing around its circumference which would be closer to the seating reference point than the center section of the barrier. The National Highway Traffic Safety Administration (NHTSA) interprets the requirements of paragraph S5.2.1 of Standard No. 222 to mean that the 20-inch distance must be measured from the seating reference point to the surface of the seat back or restraining barrier, exclusive of portions which protrude from the basic contour of the surface. The side tube portion would constitute such a protrusion.

SINCERELY,

September 13, 1976

Thomas W. Herlihy Office of Chief Counsel National Highway Traffic Safety Administration

We have a question relative to School Bus Safety Standard Number 222. The standard states "that there shall not be more than 20" from the seating reference point to the rear surface of the restraining barrier". This distance being measured along a horizontal longitudinal line through the S.R.P in the forward direction.

Our question is this: What is considered the rear surface. Is it part furthest to the rear, which in our case would be the padding on the side tube portion of our seat frame? Or is it considered to be the rear padding on the sheet metal center section of the seat?

Attached is a sketch which we hope will clarify our question.

As our new seat spacing design requirements hinge on your answer, we would appreciate your written answer as early as possible.

Lewis C. Coffey Chief Engineer

cc: TIMOTHY HOYT -- OFC. OF CRASHWORTHINESS

(Graphics omitted) (Graphics omitted)

ID: nht76-2.19

DATE: 11/22/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Crown Coach Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 7, 1976, in which you ask several questions concerning Standard No. 217 Bus Window Retention and Release, and Standard No. 222, School Bus Passenger Seating and Crash Protection.

Your first question asks whether a California regulation requiring 20-inch minimum seat spacing in school buses would be preempted by the requirement for 20-inch maximum seat spacing in Standard No. 222.

The National Traffic and Motor Vehicle Safety Act (the Act) provides in section 103(d) that any state or local law or regulation on an aspect of motor vehicle performance covered by a Federal standard must be identical to that Federal standard. Although the NHTSA requirement is phrased in terms of maximum spacing while the California standard concerns minimum spacing, the aspect of performance in question is seat spacing. Therefore, it is the NHTSA's opinion that a California standard on seat spacing regulates the same aspect of performance and to the degree it is not identical to the Federal standard, it would be preempted.

Your second question asks whether the seating reference point, as specified in relation to the "H" Point used in SAE Standard J826b, varies with the size of different individuals. The seating reference point, as defined by the NHTSA in Part 571.3 allows the manufacturer some discretion in selecting a point that approximates the position of the pivot center of the human torso and the thigh. While the NHTSA definition does refer to the SAE procedures for "H" point location that includes the specific measurements you cite, the manufacturer retains discretion to vary this point slightly as long as he can show that the point selected continues to simulate the position of the pivot center of the human torso and the thigh of the passengers for whom the seat is designed.

Finally, you note in your letter that compliance with the seat spacing required in Standard No. 222 might entail relocation of the side emergency exit, because Standard No. 217 requires that "[a] vertical transverse plane tangent to the rearmost point of a seat back shall pass through the forward edge of a side emergency door." The seat spacing requirement arguably could occasion the realignment of the side emergency door, but this does not have to be the case. The manufacturer is free to adjust seat spacing to be properly aligned with the emergency exit. The NHTSA's intent in this requirement is to provide an emergency exit opening extending at least 2 feet rearward of a vertical transverse plane tangent to the rearmost point of a seat back. The agency would not prohibit the use of doors wider than 2 feet as long as a minimum 2-foot opening is provided rearward of the reference plane and the latch mechanism is operated by a device located within the required 2-foot opening.

SINCERELY, Crown COACH CORPORATION

October 7, 1976

National Highway Traffic Safety Administration Motor Vehicle Programs Office of Chief Council

SUBJECT: Federal Standard 222-School Bus Seating and Crash Protection

We are presently trying to establish a seating floor plan to conform to your standards. So far, we know of only one manufacturer that may produce a seat meeting your requirements, namely American Seating Company.

The point in question is the establishment of some manufacturing tolerance between seats. Standard 222 states the maximum spacing from the seats, Seating Reference Point (SAE "H" Point), is 20 inches. This distance is equal to the minimum California standard of 25 inches from seat back to the back of the seat in front. This would leave no manufacturing tolerance. We know that Federal Standards take precedence, but the State could put a limitation on minimum spacing. American Seating has told us that they are using 20 inches +/- 1/2 inch. as a target. They will also have a tolerance on the thickness of their seat, which would affect seat spacing.

Another question on the "H" Point as specified in SAE Standard J826 - the distance up from the seat to the "H" Point is 3.84 Inches and from the "H" Point to the seat back is 5.28 Inches. Would not these dimensions change with respect to different percentile figures?

The location of the seats and tolerances create another problem which cannot be solved until something has been firmed up; that is, the location of the side emergency exit.

Standard 217, Docket No. 75-3, Notice 4, states "A vertical transverse plane tanget to the rearmost point of a seat back shall pass through the forward edge of a side emergency door." This means the door has to float with the seat locations. Also suppose the door is larger in size than the Standard states, this would penalize the manufacturer of the bus body, having to redesign side walls to accept different door and window locations.

We have been in contact with Mr. Tim Hoyt of your Docket Writer Section, who has been very helpful, but cannot answer our specific questions, and recommends we contact your Department for clarification of the Standard and specific answers to our problems.

If you need any clarification on our questions please phone and we will try to explain more fully.

Ray Hartman Vice President-Engineering

ID: nht76-2.2

DATE: 09/03/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your January 26, 1976, question whether Standard No. 124, Accelerator Control Devices, requires that the throttle return to the "idle position" within specified time limits in the case where an "automatic speed control device" is in operation and a failure occurs in it.

The requirements of S5.1 and S5.2 of the standard require a return of the throttle to the idle position when either one source of throttle "return energy" or a component of the accelerator control system fails or is disconnected. In the case you describe, failure does not occur as outlined in S5.1 and S5.2. Therefore, this failure is not regulated by the standard. This is the case, because the NHTSA does not consider throttle-setting devices to be a component that "[regulates] engine speed in direct response to movement of the driver-operated control and that [returns] the throttle to the idle position upon release of the actuating force" as defined in S4.1. As set out in the definition of "idle position", the agency considers the effect of a throttle-setting device to be a separate condition that affects the setting of the accelerator control system.

YOURS TRULY,

NISSAN MOTOR CO., LTD.

January 26, 1976

Frank Berndt Office of Chief Council National Highway Traffic Safety Administration

This is to ask your interpretation regarding the requirement of FMVSS 124 for automatic speed control system.

NHTSA stated in the preamble of Docket No. 69-20; Notice 3 published on April 8, 1972, "the rule does not contain requirements for automatic speed control devices . . .".

Does it mean that FMVSS 124 does not apply to automatic speed control system itself? In other words, may we understand that while the vehicle is travelling by actuating automatic speed control system, the throttle need not return to the idle position within the time limit specified in S.5 of FMVSS 124 even if some failures occur in the devices of automatic speed control system?

Thank you for your attention to the above question. We look forward to hearing your interpretation of the above in the near future.

Tokio Iinuma Staff, Safety

ID: nht76-2.20

DATE: 07/20/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

July 20, 1976 N40-30

Mr. David E. Martin, Director Automotive Safety Engineering Environmental Activites Staff General Motors Corporation Warren, Michigan 48093

Dear Mr. Martin:

It has come to the attention of the National Highway Traffic Safety Administration that General Motors Corporation is planning to include in its 1977 Cadillac incomplete vehicle document the following statement with respect to Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity:

Conformity with FMVSS 301 is not subtantially determined by the design of this incomplete vehicle and General Motors makes no representation as to conformity with this Standard.

The use of this statement would not comply with 49 CFR Part 568, Vehicles Manufactured in Two or More Stages.

A copy of the March 8, 1976, letter from Mr. W. J. Owen of the Cadillac Motor Car Division to Mr. R. B. Kurre of the Wayne Corporation is attached for your reference. That letter was included in the petition of Wayne's Miller-Meteor Division for a temporary exemption from Standard No. 301-75 as applied to the ambulances and funeral coaches that Wayne manufactures using Cadillac commercial chassis.

I understand that these chassis are delivered to Wayne with the fuel system components already installed, that Wayne removes certain components in order to mount the body, and that those components are reinstalled after the mounting of the body.

The incomplete vehicle document is required by S568.4(a)(7) to include a--

listing by number of each standard...followed in each case by one of the following three types of statement, as applicable:

(i) A statement that the vehicle when completed will conform to the standard if no alterations are made in identified components of the incomplete vehicle....

(ii) A statement of specific conditions of final manufacture under which the manufacturer specifies that the completed vehicle will conform to the standard.

(iii) A statement that conformity with the standard. is not substantially determined by the design of the incomplete vehicle, and that the incomplete vehicle manufacturer makes no representation as to conformity with the standard.

There is a factual limitation on use of the third statement. It may not be used for standards conformity to which is substantially determined by the design of the incomplete vehicle. Where the basic fuel system components, including fuel tank and lines and filler pipe, are included in the incomplete vehicle, compliance of the completed vehicle with Standard N0.301-75 is substantially determined by both the design of the incomplete vehicle and the manner of completion by the final stage manufacturer. Therefore, General Motors is required to include a statement of the first or second type with respect to Standard No. 301-75 in the incomplete vehicle documents accompanying Cadillac commercial chassis that are manufactured on or after September 1, 1976, add designed for completion into multipurpose passenger vehicles. Such chassis that are manufactured before that date are not required by Part 568 to include any statement concerning Standard No. 301-75, because there are no fuel system integrity requirements for multipurpose passenger vehicles until that date.

The above discussion also applies to any other commmercial chassis manufactured by General Motors for sale as incomplete vehicles.

Yours truly,

Frank Berndt Acting Chief Counsel

Enclosure

March 8, 1976

Mr. R. B. Kurre Wayne Corporation Industrial Road Richmond, Indiana Dear Mr. Kurre:

Confirming our phone conversation, the following statement will be used relating to FMVSS 301 Fuel System Integrity in the 1977 Cadillac Document for Incomplete Vehicle as required by Part 568-Vehicles Manufactured in Two or More Stages:

Conformity with FMVSS 301 is not substantially determined by the design of this incomplete vehicle and General Motors makes no representation as to conformity with this Standard.

Please let us know if we can help you further.

Very truly yours,

W. J. Owen Safety and Legal

-ajj

cc: Messrs. E. W. Anderson A. MacDonald

ID: nht76-2.21

DATE: 04/19/76

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Dunlop Limited

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of March 17, 1976, requesting information concerning steps which you, as a manufacturer of wheel equipment which will be offered for importation into the United States, must take in order to comply with all applicable National Highway Traffic Safety Administration regulations.

You should be aware of 49 CFR Part 566, Manufacturer Identification, and 49 CFR Part 573, Defect Reports. In addition, Federal Motor Vehicle Safety Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, may be of interest to you. Copies of these rules and an information sheet entitled "Where to Obtain Federal Motor Vehicle Safety Standards and Regulations" are enclosed for your convenience.

Section 110(e) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1399(e)) requires every manufacturer who offers a motor vehicle or item of motor vehicle equipment for importation into the United States to designate a permanent resident of the United States as his agent, upon whom service of all processes, orders, notices, decisions, and requirements may be made.

The procedural regulations (49 CFR 551.45) for designation of agent pursuant to the Act require that it include:

(1) A certification by its maker that the designation is binding on Dunlop Limited under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made;

(2) The full legal name, principal place of business and mailing address of Dunlop Limited;

(3) Trade names or other designations of origin of the products of Dunlop Limited that do not bear its legal name;

(4) A provision that the designation of agent remain in effect until withdrawn or replaced by Dunlop Limited;

(5) A declaration of acceptance duly signed by the agent appointed, which may be an individual, a firm, or a U.S. corporation; and

(6) The full legal name and address of the designated agent.

A copy of the procedural regulation for designation of agent is enclosed for your convenience.

ID: nht76-2.22

DATE: 04/30/76

FROM: JOHN WOMACK FOR FRANK BERNDT -- NHTSA

TO: Allegrette; Newitt; Witcoff & McAndrews

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of February 12, 1976. Currently, 49 CFR Part 566, Manufacturer Identification, does not require, or provide for, a manufacturer code number. The use of a code number has been proposed, but not adopted. If the use of a code number becomes mandatory, notice will appear in the Federal Register and a sufficient amount of time allowed for your client to comply.

The information you submitted in your letter is sufficient to satisfy the requirements of Part 566. Inasmuch as Tsuyama Mfg. Co., Ltd., is a foreign corporation, it will be necessary for them to designate an agent pursuant to 49 CFR 551.45.

Your understanding with respect to certification of lenses is correct. Section S4.7.2 of Standard No. 108, Lamps, Reflective Devices, and Associated Equipment (49 CFR 571.108), permits replacement equipment to be marked with the symbol DOT as a certification that it conforms to all applicable Federal motor vehicle safety standards, and there is no need to submit lenses to us for approval.

ALLEGRETTI, NEWITT, WITCOFF & MCANDREWS

February 12, 1976

Administrator, National Highway Traffic Safety Administration

I am writing in behalf of Tsuyama Mfg. Co., Ltd. of Osaka, Japan re Title 49 CRF, Part 566 and 567. Tsuyama Mfg. Co., Ltd, is a Japanese corporation and has its principal place of business at 53, 3-Chome, Kuwazu-cho, Higashi Sumiyoshi-ku, Osaka, Japan. Our client manufacturers reflectors, lenses and lamps for motor vehicles. The foregoing should enable you to provide a code number for our client under 49 CRF @ 566.5. If anything more is required, please advise.

Tsuyama Mfg. Co., Ltd. intends to sell a replacement lens for a combination rear lamp that meets all applicable SAE standards. I understand it would be proper for my client to emboss, mark or label its lenses with the symbol DOT after the lenses have been tested for compliance with the applicable standards and that there is no need to submit specimens of the lenses or other products to the Administrator for prior approval. Please confirm that my understanding is correct.

Seymour Rothstein

ID: nht76-2.23

DATE: 05/12/76

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood; NHTSA

TO: Southside Datsun

TITLE: FMVSR INTERPRETATION

TEXT: I am writing to confirm your April 29, 1976, telephone conversation with Mark Schwimmer of this office, concerning the modification work that you perform on Datsun pick-up trucks. I understand that this modification involves removal of the body from a fully certified truck and replacement of the body with a flat bed.

You are a vehicle alterer who is subject to the requirements of 49 CFR @ 567.7 (copy enclosed). That section requires that you affix a label to the vehicle stating that, as altered, the vehicle conforms to all applicable Federal motor vehicle safety standards. If any of the original vehicle's weight ratings are affected by the modification, the modified weight ratings must also appear on this label. As Mr. Schwimmer explained, "Gross Vehicle Weight Rating" is defined in 49 CFR @ 571.3 as:

the value specified by the manufacturer as the loaded weight of a single vehicle.

One constraint on this specification is found in @ 567.4(g)(3) of 49 CFR Part 567, Certification, which requires that the GVWR

shall not be less than the sum of the unloaded vehicle weight, rated cargo load, and 150 pounds times the vehicle's designated seating capacity. . . .

"Gross Axle Weight Rating" is defined as:

the value specified by the vehicle manufacturer as the load-carrying capacity of a single axle system, as measured at the tire-ground interfaces.

As one who alters completed vehicles but does not otherwise manufacture motor vehicles or motor vehicle equipment that is subject to a safety standard, you are not required to submit the information specified in 49 CFR Part 566, Manufacturer Identification.

Enclosed for your convenience is an information sheet entitled "Where to Obtain Federal Motor Vehicle Safety Standards and Regulations." If you have any further questions, please feel free to write.

ID: nht76-2.24

DATE: 04/12/76

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

TO: H. A. Heffron, Esq.

COPYEE: JOHN J. GIESGUTH

TITLE: FMVSS INTERPRETATION

TEXT: Re: Yankee Metal Products Corporation

Dear Mr. Heffron:

This is in reply to the petition of March 16, 1976, by your client Yankee Metal Products Corporation ("Yankee" herein) for an interpretation of 49 CFR 571.108, Motor Vehicle Safety Standard No. 108. Yankee seeks an interpretation "that the use of strobe type signal warning lamps on school buses is permissible provided that such lamps meet the specific performance requirements in S4.1.4 which incorporates SAE Standard J887."

Yankee has submitted a test report by Electrical Testing Laboratories, Inc. indicating conformance to SAE Standard J887 including its photometric requirements. Yankee has also submitted an opinion by a professional engineer that "the Yankee strobe lights tested by ETL meet the photometric requirements of SAE J887."

As you know, this agency does not "approve" specific lighting devices prior to their introduction into interstate commerce, and all that is legally required is that the manufacturer certify that its product meets all applicable Federal motor vehicle safety standards. The ETL report and professional opinion indicate that the design of the Yankee system complies with SAE J887, and thus they provide a basis upon which Yankee could certify that its system meets Standard No. 108. Therefore the use of its strobe type signal warning lamps appears to be permissible under Standard No. 108.

This means that the interpretation provided Mr. John J. Giesguth on December 9, 1975, does not apply to any strobe light system where an equivalency of conforming performance can be demonstrated, as Yankee appears to have done.

Sincerely,

LAW OFFICES HOWARD A. HEFFRON

202-872-0417

March 16, 1976

Frank Berndt, Esquire -- Acting Chief Counsel, National Highway Traffic Safety Administration

Re: Yankee Metal Products Corporation

Dear Mr. Berndt: I represent Yankee Metal Products Corporation of Norwalk, Connecticut in connection with the request for an interpretation of MVSS 108 submitted to your office today. Please communicate directly with me regarding this matter.

I would think that an early meeting between Yankee and NHTSA representatives to discuss the technical points presented and any related questions would be useful and help to expedite consideration of the matter and request that at an early date a conference for this purpose be scheduled.

Very truly yours,

Howard A. Heffron

ID: nht76-2.25

DATE: 05/11/76

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Thomas Kupensky

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 8 to the Department of Transportation, regarding your CAUTION and THANK YOU signals which would flash simultaneously with the turn signal lamps on trucks and trailers.

Since such signs, flashing CAUTION or THANK YOU when actually "turn" is intended, may be confusing in many circumstances, they would be prohibited by paragraph S4.1.3 of Federal Motor Vehicle Safety Standard (FMVSS) No. 108, "Lamps, Reflective Devices and Associated Equipment," (copy enclosed), because they would appear to impair the effectiveness of the turn signals. If these signs were manually operated by the driver, separately from the turn signals, at appropriate times, whether flashing or steady burnings, they would be considered auxiliary devices which did not impair the effectiveness of the turn signals, and would be permitted by Standard No. 108. In this situation, however, they would be subject to the motor vehicle regulations of the individual States.

Sincerely,

Enclosure

ATTACH.

April 8, 1976

Department of Transportation 400 - 7th Street, S. W. Washington, DC 20590

Gentlemen:

Enclosed is a copy from my Patent Attorney of a description of Safety Signal Lights, which I would like to market. I feel these lights add safety for over the road truckers, and act as a backup system for a burned out turn signal, as explained in the attached write-up. They also indicate to the vehicle following of the drivers' intentions.

I have called on a major trailer manufacturer and found that this is creating quite an interest. But the question remains -- would these be acceptable by the Department of Transportation.

Hoping that you can advise me on the above, I thank you for your assistance and any information you might be able to forward.

Sincerely,

Thomas Kupensky

Enc.

(Graphics omitted)

VEHICLE SIGNAL LIGHT ABSTRACT OF THE DISCLOSURE

A signal light system for a vehicle. A pair of auxiliary lights are mounted, preferable, on the rear of the vehicle and operate in conjunction with the vehicle turn indicator lights. Each of the lights is a (Illegible Words) enclosure having a replaceable face plate. The removable plates carry suitable logooda which are visible when the light is illuminated.

SPECIFICATION

The present invention relates to a vehicle signal system and more particularly to a system which (Illegible Word) additional information to other drivers on the road.

The continuous increase of super highway mileage and of the volume of traffic on those highways has brought (Illegible Words) systems which rapidly convey information between the vehicle and other drivers on the road. (Illegible Word) and others who do a considerable amount of high speed driving have developed (Illegible Words). The (Illegible Word) of turn signals to indicate (Illegible Word) changes and the blinking of lights by a vehicle being overtaken to indicate that the passing vehicle has cleared and can pull back into the slower speed lane (Illegible Word) among (Illegible Words). Also, a vehicle which has completed passing will blink his lights to thank the following vehicle. However, there are many people who do relatively little super highway driving and are not aware of these conventions. There is a need for a signaling system which will clearly convey the intentions of the signaling vehicle (Illegible Words) inexperienced drivers do not become confused. (Illegible Word) the practice of blinking the vehicle lights causes the vehicle driver to be momentarily distracted from his primary function, thereby increasing the risk of accident.

It is the primary object of the present invention to provide a signaling system for a vehicle which will clearly alert the following vehicles even if the operators of such vehicles are not aware of the usual signaling conventions.

It is also an object of the present invention to provide a vehicle signaling system which permits the vehicle operator to signal to following vehicles without being distracted from the primary function of driving the vehicle.

Yet another object of the invention in the provision of a signal system which may be easily applied to existing vehicles with a minimum of modification thereof.

The above and other objects of the invention which will become apparent in the following detailed description are achieved by providing a vehicle signal system which employs a pair of auxiliary light units mounted on the rear of the vehicle with the units operating in conjunction with the right and left turn signals, respectively, and with each light unit consisting of an enclosure having a removable face plate which is provided with information conveying markings visible when the signal is illuminated.

For a more complete understanding of the invention and the objects and advantages thereof reference should be had to the following detailed discription and the accompanying drawing wherein there is shown a preferred embodiment of the invention.

In the drawing:

Fig. 1 is a rear (Illegible Word) view of a trailer equipped with the signal lights of the (Illegible Word) invention;

Fig. 2 is a perspective view of one signal light unit of the present invention;

Fig. 3 is a sectional view of the light assembly of Fig. 2;

Fig. 4 is a transverse sectional view taken along the line 4-4 of Fig. 3; and

Fig. 5 is a schematic showing of the control circuit for the lights of the present invention.

A conventional semi-trailer 10 is shown in Fig. 1. The trailer is provided with rear brake lights 12 and left and right turn indicator lamps 14 and 16, respectively, in accordance with conventional practice. These lights are controlled from the vehicle cab in the usual manner. In order to convey additional information to motorists following the trailer two illiminated signs 18 and 20 are also provided on the rear of the trailer 10. While these signs are shown as being mounted at approximately the vertical mid-point of the trailer, it will be understood that the two units may be positioned at any convenient locations.

As will be described in greater detail below, the illuminated sign 18 operation in sequence with the left turn signal 14 while the illuminated sign 20 operates in sequences with the right turn signal 16. Any suitable wording or other indicators may be provided on the two signs 18 and 20. The two signs illustrated, "CAUTION" and "THANK YOU" are considered desirable as these indications reinforce the conventional turn signal indications. Thus, when the left turn signal is operated the word "CAUTION" is flashed simultaneously thus clearly alerting the following motorist to the fact that the vehicle is about to shift to the left lane. This is particularly advantageous when the truck in one of a line of trucks as following motorists frequently cannot see the right turn signals of such a truck and may misinterpret the flashing turn signal as a flashing brake light.

The use of the word "THANK YOU" in conjunction with the right turn signal allows the overtaking vehicle to express his consideration to the vehicle which has been passed without requiring him to perform any action except the operation of his right turn signal which is conventionally done when pulling back into the right lane.

The construction of the light assembly 18 is shown in greater detail in Figs. 2, 3, and 4. It will be understood that the unit 20 is of identical construction. Each of the light units consists of a rectangular bon-like housing 22 which is open on one face to receive a plastic face plate 24 which is provided with the desired indecia. The indecia 26 may be incorporated in any suitable arrangement such as the use of contracting colors or of opaque and translucent regions. The casing 22 has a rear wall 28, and walls 30, and top and bottom walls 32 and 34, respectively. The forward wages of the top and bottom walls are bent to form (Illegible Word) 36. These (Illegible Word) 36 define a channel in which the facing plate 24 in slidably received, the end walls 30 (Illegible Word) the engage the inner face of the plate 24. If desired and depending on the material used to form the face plate 24 a ridge 40 may be provided on the inner surfaces of the upper and lower walls 32 and 43, respectively, in spaced parallel relation to the (Illegible Word) 36 to provide for additional support to the face plate 24. Suitable gaskets 38 and 41 are provided to form a fluid tight seal between the face plate 24 and the casing 22. The wire leads 43 for the lamps within the casing are routed through a suitable grommet 45 to provide a fluid tight seal between the wires and the casing 22.

A vertically extending wall 42 is provided within the casing 22 and midway between the opposite ends 30. The wall may, for example, have a tab portion 44 which is welded or otherwise secured to the rear wall 28 of the casing 22. Affixed to opposite sides of the wall 42 are sockets 46 and 48 for receiving (Illegible Word) 50 and (Illegible Word) respectively. As is shown in Fig. 4, a number of holes or apetures 54 may be provided in the plate 52 so that light can be transmitted from either bulb or both sides of the casing. This assures that even if one bulb should fail at least partial illumination of the whole sign will still be possible.

One possible circuit for controlling the signal lamps 18 and 20 of the present invention is illustrated in Fig. 5 where the vehicle power source, such as the battery 60, is connected to the conventional turn signal switch 62 through a flasher assembly 64 which is also a conventional (Illegible Word). In a first position the turn signal switch 62 causes the left front signal lamp 661, the left rear lamp 14, and the two lamps 50 and 52 of the unit 18 to flash in unison. In the opposite position the switch 62 (Illegible Word) the right forward signal lamp 66r, the rear right signal lamp 16 and the two bulbs of the unit 20. It will be noted that the two bulbs 50 and 52 of each unit are connected in parallel to one another and in parallel to the other signal lamps on the corresponding side of the vehicle. If desired, suitable means such as the double hole signal throw switch 70 may be provided for disconnecting the signaling units 18 and 20 when desired.

While only the best known embodiment has been illustrated and described in detail herein, it will be clearly understood that the invention is not limited thereto or thereby. Reference should therefore be had to the appended claims in determining the true scope of the invention.

What is claimed is

1. An auxiliary signal system for a vehicle having a conventional turn signal system which comprises:

a pair of lamp housings, each having a removable face plate carrying a distinctive legend, the housings being mounted on the rear of the vehicle and adjacent the opposite sides thereof;

at least one lamp within each housing for illuminating the face plate thereof to make the legend visible; and circuit means connecting the lamp of each housing to the actuating circuit of the respective turn signal whereby the lamp operates in conjunction with the respective turn signal.

2. The auxiliary signal system according to Claim 1 wherein each housing comprises a bon-like member having a rectangular opening in one side thereof, the face plate covering the opening.

3. The auxiliary signal system according to Claim 2 wherein two lamps are provided within each housing, the lamps being connected in parallel and positioned so as to illuminate opposite ends of the enclosure.

4. The auxiliary signal system according to Claim 3 wherein each housing has a vertically extending center wall, the two lamps being mounted to the center wall on opposite sides thereof.

5. The auxiliary signal system according to Claim 1 wherein the legend carried by the facing plate of the left housing is "CAUTION" and the legend carried by the facing plate of the right housing is "THANK YOU".

ID: nht76-2.26

DATE: 10/07/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Wesbar Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 7, 1976, asking several questions concerning paragraph S4.4.1 of Federal Motor Vehicle Safety Standard No. 108. I am sorry that we were unable to respond by September 29 as you requested. Your questions and our answers are as follows:

"1. What is the DOT specific definition and interpretation of the words 'combined optically' as they appear in paragraph S4.4.1 of DOT 108?"

In pertinent part, S4.4.1 states that "no clearance lamp may be combined optically with any taillamp." The phrase "combined optically" as used here means that the luminous area of a lens used for a taillamp may not be also used as the luminous area of a lens for a clearance lamp. In other words lamps are "combined optically" when the same luminous area of a lens is lighted for more than a single function.

"2. Can a clearance lamp and tail lamp be combined in a single compartment with no opaque barrier wall existing between the clearance lamp bulb and the tail lamp bulb?"

The answer is no because the same luminous area of the lens would be lighted when both lamps are in use, and the lamps would be "combined optically."

"3. Does the DOT have no objection to a flashing red signal issuing from the side (at right angles to the fore-aft center line of the trailer) of the clearance lamp?"

Generally S4.6(b) requires most vehicle lamps to be steady burning in normal operation. If the right angle lamp serves as the rear side marker lamp, however, S4.6(b) allows it to be flashed for signaling.

"4. What is the DOT specific definition and interpretation of the term 'clearance lamp' as it is used in DOT 108?"

The term "clearance lamps" is defined by SAE Standard J592e, incorporated by reference in Standard No. 108, and are "lamps which show to the front or rear of a vehicle . . . to indicate the overall width and height of the vehicle."

"5. Does the 'clearance lamp' as the words are used in DOT 108 indicate a lamp intended to serve as its major function, a back up lamp in the event of failure of the tail light filament in the combination tail, turn and stop light bulb."

There is no intent that a clearance lamp serve as a backup lamp in the event of a taillamp filament failure though obviously both lamps perform a marking function.

"6. If DOT approves the combination of a clearance lamp and tail lamp in the same compartment, would it also approve for a boat trailer, moving the tail light outboard to show the extreme width of an over 80" vehicle and eliminate the need for a clearance lamp under those circumstances."

The question is moot since a combination clearance lamp-taillamp is not permitted.

I understand that you discussed the photometric test procedure for optically combined lamps with Mr. Owen of this agency, by telephone on September 22, 1976. So that there may be no misunderstanding I would like to set forth the test procedure in this letter. If a single lamp bulb (or filament) is used in the combined lamp, the photometrics for all of the functions must be met simultaneously. If two or more lamp bulbs (or filaments) are used and each is to provide a separate function, only those which provide that function are to be energized during the photometric test. Therefore, in a multiple compartment side marker and clearance lamp (or a multiple compartment tail and clearance lamp that is not optically combined), the clearance lamp bulb is not energized during the photometric test for the other function, and vice versa.

I hope this answers your questions.

SINCERELY,

WESBAR CORPORATION

September 7, 1976

Frank Berndt Acting Chief Counsel U.S. Dept. of Transportation National Highway Traffic Safety Administration

Refer: DOT 108, paragraph S4.4.1

On June 9, 1975 your predecessor in office answered an inquiry we made relative to a light design, and the last paragraph of his letter stated in part:

"Since the clearance lamp and tail lamp are in separate compartments and not optically combined -- the lamp design does not violate S4.4.1."

We have recently seen two lamps which bear the letters "DOT", in each of which the clearance, tail light and turn signal bulbs are all in the same compartment, i.e. the clearance lamp is not in a separate compartment.

It has always been the opinion of the writer and of boat trailer manufacturers, that in order to comply with S4.4.1, the clearance lamp would have to be in a compartment separated from the tail and stop lamp. However, while we were in Washington last week visiting your compliance office, we were advised that a Mr. Lou Owen had given a verbal interpretation of S4.4.1 in which he gave approval for the tail and clearance lamp to be in a single compartment, with no separating wall between them.

It would seem logical that tail lamp and clearance lamp should be separately compartmented. If the bulbs were in the same compartment with no shielding between them, the stop and turn light would illuminate that section of the compartment intended as a clearance lamp area, and at times the clearance lamp would appear to be flashing as well as varying in intensity. This would make for a confusing and hazardous situation for a driver traveling some distance behind a trailer equipped with such a combination lamp.

If this verbal interpretation which approves having the two lamp bulb mounted in the same compartment without a separating wall is valid, why should there be any need for a clearance lamp on a boat trailer since the tail lights could be mounted sufficiently outboard so they would indicate, when lighted, the overall width of the trailer?

We would appreciate receiving the DOT's specific interpretation of the words "combined optically". In its usual context, the words "combined optically" would mean a combination of light source and lens, and applied to S4.4.1 would seem to indicate that, in fact, the clearance lamp would have to be separately compartmented from the tail, stop, turn, and hazard lamp compartment.

When the clearance and tail lamp are housed in the same compartment there is a definite impairment of the combination turn, stop and hazard function of the lamp and an unsafe and confusing situation exists. We can report to you that while conducting an actual night test at a country road intersection, when a trailer was approaching the intersection with turn signal bulb flashing in the uncompartmented tail light, at 150 feet distance it was difficult to tell if the trailer ahead was on the same course as the following vehicle or crossing ahead of it at right angles.

While we were at the compliance section office, we were appalled to hear an interpretation of the term "clearance light" to the effect that the clearance lamp was not necessarily a separate lamp but was intended as a "back-up" light in the event the tail light filament should fail.

We have never ever heard or had it intimated to us that such was the purpose of a clearance lamp and we don't believe that it was ever intended to be so defined. When you consider the fact that the lamp on a semi trailer is at the uppermost corner of the trailer body (a long distance from the tail lamp!), and that travel trailers, buses and other vehicles also have the clearance lamp at the top extreme corners of the vehicles, it is difficult to conceive of their application as being a back up substitute for a defective tail lamp.

Carrying our argument further, on a trailer of less than 80" in width NO clearance lamp is required but the possibility of failure of the tail lamp filament is just as great. What then is supposed to serve as "back up" lamp for it? It is our observation that someone was just not thinking when he made the statement that a clearance lamp is really only there to serve as a "back up" lamp for the tail light.

In summary we ask for your specific answers to the following:

1. What is the DOT specific definition and interpretation of the words "combined optically" as they appear in paragraph S4.4.1 of DOT 108?

2. Can a clearance lamp and tail lamp be combined in a single compartment with no opaque barrier wall existing between the clearance lamp bulb and the tail lamp bulb?

3. Does the DOT have no objection to a flashing red signal issuing from the side (at right angles to the fore-aft center line of the trailer) of the clearance lamp?

4. What is the DOT specific definition and interpretation of the term "clearance lamp" as it is used in DOT 108?

5. Does the "clearance lamp" as the words are used in DOT 108 indicate a lamp intended to serve as its major function, a back up lamp in the event of failure of the tail light filament in the combination tail, turn and stop light bulb.

6. If DOT approves the combination of a clearance lamp and tail lamp in the same compartment, would it also approve for a boat trailer, moving the tail light outboard to show the extreme width of an over 80" vehicle and eliminate the need for a clearance lamp under those circumstances.

On September 29, 1976 there will be a meeting of the Trailer Manufacturers Association. In attendance will be representatives of all major manufacturers of boat trailers. We would appreciate your expediting your replies to the six questions posed above in order that we may give a copy of them to the group attending that meeting.

Since your interpretation of the questions given in this letter are of such vital importance to the boat trailer manufacturer, dealer and consumer, we would be most grateful for your clear, concise answers.

For your ready reference we attach copies of our previous correspondence and the reply we received. We also submit for your study, photos of a typical lamp where tail lamp and clearance lamp are combined in one compartment.

Looking forward to receiving your prompt response, we remain.

B. R. Weber Executive Vice President

cc: SEN. WILLIAM PROXMIRE; SEN. GAYLORD NELSON; REP. WILLIAM A. STEIGER