ID: nht74-1.13

DATE: 03/06/74

FROM: AUTHOR UNAVAILABLE; L. R. Schneider for R. B. Dyson; NHTSA

TO: Lufkin Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your January 30, 1974, request for inclusion in Standard 106, Brake hoses, of J1402 type A and B hose and J844 (nylon type 3) hose.

Standard 106 has already been amended by the addition of 3/8-in and 1/2-in special sizes to the list of hose sizes which may be used with reusable fittings, and this addition permits continued use of commonly utilized types of A and B hose.

The nylon 3 hose to which you refer is not excluded from use under the standard. Several of its manufacturers have indicated that it does conform to the requirements of the standard, which have been modified to reflect the lower tensile strength valves needed when used at non-articulating points in the system.

Yours truly,

ATTACH.

January 30, 1974

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION -- Docket Section

Re: Docket No. 1-5 Notice 8 49 CFR 571.106; 38 FR 31302 (November 13, 1973)

PETITION FOR NEW RULEMAKING - FMVSS

Gentlemen:

LUFKIN INDUSTRIES, Trailer Division, is a manufacturer of a variety of on and off-highway trailer equipment. We operate a number of branch offices that sell, service, repair and distribute parts for LUFKIN and other trailers.

We are concerned that FMVSS 106, in its present form, is design restrictive. The law will severely effect our timetable of preparation for FMVSS 121, for the following reasons:

1. Failure to list SAE J1402 type A and B hose as acceptable air brake hose.

2. Failure to list SAE J844 (Nylon Type 3) as acceptable "Chassis plumbing".

According to test data provided by our vendors, J1402 type A and B hose meets FMVSS 106, Paragraph S7. We strongly recommend that you recognize this product as acceptable due to its apparent safety and economy.

We have used J1402 type B for years as plumbing from air valve to brake chamber, and from belly of trailer down to sliding bogey. Repair manager interviews and review of documentation and warranty reports show no failures due to excessive pressure. Only two hose failures have occurred during the past two years. Both resulted from mechanical damage so severe that SAE 100RS, SAE J1402 type D, wire braid hose could not have prevented failure.

The same statements are true concerning SAE J844 (Nylon Type 3) tubing. The tubing's adaptability and workability have simplified complex varieties of air brake "chassis plumbing" on a variety of trailer configurations without sacrificing safety or dependability. We petition that SAE J844 (Nylon Type 3) tubing be accepted as "chassis plumbing" except for delivery lines from air relay valve to brake chambers, trailer-tractor connections, trailer-dolly-trailer connections, and trailer belly to sliding bogey connections.

If SAE J1402 type A and B hose and SAE J844 (Nylon Type 3) tubing are not accepted as brake hose under this law, we, as well as numerous trailer manufacturers, will be faced with unusable hose, tubing and fittings. Because of quantity order requirements necessitated by scarcity, long trailer construction lead times and planning uncertainties generated by FMVSS's 106 and 121, we may be unable to phase-out obsolete material in the time remaining. Additionally, all LUFKIN brake actuation and release timing tests have been conducted on equipment using the type B hose and nylon tubing. Duplication and waste will result if new components are to be introduced now.

We respectfully submit that the final disposition of FMVSS 106 needs immediate resolution. We must finalize drawings, purchase required parts, establish pricing, prepare a firm schedule for phase-out of any unusable parts and complete our shop training program. We need, from you, a finalized FMVSS 106 regulation that will allow us to plan effectively to meet mutual safety and reliability goals.

Yours very truly,

LUFKIN INDUSTRIES, INC.

W. T. Little -- Vice-President General Manager, Lufkin Trailer Division

cc: A. G. Colburn; Joe Bills

ID: nht74-1.14

DATE: 07/03/74

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

TO: Imperial-Eastman Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 2, 1974, questions concerning the labeling of multi-piece end fittings, the use of hose marked with the DOT symbol in non-brake applications, and the acceptability of an end fitting design under the requirements of Standard No. 106, Brake hoses.

The answers to your first two questions will appear in the upcoming notice responding to petitions for reconsideration of amendments to Standard No. 106.

As to the acceptability of a certain end fitting design, the standard specifies performance requirements for end fittings. Any design which meets the specifications of the standard may be manufactured after the effective date of the standard.

Yours truly,

May 2, 1974

Docket Room National Highway Traffic Safety Administration

Ref: FMVSS106, Docket 1-5, Note 10

Gentlemen:

Imperial-Eastman Corporation, a manufacturer of brake hose, couplings, and hose assemblies have a direct interest in FMVSS106, and hereby submit the following comments or requests for interpretations; they are not items for petition.

1. S7.2 Labeling

"Except for two-piece end fittings that are attached by deformation of the fitting about a hose by crimping or swaging, each air brake hose end fitting shall be permanently etched, embossed or stamped, in block capital letters and numerals at least one-sixteenth of an inch high with the DOT labeling information."

We assume that on three-piece air brake hose end fittings which utilize sacrificial sleeves or ferrules, and are considered permanently attached end fittings, that it would be permissible to mark only the coupling nut, with the DOT labeling information.

2. Thermoplastic air brake hose in accordance with SAE J844, Type 3 is currently being used by practically most major truck manufacturers in the United States on original equipment. This hose is normally used to replace copper tubing and/or rubber hose in air brake systems.

This type of thermoplastic hose with air brake hose end fittings is also used for auxiliary lines to windshield wipers, air horns, pressure gages, etc., and for fuel lines.

Fittings and/or fitting components used in these applications may be identical with those used in and marked for air brake applications. Is it permissible for these items to retain the DOT labeling information when used in these other applications?

3. The SAE has a committee which has proposed a fitting performance specification for SAE J844, Type 3, Nylon air brake tubing. One of the types of fittings that meet this performance specification and is currently being used by most major truck manufacturers on air brake systems, consist of a nut, sleeve, tube support and body. The tube support is a brass eyelet, pressed into the body by the coupling manufacturer, which prevents collapse of the tubing. The body is a standard air brake body which meets SAE J246 Standard. For service replacement a loose eyelet and sleeve are provided.

Such fittings are neither described within the DOT Standard, nor specifically excluded from it. Assuming that such fittings are qualified to the DOT test requirements of the standard, and are marked in accordance with the standard, may we then assume they are acceptable?

Sincerely,

IMPERIAL-EASTMAN CORPORATION Imperial Division

Robert C. Gibson Standards and Specifications Engineer

ID: nht74-1.15

DATE: 05/01/74

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

TO: The Mansfield Tire & Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 19, 1974, inquiring whether Motor Vehicle Safety Standard No. 109 permits the labeling of both the 175R13 and the BR78-13 tire size designations on the same tire.

Paragraph S4.3 of Standard No. 109 permits the labeling on the same tire of equivalent inch and metric size designations. Based upon the Tables in the Appendix of Standard No. 109, we would consider the two size designations to be equivalent inch and metric size designations, and both may therefore be labeled on the sidewall of the same tire.

Yours truly,

ATTACH.

Maximum Tire Loads (Pounds) At Various Cold Inflation Pressures Size 16 18 20 22 24 26 28 30 32 34 175R13 790 840 890 930 980 1030 1070 1110 1150 1190 BR78.13 780 840 890 930 980 1030 1070 1110 1150 1190

THE MANSFIELD TIRE & RUBBER COMPANY

March 19, 1974

L. R. Schneider -- Chief Counsel, National Highway Traffic Safety Administration, United States Department of Transportation

Dear Mr. Schneider:

In the Federal Register November 1, 1973, Part III, the Department of Transportation published Passenger Car Tires and Rims Information under MVSS 109. Reviewing Rules and Regulations for Radial Ply Tires, it is noted that under Table I-H for the 175R-13 and under Table I-H for the BR78-13, the loads, inflations, rim, minimum size factor and section width are basically the same. For your observation, we are listing from the Tables both of these sizes as spelled out in these Rules and Regulations.

Maximum Tire Loads (Pounds) At Various Cold Inflation Pressures Test Min.

Rim Size Sect.

Width Fact. Width Size 36 38 40 (In.) (In.) (In.) 175R13 1230 1270 1300 4 1/2 30.30 6.75 BR78.13 1230 1270 1300 4 1/2 30.31 6.75

As these tires are both the same for the American size radial and the millimeter radial, it is our intent to mark both these sizes, as noted in MVSS 109, Part 571, Section S4.3 "Labeling Requirements", on the same tire with the maximum load and inflation branded on the tires. We are intending to use the American size tire code in the tire identification serial.

We will appreciate your reviewing this matter and unless advised to the contrary, we are intending to proceed with the marking as described above. We will appreciate hearing from you at your earliest convenience.

Sincerely,

R. C. Hudson -- Director, Tire Engineering, Tech Service/Quality Control

ID: nht74-1.16

DATE: 07/03/74

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 18, 1974 informing us that Volkswagen of America, Inc. has decided not to initiate a notification campaign as a result of a technical violation of Motor Vehicle Safety Standard No. 110. You ask for our concurrence in your decision.

The designated seating capacity of the Dasher vehicle is 5 (2 in front, 3 in rear) and you have informed us that "some early production cars" bore tire inflation pressure labels stating that the capacity was 4 (2 in front, 2 in rear). The other required information (vehicle capacity weight, tire size designation, and recommended inflation pressures) are, you state, correctly indicated.

We agree with you that "religious observance of the instructions contained on the placard would provide the car with additional load capacity that would go unused", and have concluded that the situation you describe does not indicate the existence of a safety-related defect.

Sincerely,

ATTACH.

VOLKSWAGEN OF AMERICA, INC.

June 18, 1974

Lawrence R. Schneider, Esq. -- Chief Counsel, Office of the Administrator, National Highway Traffic Safety Administration

Dear Mr. Schneider:

This will confirm my phone conversation with Mr. Taylor Vincent concerning the issue of recalling a number of early production Dasher vehicles bearing FMVSS No. 110 labels, which incorrectly state the vehicle's designated seating capacity.

Dasher models are manufactured with and equipped for five (5) seating positions. Inadvertently, some early production cars were fitted with placards required by S4.3 of FMVSS No. 110, which erroneously state the designated seating capacity of the vehicle to be four (4) seats (two (2) front and two (2) rear), when in fact it has five (5) seats (two (2) front and three (3) rear). Sample of a correct label is attached. Vehicle capacity weight, recommended inflation pressures for maximum and half load as well as tire size designations are correctly indicated.

Mr. Vincent suggested that this error probably did not amount to a safety related defect within the meaning of Section 1402 of Volume 15 USCA, as amended, and regulations issued thereunder, because vehicle owners and occupants are not likely to be misled into using the vehicle in a manner that would make it less safe. In fact, religious observance of the instructions contained on the placard would provide the car owner with additional load capacity that would go unused.

Since inconvenience to the owner resulting from a recall would outweigh any benefits to be gained from a corrected label, we believe it would not be in the public interest for us to conduct a notification and recall campaign in this instance.

Your confirmation of our position would be appreciated.

Sincerely,

Cerhard P. Riechel -- Attorney

Enc.

cc: Taylor Vincent

ID: nht74-1.17

DATE: 07/15/74

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

TO: National Campers & Hikers Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 27, 1974, objecting to the use of extension mirrors on automobiles when a trailer is not in tow.

Although we fully appreciate the possible dangers inherent in the use of extension mirrors, this agency has no authority to regulate the use of such equipment. The authority that Congress has conferred upon the National Highway Traffic Safety Administration relates to the safe manufacture of motor vehicles and motor vehicle equipment, and not directly to its use. Therefore, unless some showing can be made that the design of the mirrors is dangerous, we have no authority to deal with the problem you describe.

Your truly,

ATTACH.

June 27, 1974

Lawrence R., Schneider, Chief Counsel -- U.S. Department of Transportation, National Highway Traffic Safety Administration

Dear Mr. Schneider:

As a frequent camper in Michigan's out-of-doors, I am concerned that there are far too many pedestrians being injured and sometimes killed, by the uncontrolled use of extension mirrors on automobiles used for towing travel trailers.

The offending mirrors are the ones which are clamped on the front fenders or doors of automobiles and are easily detached. They extend out to approximately 8 Ft. and are chest high for all adults and head high for children.

These mirrors are not to be confused with permanent standard equipment on trucks and automobiles.

I believe that legislation should be passed that would outlaw extension mirrors on automobiles when a trailer is not being towed.

Sincerely

Lee & Winnie Jones -- District Directors, National Campers & Hikers Assoc.

ID: nht74-1.18

DATE: 05/20/74

FROM: AUTHOR UNAVAILABLE; James B. Gregory; NHTSA

TO: The Japan Automobile Tire Manufacturers' Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 22, 1974, petition to permit the use of the DOT symbol on tires to which no standard applies.

The provisions appearing in the April 3, 1974, Federal Register (39 FR 12104) are amendments to the standard, and your submission is in effect a petition for reconsideration of these changes.

Our reasons for prohibiting the use of the DOT symbol on tires to which no motor vehicle safety standard is applicable are listed in Notice 7. We have found the expense of covering the label to be justified, to avoid confusion in the symbol's meaning and the concept of compliance. We have determined that means are available to securely cover the DOT symbol, or in the alternative, to remove it after the molding process.

For these reasons, your petition is denied.

Sincerely,

ATTACH.

Date: April 22, 1974

Docket Section -- National Highway Traffic Safety Administration

Subject: Petition on Label Covering the DOT Symbol of @ 574.5;

(Docket No. 71-18 Notice 7)

Gentlemen,

The Japan Automobile Tire Manufacturers' Association, on behalf of six tire manufacturers in Japan, hereby submits petition on the subject proposed Standard published in the Federal Register of April 3, 1974.

It is described in the preamble of subject Docket to the effect;

The DOT symbol shall not appear on tires to which no Federal Motor Vehicle Safety Standard is applicable, unless, in the case of tire for which a standard has been issued but which is not yet effective, the symbol is covered by a label that is not easily removable and that states "No Federal Motor Vehicle Safety Standard Applies to This Tire".

As this provision imposes unnecessary burdens on the tire manufacturers and would give very little benefit to the consumer, we would like to request that the NHTSA take following step for the reasons stated below: 1. DOT symbol may be molded into or onto the tires which conform to the final standard of FMVSS #119 even if the tires are manufactured prior to the effective date.

2. And, the tire manufacturers and brand name owners may sell tires without covering the DOT symbol by the label for three months prior to the effective date, in the case of tires for which a standard has been issued but which is not yet effective.

Reasons:

1. We believe that even if we covered the DOT symbol with the label, it could not contribute the safety of the consumer. In addition, there are the following demerits:

1.1 To require the tires which conform to the requirements of FMVSS #119 to have the DOT symbol covered by a label is not only burdensome to the tire manufacturers but also the consumers will ultimately bear the expense of providing labels.

1.2 From our past experience, 5 to 10% of the labels attached to the tire will come off during handling and shipping. Should it fall between the tire and the tube it may cause a flat tire which would involve a possible safety hazard and expose tire manufacturers to a product liability suit.

1.3 In the case of the tire sold as original equipment on a new motor vehicle, each motor vehicle is tested by running check before sending it out, we are afraid that some of the labels may come off before the consumer receives the car.

2. We think it is highly unlikely that any tire manufacturer would produce low quality tires and sell them in this short time before effective date. Some small degree of trust and practicality must exist.

3. We understand the lead time is defined as the period for molding the DOT symbol mark only on tires which conform to the final standard.

We would greatly appreciate your consideration on the above petition.

Very truly yours,

THE JAPAN AUTOMOBILE TIRE MANUFACTURERS' ASSOCIATION, INC.; Keigo Ohgiya, Executive Director

ID: nht74-1.19

DATE: 09/23/74

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

TO: Dexter Axle Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 19, 1974, request to be advised of the steps necessary to acquire a manufacturer code number as required by Standards No. 119, New pneumatic tires for vehicles other than passenger cars, and No. 120, Tire selection and rims for motor vehicles other than passenger cars.

Standard No. 119 applies to tires-only and it is the responsibility of the tire manufacturer to obtain a code number and label it on his products. As a user of tires, you do not have obligations under this standard.

Standard No. 120 is a proposal which applies to rim construction and the selection of the correct rim for the (Illegible Word) equips. As a manufacturer of rims you would have a responsibility to label your products if this proposal becomes an effective regulation. However, we noted in the preamble to that proposal (copy enclosed) that we will not require manufacturer codes until a separate manufacturer code system has been established.

I am also enclosing a copy of the most recent proposal on manufacturer codes.

Yours truly,

ATTACH

August 19, 1974

Docket Section NHTSA

Re: FMVSS 119 and 120

Dear Sir:

Dexter Axle Co. Inc. is a manufacturer of running gear equipment for Mobile Homes and Recreational Vehicles. In our product line are wheels and rims subject to standards 119 and 120.

Please advise on the steps we must take to obtain a manufacturers code number as required.

Thank you.

Very truly yours, DEXTER AXLE COMPANY, INC.; J. A. Brown -- Manager - Engineering Res. & Dev.

ID: nht74-1.2

DATE: 10/25/74

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

TO: Toyota Motor Sales, USA, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

OCT 25 1974 N40-30 (ZTV)

Mr. K. Nakajima Director/General Manager Factory Representative Office Toyota Motor Sales, U.S.A. Inc. 1099 Wall Street, West Lyndhurst, New Jersey 07071

Dear Mr. Nakajima:

This is in reply to your letter of October 18, 1974 to Dr. Gregory asking whether the start position may be designated as the check position required by paragraph S5.3.2 of Standard No. 105-75.

The answer is yes. Any position between "on" and "start", including "on" and "start" may be designated by the manufacturer as a check position.

Yours truly,

Richard B. Dyson Acting Chief Counsel

ID: nht74-1.20

DATE: 07/23/74

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

TO: Toyo Rubber Industry Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 8, 1974, question whether publication of a brochure that lists the rims that may be used with the tires produced by Toyo Tire Corporation would meet the requirements of S5.1 of Standard No. 119, New pneumatic tires for vehicles other than passenger cars.

Publication of such a brochure would meet the requirement of S5.1 so long as the tires are listed in accordance with S5.1(a), that is by manufacturer name or brand name, followed by a listing of rims that may be used with each tire listed. The brochure would have to be supplied to dealers of the manufacturer's tires, to any person upon request, and in duplicate to: Tire Division, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590.

Yours truly,

ATTACH.

National Highway Traffic Safety Administration -- Docket Section

SUBJECT: Federal Motor Vehicle Safety Standard No. 119, S5 Tire and Rim Matching Information

Dear Sir:

FMVSS No. 119 is requiring as follows:

S5 Tire and Rim Matching Information

S5.1 Each manufacturer of tires shall ensure that a listing of the rims that may be used with each tire that he produces is provided to the public in one of the following forms:

(a) Listed by manufacturer name or brand name in a document furnished to dealers of the manufacturer's tires, to any person upon request, and in duplicate to: Tire Division, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590; or

(b) Contained in publications, current at the date of manufacture of the tire or any later date, of at least one of the following organizations:

The Tire and Rim Association.

The European Tyre and Rim Technical Organization.

Japanese Industrial Standards.

Deutsche Industrie Norm.

The Society of Motor Manufacturers & Traders, Ltd.

British Standards Institution.

Scandinavian Tire and Rim Organization.

In case any particular tire and rim matching information is not contained in the publications mentioned in S5.1(b), and since S5.1(a) requires the tire manufacturer to provide a document to the public, we are going to use as a document a brochure which shows the tire and rim combination to be used.

We understand that such a brochure would comply with the requirement of S5.1. Please let us know your opinion as to whether our understanding is correct or not.

Should our understanding be incorrect, please let us know what kind of document we must provide to the public.

Your prompt reply would be greatly appreciated.

Sincerely, Y. Takami -- Technical Representative, TOYO RUBBER INDUSTRY COMPANY, LTD.

ID: nht74-1.21

DATE: 07/08/74

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Lackey, Alexander & Jackson

TITLE: FMVSS INTERPRETATION

TEXT: We are enclosing herewith a copy of new Federal Motor Vehicle Safety Standard No. 119, which becomes effective March 1, 1975, and a copy of a notice of proposed rulemaking regarding a new Federal standard (No. 120) which proposes requirements for tire selection and rims for motor vehicles other than passenger cars.

There are no Federal requirements regarding the tensile strength of tire bead.

We regret we cannot be of further assistance.

Sincerely,

ATTACH.

LAW OFFICE

LACKEY, ALEXANDER & JACKSON

June 15, 1974

United States Department of Transportation -- National Highway Traffic Safety Administration;

Atten: E. T. Driver,

Dear Mr. Driver:

In your letter addressed to the undersigned, you enclosed copies on Standard Regulation Nos. 109, 110, 117, and part of 574. You stated that you were in the process of developing proposed Standards Nos. 119 and 120. If these standards have been completed, I will appreciate your forwarding a copy of the same to me.

I do not intend to impose upon you, but if you have in your rules and regulations any test of the tensile strength of the steel wires forming the bead as defined in 22914, Section 571.109, Standard No. 109, Sub-Section S-3, I would appreciate your also forwarding a copy of same.

I am now prosecuting a case against a manufacturer and find that the bead wire is completely separated. When it was placed upon the rim to be mounted, air was put in the tire to cause it to expand to the rim; and the party mounting the tire lost an eye when the air escaped with great force at the break in the bead into his face.

The defense to this law suit appears to be that the party mounting the tire put too much air in the tire which caused the bead to separate. I have had the tire X-rayed and find a clean break in the steel wires in the bead; but there is no breaking of the fabric or the rubber.

I, therefore, need to know the tensile strength of the wires forming the bead in order to meet my opponents' effort to prove that the steel wires were broken because of excessive inflation of the tire. If you have any regulation as to the required tensile strength of the bead wires, I will appreciate your furnishing me a copy of such regulation or specification.

Your cooperation in this matter is very much appreciated.

Yours very truly,

Joseph L. Lackey