ID: nht68-3.12

DATE: 01/26/68

FROM: AUTHOR UNAVAILABLE; Roger H. Compton: NHTSA

TO: Fire Department, Lynn, Massachusetts

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 12, 1967, you questioned several requirements of Initial Motor Vehicle Safety Standard No. 108 as applied to fire trucks.

Paragraph S3.1.1.3, which permits the installation of additional equipment if it does not impair the effectiveness of the required equipment, will not prohibit the installation of rotary flashing lights on fire trucks. Therefore, a waiver of this clause is not necessary for fire trucks.

Paragraph S3.5 a revised by the latest amendment to Standard No. 108, and issued December 11, 1967, (copy enclosed), permits the flashing of steady-burning lamps for signalling purposes. Therefore, the flashing of side marker and clearance lamps on fire trucks to signify an emergency vehicle will not be prohibited by the requirements of this paragraph.

Standard No. 108 does not require that front identification lamps be located on the roof of the vehicle cab, but only that they be "as near as practicable to(Illegible Word) vertical centerlines." If, however, they are mounted on the upper body structure, "no part of the lamps or mountings may extend below the top of the vehicle's windshield." This mounting flexibility will permit a selective location of identification lamps and rotary warning lamps which will not cause the rotary lamps to blot out the identification lamps. Also to be considered is the effectiveness of the identification lamps when the vehicle is operated on the highway and without illumination of the rotary lamps. Therefore, fire trucks need not be excepted from the requirement for front identification lamps.

Rear identification lamps mounted on the edge of or under the rear step of a fire truck will meet the location requirements as specified in Standard No. 108. Adequate guards or protective shields are available and commonly used on lamps located in these positions. Therefore, fire trucks need not be excepted from the requirement for rear identification lamps.

If you have any further comments or questions on the requirements of Standard No. 108, I hope you will let us know.

ID: nht68-3.13

DATE: 02/09/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Electrographic Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 18, 1967, to Mr. Lowell K. Bridwell, you describe the procedure initiated by you for identifying and marking light hit containers. You ask for our acknowledgement of the procedure. It is not clear from your letter, but we gather that you manufacture truck bodies and ship light kits in a separate box, either to accompany or separate from the truck bodies.

The so-called "lighting Standard," Standard 103 of the initial Federal Motor Vehicle Safety Standards, to entitled "Lamps, Reflective Devices, and Associated Equipment." The standard applies to multipurpose passenger vehicles, trucks, trailers and buses, that are 80 or more inches wide overall, except pole trailers and converter dollies. It is the manufacturer of the completed vehicle who must certify that the vehicle conforms to all applicable Federal motor vehicle safety standards, including Standard No. 103. Unless the manufacturer of the lighting equipment and the completed vehicle are the same, the manufacturer of lighting equipment is not required to certify that such equipment conforms to Standard No. 103. It would seem logical to expect that the manufacturer of the completed vehicle would require from the manufacturer of the lighting equipment some indication that the lighting equipment is in conformity, but that is a matter to be settled between the two persons involved. Thus, while we have no objection to the procedure described in your letter, we do wish to emphasize that it does not relieve the vehicle manufacturer of insuring compliance and certifying to such compliance where appropriate.

Thank you for your interest. If further information is needed, please feel free to contact this office.

ID: nht68-3.14

DATE: 05/24/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 5, 1968, (Reference 61.A218.A1115) addressed to Dr. William Haddon, Jr., concerning the location of clearance lamps on several styles of truck bodies manufactured by the Utility Body Company.

Rear clearance lamps mounted at the top corners of the sleeper cab of the vehicle in Figure 1 of the drawing attached to your letter would not be in conformance with the requirements of Federal Motor Vehicle Safety Standard No. 108. On this same vehicle, the required location of the front clearance lamps is at the top corners of the sleeper cab. The additional set of front clearance lamps on the truck cab would not be required or prohibited by Standard No. 103. Locations of rear clearance lamps on the vehicles shown in Figure 2 and Figure 3 of the drawing are in accordance with the requirements of Standard No. 108.

Our records do not indicate that we have furnished any evidence to the Utility Body Company regarding location of rear clearance lamps as shown in Figure 1. Under their letter of March 11, 1968, this company submitted to us a print of their drawing, which is identical to the drawing enclosed with your letter, and requested our comments on the proposed locations of their lighting equipment. The above information will be furnished to the Utility Body Company in reply to their March 11 letter and should serve as clarification of the requirements of Standard No. 108. This clarification also indicates that no conflict exists between the requirements of Standard No. 108 and the requirements of the California Vehicle Code with respect to location of your clearance lamps.

ID: nht68-3.15

DATE: 05/15/68

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

TO: Mercedes Benz of America, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your telegram of May 3, 1968, concerning the use of tabular-type bulbs to back the requirements of Federal Motor Vehicle Safety Standard No. 108.

Paragraph S3.1 and Tables I and III of Standard No. 108, as amended (32 F.D. 13933, December 10, 1967), specify that certain lamp assemblies such as license plate lamps, backup lamps and tail lamps, shall conform to the basic SAE Standards for the lamp assemblies. These basic standards in turn refer to SAE Standard 7573 on bulbs and to SAE Standard 3567 on bulb sockets. This relationship between the basically referenced standards and subreferenced standards has been the subject of prior communications with the industry and appears to be in need of clarification.

The basically referenced SAE Standards also refer to SAE Standard J575, "Test for Motor Vehicle Lighting Devices and Components." Paragraph "C" of SAE Standard J575 states in part as follows: "Where special bulbs are specified, they should be submitted with the devices and the same or similar bulbs used in the tests and operated at their rated mean epherical candlepower." This provision of SAE Standard J575 permits the use of special bulbs, including tubular-type bulbs, which do not conform to the detailed requirements of Table I of SAE Standard J573. It also follows that the sockets for these special bulbs need not conform to SAE Standard J567. I must emphasize, however, that these provisions for special bulbs in no way except the lamp assemblies from testing all performance requirements specified in Standard No. 108, including those specified in the basically referenced SAE Standards and in subreferences SAE Standard J575.

In view of the several inquiries we have resolved on this particular(Illegible Word) of the requirements of Standard No. 108, we anticipate that an official interpretation, providing the clarification presented in this letter, will be published in the Federal Register in the near future.

Thank you for your continued interest in the Federal Motor Vehicle Safety Standards.

ID: nht68-3.16

DATE: 02/07/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: American Quality Coach Corporation

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of January 8, 1968, to the Federal Highway Administration, requesting regulations relating to motor vehicle safety requirements.

The type of vehicle that you have described appears to be a bus accordingly to the statutory meaning of Part 255.3, Initial Federal Motor Vehicle Safety Standards. Accordingly, Standards 102, 107, 205 and 209 would be applicable to your vehicles manufactured after January 1, 1968. We invite your attention to Section 114 of Public Law 89-563 and the notice of Certification Requirement.

In addition to the existing Federal Motor Vehicle Safety Standards and Public Law 89-563, we are enclosing information concerning proposed rule making that may affect future regulations.

We trust this information will be of assistance to you.

ID: nht68-3.17

DATE: 03/02/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Field Body Company Inc.

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of January 8, 1968, in regard to certification of your product and questions regarding interpretation of the Chassis-Cab regulation.

In regard to your letter furnishing us certification information, what you have provided will be very useful to us; however, in accordance with Section 112 of the National Traffic and Motor Vehicle Safety Act of 1966, it would be appreciated if you would provide us with an actual sample of your certification label and the method of attachment.

Concerning your request for clarification in regard to the extent of responsibility for adherence to applicable safety standards to your type of vehicle, the following should be of assistance:

First, your vehicle, completed, falls into the category defined as a "truck" and as such, must adhere to Safety Standards 102, 107, 108, 205 and 209. We have enclosed a copy of the Federal Register, Volume 32, No. 23, dated February 3, 1967, and several other pertinent amendments.

Regarding extent of responsibility of the chassis-cab body manufacturer, and final assembler of the units into a completed vehicle, these are clarified in Section 2 you refer to in your letter. I assume this is Federal Register Volume 33, No. 1, dated January 3, 1968, "Notice of Ruling regarding Chassis-Cabs," but in case it is not I am enclosing a copy for your reference. This notice defines two main points which I will endeavor to state in a few words as follows:

If the original manufacturer of the chassis, after January 1, 1968, cannot or does not include all the safety standard regulations required for the type of end product or completed assemblage, then the final assembler is responsible to certify that all applicable safety standards are included and the vehicle is so certified and labeled.

Thank you for your interest in the safety program.

ID: nht71-4.38

DATE: 11/02/71

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

TO: American Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your recent telephone inquiry as to whether the recent amendment of Standard 215, Exterior Protection, requires that vehicles meet the photometric requirements of Standard 108 after being subjected to the Standard 215 impacts.

S5.3.1 of Standard 215 reads:

"Each lamp or reflective device, except license plate lamps, shall be free of cracks and shall comply with the applicable requirements of Motor Vehicle Safety Standard No. 108."

S4.3.1.1 of Standard 108 reads in relevant part:

"Each lamp and reflective device shall be located so that it meets the visibility requirements specified in any applicable SAE Standard or Recommended Practice. In addition, no part of the vehicle shall prevent the device from meeting the photometric output at any test point specified in any applicable SAE Standard or Recommended Practice." (Emphasis supplied.)

Thus, although the actual photometric tests may be considered "bench tests", that is, tests whose procedures include removing the devices from the vehicle, the above provision of Standard 108 requires that the configuration of the vehicle external to the devices not prevent them from meeting the photometric requirements. The test procedures themselves require the devices to be placed

in their actual orientation on the vehicle. Therefore, the provision in Standard 215 that the lamps and reflective devices shall meet all the requirements of Standard 108 after the impacts includes the photometric requirements.

ID: nht71-4.39

DATE: 11/03/71

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

TO: Patton; Blow; Virrill; Brand & Boggs

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of October 12, 1971, in which you made several requests with respect to the Tire Identification and Record Keeping (49 CFR Part 574) and Certification (49 CFR Part 567) regulations.

1. You suggested that the Tire Identification and Record Keeping regulation be amended to provide that where tires are not shipped on or in a vehicle, the vehicle manufacturer's record keeping obligation be limited to three years from the date of sale. We will take this request into consideration, and let you know when a decision is made. It appears that since the minimum time would apply to all vehicle manufacturers, such a requirement should appear in a regulation other than Part 574.

2. You requested the deletion of the requirement that information on the certification label be placed "in the order shown." We have previously denied petitions relating to the order of information on the label (36 F.R. 19593), and this request is also denied. The requirement that the label information be placed in a definite order has been in effect for over two years, and has been found to enhance the readability and hence the usefulness of the label. Now that further numerical information is to be required on the label, we consider that it will be even more important that this requirement be maintained.

3. You requested "an interpretation that a multi-column label or a label in two parts each with an information column, will meet the requirements of [Part] 567," because of the space limitations on some trailers. As long as the information appears in the order specified in the regulation, the NHTSA has no objection to a multi-column label or a label in two parts.

4. Finally, you requested that a trailer manufacturer be allowed to use up his existing supply of labels, by affixing a supplementary label with the additional required information. As stated above, we have decided to adhere to the requirement that the information on the label be in the order specified, although it may be in more than one column or part. To the extent that the action requested would allow a manufacturer not to conform to that requirement, the request is denied. Although the deviation might appear small, it would seriously detract from the integrity and enforceability of the regulation to allow incidental nonconformity without amending the requirement. The other vehicle manufacturers have undoubtedly already incurred costs similar to those cited by your client, and it would be distinctly unfair not to enforce the regulation evenhandedly as to all parties.

ID: nht71-4.4

DATE: 08/16/71

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

TO: Truck Equipment & Body Distributor Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 28 requesting a clarification of paragraph S4.3.1.1 of Standard No. 108. This paragraph requires the installation of auxiliary lighting equipment, if the required lighting equipment is prevented from conforming to photometric output and visibility values by motor vehicle equipment such as snow plows, street sweepers, etc. You ask, in essence, whether auxiliary lamps must be provided in two situations: when the motor vehicle equipment is sold with but not attached to the vehicle, and when no equipment is sold with the vehicle but the vehicle is equipped with a hoist upon which equipment may be mounted.

With respect to the first situation, compliance should be determined with the equipment attached which(Illegible Word) the vehicle at the time it is sold. As for the second situation, compliance of a vehicle which is equipped at time of sale with hoists or mounting brackes only, and for which equipment will be provided at a time subsequent to sale, should be determined with the vehicle in its as-sold condition.

ID: nht71-4.40

DATE: 11/05/71

FROM: AUTHOR UNAVAILABLE; C. A. Baker for E. T. Driver; NHTSA

TO: Truck-Lite Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 14, 1971, to Mr. Lewis Owen of this Office concerning an interpretation regarding your Truck-Lite No. 127 License plate light.

The requested interpretation concerns the 8 degree incident light angle specified in SAE J587, "License Plate Lamps," as follows:

"When a single lamp is used to illuminate the plate, the lamp and license plate holder shall bear such relation to each other that at no point on the plate will the incident light make an angle of less than 8 deg to the plane of the plate."

Since the 8 degree incident light angle is also a requirement of Federal Motor Vehicle Safety Standard No. 108, all license plate lamp designs must conform to it. It is our position that the angle be measured from the optical center of the lens; therefore, the Electrical Testing Laboratories' position is valid. That is, the incident light angle of your lamp, without the paint shield and when mounted as it will be installed on the vehicle, is below the 8 degree minimum requirement.