ID: nht87-2.12

TYPE: INTERPRETATION-NHTSA

DATE: 06/17/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: MMC Services Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Nobuyoshi Takechi Technical Manager MMC Services Inc. 3000 Town Center Suite 1960 Southfield, MI 48075

Dear Mr. Takechi:

This is in reply to your letter of April 24, 1987, with reference to the legality of a proposed concealed headlamp design. As we understand the proposed design, the headlamp could be used in the "concealed" position as a forward warning (which you believ e "is similar to the daytime running light principle" and "is useful to avoid accidents") and in the unconcealed position as a headlamp to provide visibility of the roadway ahead. A portion of the vehicle body in front of the concealed headlamp would be clear, allowing the beam from the concealed lamp to shine through it. The steady burning forward warning signal would be given by pulling a spring-loaded switch. Releasing the switch would turn off the headlamp. Thus, the concealed headlamp would not, as a practical matter, be used for providing visibility of the roadway ahead but as an alternative to the vehicle's audible warning device, the horn. The proposed use would be a visual "horn." Finally, you state that the beam pattern and intensity of the l amp "is corresponding to the headlamp's," although you do not explain how this is possible, given the potential for interference from the vehicle's body.

Standard No. 108 prohibits covers or other styling features in front of a required headlamp when it is being used for purposes such as illuminating the roadway ahead or increasing the visibility of the vehicle in conditions of reduced visibility. We do n ot consider this prohibition applicable when a headlamp is being used, in all likelihood momentarily, for forward signalling as described. Further, use in this manner would not appear to impair the lighting equipment required by the standard. Additionall y, headlamps may be wired to flash for signalling purposes, as you have proposed, however, we are unable to advise you whether operation of this device is acceptable under the laws of the individual States. Your letter does not indicate whether the beam utilized is the upper beam or the lower beam; some jurisdictions such as the District of Columbia and Virginia prohibit use of the upper beam for signaling purposes. Others may restrict use of headlamps or a portion of them during daylight hours; we expe ct to learn more about this in comments to the docket on the daytime running lamp proposal. In the meantime, I would advise you to write the American Association of Motor Vehicle Administrators, 1201 Connecticut Avenue, NW, Washington, DC 20036, for its views on State laws.

You have stated that this use "is similar to the daytime running light principle." However, as proposed by the Government of Canada, and by the U.S. Government in the Federal Register (52 FR 9316) such "DRLs" would be automatically energized, and not ene rgized at the driver's choice as is your device. Therefore, we do not view the operation of your device as similar to the daytime running light principle.

Sincerely,

Erika Z. Jones Chief Counsel

April 24, 1987

Ms. Erika Jones, Chief Counsel NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION U. S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Ms. Jones:

MMC has been developing concealed headlamps for application to our future models. (See attached). In this design, a portion of the body in front of the concealed headlamps is replaced with a clean material. This will allow the driver to give a steady-state forward warning without having to open the headlamp. The driver gives a forward warning by pull ing a spring-loaded switch, such as the headlamp upper/lower beam changing lever, and the headlamps are turned off by release of this switch. The photometric performance (beam pattern and intensity) is corresponding to the headlamp's.

We believe this function is similar to the daytime running light principle, is useful to avoid accidents, and we find no regulations prohibiting such system.

Please provide us with your opinion as to the legality of this system.

If you have any questions, please contact me at (313) 353-5444. Very truly yours,

Nobuyoshi Takechi Technical Manager

NT/sg MMC SERVICES, INC.

Enclosure

ID: nht87-2.13

TYPE: INTERPRETATION-NHTSA

DATE: 06/17/87

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: C.M. METHA -- AUTOLITE[INDIA] LIMITED

TITLE: NONE

ATTACHMT: LETTER DATED 02/23/87 FROM C.M. MEHTA TO NHTSA RE DOT APPROVAL ON HEADLAMPS, DRIVING LAMPS ETC FOR MARKETING IN USA

TEXT: Dear Mr. Mehta:

This is in reply to your letter of February 23, 1987, to the Department of Transportation. You mentioned an earlier letter dated January 9, 1987, enclosing a copy of your product catalogue, but I regret to say that this Office has not received it.

As a producer of motor vehicle lighting equipment, you have asked for answers to the following questions:

"1. Details of DOT/SAE approval required in marketing our Headlamp Units 7", 5 3/4" (Round) and Rectangular small and large".

In the United States no "approval" is required to import the headlamps that you mention. However, the manufacturer must assure itself that the headlamps comply with the requirements of Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Dev ices, and Associated Equipment (essentially those of the SAE for round and rectangular sealed beam headlamps), and certify each one as meeting all applicable Federal motor vehicle safety standards. This certification is a DOT symbol on the headlamp lens .

"2. Can we market those lamps as referred in Para. No. 1 fitted with 9004, 9005 and 9006 Bulbs. If there is any specifications/technical details available with you, please send us a copy."

The headlamps discussed in paragraph 1 are sizes traditionally associated with sealed beam headlamps, rather than with replaceable bulbs such as the DOT HB1 (9004), HB3 (9005), and HB4 (9006). However, it is permissible to produce headlamps in these siz es, which incorporate replaceable light sources that are specified by Standard No. 108. However, such headlamps must meet all the requirements of the standard applicable to replaceable bulb headlamps. I enclose a copy of Standard No. 108 for your infor mation.

"3. We understand that the use 9004, 9005, 9006 bulbs are permitted on Headlamps with Lens and Reflectors made of Plastic. Kindly advise, if we can use these Reflector made of metal?"

Yes, a headlamp may have a reflector of either plastic or metal.

"4. Details of approval required for High Beam Driving Lamps to be used for off-road vehicles."

"5. The details of specifications for Driving Lamps to be used on Cars, Trucks, etc."

Standard No. 108 does not require vehicles to be equipped with driving lamps and it establishes no requirements for them. If there are any specifications or approvals required, they are those of the individual States in which these lamps would be sold a nd used. For further information on State requirements you should write: American Association of Motor Vehicle Administrators (AAMVA), 1201 Connecticut Avenue, N.W., Washington, D.C.

It is the position of this Department that any headlamp unit which is capable of replacing a passenger car headlamp must meet the applicable requirements of Standard No. 108, even if it may also be used on off-road vehicles.

You have also asked for copies of "SAE F-80 Front Fog Lamps" and SAE-J-79 Motor Cycle Headlamps". We are not familiar with these materials and advise you to write: Society of Automotive Engineers, Inc., 400 Commonwealth Drive, Warrendale, Pa. 15096. As for "Specification for Driving Lamps Using H3 Bulb", this appears to be a European specification unknown to us, as the H3 bulb is one that is not widely used in the United States.

The following is a listing of those requirements that must be completed before shipments begin. You must:

1. Appoint an agent for service of process in accordance with Title 49, Code of Federal Regulations, Part 551 (49 CFR 551).

2. Provide information as specified in 49 CFR 566, "Manufacturer Identification."

If you determine in good faith that any lamp manufactured by you does not conform with Standard No. 108 or contains a safety-related defect, section 151 (15 USC 1411) of the Act requires that you furnish notification to the Secretary and to owners in acc ordance with section 153 (15 USC 1413) and to remedy without cost the failure to conform or defect in accordance with 154 (15 USC 1414). Details are contained in 49 CFR 573, 576 and 579.

We are enclosing the following pertinent publications:

1. The Act 2. 19 CFR 12.80, "Regulations for Motor Vehicle "Importation" 3. 49 CFR 551, "Procedural Rules" 4. 49 CFR 573, "Defect and Noncompliance Reports" 5. 49 CFR 576, "Record Retention" 6. 49 CFR 579, "Defect and Noncompliance Responsibility" 7. Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment

If we may be of further assistance, please let us know.

Sincerely,

Enclosures

ID: nht87-2.14

TYPE: INTERPRETATION-NHTSA

DATE: 06/18/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable William Proxmire

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable William Proxmire United States Senate Washington, DC 20510

Dear Senator Proxmire:

This is in reply to your recent inquiry on behalf of your constituent, Todd Suer of Janesville.

Mr. Suer, in his letter to you of April 15, 1987, refers to cars "that have extra clear head lights besides the ones that are built in" and asks if there is a law against them.

We are not familiar with the lighting equipment that Mr. Suer mentions. It is not part of the front lighting equipment required by the Federal motor vehicle safety standards. It appears to be aftermarket, accessory equipment, and as such, its use is subj ect to regulation under State law. We suggest that Mr. Suer direct his complaint to State or local authorities.

Sincerely,

Erika Z. Jones Chief Counsel

Todd Suer Rt Dunbar Road Janesville, Wi. 53545

April 1, 1987

The Honorable William Proxmire United States Senate

Dear Senator Proxmire

I am writing to you about people that drive cars that have extra clear head lights besides the ones that are built in. Is there a law against them? If they have them they should only be on when the brights are on. When they have there dims on they should be off. The little lights are ok. Some people have fog littles on all the time, they should only be used in the fog. Some people have there dims on, and they shine right in your face.

I think the police should stop people that have these light problems because they blind you. Please inform me of this problem. Thank you very much.

Yours truly,

Todd Suer

ID: nht87-2.15

TYPE: INTERPRETATION-NHTSA

DATE: 06/18/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Joe Rutman -- Travelite Division

TITLE: FMVSS INTERPRETATION

ATTACHMT: 5/12/86 letter from Erika Z. Jones to Mary Fulton (Std. 108); 1/12/87 letter from Erika Z. Jones to Fred E. Maynard

TEXT:

Mr. Joe Rutman Travelite Division Pathway, Ltd. BOX 195 Grand Rapids, MI 49508

This is in reply to your letter of February 11, 1987, providing information about the electronic message display known as "Tellite" which has been developed by Pathway Limited.

I enclose copies of two recent agency interpretations on electronic message displays similar to yours. You will see that under Federal law such displays may not be used as original equipment, or as replacement equipment on passenger cars that carried cen ter highmounted stop lamps as original equipment. Whether they are acceptable as aftermarket equipment on other vehicles depends on the laws of the individual States there the display will be sold and operated.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

(See 5/12/86 and 1/12/87 NHTSA letters to Mary Fulton and Fred E. Maynard

Re: Pathway Limited

Dear Ms. Jones:

This is in response to your letter of January 7, 1987, regarding the electronic message display known as "Tellite" which has been developed by Pathway Limited.

Enclosed with this letter, you will find the following:

1. A letter from the Company's engineers, explaining certain material features of the display, and

2. Drawings of the display and the handheld keyboard which is used to activate the display.

It should be pointed out that the display can be read from directly behind the vehicle, but cannot be read from the side. You should also be aware that the handheld keyboard only activates the display, and does not program messages.

I am also enclosing the 16 messages with which it is currently intended that every chip will be programmed.

If you require anything further, please advise.

Sincerely,

PATHWAY LTD. Joe Rutman

February 9, 1987

Mr. Joe Rutman President Travelite Division of Pathway, Ltd. P.O. Box 88111 Grand Rapids, MI 49508

Subject: U.S. DEPARTMENT OF TRANSPORTATION LETTER OF INQUIRY

In regards to the questions raised in the aforementioned letter:

1. light emitted by the brake-light portion of the display will pass through the message portion, as the light sources for both portions originate from the same printed circuit board. Red L.E.D.'s are used for the brake-light and yellow L.E.D.'s are used for the message display.

2. The brake-light circuit overrides the message display by disabling and blanking out any message displayed at the time the brake-light is turned on.

I hope the above answers are satisfactory. If you have any other questions, feel free to call.

FRANK HOCKEBORN, PROPRIETOR

SEE DIAGRAMS...

TELLITE MESSAGES

1. CAUTION. CHANGING LANES LEFT.

2. CAUTION. CHANGING LANES RIGHT.

3. PLEASE DIM YOUR LIGHTS...THANK YOU.

4. PLEASE DON'T FOLLOW SO CLOSE...THANK YOU.

5. I AM OUT OF GASOLINE...PLEASE SEND HELP.

6. DEAD BATTERY...I NEED A JUMPER.

7. I HAVE A FLAT TIRE...PLEASE SEND HELP.

8. MY CAR WILL NOT START...NEED HELP.

9. SORRY.

10. PLEASE SEND A WRECKER...THANK YOU.

11. MY CAR IS STUCK...PLEASE SEND HELP.

12. GO AROUND...I AM WAITING FOR A PARKING PLACE...THANK YOU.

13. THANK YOU.

14. CAUTION...SLOWING TRAFFIC...ROAD REPAIRS? ACCIDENT?

15. ILLNESS...HELP...HELP...HELP.

16. PLEASE CALL POLICE...SEND AN AMBULANCE.

ID: nht87-2.16

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 18, 1987

FROM: MARY F. BARRAS -- SALES ASSISTANT, CONTRACT ADMINISTRATION, M.A.N. TRUCK & BUS

TO: MICHAEL W. VORIS -- BUS PROCUREMENT SUPERVISOR, METRO

TITLE: CONTRACT NO. T/F 19-84 REAR EMERGENCY WINDOW

ATTACHMT: MEMO DATED 2-23-88, TO JAY COSTA, FROM ERIKA Z. JONES, STD 271, REDBOOK A31; MEMO DATED 7-1-87, TO ERIKA Z. JONES, FROM JAY COSTA; MEMO DATED 6-25-87, CONTRACT NO. T/F 19-83 REAR EMERGENCY WINDOW

TEXT: In response to your letter of June 16, 1987 I am providing the following information in regard to converting the rear emergency window to a non-openable type window.

According to FMVSS 217, a total of 4,355 square inches is required for this bus. Please see the attached FMVSS information provided in regard to the computations used to arrive at this figure. Our bus has 19 windows, including the rear window, which totals 536 square inches per window. The bus also has 3 roof hatches which total 506.25 square inches per hatch. Therefore, the computations are listed below: 536 sq. ins. x 19 windows, including rear = 10,184 sq. ins. 506.25 sq. ins. x 3 roof hatches = 1,519 sq. ins. *11,703 sq. ins. * This total can be considered the accountable square inches on the bus in regard to safety requirements set forth by FMVSS 217. Also, 1,742 square inches (40%) of one side of the bus is unobstructed thereby, complying with this standard.

Therefore, the rear emergency window may be changed and the bus will remain within the FMVSS 217 boundries.

May we suggest that Metro directly contact the window manufacturer in regard to any modification to be made to this window so that warranty provisions do not become void. Please feel free to contact Mr. Mike Hurtekant at Excel Industries at (219) 264 -2131 in Elkhart, Indiana. ATTACHMENTS

ID: nht87-2.17

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

AIR MAIL

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

Dear Mr. Chikada:

This is in reply to your letter of March 4, 1987, with reference to aiming adjustment of fog lamps. We understand that Stanley is developing a fog lamp and replaceable bulb headlamp with a common lens and housing. Since the portion of the housing also fu nctions as a reflector, the fog lamp moves simultaneously with the headlamp in aiming adjustment. In your view, it will not impair the effectiveness of the headlamp, and you ask for confirmation that the lamp "is acceptable in the U.S.A."

Federal Motor Vehicle Safety Standard No. 108 contains no requirements for a fog lamp, and would prohibit it only if it impaired the effectiveness of any other lamp mounted on the front of a vehicle that is required by the standard. Assuming that the fog lamp does not impair the effectiveness of the headlamp, its installation would not create a noncompliance with Standard No. 108. However, in the absence of a Federal standard on fog lamps, the individual States may establish their own requirements for f og lamps. We are unable to advise you whether this design would be acceptable in each of the 50 States, and other jurisdictions in which the Federal standards must be met; we can only advise you that it does not appear prohibited by Federal law.

The American Association of Motor Vehicle Administrators (AAMVA), 1201 Connecticut Avenue, N.W., Washington; D.C., 20036 may be able to advise you as to state laws relevant to your design.

Sincerely,

Erika Z. Jones Chief Counsel

March 4, 1987

Ms. Erika Z. Jones Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones,

Re : Aiming adjustment of Front fog lamps

We are now developing a new fog lamp, which has a common lens and housing with a replaceable bulb headlamp. (See attached drawing.)

Since the portion of housing also functions as a reflector, this new fog lamp moves simultaneously with headlamp in aiming adjustment.

This fog lamp is designed to satisfy the requirements of SAE Standard J583. So it will not impair the effectiveness of the headlamp, or rather, it will promote the function of headlamp. We Think this new fog lamp is acceptable in the U.S.A.

Please give your advice whether our understanding is right or not.

Sincerely yours,

Stanley Electric Co., Ltd.

T. Chikada Manager, Automotive Lighting Engineering Control Dept.

SEE ATTACHMENT

ID: nht87-2.18

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Jim Ross

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Jim Moss President, Auto Mark Corp. 3901 Atkinson Drive Suite 220 Louisville, Kentucky 40218

Dear Mr. Moss:

This responds to your letter to Ms. Barbara Kurtz of our Office of Market Incentives. In your letter, you posed several questions about a stencil your company would like to offer to direct importers for marking their vehicle parts in compliance with 49 C FR Part 541, Federal Motor Vehicle Theft Prevention Standard. Before responding to your specific questions, I would like to briefly explain the parts marking requirements of Pact 541 as they apply to direct importers.

Direct importers are required to inscribe an identifying number on the specified parts for each passenger car subject to Part 541 that they import: @541.5(a). The identifying number inscribed on the parts must be the original vehicle identification numbe r assigned to the car by its original manufacturer in the country where the car was assembled or produced: @54l.5(b) (3). The identifying number inscribed on the parts must satisfy the size and style requirements specified for vehicle certification label s: @54l.5(c). Finally, the identifying number inscribed on the parts must comply with the three requirements of @54l.5(d) (2). These requirements are:

1. Removal or alteration of any portion of the number must visibly alter the appearance of the section of the vehicle part on which the identification is marked:

2. The number must be placed on each part in a location that is visible without further disassembly once the part has been removed from the vehicle: and

3. The number must be placed entirely within the target area specified by the original manufacturer for that part.

There are no other requirements for marking direct importers' vehicles. Once the direct importer determines that its vehicle complies with these requirements, it certifies that compliance by affixing a label to the vehicle, as specified in 49 CFR S567.4( k). This certification label must be affixed to the vehicle before it is imported into the United States.

To respond to your specific questions, you stated that you advise direct importers to leave your stencil on each part after etching it. You then posed three questions:

1. Must the initials DOT appear on the stencil?

ANSWER: No. Part 541 does not require that the DOT symbol appear as a part of or in conjunction with inscribed markings on parts.

2. May we leave our name (logo) printed on the stencil? ANSWER: Yes. Using the same principles we have applied in the case of labeling requirements in our safety standards, manufacturers may label information in addition to that which is required by the theft prevention standard, provided that the additional information does not obscure or confuse the meaning of the required information or otherwise defeat its purpose. The purpose of requiring the vehicle identification number to be inscribed on specifi ed parts is to allow law enforcement officials to quickly and conclusively establish whether a vehicle or major part is stolen. We do not believe it is possible that law enforcement officials will be distracted from examining the markings inscribed on th e parts by the presence of a stencil with your company name on it. Therefore, you are free to leave your company name on the stencil.

3. Do you have any suggestions or objections to offer?

ANSWER: Our only concern is that direct imports comply with the requirements of Part 541. Assuming that your stencil is a means for direct importers to comply with those requirements, we have no additional advice to offer.

If you have any further questions or need more information on this subject, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Erika Z. Jones Chief Counsel

ID: nht87-2.19

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Ted Stevens

TITLE: FMVSS INTERPRETATION

TEXT: The Honorable Ted Stevens United States Senate Washington, DC 20510

Dear Senator Stevens:

Thank you for your April 23. 1987 letter on behalf of your constituent, Ms. Nadra L. Angerman of Wrangell, who is concerned that there is no Federal requirement for safety belts on school buses. Your letter has been referred to my office for reply, since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety.

I appreciate this opportunity to respond to Ms. Angerman 's concerns. As explained below, NHTSA does not require large school buses to have safety belts for passengers because we require those buses to provide an alternate form of passenger crash protect ion. Our safety standards are directed at improving the interior of large school buses so that passengers will be provided adequate crash protection even if safety belts are not used.

I Would like to begin with some background information on our school bus regulations. NHTSA is responsible for developing safety standards applicable to all new motor vehicles, including school buses. In 1977, we issued a set of motor vehicle safety stan dards for various aspects of school bus safety. Included in that set is Federal Motor Vehicle Safety Standard No. 222, School Bus passenger Seating and Crash Protection. Standard No. 222 requires large school buses--i.e., those with gross vehicle weight ratings over 10,000 pounds--to provide passenger crash protection through a concept called "compartmentalization." Compartmentalization refers to designing the interior of large buses so that children are protected regardless of whether they have fasten ed a safety belt. The key features include higher hnd stronger seat backs, additional seat padding, and better seat spacing and performance.

Our safety standards require a safety belt for the school bus driver since the driver's position is not compartmentalized. We also require safety belts for passengers in smaller school buses because those buses experience greater crash forces than do lar ger buses.

However, because large school buses already offer substantial protection to passengers, we believe a Federal requirement for safety belts in those vehicles is unnecessary. Large school buses are very safe vehicles not only because they meet Federal schoo l bus safety standards, but also because of their size and weight, the training and experience of their drivers and the extra care that other road users employ in the vicinity of school buses. NHTSA does not prevent States and local jurisdictions that wi sh to order safety belts on their own large school buses from doing so. Such a decision is a matter for the officials of the particular State or local jurisdiction, who are best able to assess their own preferences regarding pupil transportation.

A June 1985 NHTSA publication entitled, Safety Belts in School Buses, discusses many of the issues relating to safety belts in large school buses. I have enclosed a copy of the report for your information.

I hope you have found this information to be helpful. If you or your constituent have any further questions, please do not hesitate to contact me.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

Edward Babbitt, Director Office of Congressional Relations Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Babbitt:

One of my constituents/ Ms. Nadra L. Angerman of Wrangell( Alaska, has recently informed me of her concern about the need for mandatory seat belt installation laws for school buses nation-wide. I've enclosed a copy of her letter on this subject for your reference.

I would greatly appreciate any information you could provide on recent proposals or assessments relating to possible national requirements to install seatbelts in school buses. Thank you for your assistance in addressing my constituent' s concerns. With best wishes,

TED STEVENS

Enclosure

April 13 1987

The Honorable Ted Stevens United States Senate Washington, D.C. 20515

Dear Senator Stevens:

Automobile safety is becoming one of the most common concerns of Americans. Automobiles traveling at excessive speeds, unsafe road conditions, and the risks of drunk drivers almost makes me want to stay off the highways.

With recent bills pertaining to mandatory use of seat belts I can say that use of seat belts is a very good idea for everybody. Senior citizens, adults, teenagers, and small children should all be protected by such devices.

My main concern is that there are no seat belts school buses. School buses serve as a major source of transportation for children ranging from grades K through 12. In event of an accident there is nothing to keep a child in his/her seat. This fact should be looked at more seriously.

Thank you for your time, please keep my concerns with automobile safety and seat belts on school buses a priority in your busy schedule.

Sincerely,

Nadra L. Angerman

ID: nht87-2.2

TYPE: INTERPRETATION-NHTSA

DATE: 06/08/87

FROM: ROSE TALISMAN -- JOAN FABRICS CORP

TO: DOUG COLE -- NATIONAL VAN CONVERSION ASSOC., INC.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A32, STANDARD 302; LETTER DATED 06/29/87 FROM JONATHAN JACKSON TO DOUG COLE; LETTER DATED 06/22/87 FROM ROSE M. TALISMAN TO DOUG COLE; LETTER DATED 06/23/87 FROM DOUG CO LE TO STEVE KRANTZKE

TEXT: Dear Mr. Cole:

In accordance with our understanding from Mr. Irving Brown of C.M.I. Automotive, we are sending to your attention the specifications from both Ford Motor Company and General Motors in Detroit regarding the specific testing procedures required for meeting their codes for fire retardancy.

As you are well aware, we have run correlation studies on our pattern Passport with your recommended testing agency, Commercial Testing Company of Dalton Georgia. The test results have indicated a specific difference in correlation depending on the test method utilized. The method utilized and recommended to us by both Ford Motor Company and General Motors which requires the use of heat resistance support wires as stated on the attached specification are the direct guidelines we utilized in testing al l fabric designated for motorized product from our mill.

We certainly would be happy to discuss the rational and our specific methods for testing based on Detroit's specific requirements. Do not hesitate to call if you have any questions or need additional information.

Ford Laboratory Test Methods;

FLAMMABILITY TEST FOR AUTOMOTIVE INTERIOR MATERIALS

II. Small Parts (contd.)

A surrogate test plaque specimen made with a composition identical to that of the component material(s) shall be produced in the shape of a rectangle 4 inches (100 mm) wide, 14 inches (356 mm) long and the minimum thickness of the component up to 1/2 inch (12.7 mm) maximum, employing the same or equivalent process as used to produce the component part. The thickness of the plaque is that of the material as utilized in the vehicle except where it exceeds 1/2 inch (12.7 mm). In those applications, th e plaque is to be reduced to a uniform thickness of 1/2 inch (12.7 mm) to include the surface material exposed to the occupant compartment air space.

Test Procedure 1. Prior to testing, each specimen is conditioned for 24 hours at a temperature of 73.4 +/- 3.6 degrees F (23.0 +/- 2.0 degrees C) and 50 +/- 5% relative humidity and the test is conducted under those conditions.

2. Material is placed in the specimen holder as indicated below and tested in the direction (transverse or longitudinal) that produces the most adverse results. The specimen is oriented so that the surface closest to the occupant compartment air spa ce faces downward on the test frame.

(a) The standard test specimen (4 x 14 in (100 x 356 mm) x thickness) is inserted between two matching U-shaped frames (specimen holder) so that both sides of the specimen are held by the frames. The temperature of the frame in Figure 4 at the start of each test shall not exceed the conditioned temperature as stated above in Paragraph 1 of Test Procedure.

(b) Where the maximum available width of the specimen is 2 in (50 mm) or less so that the sides of the specimen cannot be held in the two matching U-shaped frames, it is to be supported by the use of 10 mil (0.25 mm) wires spanning the top surface of the bottom U-shaped frame at 1 in (25 mm) intervals, keeping such specimens from bending away from the horizontal at the flaming end, thereby allowing a more uniform and constant burn rate (see Figure 5). The bottom U-shaped frame shall always be positi oned so that the wires are "sandwiched" between the top and bottom frames.

(c) Samples tested with support wires: Flexible specimens, such as genuine leather, supported and unsupported vinyls, textile and backing fabrics, foams, textile padding[Illegible Word] compounds, etc., that frequently soften and bend at the flaming e nd so as to cause a non-uniform, uneven burn rate.

Samples tested without wires: Less flexible materials such as paperboard, carpets, rigid plastics, etc., seldom soften and bend at the flaming end; therefore, do not justify or necessitate support wires.

(d) Adjust ventilation hood door opening to approximately 23 in (580 mm) and regulate ventilation up to 110 CFM (0.052 m<3>/s) maximum air flow to prevent smoke and fumes from entering room.

ID: nht87-2.20

TYPE: INTERPRETATION-NHTSA

DATE: 06/22/87

FROM: ROSE M. TALISMAN -- JOAN AUTOMOTIVE INDUSTRIES TESTING LAB

TO: DOUG COLE -- NATIONAL VAN CONVERSION ASSOCIATION, INC.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A 32, STANDARD 302; LETTER DATED 06/08/87 FROM ROSE TALISMAN TO DOUG COLE; LETTER DATED 06/23/87 FROM DOUG COLE TO STEVE KRANTZKE; LETTER DATED 06/29/87 FROM JONATHAN JA CKSON TO DOUG COLE

TEXT: Dear Doug:

As I stated earlier correspondence Joan Automotive Industries conducts its flammability testing according to Federal Motor Vehicle Safety Standard No. 302. This includes the use of heat resistant support wires as indicated in paragraph S5.1.3, "A specime n that softens and bends at the flaming end so as to cause erratic burning is kept horizontal by supports consisting of thin, heat resistant wires, spanning the width of the U-shaped frame under the specimen at 1-inch intervals."

It is our belief that this method satisfies the requirements of FMVSS 302 testing and is the standard industry procedure for testing automotive bodycloth.

Please keep us informed as to what the Department of Transportation's response is to your inquiry.