ID: nht67-1.33

DATE: 03/18/67

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Petroleum Equipment Institute

TITLE: FMVSR INTERPRETATION

TEXT: The General Counsel of the Department of Transportation has asked that(Illegible Word) further to your letter of February 13, 1968 to the Department of Transportation.

Enclosed in a copy of the National Traffic and Motor Vehicle Safety Act of 1966, published Federal Motor Vehicle Safety Standards and a regulation and ruling issued December 29, 1967 pertaining to "chassis-cabs" and persons who combine "chassis-cabs" with motor vehicle bodies or other like structures.

Based on the limited information given in your letter it appears that members of your organization who affix a task to a chassis-cab, as defined in(Illegible Word) 5.3(b), will be responsible for "(1) compliance of the combined assemblage with. . .standards in effect in the date of(Illegible Word) of the chassis-cab. . .not already. . .certified to by the chassis-cab manufacturer, and (2) compliance with all applicable standards in effect on the date of manufacture of the chassis-cab to the extent that the addition of a body or other structure to the chassis-cab affects the chassis-cabs previous conformance with applicable standards."

As to the certification requirement, which is set forth in section 114 of the National Traffic and Motor Vehicle Safety Act of 1966 (copy enclosed) and amplified by a notice issued October 31, 1967, ((Illegible Words) than requirement as it relates to your organization members would be limited to a situation where your members combine a chassis-cab which has not been certified to be in conformance with Standard 108 with a body or other like structure and sells the combined assemblage to a distributor or dealer. In this case certification of compliance with the lighting standard (Standard No. 108) would be mandatory.

The Petroleum Equipment Institute(Illegible Word) will be added to the Federal Highway Administrator's Office of Public Affairs mailing list and it will(Illegible Words) published rulings and regulations relating to traffic safety. Additionally, enclosed is a copy of present regulations and rulings published to date.

I hope this letter adequately answers the question you raise.

ID: nht67-1.34

DATE: 12/13/67

FROM: AUTHOR UNAVAILABLE; Z. Taylor Vinson; NHTSA

TO: Metropolitan Cycle Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of December 4 to Mr. Boaz, Public Information Office, Federal Highway Administration, inquiring about the applicability to motorcycles and scooters of the proposed Department of Transportation-Department of the Treasury customs regulations.

The regulations do apply to motorcycles and scooters imported into the United States, but not to similar type vehicles imported into or manufactured in Canada for use in Canada. I am enclosing a copy of the regulations for your information.

ID: nht67-1.4

DATE: 08/22/67

FROM: AUTHOR UNAVAILABLE; William Maddon, Jr., M.D.; NHTSA

TO: The Anderson Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 30, 1967, to Mr. Bridwell concerning windshield wiper parts.

We recognize that it may be difficult to obtain reflectance values from all metal components on the windshield wiper assembly which come into the driver's field of view. For this reason, Motor Vehicle Safety Standard No. 107 includes reflectivity requirements for only the wiper arm and blade. As stated in your letter, the reflectivity of these components may be determined by using flat samples of identical material. Reflectivity requirements for the spring, rivets and other hardware items, which are attached to the wiper arm and blade, are not presently specified in Standard No. 107.

ID: nht67-1.5

DATE: 09/21/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Fire Apparatus Manufacturers Association Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 17, 1967, requesting clarification of several requirements specified in Motor Vehicle Safety Standard No. 108.

In answer to question No. 1 of your letter, the addition of a side mounted ladder would not be considered as an extension of the length of the vehicle.

Question No. 2 concerns the requirement for use of front identification lamps on open-cab fire trucks and trucks equipped with rotating red lights. We agree that the front identification lights might be slightly obscured while the emergency red lights are flashing. However, when these lights are not flashing, the identification lights would clearly identify a vehicle that is more than 80 inches in overall width. Therefore, identification lights will be required on the fire trucks which are depicted on the photographs enclosed with your letter.

With respect to question No. 3 regarding possible locations for rear identification lamps on fire trucks, it should be noted that Standard No. 108 does not specify a height requirement for location of these lamps. Therefore, a possible location for the lamps would be along the edge or under the edge of the rear step. In any event, the problem of providing the lamps does not appear to be a major one.

Question No. 4 relates to possible locations for clearance lamps on the front and rear of fire trucks. Standard No. 108 requires that clearance lamps be mounted as near as practicable to the upper left and right extreme edges of the vehicle. A provision is also included for mounting the rear clearance lamps at an optional height, when the rear identification lamps are mounted at the extreme height of the vehicle. We note from your photographs that (Illegible Word) lamps are normally mounted at approximately the extreme edges of the vehicle. It appears that a similar arrangement could be provided for mounting the clearance lamps.

Thank you for your interest in the motor vehicle safety standards.

Sincerely,

ATTACH.

FIRE APPARATUS MANUFACTURERS ASSOCIATION, INC.

July 17, 1967

George C. Nield, Acting Director -- Motor Vehicle Safety Performance Service, U.S. Department of Transportation

Dear Mr. Nield: The Technical Committee of our Association has reviewed the requirements of "Initial Federal Motor Vehicle Safety Standards, Volume 32, Number 23, Federal Register of February 3, 1967. The following questions have arisen and we request clarification.

1. Standard 108, Par. S3.1.1.2, page 2411. Your paragraph refers to 30 ft. overall length. The industry builds many pumpers that are less than 30 ft. length but occasionally the addition of a side mounted ladder will extend beyond the rear step and will increase the overall length beyond 30 ft. The Pirsch picture 5904 enclosed illustrates a ladder so mounted.

The question is - would this ladder addition be interpreted to mean a length greater than 30 ft.?

2. Standard 108, Par. S3.1.1.3, page 2411. Almost every fire truck will include a rotary type flashing red light and other flashing red lights which of necessity will impair the effectiveness of the front identification lights and would seemingly make (Illegible Word) lights (Illegible Word). Will these three front identification (Illegible Words) on a fire truck? See Pirsch picture 622 enclosed as (Illegible Words) please note Pirsch picture 6124 enclosed showing an (Illegible Words) is commonly used and advise if identification lights (Illegible Words) on this type.

3. Standard 108, page 2411, Trucks I and II. The (Illegible Words) lights do not appear to be (Illegible Word) to fire truck picture 5904, a rear step is included on the average fire truck with (Illegible Word) riding the rear step. As it is readily seen, there is no place for the three identification lights that could possibly be effective. We definitely feel that rear identification lights are not feasible on a fire truck.

4. The side clearance lights are specified to be mounted as near as possible to the upper right and left front edges and the upper right and left rear edges. Our pictures illustrate the problem of the extreme edges and we would like to know where lights should be placed on this type of vehicle.

Very truly yours, E. L. Koepenick -- Secretary-Treasurer

Encls.

ID: nht67-1.6

DATE: 09/12/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Your June 2, 1967, letter contained nine questions concerning several areas of Public Law 89-563 and Motor Vehicle Safety Standard No. 108. Answers to several of these questions are of common interest to many manufacturers and the National Highway Safety Bureau is developing and planning to issue appropriate policies, procedures and rules to guide manufacturers in respect to some of these questions. In the meantime, we are able to reply to questions 5, 7, and 8 of the June 2, 1967, letter and question 9 of the June 2, 1967, letter as amended by the corrected drawings furnished by your letter of July 18, 1967.

Question 5. Section 113 of Public Law 89-563

Will forms be furnished to us to use to notify the first purchaser, dealer, and Secretary of defects we might find? If not, will an example of an acceptable form be available? Will a more detailed procedure be made available on the action required under Section 113? What would be our liability if a component purchased by us and certified to us to be in conformance with the Motor Vehicle Safety Standards was found after manufacture and delivery not to be in conformance?

Answer

The Bureau is studying the requirements for procedures and forms on defect notification. At present a form is being considered for the manufacturers to report defect information to the Secretary. If after further study forms are also considered desirable for the manufacturer to report to his dealers and the purchasers, you will be advised as to what types of forms are acceptable via publication in the Federal Register.

It is not clear what you mean by "liability." If you refer to your obligations under Section III, this section defines the responsibilities of manufacturers in regard to motor vehicles or items of motor vehicle equipment determined not to be in conformance with applicable Federal motor vehicle safety standards. Section III also requires the immediate repurchase of the nonconforming vehicle or item of motor vehicle equipment, or that the required conforming part or parts of equipment be furnished to the dealer or distributor for installation and that financial renumeration be made for incoveniences involved. Additionally, the provisions of Section 108 would apply.

Question 7. Title 23, Section 255.7 Applicability:

"(b) Military vehicles. No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with Contractual specifications.

(c) Export. No standard applies to a vehicle or item of equipment in the circumstance provided in section 108 (b) (5) of the Act (15 U.S.C. 1397) (b) (5)."

We understand that the standard does not apply to military or export vehicles. Will we be allowed to drive on public roads export and/or military buses that do not meet the minimum standards to a port or other destination? If not, what will we have to do to them so that they can be driven on public roads?

Answer

Motor vehicles intended solely for military or for export use are specifically excluded from compliance with Federal motor vehicle standards, and therefore not subject to the provisions of the Act.

Question 8. Standard No. 108 S3.4.3

"Taillamps, license plate lamps, and side marker lamps shall be illuminated when the headlamps are illuminated."

This standard does not mention parking lamps. We would then assume that the parking lamps may or may not be illuminated when the headlamps are illuminated at our discretion or the chassis manufacturer's discretion. Is this correct?

Answer

The parking lamps may or may not be illuminated when the headlamps are illuminated.

Question 9. Standard No. 103 Table II Location of Equipment

These prints show the location of lamps and reflex reflectors we plan to supply to comply with Standard 108 Table II. Are these locations in compliance? If not, please mark one each of the prints with acceptable locations and return them to us.

Answer

The location of lamps and reflectors, as shown on the drawings dated July 17, 1967, appear to be acceptable.

Questions 1, 2, and 6 relate to the subject of "Incomplete vehicles" and questions 3 and 4 relate to labeling and record-keeping. We are currently working on the entire area relating to these other questions and you will be furnished with detailed answers as soon as possible.

Sincerely,

ATTACH.

June 2, 1967

George C. Nield -- Acting Director, Motor Vehicle Safety Performance Service, U. S. Department of Transportation

Dear Mr. Nield: Listed below are several areas of Public Law 89-563 and the Motor Vehicle Safety Standards that we are concerned about and need rulings and/or clarification. If at all possible, we need this information by June 12, 1967.

1. Section 108 of Public Law 89-563

It is quite possible that there might be new chassis at our plant January 1, 1968, to have new bodies mounted on them that do not meet the Motor Vehicle Safety Standards. Will we be able to mount bodies on these? From time to time it is a couple of months after a chassis arrives before a body is mounted on it. They also sometimes sit in our field for long periods of time finished before the end customer comes for them or arranges for delivery. I believe you can appreciate the situation we could find ourselves in if we are unable to mount or deliver chassis after January 1, 1968, that were received prior to January 1, 1968. Could we have your comments and a ruling on this?

2. Section 108 of Public Law 89-563 Paragraph (a) (1)

Will replacement parts for buses built prior to January 1, 1968, have to meet applicable Motor Vehicle Safety Standards? In some cases the conforming parts might not fit or work without a lot of rework, etc.

3. Section 108 of Public Law 89-563 (b) (5)

In what manner should we label or tag motor vehicles or items of motor vehicle equipment intended solely for export? Do you have examples or acceptable forms for this?

4. Section 112 of Public Law 89-563

What records, reports, technical data, performance data, and other information are we required to establish and maintain? Will we be required to give notification of performance and technical data to the Secretary and/or to the original purchaser? What will we be expected to do to satisfy this law?

Will we be able to have inspectors designated by the Secretary come here prior to January 1, 1968, to be sure we are in compliance with all applicable Safety Standards if we feel the need?

5. Section 113 of Public Law 89-563

Will forms be furnished to us to use to notify the first purchaser, dealer, and Secretary of defects we might find? If not, will an example of an acceptable form be available? Will a more detailed procedure be made available on the action required under Section 113? What would be our liability if a component purchased by us and certified to us to be in conformance with the Motor Vehicle Safety Standards was found after manufacture and delivery not to be in conformance?

6. Section 114 of Public Law 89-563

We mount bodies on three types of chassis. We build the Blue Bird Forward Control Chassis. The Conventional and Pusher Chassis are built by others, and we mount bus bodies we manufacture on them. It seems logical to me that the chassis manufacturer should certify the chassis by label or tag as stated in the law. Is this correct? We would then be required to certify what? The bus body or the complete vehicle? I don't see how we could certify items such as those cited in Standard No. 102 which we would not alter in any way or some of the equipment in Standard No. 108 that comes in on the chassis that we would not bother such as headlamps. What should the certification tag or label say? Do you have forms or acceptable examples for this?

7. Title 23, Section 255.7 Applicability:

"(b) Military vehicles. No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications.

(c) Export. No standard applies to a vehicle or item of equipment in the circumstances provided in section 108 (b) (5) of the Act (15 U.S.C. 1397 (b) (5)."

We understand that the standard does not apply to military or export vehicles. Will we be allowed to drive on public roads export and/or military buses that do not meet the minimum standards to a port or other destination? If not, what will we have to do to them so that they can be driven on public roads?

8. Standard No. 108 S3.4.3: "Taillamps, license plate lamps, and side marker lamps shall be illuminated when the headlamps are illuminated."

This standard does not mention parking lamps. We would then assume that the parking lamps may or may not be illuminated when the headlamps are illuminated at our discretion or the chassis manufacturer's discretion. Is this correct?

9. Standard No. 108 Table II Location of Equipment

Enclosed are two prints of

34754 Layout, Lamps and Reflex Reflector Locations, 1968 Model, 74" Headroom Conventional Bus

34755 Layout, Lamps and Reflex Reflector Locations, 1968 Model, 77" Headroom Conventional Bus

34756 Layout, Lamps and Reflex Reflector Locations, 1968 Model, 74" Headroom All American and Pusher Bus

34757 Layout, Lamps and Reflex Reflector Locations, 1968 Model, 77" Headroom All American and Pusher Bus

These prints show the location of lamps and reflex reflectors we plan to supply to comply with Standard 108 Table II. Are these locations in compliance? If not, please mark one each of the prints with acceptable locations and return them to us.

We certainly appreciate your help and consideration on these matters.

Sincerely, David A. Phelps, Jr. Engineering Services

Enclosures

ID: nht67-1.7

DATE: 12/27/67

FROM: AUTHOR UNAVAILABLE; Howard A. Heffron; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: The Federal Highway Administrator has asked me to reply to your letter of November 24, 1967, in which you asked whether tow cars (as defined in the California Vehicle Code), "emergency vehicles, and other specially designed vehicles" come within the coverage of Motor Vehicle Safety Standard No. 108.

Standard No. 108 prescribes requirements for lamps, reflective devices, and associated equipment. It applies, by its terms, to "trucks . . . that are 80 or more inches overall." As you point out, the term "truck" is broadly defined in Subpart A of the Standards and includes any "motor vehicle with motive power . . . designed primarily for transportation of property or special purpose equipment." There is nothing in the definition, nor is there any other reason, to exclude vehicles designed to tow or otherwise assist other disabled vehicles from the coverage of the Standard. Moreover, paragraph S3.4.4.2 of Standard No. 108 provides that "stoplamps on a towing vehicle need not be actuated when service brakes are applied to the towed vehicle or vehicles only." The adoption of specific requirements pertaining to vehicles being towed would indicate that no exclusion for tow cars or tow trucks was intended.

We conclude, therefore, that tow trucks and tow cars that are 80 or more inches wide overall must comply with the provisions of Standard No. 108. That Standard applies to vehicles manufactured on or after January 1, 1968. State standards, if any, would continue to apply to tow cars or trucks manufactured prior to that date. I also wish to point out that, by a formal interpretation (published at 32 F.S. 8803), the term "overall width" in Standard No. 108 has been deamed to refer to "the nominal design dimension of the widest part of the vehicle, exclusive of signal lamps, market lamps, outside rearview mirrors, flexible fender extensions, and mud flaps. . . ." We are presently considering an amendment which would extend Standard No. 108 to trucks having a width of less than 80 inches, but the Standard in its prevent form is limited to the larger trucks.

In your letter, you refer to "emergency vehicles" and "special purpose vehicles" and ask whether such vehicles are covered by Standard No. 108. Since you did not further describe the vehicles you had in mind, we cannot tell whether they are of a type which must meet the requirements of the Standard. Since you mention the possibility that some of these vehicles may be deemed "truck tractors," we wish to call your attention to the fact that Standard No. 108, by its terms, does not apply to truck tractors.

If we can be of further assistance to you, please do not hesitate to call upon us.

Sincerely,

ATTACH.

DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

November 24, 1967

Lowell K. Bridwell -- Federal Highway Administrator, U.S. Department of Transportation

Dear Mr. Bridwell:

A question has arisen concerning the application of Federal Motor Vehicle Safety Standard No. 108 issued January 31, 1967, to tow cars.

A "tow car" is defined in the California Vehicle Code as "a motor vehicle which has been altered or designed and equipped for and exclusively used in the business of towing vehicles by means of a crane, hoist, tow bar, tow line, or dolly or is otherwise exclusively used to render assistance to other vehicles."

Although the definitions for "truck" and "truck tractor" included in Subpart A of Initial Motor Vehicle Safety Standards are broad, there appears to be a number of special purpose vehicles such as tow cars, emergency vehicles, and other specially designed vehicles which may not be included.

Will you please clarify for us the definition of "truck" and "truck tractor" with relation to the above special purpose vehicles.

Very truly yours,

H. W. SULLIVAN -- Commissioner

ID: nht67-1.8

DATE: 09/21/67

FROM: William Haddon, Jr., M.D.; NHTSA

TO: Kurzman & Goldfarb

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 29 requesting a verification of the interpretation of Standard No. 205 contained in a letter to you dated August 10 from Max Brand of Mercedes-Benz of North America.

Mr. Brands's understanding that glazing materials manufactured on or after January 1, 1968, for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses must conform to Standard No. 205, but that dealer inventories of prestandard materials manufactured before January 1, 1968, may be used for replacement purposes until exhausted is correct.

ID: nht68-1.1

DATE: 05/29/68

FROM: AUTHOR UNAVAILABLE; R. M. O'Mahoney; NHTSA

TO: Royal Brass, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 26, 1968, concerning certification of brake hoses. Hydraulic brake hose for use in passenger cars and multipurpose passenger vehicles manufactured after January 1 1968 must comply with Federal Motor Vehicle Safety Standard No. 106. Hydraulic Brake Hoses - Passenger Cars and Mutipurpose Passenger Vehicles.

At the time of delivery of the completed brake hose assembly to a distributor or dealer the manufacturer of the completed brake hose assembly must certify that it complies with the applicable standard. In the case of equipment such as the brake hose assembly the certification may be in the form of a label or tag on the completed brake hose assembly or on the outside of the container in which the brake hose assembly is delivered.

For your information I have enclosed a copy of the Federal Motor Vehicle Safety Standards, the notice published in the Federal Register concerning certification and a copy of the National Traffic and Motor Vehicle Safety Act of 1966. Particular attention should be paid to sections 108 and 114 of the Act.

I hope this letter and the enclosures are adequately responsive to your questions.

Sincerely,

April 26, 1968

U.S. Department of Transportation Federal Highway Administration

Attn: Robert M. O'Mahoney

Gentlemen:

We are manufacturer and distributor of automotive brass fittings, steel hydraulic fittings, hydraulic brake fittings, hydraulic brake hose assemblies, and make equipment for the assembly of hydraulic hoses and hydraulic brake hoses. The bulk brake hose is purchased from Inland Rubber Division of General Motors. All of our fittings are made to SAE specifications as shown in the SAE Handbook. What type of certification must we give to our customers? We sell to original equipment manufacturers, trucking companies, jobbers, and garages.

An early reply will be appreciated.

Very truly yours,

ROYAL BRASS, INC. -- R. R. McLain

Sales Manager

ID: nht68-1.10

DATE: 04/11/68

FROM: AUTHOR UNAVAILABLE; William Hadden, Jr.; NHTSA

TO: House of Representatives

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 16, 1968, in reference to an inquiry from Mitts and Merrill, Incorporated, concerning the application of the Federal Motor Vehicle Safety Standards to their brush chipper.

The brush chippers as shown in the brochures you enclosed are less than 80 inches in width; therefore, Motor Vehicle Safety Standard No. 108 does not apply at present. However, after January 1, 1968, Table No. III of Motor Vehicle Safety Standard No. 108, will apply to passenger cars, multi-purpose passenger vehicles, trucks, buses, trailers and motorcycles.

We are enclosing a copy of the Federal Motor Vehicle Safety Standards as per your request and trust they assist you in this matter.

Sincerely,

mitts & merrill, inc.

March 14, 1968

Honorable James Harvey, M. C.

Sir:

REFERENCE: Your Letter of March 6 and Wire of March 11 1968

We have studied the Motor Vehicle Safety Act of 1966 and also reviewed your wire.

With regard to the above Act, the Federal Safety Standards were not sent with it. The establishment of these standards is stated in the Act under Title I, Section 103, paragraph (h) concerning issuance of Federal Safety Standards and subsequent revised standards. Please have copies of these standards sent(Illegible Word) immediately or advise at once where we may obtain same. We must know if our Brush Chipper falls under this Act.

Concerning your wire, enclosed are two copies each of our specification sheets and outline drawings of our Brush Chipper. You will note that no models are over 80" wide which will not bring them under the trailer lighting standards. Our units do require license plates.

Thank you for your efforts in our behalf.

Very truly yours,

Norman E. Hess -- Chief Engineer

enclosures

MITTS & MERRILL CHIPPER SPECIFICATIONS

MODELS -- M7, M8, M9

TRAILER UNITS -- SERIES 160 (16 INCHES) TRAILER: Frame All tubular steel, welded construction. Draw Bar Pintle eye-standard. Ball and socket-optional. Axle Coil spring torsion type, 2" O.D., tubular construction - 61-1/2" track. Wheels Two (2) - Semi-drop center. Tires Two (2) - 15" 8-ply rated - commercial Fenders Two (2) Safety Chains Standard. Parking Wheel Screw action to raise and lower. Rear Stand Folding type.

Combination tail light and license plate holder furnished.

CHIPPING UNIT: Housing Steel Plate, welded construction. Feed Opening 10" x 16" Cutting Bar 7/8" x 2-7/8" x 16-1/2" - Special steel and heat-treated. Dia. of Cylinder 16" Length of Cylinder 16" Cylinder Material Flame cut steel plate. Dia. of Shaft 3" Bearings Two (2) 2-15/16" Dia., single row, piloted and flange mounted. R.P.M. of Cylinder 3000 Number of Knives Twelve (12) Knife Dimensions 4-1/4" x 2-3/8" x 1/2" Type of Knife Double-edged, special knife steel, heat- treated, and with positive lock arrangement.

Cylinder is dynamically and statically balanced. Flywheel and auxiliary blower not required.

POWER UNIT:

Ford Industrial Engines-Standard. Available in the following models:

Model "300", 6-cylinder. 149 B.H.P. with either torque converter, or heavy-duty springloaded type clutch. Engine is calibrated at 2800 RPM.

Model "330", 8-cylinder, 155 B.H.P. with heavy-duty springloaded type clutch. Engine is calibrated at 2800 RPM.

EQUIPMENT-STANDARD WITH ALL MODELS:

Swing-away Feed Chute. Telescoping discharge chute with deflector bonnet, adjustable for height, with 360 degrees rotation for complete control for discharging right, left, or into a truck. Hinged Cover for easy access to cylinder. Matched set of high capacity "V"-Belts. Covered Battery Box. Tool box containing Knife Wrench, Sharpening Stone, Grease Gun and Operating Manual. Mechanical Governor. Paint - Color (customer option) either highway yellow Kem-Lustral F65YQ317, orange Kem-Lustral F65E1, or green Kem-Lustral F65G7.

WEIGHTS - (APPROXIMATED): M & M MODEL NO. POWER UNIT & DRIVE WEIGHT M-7 "300" with Clutch 3675 lbs.

M-8 "300" with Torque 3725 lbs.

M-9 "330" with Clutch 3825 lbs.

OPTIONAL EQUIPMENT: Tachometer Directional Signals Brakes Solenoid Throttle Control Engine Hour Meter Flashing Warning Light Engine Side Panels Fuel Gauge

WARRANTY

Machine & Parts -- 1 year

Service -- Ninety Days

Purchased Parts -- Subject to Original Manufacturer's Warranty.

The Company reserves the right to change the list price of its products without notice. It shall have the right to discontinue the manufacture of any model or type of product, and change design or add improvements at any time without incurring any obligation to install the same on M & M products previously purchased.

For further information, contact your nearest M & M Chipper Dealer, or contact the factory direct.

MITTS & MERRILL will engineer units to suit your needs and requirements.

168 BC-12

MITTS & MERRILL CHIPPER SPECIFICATIONS

MODELS M2, M3, M4, M11, M12, M13

TRAILER UNITS -- SERIES 120 (12 INCHES)

TRAILER: Frame All tubular steel, welded construction. Draw Bar Pintle eye-standard. Ball and socket-optional. Axle Coil spring torsion type, 2" O.D., tubular construction - 61-1/2" track. Wheels Two (2) - Semi-drop center. Tires Two (2) - 15" 8-ply rated - commercial Fenders Two (2) Safety Chains Standard. Parking Wheel Screw action to raise and lower. Rear Stand Folding type.

Combination tail light and license plate holder furnished.

CHIPPING UNIT: Housing Steel plate, welded construction. Feed Opening 10" x 12" Cutting Bar 7/8" x 2-7/8" x 12-1/2" -- Special steel and heat-treated. Dia. of Cylinder 16" Length of Cylinder 12" Cylinder Material Flame cut steel plate. Dia. of Shaft 3" Bearings Two (2) 2-11/16" Dia., single row, piloted and flange mounted. R.P.M. of Cylinder 3000 Number of Knives Nine (9) Knife Dimensions 4-1/4" x 2-3/8" x 1/2" Type of Knife Double-edged, special knife steel, heat- treated, and with positive lock arrangement.

Cylinder is dynamically and statically balanced. Flywheel and auxiliary blower not required.

POWER UNIT:

Ford Industrial Engines-Standard. Available in the following models:

Model "172", 4-cylinder, 59 B.H.P. with torque converter. Engine is calibrated at 2500 RPM.

Model "240", 6-cylinder, 124 B.H.P. with either torque converter, or heavy-duty springloaded type clutch. Engine is calibrated at 2800 RPM.

Model "300", 6-cylinder, 149 B.H.P. with either torque converter, or heavy-duty springloaded type clutch. Engine is calibrated at 2800 RPM.

Model "330", 8-cylinder, 155 B.H.P. with heavy-duty springloaded type clutch. Engine is calibrated at 2800 RPM.

(Graphics omitted) Mitts & Merrill Brush Chipper

engineered for years of maintenance-free service

improved to do all jobs(Illegible Words)

[] telescoping discharge chute

The new telescoping discharge chute gives the operator maximum flexibility in getting jobs done easier and in less time. The chute is adjustable to various heights, and rotatable . . . a combination that means dump boxes can be filled quickly from corner to corner with minimum spill. An adjustable bonnet at the end of the chute also permits discharge to either side, or forward, providing complete freedom in cases such as road right-of-way maintenance where chips may be left on the ground.

[] swing-away feed chute

Knife removal and throat bar adjustments are made relatively easy by the swing-away feed chute. The cutting cylinder is completely exposed when the chute is moved to the side and the hinged cover is lifted. These two features are exclusive with Mitts & Merrill Brush Chippers.

[] staggered knife pattern

The staggered knife pattern, found only on Mitts & Merrill Brush Chippers, provides more cuts per revolution. This results in smoother, more efficient cutting action that reduces material by shaving action rather than the conventional chopping motion. The double-edged knives are securely held in place by a wedge-lock which can be easily disengaged for knife reversal.

[] More outstanding features

Safety-lock pin

The double-edged knives have a positive safety locking pin between the wedge block and the special tool steel knife. This safety feature prevents throw-out of knives not properly tightened.

Easy loading

The feed chute is low to the ground and designed to permit wide-angle loading of brush and free limbs. No pushing is required . . . the cylinder draws the material into the cutting chamber quickly and safely.

All-steel cylinder

The solid steel plate cylinder is supported by a heavy-duty flange mounted ball bearing assembly. The cylinder, rotating in an all-steel welded cutting chamber, has a built-in flywheel and blower arrangement, eliminating the need for any optional equipment for blowing material into the discharge chute.

Excellent roadability

The low profile, strong tubular frame and torsion spring axle assure better roadability over any type of terrain. The certified 100-pound weight at the trailer hitch reduces wear and tear on towing vehicle and adds to the over-all strength and rigidity of the equipment.

Over 70 years of experience . . .

Mitts & Merrill has over 70 years of experience in producing and improving wood reduction machinery. The equipment offered today by Mitts & Merrill is the highest quality, best performing . . . first choice of municipalities, public utilities, highway departments, tree surgeons and others who seek economy in equipment operation through many years of maintenance-free service. The Mitts & Merrill Brush Chipper is the standard by which all brush chippers are judged. You buy it with confidence.

TRAILER UNITS -- SERIES 120 (12 INCH) Total Approximate Pounds Shipping Model Engine Drive Chipping Capacity Weight M-2 Ford "172" Torque Converter Up to 6" Dia. Logs 3350 M-3 Ford "240" Clutch Up to 6" Dia. Logs 3480 M-4 Ford "240" Torque Converter Up to 6" Dia. Logs 3530 M-11 Ford "300" Clutch Up to 8" Dia. Logs 3500 M-12 Ford "300" Torque Converter Up to 8" Dia. Logs 3550 M-13 Ford "330" V8 Clutch Up to 8" Dia. Logs 3675

TRAILER UNITS -- SERIES 160 (16 INCH) Total Approximate Pounds Shipping Model Engine Drive Chipping Capacity Weight M-6 Ford "240" Torque Converter Up to 6" Dia. Logs 3700 M-7 Ford "300" Clutch Up to 8" Dia. Logs 3675 M-8 Ford "300" Torque Converter Up to 8" Dia. Logs 3725 M-9 Ford "330" V8 Clutch Up to 8" Dia. Logs 3825

All trailers are equipped with tires, fenders, taillight, license plate holder, rear support jack, covered tool box, covered battery box, choice of ball or pintle eye hitch on telescopic draw bar, and adjustable front landing wheel. Machines are painted with prime coating plus hi-gloss enamel with color choice optional.

WARRANTY

Parts -- One year; Service Adjustments -- 90 days: Purchased parts are subject to original manufacturers guarantees.

Mitts & Merrill reserves the right to discontinue the manufacturer of any model, to redesign and to add improvements to existing models without incurring any obligation to install same on products previously furnished.

. . . then note how many features are exclusive with Mitts & Merrill Brush Chippers Mitts & Merrill General Brush Chipper Specifications Specifications Trailer frame All tubular steel, welded construction Suspension * Coil spring, torsion type Feed chute * Swing-away type Cutting chamber cover Hinged type Cylinder * 16-inch diameter, dynamically balanced with staggered knife design Cylinder material Flame cut steel plate RPM of cylinder 2,800 to 3,000 Type of knife * Self-adjusting, double-edged, positive-lock type Diameter of shaft 3 inches Feed opening * 10-inch by 12-inch, or 10-inch by 16-inch Bearings 2-15/16 inch diameter, single row, piloted and flange mounted Flywheel * Unnecessary Power Ford 172, 240, 300 or 330 cubic-inch displacement Drive * Torque converter or clutch Blower Standard equipment

ID: nht68-1.11

DATE: 09/27/68

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Blaw-Knox Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 11, 1968, in which you provided certification information.

With reference to the Service Bulletin dated "4-10-68" in the second paragraph you state that mixer units mounted at the factory will display a "Certification of Compliance" plate. Blaw-Knox, when it is the party mounting a mixed to a chassis-cab, must insure compliance with Federal Standard No. 108 in effect on the date of manufacture of the chassis-cab, but it is required to furnish certification only when the completed vehicle is being shipped to a dealer or distributor for sale to the ultimate purchaser. No certification is required when such a purchaser brings a chassis-cab to the factory for mixer installation. With reference to the third paragraph, it is not necessary for you to supply a certification plate for mixer equipment, which is shipped from the factory for mounting elsewhere. Compliance with Federal Standard No. 108 is the responsibility of the party who mounts the mixer to the chassis-cab.

Since the chassis-cab manufacturer will have provided serial number information sufficient to determine the requirements of Standards No. 108 in effect on the date of manufacturer of the chassis-cab, it is not necessary to include the mixer serial number on the certification plate. We would suggest that you may comply with the certification plate. We would suggest that you may comply with te certification requirements of Section 114 of the Act when you deliver the completed vehicle to a dealer or distributor for sale to the ultimate purchaser by wording your certification as follows:

"Blaw-Knox Company certifies to the distributor or dealer that it has mounted the mixer unit to the chassis and that the completed vehicle conforms with Federal Motor Vehicle Safety Standard No. 108."

A notice of proposed rule making which will result in more specific requirements with reference to certification will be published in the Federal Register in the near future. A copy of the notice will be sent Blaw-Knox.

Sincerely,

July 11, 1968

U.S. Department of Transportation Federal Highway Administration National Highway Safety Bureau

Attention: Joseph R. O'Gorman -- Acting Director, Office of Performance Analysis Motor Vehicle Safety Performance Service

Subject: Motor Vehicle Safety Standard No. 108

Gentlemen:

The following information is being sent to you at the direction of Mr. David A. Fay, Office of Standards on Accident Avoidance, Motor Vehicle Safety Performance Service, per his letter of June 27th, 1968 (copy enclosed).

Mr. Fay's letter was in answer to the writer's letter of May 6th (copy enclosed) requesting approval of the method being used by Blaw-Knox Company in order to comply with the certification requirements of Motor Vehicle Safety Standard 108. Mr. Fay indicated that the following additional information would be required.

1. The location on the vehicle at which the certification label or tag will be placed: This location is indicated on Blaw-Knox drawing C-8450-911 (enclosed).

2. Actual sample certification tag: Enclosed

3. The means by which the certification tag will be attached: Also indicated on drawing C-8450-911.

Should any additional information be required please write or call Blaw-Knox Company, Construction Equipment Division, Mattoon, Illinois.

Very truly yours,

BLAW-KNOX COMPANY

Construction Equipment Division --

J. M. Wright,

Assistant Sales Manager

Enclosures