ID: nht74-5.51

DATE: 04/18/74

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Law Ofices of William and Black

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 29, 1974, requesting information and documentation concerning Fuel System Integrity Standards.

The GSA 515/26 Standard which you mentioned was published July 15, 1966, and was effective October 13, 1967. This standard was effectively supplanted by Federal Motor Vehicle Safety Standard No. 301 which was effective January 1, 1968. A copy of this original Standard No. 301 is enclosed for your information along with a recent amendment (F.R. 39, 10586, March 21, 1974) that substantially upgrades the requirements of this standard.

We do not consider it appropriate to give advice concerning private incidents or controversies, beyond what is contained in our regulations and other public issuances. You may find it helpful to contact private-sector groups such as the Society of Automotive Engineers for further information.

ENC. (3)

Williams and Black

March 29, 1974

Department of Transportation National Highway Traffic Safety Administration OFFICE OF CRASHWORTHINESS

Attention: Guy Hunter

Re: KLANN vs. FORD MOTOR COMPANY

I had a very lengthy conversation with Mr. Koschak in the Los Angeles Office of the General Services Administration. He very kindly referred me to you for help needed in this matter.

We presently have an action pending against the Ford Motor Company for the deaths of two adults following a collision while they were driving a 1965 Model P-250 pick-up truck. This pick-up truck had a camper installed on the bed.

The accident would be a barrier-type crash in which a vehicle went out of control on the opposite side of the road, came into the lane of the subject vehicle and the crash ensued.

The husband and wife occupying the pick-up truck were burned to death. We have had several experts examine this vehicle and have described the mechanism of their incineration as a shearing of the neck of the gas-tank filler pipe, along with some displacement of the cab of the vehicle itself. Between the shearing of the neck, as well as the displacement, the fuel in the tank was forced into the driving compartment, and a fire of great intensity developed.

This fire was of sufficient intensity to melt the interior fittings of the vehicle, as well as causing fatal injuries to the occupants.

During the process of our litigation with Ford Motor Company, we have had occasion to examine, but not photocopy certain of their crash tests. These crash tests make reference to a publication specifically referred to as "1968 GSA Standard 515/26-53.2." This reference was contained in test No. D-5192 performed on October 15, 1966. This was a sixteen mile per hour crash into a movable barrier. I further note that in one of the additional tests, more particularly, No. D S126 performed on August 5, 1966, which was a 29.5 m.p.h. crash into a barrier, the test results indicated that the fuel tank displaced; however, no photos of the crashed vehicle were attached to the Ford test.

We are interested in learning the specifications or directions from the Department of Transportation to auto manufactuers and, more particularly, as relates to the fuel systems and locations in 1965 and 1966 model vehicles -- i.e., pick-up trucks. We would also like to know whether or not the Department of Transportation directed any recall or modification campaigns, either by direction or by suggestion to the automobile manufacturers, especially Ford Motor Company.

We have been advised by our own automotive engineers that the location of the gasoline tank is a defect in design. We believe that our position would be further fortified by some communications or directions from the Department of Transportation directed to the various automobile manufacturers as relate to the location or stability of gasoline tank systems.

I am uncertain as to what we are looking for is adequately described within this letter; however, I believe the brief description I have given may be sufficient for you to determine specifically what we are looking for.

We would certainly appreciate any copies of correspondence or any other documents you may have as pertains to this problem and, more particularly, communications directed to the Ford Motor Company referring to their fuel system in their pick-up trucks.

Thanking you in advance for your anticipated courtesy and cooperation, I remain,

ROBERT S. PRIVER

cc: Mike Koschak c/o General Services Administration Motor Pool 300 North Los Angeles Street, Suite 3124 Los Angeles, California 90012

ID: nht74-5.52

DATE: 01/22/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: West & Wilkinson

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 2, 1974 requesting information concerning the legal permissibility of an automobile dealership furnishing private passenger motor vehicles with add-on gasoline tanks or modifying existing gasoline tanks.

Motor Vehicle Safety Standard No. 301, Fuel System Integrity, establishes minimum performance requirements for motor vehicle fuel systems. Compliance with the level of performance mandated by the standard is enforced by Section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act which prohibits the manufacture, sale, delivery, or importation of vehicles or motor vehicle equipment that do not meet the requirements of applicable safety standards. Therefore, if your client modified a motor vehicle fuel tank in such a manner that it no longer complied with Standard No. 301 and then offered it for initial sale for purposes other than resale he would be in violation of the Motor Vehicle Safety Act and would be subject to civil penalties of not more than $ 1,000 for each such violation. If, however, your client performed a fuel tank modification on a vehicle that was already owned by and in the possession of a buyer who purchased the vehicle for purposes other than resale, no violation of the Act could result. The installation of an add-on fuel tank would be considered a modification. Therefore, the fuel system would have to comply with Standard No. 301 with the add-on fuel tank considered as part of the system.

There are no Motor Vehicle Safety Standards applicable to add-on gasoline tanks since these are items of motor vehicle equipment and Standard No. 301 restricts its application to motor vehicles. Section 113(c)(2) of the Motor Vehicle Safety Act, however, authorizes the Secretary of Transportation to determine whether or not an item of motor vehicle equipment contains a defect which relates to motor vehicle safety. If the Secretary finds that a safety-related defect exists, your client may be compelled to notify all purchasers of vehicles with the add-on fuel tanks of the attendant hazard.

The action of installing add-on gasoline tanks in motor vehicles exposes your client to the requirements of yet another safety regulation (49 CFR 567.7) If the vehicle in which he installs the fuel tank is a certified and complete vehicle that has not yet been purchased in good faith for purposes other than resale, your client will be considered an alterer of the vehicle, and he must provide a certification that the vehicle as altered still conforms to the standards.

YOURS TRULY,

WEST & WILKINSON January 2, 1974

Secretary of Transportation Department of Transportation

According to the Federal Motor Vehicle Safety Standards Act, 15 USC Sections 1391 et seq., and particularly Section 1392, your office was empowered and directed to adopt minimum safety standards for motor vehicles. We do not have ready access to whatever standards have been promulgated but have received inquiry from a client concerning the existence of a specific provision in such standards. Specifically, my client, an automobile dealership, inquires if there is any prohibition(Illegible Word) civil or criminal sanctions on adding gasoline tanks to private passenger motor vehicles, including campers, or modifying existing gasoline tanks on such vehicles.

Your assistance will be appreciated.

Richard Wright West

ID: nht74-5.53

DATE: 08/05/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Adams & Westlake Company

TITLE: FMVSS INTERPRETATION

TEXT: Dear Mr. Hansing:

This is in reply to your letter of July 3, 1974, regarding Motor Vehicle Safety Standard No. 217. You requested that we reconsider our opinion of June 11, 1974, that a bus emergency release mechanism which you describe must meet the requirements for emergency exit release in S5.3.2 of the standard after as well as before the retention test required by S5.1, when the glass breaks during the retention test.

Paragraph S5.3.2 requires that the release requirements be met both before and after the retention test. We do not find sufficient justification to relax this requirement in the situation you described. First, it is not clear that it is as easy as you represent to eliminate by hand all of the glazing material left in the frame. More importantly, however, we still question whether most persons are sufficiently cognizant of the qualities of tempered glass to attempt to remove the remaining fragments in an emergency situation. Finally, glazing with completely different breakage characteristics may be used to replace the original tempered glass at some time during the life of the bus. For these reasons, our conclusion of June 11 remains the same.

Yours Truly,

July 3, 1974

Office of Chief Counsul

National Highway Traffic Safety Administration

Attention Mr. Richard Dyson

In regard to Motor Vehicle Safety Standard #217, "Bus Window Retention and Release S5.3.2 and our previous correspondence (here enclosed), please reconsider our request for exemption from having operable release mechanisms after the retention test when glazing with tempered glass.

In my letter to you of April 16, 1974 we noted that tempered glass once broken made the operation of any release mechanism unnecessary, as any glass remaining in the opening would be easily removed by touch. We therefore asked for exemption from the requirement that the release mechanism be operable after the retention portion of the test on the basis that the release mechanism would no longer be necessary in the event of glass breakage.

Our design, which is proposed for use on short and mid-range transit busses, uses an extruded aluminum frame which is screwed to the coach body. The glass is glazed directly into the frame; the stationary lite being returned by a rubber extrusion and bedding tape. The sliding glass is also retained directly in the frame and glides horizontally in a pocket weatherstrip. The release lock mechanism is bonded directly to the sliding lite and retains it in a closed position by engaging a groove in the extruded frame rail.

To meet the opening requirement of S5.2.2B of the spec, the release lock mechanism is disengaged and the sliding lite is moved foreward or rearward, depending on which half contains the sliding lite, until the minimum opening width of 20 inches is obtained. See drawing #DK-1553 and test pictures which show the type of window proposed.

This system meets the preliminary release test and the retention test without question, but if the tempered sliding glass shatters during the lotter test most of the glass, often including the release lock mechanism, falls out of the opening. This obviates any further practical need for the release

lock mechanism as the required opening, if not immediately obtained by the breakage of the sliding lite, can be obtained by touching any remaining glass cubes which will cause them to crumble and fall out. In the event that the tempered glass does not break during testing, or more importantly during crash impact, the mechanism would obviously be required to function.

We feel that our system fully meets the intent of the specification in providing unobstructed openings for emergency agress. We respectfully request that you reconsider our request for exemption from the portion of paragraph S5.3.2 which requires that the release lock mechanism remain operable after the retention test when tempered glass is used in this manner and has broken out during that test. Please give this request your earliest consideration as a reply is urgently needed by August 1, 1974.

Ronald J. Hansing Project Engineer

(Graphics omitted)

ID: nht74-5.54

DATE: 07/10/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Hellstar Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 17, 1974, requesting further information on the applicability of Federal safety standards to auxiliary fuel tanks.

Standard No. 301 does not apply directly to auxiliary or extra-capacity fuel tanks. However, it does apply to motor vehicle fuel systems. Therefore, if an auxiliary or extra-capacity tank is installed in the fuel system of a vehicle that is subject to the performance requirements of Standard No. 301, before its first purchase for purposes other than resale, causing that fuel system not to be in compliance with the standard, the person installing the tank or offering the vehicle for sale would be in violation of @108 (a)(1) of the National Traffic and Motor Vehicle Safety Act. Since Standard No. 301 becomes applicable to trucks with a GVWR of 6,000 pounds or less on September 1, 1976, the fuel systems of such trucks will have to meet the performance requirements of the standard as of that date.

The fact that a customer may have ordered the auxiliary or extra-capacity tank to be installed in the vehicle he is purchasing does not affect the installer's responsibilities under the Act. He would still be in violation of Standard No. 301 if the tank were installed prior to the first purchase causing the fuel system to be in noncompliance.

Auxiliary and extra-capacity fuel tanks are not subject to regulation under Standard No. 301 where they are installed after the first purchase of the vehicle for purposes other than resale. However, the auxiliary and extra-capacity tanks are subject to the

2 section of the National Traffic and Motor Vehicle Safety Act that authorizes the Secretary of Transportation to make a determination as to whether or not an item of motor vehicle equipment contains a safety-related defect. In the event that such a determination is made, the manufacturer may be compelled to notify purchasers of the hazard.

If the installation of the fuel tank occurs before the first purchase of the vehicle for purposes other than resale, the installer must affix to the vehicle an additional certification label stating the alterer's name, the date of the alteration completion, and that the vehicle conforms to all applicable safety standards in effect on a date no earlier than the manufacturing date of the original vehicle, and no later than the date the alterations were completed.

We appreciate your interest.

YOURS TRULY,

CORPORATION June 17, 1974

Richard B. Dyson Assistant Chief Counsel -- NHTSA

Re: N40-30 KK

Your letter to Merle Robberts did not state clearly what effects standard No. 301, Part 571 would have to pick up truck auxiliary fuel tanks when this standard takes effect in 1976.

If I am reading your letter correctly auxiliary fuel tanks will not be effected, even after 1976, as long as they are not installed prior to first sale. Is this a correct assumption?

We also manufacture a line of extra capacity fuel tanks where the original tank is removed and our tank is installed in its place. Would the above be true in this situation?

If a new truck dealer installed an auxiliary or a replacement fuel tank on a vehicle that was ordered by the customer, would he be in violation of Standard 301?

Would a person that installs an auxiliary or replacement fuel tank on a vehicle have to recertify this vehicle under Part 567 certification rules?

A reply to the above at your earliest convenience will be greatly appreciated.

John J. Gostomski President

ID: nht74-5.55

DATE: 08/20/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Toyda Gosei Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 8, 1974, question whether the effective date of Standard No. 106-74, Brake hoses, is September 1, 1974, for hose (and fittings) and March 1, 1975, for nose assemblies.

Your interpretation is correct. The standard requires conforming hose (and fittings) as of September 1, 1974. It requires conforming assemblies (including the label band) only on March 1, 1975, and thereafter.

ID: nht74-5.56

DATE: 06/06/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Hellstar Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 13, 1974, requesting information concerning the existence of any Federal Motor Vehicle Safety Standards applicable to auxiliary fuel tanks.

The National Highway Traffic Safety Administration has promulgated no motor vehicle safety standard relating to auxiliary fuel tanks. There is, however, a safety standard which imposes performance requirements upon motor vehicles with regard to their fuel systems. Thus, if installation of the auxiliary tank is accomplished prior to the first purchase of the vehicle for purposes other than resale causing the vehicle's fuel system not to be in compliance with the applicable safety standard, the person installing the tank or offering the vehicle for sale would be in violation of @ 108(a)(1) of the National Traffic and Motor Vehicle Safety Act. That would make the installer or seller subject to civil penalties of up to $ 1,000 for each violation.

The National Traffic and Motor Vehicle Safety Act authorizes the Secretary of Transportation to make a determination as to whether or not an item of motor vehicle equipment contains a defect which relates to motor vehicle safety. If he finds that a safety-related defect exists, he may compel the manufacturer to notify purchasers of the hazard. Therefore, even though auxiliary fuel tanks are not the subject of a standard, they still must be safely designed.

For your information, I have enclosed a copy of the Federal Safety Standard relating to motor vehicle fuel systems.

Enc.

HELLSTAR CORPORATION

May 13, 1974

U. S. Department of Transportation National Highway Traffic Administration

Hellstar is making auxilary gas tanks for pickups, which is added to the pickup after manufactured from original manufacturer.

What are the regulations and what standards do we have to meet? Is there any test requirement necessary?

Merle O. Roberts Controller

ID: nht74-5.57

DATE: 05/15/74

FROM: LAWRENCE R. SCHNEIDER -- CHIEF COUNSEL, NHTSA

TO: PETER J. PITCHESS -- SHERIFF, COUNTY OF LOS ANGELES,

TITLE: NONE

TEXT: This is in response to your letter of May 2, 1974, requesting the results of the public hearing concerning safety standards for police vehicles held on December 10, 1973, and your petition in this regard.

As you know, that hearing was held in conjunction with an advance notice of proposed rulemaking issued by this agency. We are in the final stage of analysis of both the public bearing and the comments in response to the advance notice, and will issue our conclusions in the near future. In the interim, all Federal Safety Standards continue to be applicable to police vehicles although you remain free to alter your vehicles after they are delivered to you.

ID: nht74-5.6

DATE: 02/20/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Douglas F. Welebir, Esq., Attorney at Law

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 28, 1973, File No. 1041, requesting information on the Federal installation requirements for safety belts in a 1971 Toyota Land Cruiser.

Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection (formerly titled "Seat belt installation"), required safety belts in all designated seating positions of all passenger cars manufactured on or after January 1, 1968. Similar requirements were instituted for trucks and multipurpose passenger vehicles manufactured after July 1, 1971. The Toyota Land Cruiser is classified as a multipurpose passenger vehicle. If it were manufactured before July 1, 1971, no installation requirement would have applied. It should be noted that seat belts were not factory-installed in some Land Cruisers, and we know of one Arizona dealer who failed to install seatbelts in a Land Cruiser built after that date.

In answer to your second question, the Land Cruiser did not have any exemption under 15 U.S.C. @ 1410 or any other section of the Act.

ENC.

December 28, 1973

Director National Highway Safety Bureau

I represent a young man injured in an automobile accident primarily because of the lack of seat belts in a 1971 Toyota Land Cruiser. Would it be possible to obtain a copy of the vehicle safety standards enacted pursuant to the National Traffic and Motor Vehicle Safety Act of 1966 relating to the installation of seat belts in new automobiles.

I would also appreciate knowing whether or not Toyota Motor Company of the United States has been exempt from compliance with this Act under 15 USC 1410 or any other section.

I thank you for your assistance and helpfulness in this important matter.

DOUGLAS F. WELEBIR

ID: nht74-5.7

DATE: 04/01/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Charles F. Aycock

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 16, 1974, asking whether courtesy lights for trucks carry the message "clear" and "thanks" are in violation of any Federal regulations. The courtesy lights to which you refer in your letter do not violate any regulation of the National Highway Traffic Safety Administration. We have forwarded a copy of your letter to the Bureau of Motor Carrier Safety in the Federal Highway Administration for a response in regard to the motor carrier safety regulations.

ALDRIDGE, HARDING & AYCOCK

FEBRUARY 16, 1974

LAWRENCE SCHNEIDER -- CHIEF COUNSEL, DEPT. OF TRANSPORTATION

RE: COURTESY LIGHTS

I represent Tom Paine, of Bovina, Texas, who has developed a lighting system for large tractor-trailer vehicles and a patent is now pending on same.

During the course of developing the product we were advised to contact the American Association of Motor Vehicles to obtain their Certificate of Approval in the 47 states represented by the Association. We are now in the process of filing that application, and on this date I discussed same with Mr. Frank Bergsman, in your office of Standards and Enforcement. Mr. Bergsman suggested that we write to you regarding the legality of the use of the product insofar as any Federal regulations are concerned.

Specifically, the courtesy lights are a set of two lights, one of which is a green light with the word "clear" stamped on the lens. The other light is a blue light with the word "thanks" stamped in the lens. The green light goes on the front of the motor vehicle and when a truck passes the vehicle with the green light on the front the operator of the vehicle being passed simply turns a toggle switch which activates the green light that may readily be seen in the rear view mirrow of the passing trucker. Of course, the purpose of this light is to show the passing trucker that his trailer has cleared the vehicle he is passing. The lens which go on the back of the truck would simply be a 'thank you' device which may also be activated by a simple toggle switch.

I am enclosing a copy of the Application filed in the

2 Patent Office with the describing pictures, which I think will make the purpose of the units more clear. My client was a trucker for many years, and during the course of driving trucks noted that truckers wore out many sets of head lights and clearance lights blinking them off and on as a courtesy gesture to passing vehicles. His product simply is designed to avoid those problems.

Specifically, we cannot find anything in the motor carrier safety regulations as revised, including the amendments, that prohibits the use of said equipment. We were, however, wanting an opinion from your office as to whether or not we would be in violation of any Federal safety regulation if these products were manufactured and placed on motor carrier vehicles.

We do understand that there are certain state jurisdictions that we will have to obtain permission from before selling the product in that state. We will proceed to obtain that jurisdiction, but we want to satisfy ourselves that we were completely in compliance with any Federal statutes or regulations.

Your assistance and opinion would surely be appreciated, and we would look forward to hearing from you as quickly as possible. If you have any questions please do not hesitate to contact me.

CHARLES F. AYCOCK

ENCL.

Graphics omitted)

THOMAS G. PAINE

THRU: CHARLES F. AYCOCK

COURTESY LIGHT FIXTURE

ABSTRACT OF THE DISCLOSURE

A visual signaling system for large trucks passing each other while traveling in the same direction, after nightfall. Each vehicle mounts a pair of signal lamps adjacent the front and rear ends which lamps are illuminated under control of the driver to signal another vehicle or acknowledge receipt of a signal.

This invention relates to signaling systems for relatively large road vehicles such as trailer trucks.

One of the hazards encountered during nighttime motor vehicle travel, is difficulty in judging distances. This problem arises in particular when one vehicle passes another while traveling in the same direction and after passing moves laterally into the right-hand lane from the left-hand passing lane. Before moving back to the right-hand lane, a driver of a passing vehicle should be certain that there is sufficient clearance between his vehicle and the vehicle just passed. Judging such clearance is particularly difficult in connection with relatively long trucks such as tractor cabs with trailers hitched thereto. It is current practice in such vehicle passing situations, for the driver of the vehicle being passed to momentarily turn on the high beams of the headlamps which are reflected in the rear view mirror of the passing vehicle in order to signify to the driver that his vehicle has cleared the front end of the vehicle being passed. It is therefore an important object of the present invention to provide a signaling system to more positively and reliably take care of the foregoing situation in which the drivers of two vehicles wish to communicate with each other.

In accordance with the present invention, large vehicles such as elongated trucks are provided with a pair of signal lamps adjacent the front and rear ends thereof, said lamps being provided with bulb covers of different colors having faces on which a message is made visible by illumination of the lamp. Illumination of the lamp adjacent the front end is effected under control of the vehicle driver within the cab in order to signal the driver of a passing vehicle that his vehicle has cleared the front end of the vehicle being passed. The lamp mounted adjacent the front end may accordingly bear the letters "Clear" that become visible to the driver in a passing vehicle through the rear view mirror when the lamp is illuminated. The rear end mounted signal lamp, on the other hand, is provided with lattering such as "Thanks" so that the driver of the passing vehicle may acknowledge receipt of the "Clear signal by illuminating the rear mounted lamp. The illumination produced by the two lamps is of different colors so that the messages may be readily distinguished from each other at a glance.

These together with other objects and advantages which will become subsequently apparent reside in the details of construction and operation as more fully hereinafter described and claimed, reference being had to the accompanying drawings forming a part hereof, wherein like numerals refer to like parts throughout.

Figure 1 is a simplified top plan view of a pair of road vehicles in a passing situation, the vehicles being provided with the signaling system of the present invention.

Figure 2 is a perspective view illustrating one of the signal lamps associated with the system of the present invention.

Figure 3 is a perspective view illustrating the other of the lamps associated with the signaling system.

Figure 4 is a longitudinal sectional view through one of the lamps.

Figure 5 is a simplified electrical circuit diagram corresponding to the system of the present invention.

Referring now to the drawings in detail, Figure 1 illustrates a typical two lane road generally referred to by reference numeral 10 on which vehicles travel in the same direction. A vehicle generally referred to by reference numeral 12 traveling in the right-hand lane is accordingly shown being passed by another vehicle generally referred to by reference numeral 14 traveling in the same direction in the left-hand or passing lane. As is well known, the passing lane is only used during the passing maneuver and the passing vehicle will return to the right-hand traveling lane after passing another vehicle, with sufficient clearance. Figure 1 illustrates this passing situation wherein the passing vehicle has cleared the vehicle 12 being passed.

The system of the present invention is shown installed on relatively long vehicles which include, for example, a tractor cab 16 at the front end to which a trailer 18 is hitched. Each vehicle mounts a pair of signal lamps including a signal lamp 20 mounted adjacent the front end of the vehicle and a signal lamp 22 mounted adjacent the rear end of the vehicle. When the passing vehicle 14 has cleared the vehicle 12, as shown in Figure 1, the driver of the vehicle 12 will cause signal lamp 20 thereon to be illuminated producing illumination 24 emitted forwardly therefrom, which will be observed by the driver of the passing vehicle 14 through the rear view mirror. This signal will then be acknowledged by the driver of the vehicle 14 by causing the rear mounted signal lamp 22 to be illuminated producing illumination 26 emitted rearwardly therefrom.

Each of the signal lamps 20 and 22 is similar in construction and operation to each other except for the signaling indicia and color of it light transmitting cover 28 as shown in Figures 2, 3 and 4. Each lamp includes a relatively rigid base 30 adapted to be fixedly mounted on the vehicle. The base includes a relatively flat, rectangular reflective portion 32 from which a peripheral flange 34 extends rearwardly terminating in a seating rim 36 adapted to abut the surface of the vehicle. Extending from the front face 38 of the cover 28, is a peripheral rim 40. The rim 40 of the cover is provided with a plurality of spaced projections 42 adapted to be snapped into retainer openings 44 formed in the flange portion 34 of the base 30. A sealing gasket 46 is sandwiched between the rims 36 and 40 of the base and cover, when the cover is assembled on the base as shown in Figure 4. Ventilation holes 48 are formed in the flat reflective portion of the base so as to permit dissipation of heat generated within the space 50 enclosed by the cover.

A pair of incandescent bulb assemblies 52 are mounted on the reflective portion 32 of the base within the space 50 in order to emit illumination through the colored cover 28 on which the signal indicia is mounted as shown in Figures 2 and 3. Electrical conductors extend from the bulb assemblies 52 through a central opening in the base lined by a nonconductive grommet 54.

As shown in Figures 2 and 3, the indicia mounted on the cover of lamp 22 is in the form of letters spelling "Clear" in order to signify that a passing vehicle has sufficiently cleared another vehicle as shown in Figure 1. The lamp 20 on the other hand is provided with indicia on its cover which spells "Thanks" thereby acknowledging receipt of the "Clear" signal. The lamps may be selectively controlled by the driver in a vehicle from the cab by means of switches 56 and 58 as shown in Figure 5 which thereby complete parallel lighting circuits through the associated lamps connected, for example, to the vehicle battery 60.

The foregoing is considered as illustrative only of the principles of the invention. Further, since numerous modifications and changes will readily occur to those skilled in the art, it is not desired to limit the invention to the exact construction and operation shown and described, and accordingly all suitable modifications and equivalents may be resorted to, falling within the scope of the invention.

What is claimed as new is as follows:

1. In combination with an elongated, road vehicle having front and rear ends, a signaling system comprising, a pair of lamps respectively mounted adjacent the front and rear ends of the vehicle, and means for selectively illuminating said lamps to signal another vehicle traveling in the same direction, the lamp on the front end bearing indicin signifying clearance in the direction of travel and the lamp on the rear end bearing acknowledgment indicia.

2. The combination of claim 1 wherein said lamps respectively include covers of different colors.

3. The combination of claim 2 wherein each of said lamps includes a relatively rigid base having a substantially flat reflective surface and a rim portion provided with retainer openings, each of said covers having a peripheral flange provided with projections received within said retainer openings, and incandescent bulb means mounted on the reflective surface enclosed within the cover.

4. The combination of claim 1 wherein each of said lamps includes a relatively rigid base having a substantially flat reflective surface and a rim portion provided with retainer openings, a cover having a peripheral flange provided with projections received within said retainer openings, and incandescent bulb means mounted on the reflective surface enclosed within the cover.

5. The combination of claim 4 wherein the cover for the lamp adjacent the front end is colored green as background for the indicin "clear", while the cover for the lamp on the rear end is colored blue as background for the indicia "thanks".

6. The combination of claim 1 wherein said lamps include light transmitting covers respectively colored green and blue, the indicia on the cover for the front end mounted lamp reading "clear" while the indicia on the cover for the rear end mounted lamp reading "thanks".

ID: nht74-5.8

DATE: 02/21/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Bridges and Collins

TITLE: FMVSR INTERPRETATION

TEXT: In reply to your request of January 30, 1974, I am enclosing a copy of the regulation issued to implement the odometer disclosure requirements of Public Law 92.513.

Although there are a variety of ways to determine whether a vehicle's actual mileage is greater than shown on the odometer, I know of only one method to establish the exact amount by which the indicated mileage has been exceeded: the testimony of a witness who knew the exact mileage on the car at the time the odometer was changed and who knows the accuracy of the odometer's performance after the change.

I would be most interested to learn of the progress of your action.

BRIDGES AND COLLINS

January 30, 1974

Department of Transportation National Highway Traffic Safety Administration

IN RE: Odometer Disclosure Requirements

Dear Administrator:

I am at the present time attempting to prosecute a civil action under Section 408 (a) of Title IV of the Motor Vehicle Information and Cost Savings Act (Public law 92-513). (This statute may be found in 15 U.S.C.A. @ 1988.)

Please send me a copy of the current rules regulating this statute.

I am having some difficulty determining the true mileage of the vehicle in question. If you know of a procedure for determining the actual mileage of a motor vehicle, please pass that information along to me. I would be most appreciative.

I can use the above-requested information as quickly as you can supply it.

Thank you for your prompt assistance and cooperation.

James B. Steward