ID: nht71-1.50

DATE: 01/29/71

FROM: AUTHOR UNAVAILABLE; C. H. Hartman for D. W. Toms; NHTSA

TO: Morgan Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: By letter of November 19, 1970, you petitioned for reconsideration of Federal Motor Vehicle Safety Standard No. 214 - Side Door Strength (35 F.R. 16801, October 30, 1970). After consideration of the issues raised by Morgan's petition, the National Highway Traffic Safety Administration has found no sufficient justification for amending the standard and the petition is therefore denied.

Your company's petition states that the standard presents difficulties for cutaway doors, and that the structure of Morgan automobiles supplies a measure of protection through Clared side fenders that extend beneath the doors. The Administration recognizes that there is considerable variety in door and side structure. However, the need to protect occupants of all vehicles from injury in side collisions dictates a uniform measure of such protection, and the Administration has determined that the requirements of Standard No. 214 are reasonable, practicable and appropriate for passenger cars.

The remaining points in your letter of November 19, 1970, are more nearly questions for interpretation than requests for reconsideration. Your second question pertains to the height (or length) of the loading device. The standard states only that the device must not contact any structure above the bottom edge of the door window opening. There is no other restriction on the maximum height of the test device, and it is not clear, without further explanation, why Morgan would be limited to a cylinder only 4 inches high.

Your remaining question deals with the positioning of side windows. Although the standard specifies that side windows shall be in the uppermost position, it does not require that side windows exist and should not be so interpreted.

ID: nht71-1.6

DATE: 08/09/71

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Holen Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of June 30 and August 2 on the subject of the applicability of Standard No. 210 to multipurpose passenger vehicles, trucks, and buses as amended by notice of March 4, 1971 (36 F.R. 4291). The standard applies to these vehicles effective July 1, 1971, even though the heading published in the Register refers only to passenger cars. The application of the standard is controlled by the application section, S2, and not by the heading of the standard. The heading only reflects the substance of the application section and should automatically change whenever the application is changed. Through oversight, the Federal Register was given no instructions as to handing changes, and therefore inserted the old heading into the March 4 notice. Since the heading has no substantive role, and since the amendment is only in effect until the revised Standard No. 210 becomes effective January 1, 1972, we have not requested the Federal Register to alter the heading.

I hope this is responsive to your question.

ID: nht71-1.7

DATE: 06/01/71 EST

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Volkswagen of America Inc.

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of June 7, 1971, you asked for confirmation of your understanding that under the NHTSA regulation (49 CFR @ 553.39) interpreting section 105(a)(1) of the National Traffic and Motor Vehicle Safety Act, a petition for judicial review of Standard No. 208 would be considered timely if filed within 60 days after the publication in the Federal Register of the Administrator's decision on any petitions for reconsideration of that standard.

Your understanding is correct. As the standard currently stands, we consider it (that is, the standard as it becomes effective January 1, 1972) a "single rule", to use your phrase, and the judicial review period will not begin to run until the publication of the decision on any timely-filed petitions for reconsideration of any part of it. If at a future date we wish to sever any portion of the standard for judicial review purposes, and consider it "final" despite pending action on other portions, we will give explicit notice of that action in the Federal Register.

We are pleased to be of assistance.

ID: nht71-1.8

DATE: 02/18/71

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Strick Corporation

TITLE: FMVSR INTERPRETATION

TEXT: Mr. Toms has asked me to reply to your letter of December 3, 1971, in which you enclosed a drawing of a certification label you intend to use to fulfill the amended requirements of Part 567 of Title 45 of the Code of Federal Regulations.

In a telephone conversation with you, Mr. George Shifflett of my staff has explained that the (Illegible Word) used on your proposed label does not fulfill the requirements. The Certification regulations require each vehicle to be labeled with specific information applicable to that vehicle. The information is to be presented in a specific order and manner. We do not consider a multipurpose label such as the one you have submitted to be consistent with those requirements. The label for each vehicle should reflect information only for that vehicle.

Multiple GVWR and GAWR are permissible as specified in the amendments to the regulation published in the Federal Register on December 19, 1971. A copy of that publication is enclosed. (Illegible Word) multiple listings are to be applied to the label in keeping with the format outlines in the amendment. For example:

GAWR:

Front - 10,000 with 7.50 x 15E Tires 13,000 with 8.25 x 15F Tires 15,000 with 8.25 x 15X Steel Cord Tires

Rear - 19,000 with 7.50 x 15E Tires 13,000 with 8.25 x 15F Tires 15,000 with 8.25 x 15X Steel Cord Tires

The other nonrequired information in the body of your label, "when load is properly distributed" and "based on tire capacity for each axle (Illegible Word) of position," should be removed from its present location on the label. Section 567.4(g) requires all information on the label to be placed in the order listed in all information. However, we have no objection if you wish to add the additional information to the bottom of the label, below the required information. We would expect vehicles produced by your company to bear conforming labels by April 1, 1972.

If you have further questions I will be pleased to answer them.

Sincerely,

Enclosure

ID: nht71-1.9

DATE: 03/09/71

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: Truck Body and Equipment Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 23, 1971, to Mr. Julian B. Leysath of this office requesting an interpretation on the mounting location of rear clearance lamps on slant-sided beverage truck bodies.

Rear clearance lamps mounted on the outermost top corners of the body, as indicated on the TBEA diagram, adequately meet the location requirements of Federal Motor Vehicle Safety Standard No. 108.

ID: nht71-2.1

DATE: 02/02/71

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Department of Public Utilities and Transportation

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of December 14, 1970, concerning taxicab driver security.

It is our opinion that the facts presented do not warrant rule making action in the form of safety performance standards applicable to new vehicle manufacture.

There are available, however, manufacturing options that may be procured to satisfy operational requirements. Bullet resistant glass between the cab driver and holdup men is one that quickly comes to mind. Further, we have issued a notice of proposed rule making (on December 31, 1970, which proposes amendment to the glazing Standard No. 205, (36 PR 326), a copy of which is enclosed. This(Illegible Word), if carried to a rule, would allow high strength plastics such as cellulose acetate butyrate and polycarbonate in areas not necessary for driving visibility. Cellulose acetate butyrate and polycarbonate do not meet requirements of the glazing standard as presently written.

(Illegible Word) share your concern for the security of cab drivers who seem to be under constant threat of robbery. However, we feel that the matter is one of satisfying operational needs rather than safety performance requirements as dictated in the National Traffic and Motor Vehicle Safety Act of 1966.

Enclosure

ID: nht71-2.10

DATE: 03/01/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Bolt Beranek and Newman, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 5, 1971, concerning certification of child seating systems. Your letter asks whether the statement, "This (child seating system) conforms to all applicable Federal Motor Vehicle Safety Standards in effect on the date of manufacture shown above," or alternatively the symbol "DOT," may be used to certify that a child seating system complies with Standard No. 213. You also ask whether the certification statement may be placed on the label required on the child seat pursuant to S4.1 of the standard.

The statement that you submit is an adequate certification statement. Furthermore, this statement or a similar statement may be placed on the label required pursuant to S4.1 of the standard, as the certification would therefore be "in the form of a label or tag" on the item of motor vehicle equipment as specified in section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1403).

With reference to use of the symbol "DOT" for certifying child seating systems, while this symbol is presently used by manufacturers to certify other items of motor vehicle equipment, its use as such is only pursuant to specific provisions of the standards. We cannot approve of its use for child seating systems without prior rulemaking.

WE ARE PLEASED TO BE OF ASSISTANCE.

ID: nht71-2.11

DATE: 03/01/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Recreational Vehicle Institute Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is to confirm your interpretation of the Tire Identification and Record Keeping Regulations as expressed in your letter of February 18, 1971.

The vehicle manufacturer is responsible for the retention of records of tires shipped "in or on" a new vehicle. However, if the vehicle is used to transport extra tires, the manufacturer is not obliged to retain records of those tires, but rather, the vehicle dealer will be responsible for communicating the appropriate information to the tire manufacturer in accordance with either section 574.8 or section 574.9 of Part 574.

ID: nht71-2.12

DATE: 03/09/71

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: Koito Manufacturing Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 25, 1971, concerning the photometric requirements for amber turn signal lamps.

You have correctly interpreted the photometric requirements for amber turn signal lamps as specified in paragrap S4.1.1.7 of Federal Motor Vehicle Safety Standard No. 108, effective January 1, 1972.

ID: nht71-2.13

DATE: 03/10/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Bolt Beranek and Newman, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: During your visit which Michael Peskoe on March 4, 1971, you indicated that you were desirous of having a reply to the question that you posed in your letter of December 14, 1970, concerning S4.6 of Standard No. 213, without delaying that answer until the response to the entire letter had been prepared.

Your question concerning S4.6, which states in part, " . . . [Each] forward-facing child seating system shall have a seat back. The height of the seat back shall be . . .," is whether an adjustable head restraint can be used to meet this requirement provided "(a) it meets the height requirement measured at the lateral center of the head restraint, and (b) it is accompanied, in the instruction sheet, by instructions for adjustment to fit the child."

It was intended by paragraph S4.6 that a head restraint could be used to meet the above height requirement, proviced that it meets the other requirements of the standard, such as the head impact protection requirements of S4.10, as well as those you described.