ID: nht73-5.12

DATE: 09/25/73

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

TO: Crown Coach Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 28, 1973, concerning the effective date of Motor Vehicle Safety Standard No. 121. Your direct question is whether the effective date is the starting or completion date for the vehicle's components or the starting date for the vehicle.

Standard No. 121 applies to the vehicle and its effective date therefore relates to the vehicle, rather than to any of its components. A vehicle completed after the effective date will have to meet the standard, even though it is equipped with a foundation brake system that was manufactured before the effective date.

The vehicle's completion date, rather than its starting date, is the date that determines whether it must conform to the standard. If your company manufactures its vehicles from the ground up, rather than installing a body on a vehicle built by another manufacturer, the relevant completion date is the date you complete your manufacturing operation. However, if you buy an incomplete vehicle, as defined in our regulation on vehicles manufactured in two or more stages (49 CFR Part 568), and complete that vehicle, you may choose as the completion date for purposes of Standard No. 121 the date on which the manufacturer of the incomplete vehicle finished his work, the date on which you completed the vehicle or any date in between.

ENC.

ID: nht73-5.13

DATE: 09/25/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Taylor Machine Works

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 6, 1973, in which you ask whether a sample certification label you enclosed will conform to NHTSA Certification regulations (49 CFR Part 567). We assume from the weight ratings specified in the sample that the trailer is a semitrailer.

As we indicated to you in our letter of June 26, 1973, the regulations do not provide for the listing of inflation pressure with the tire size designation, and the inflation pressure you have included should not appear in its present location on the label. You may, if you wish, include it following all the required information.

Apart from this item, a label similar to that you have submitted, affixed in both an appropriate manner and location, will conform to Part 567.

We are happy to have been of assistance.

ID: nht73-5.14

DATE: 09/17/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Toyota Motors Sales, U.S.A., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 24, 1973, concerning Toyota's use of a clip to prevent the shoulder belt from rubbing the occupant's neck. Your questions are (1) whether a clip of this type is permitted by Standard No. 208 and (2) whether the clip would be considered a part of the anchorage under Standard No. 210.

Your description of the clip indicates that it does not restrict the free travel of the webbing. The clip would therefore not inhibit the ability of the belt to adjust automatically to fit the occupant, as required by S7.1.1 of Standard No. 208. It is our opinion that such a clip is permitted by Standard No. 208.

We have also concluded that a plastic guide clip designed so as not to affect the basic geometry of the belt during a crash is not a seat belt anchorage for purposes of Standard No. 210. The clip you describe would therefore not be required to meet the strength of location requirements of that Standard.

TOYOTA MOTOR SALES, U.S.A., INC.

August 24, 1973

Dr. James B. Gregory, Administrator National Highway Traffic Safety Adm.

For the purpose of encouraging our customers to use the seatbelt system, Toyota has been striving to minimize the possible discomfort or irritation which they may experience when wearing the upper torso belts, and we have developed a clip which is attached to the upper portion of the seat back as shown in the enclosed photo.

This clip is used to prevent the shoulder harness from contacting the occupant's neck and does not affect the retractive movement of the seatbelt shoulder harness. This clip, which is made of plastic, is designed so as not to hinder the performance of the seatbelt system during an accident.

Toyota believes the above-mentioned clip meets the intent of FMVSS No. 208 and the requirements of paragraph @ 7.1.1 of that standard. Toyota does not consider a clip of this nature to be an anchorage to which the requirements of FMVSS No. 210 apply.

As soon as we receive your favorable reply regarding this interpretation, we would like to install the clip on some of our models to improve the comfort of the seatbelt system.

Your prompt response to this matter would be greatly appreciated.

Keitaro Nakajima Director/General Manager Factory Representative Office

Attachment

(Graphics omitted)

ID: nht73-5.15

DATE: 05/18/73

FROM: AUTHOR UNAVAILABLE; James E. Wilson; NHTSA

TO: Hon. M. J. Rinaldo - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 30, 1973, concerning the requirement of Motor Vehicle Safety Standard No. 121, Air brake systems, that air-braked vehicles be capable of stopping in a specified distance without locking their wheels.

Standard No. 121 was originally proposed in notices of proposed rulemaking published June 25 and 26, 1970. A public meeting was held on October 20, 1970, at which representatives from all interested members of industry and government reviewed the proposal. The standard was issued as a final rule on February 27, 1971, with an effective date of September 1, 1974. Following issuance of the rule, a number of petitions for administrative reconsideration were received, and after lengthy consideration of these petitions the agency responded by amending the standard in a notice published February 24, 1972. This amendment also prompted petitions for reconsideration, which were answered by further amendments on June 24, 1972. The standard has not been further amended since that time.

The antilock requirement to which you refer was a feature of the initial proposal and has remained, with minor adjustments, in all succeeding versions of the standard. it is the third of three performance criteria that a truck or bus must meet in a stop under actual road conditions. The first requirement is that the vehicle must be capable of stopping in specified distances from 60 mph and 20 mph on high and low friction surfaces. The second requirement is that the

2 stops must be made without leaving a straight 12-foot wide lane. The third is that the vehicle must stop without lockup of any wheel at speeds over 10 mph, except for lockup of a wheel controlled by an antilock system.

The aim of each of these requirements is reasonably clear. The stopping distances specified represent a significant improvement in the stopping capability of most air-braked vehicles. The stay-in-the-lane requirement is an important measure of brake balance. The antilock requirement is intended to upgrade the maneuverability of air-braked vehicles in nonlinear braking situations, where locked wheels would result in a partial or complete loss of directional control.

It should be noted that the standard does not require an "antilock system". It requires that a vehicle be capable of stopping without lockup, but it does not require a specific system to accomplish this result. As a practical matter, most manufacturers appear to have chosen antilock systems as the means of meeting the standard, although consideration has been given to other systems such as proportional braking systems in some vehicle applications.

A good deal of attention was focused on the antilock requirements during the rule making process. The agency's conclusion was that, if controlled braking was to remain as a goal of the standard, there was no satisfactory means to achieve this goal except by preventing the wheels from locking. Having chosen to require antilock braking, the agency cannot amend the requirement except through a full rulemaking procedure. If presented with a petition for rulemaking that appeared to have merit, the agency would propose the amendment by issuing a notice in the Federal Register. It would then allow time for public comment before deciding whether to adopt the proposed amendment. At this time we have no petitions under consideration on the subject of antilock braking.

In the rulemaking process followed to develop Standard No. 121, as well as in any rule making to amend it, the other Federal agencies are invited to participate on the same basis as other interested persons. We do not

3 routinely follow special procedures with other Federal agencies, except for the Bureau of Motor Carrier Safety, whose regulations interact closely with ours. As a matter of record, no Federal agency other than BMCS submitted comments during the rule making on Standard No. 121.

The(Illegible Word) has limited research funds and has, partly for that reason, conducted very few tests of specific product designs. The agency is directed under the terms of its legislative authority to issue performance standards, rather than design standards, and such testing as it has done relates to the feasibility of achieving a certain level of performance rather than to the characteristics of a particular product. The agency's staff has reviewed the results of testing done by manufacturers that bears on Standard No. 121, but has not conducted tests itself.

The cost of a typical antilock system is difficult to determine accurately. For competitive reasons, cost data is closely held by the manufacturers, particularly in the period before the systems are actually in production. We have estimated that some systems will be selling in the range of 100 dollars per axle, but there are a great many variables to be considered and we do not know if that figure will prove to be representative of actual prices.

ENCS.

April 30, 1973

James E. Wilson Acting Administrator National Highway Traffic Safety Administration

I would greatly appreciate your cooperation in furnishing me with background information concerning Federal Motor Vehicle Safety Standard No. 121 which, as I understand it, requires the installation of a computerized anti-wheel lock device on trucks and tractor-trailers. Specifically, I would appreciate the following information:

1. A brief statement of the requirements of the standard.

2. The dates on which the standard was adopted and becomes effective.

3. What, if any, alternative devices were studied to accomplish the same objectives prior to the adoption of the standard?

4. What administrative procedures were followed in the consideration and adoption of the standard?

5. What procedures would be required in the event of an amendment or addition to the standard prior to its effective date?

6. Are any such amendments or additions to the standard presently under active consideration?

7. What is the estimated cost per unit of equipping trucks and tractor-trailers with the computerized

2 anti-wheel lock device?

8. To what extent were the needs and experience of other Federal agencies which utilize or operate trucks and tractor-trailers considered in the course of adopting the standard?

9. In adopting standards of this kind, are such Federal agencies regularly consulted?

10. In cases where proposed standards may involve a requirement for the installation of a specific safety device, are such devices and alternative designs ordinarily tested by NHTSA?

11. Under what conditions would NHTSA consider it necessary or useful to conduct tests on newly developed safety devices?

Thank you very much for providing me with this information.

Matthew J. Rinaldo Member of Congress

ID: nht73-5.16

DATE: 04/12/73

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

TO: District Director of Customs

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 15, 1973, to Mr. Armstrong asking "whether a hub cap with a wing type attachment is subject to Standard 211."

Standard No. 211 prohibits wheel discs, wheel nuts, and hub caps that incorporate winged projections. The item that you enclosed appears to be a wheel spinner which, when attached to a wheel disc or hub cap would create an assembly incorporating a winged projection in violation of Standard No. 211. The item itself is not literally prohibited by the standard, but it evidently has no function apart from this end use. I am therefore of the opinion, if the same source is separately shipping spinners and wheel discs/hub caps to which the spinner may be attached, that these items may be refused entry into the United States.

THE DEPARTMENT OF THE TREASURY

BUREAU OF CUSTOMS LOS ANGELES, CALIF.

MAR 15 1973

Francis Armstrong, Director Office of Standards Enforcement Motor Vehicle Programs National Highway Traffic Safety Administration

A question has arisen as to whether a hub cap with a wing type attachment is subject to Standard 211 of the National Traffic Motor Vehicle Safety Act.

A sample of the subject hub cap is forwarded for your inspection and decision.

C. A. MCGONIGLE Senior Import Specialist

Encl.

ID: nht73-5.17

DATE: 04/04/73

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

TO: Truck Trailer Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 19, 1973, asking whether a towbar dolly must be included in determining the overall length of semitrailers for compliance with Federal Motor Vehicle Safety Standard No. 108.

The answer is no. Standard No. 108 is a manufacturing standard, and semitrailers are not manufactured with dollies attached. 49 CFR @ 390.7, to which you refer, is a definition of the Bureau of Motor Carrier Safety which regulates the operation of certain motor vehicles, and since trailers often use converter dollies, it is understandable that that agency would deem a trailer with a dolly a "full trailer."

TRIAD SERVICES INC.

March 10, 1981

National Highway Traffic Safety Administration 400 7th St. S.W. Washington, D.C. 20590

Attn: Chief Counsel

This letter is to formally request your review and interpretation of Federal Motor Vehicle Safety Standard 108 as it relates to the placement of a clear lens cover in front of a motorcycle headlamp. The attached drawings demonstrate the specific concept in question.

Information contained in SAE standards referenced in Table III of FMVSS 108 indicates that a specific prohibition exists regarding a headlamp lens cover for passenger cars, multipurpose vehicles, trucks and busses. The SAE Motorcycle Headlamp Standard (SAE J584) contains no such prohibition. It is our understanding that a component configuration such as the one illustrated would not conflict with SAE referenced requirements.

Another section of FMVSS 108 which could relate to this issue is Paragraph S4.1.3 which states that "No . . . . automotive equipment shall be installed that impairs the effectiveness of lighting equipment required by this standard." If, when the secondary lens in question is in place, the photometric requirements of FMVSS 108 can be met or exceeded, the lens cover would then be compatible with the standard.

2

Detailed review of FMVSS 108 and the other Federal Motor Vehicle Safety Standards have revealed no other requirements germane to this issue.

Your review of our analysis will be most appreciated. We feel that the proposed concept is in keeping with the spirit as well as the letter of the law. Hopefully your review will confirm our opinion. Should you have any questions on this matter please do not hesitate to contact me.

Stephen W. Matson

[Enclosure Omitted.]

ID: nht73-5.18

DATE: 03/29/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. R. W. Lillie

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 30, 1973 and our sincere apologies for the delay in responding to your letter.

There are no Federal Motor Vehicle Safety Standards applicable to plastic fuel tanks. Standard No. 301, which includes the fuel tank in the(Illegible Word) performance requirements of the vehicle, makes no reference to the construction or design details of the fuel tank. A booklet briefly describing the issued standards is enclosed.

The Department of Transportation does not routinely receive and test fuel tanks of the various manufacturers; however, the Department keeps abreast of technical advancements of these companies through technical society meetings and trade journals. It has been brought to our attention that Dow Chemical Company has done considerable work with high density polyethylene fuel tanks and offers an internal treatment of these tanks which is claimed to reduce considerably the permeation of gasoline through the walls. Further information may be obtained from the following source:

Dow Chemical U.S.A. Plastics Department Midland, Michigan 48640

Standard No. 116 is applicable to Hydraulic Brake Fluids and is included in the consolidated edition of the Federal Motor Vehicle Safety Standards and Regulations, as per the enclosed order form.

2

The physical characteristics and labeling requirements of brake fluids, including silicones, are included in this standard, a copy of which is enclosed for your information. Your inquiry concerning the use of silicones in automobiles can best be answered by the Original Equipment Manufacturers or the automotive companies. The interest of the Department in materials is primarily performance rather than design considerations, for example, an(Illegible Word) material could be silicone, neoprene or ether(Illegible Word) as long as the standards are complied with.

The Bureau of Motor Carrier Safety has issued standards that are applicable to commerical vehicles engaged in interstate commerce, and some of these standards apply to fuel tanks. A portion of these regulations that pertains to fuel tanks is also enclosed for your information, along with an Advance Notice of Proposed Rule Making that concerns plastic fuel tanks (F. R, Vol. 36, No. 178, September 14, 1971). Additional information is available from the Bureau of Motor Carrier Safety Federal Highway Administration, 400 Seventh Street, S. W., Washington, D.C. 20590.

5 ENCLS.

R. W. LILLIE & COMPANY

January 30, 1973

United States Department of Transportation National Highway Traffic Safety Administration

Dear Sir:

Your reply doesn't answer our questions. How do we get those which are not in NHTSA standards?

Very truly yours,

R. W. Lillie

(Illegible Word)

U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION WASHINGTON, D.C. 20590

In reply refer to N48-51

Thank you for your inquiry regarding the Federal Motor Vehicle Safety Standards. The standards are not available from the NHTSA, but may be purchased from the Superintendent of Documents on a subscription basis. An order form is enclosed for your convenience.

R. W. LILLIE & COMPANY

December 8, 1972

United States Department of Transportation

Dear Sir:

We are aware that certain efforts have been underway aimed at the use of plastic fuel tanks for autos. We would like to know the status of these developments, and since we are sure DOT is involved in testing and/or approval procedures, we would appreciate any reports you can send us on this subject: Such matters as the following would be of interest, as well as any othermatters influencing the ultimate use of these tanks:

1. Tests that must be met to receive DOT approval

2. Results of tests on any tanks already submitted

3. Indications of which polymers may be suitable

4. Other interesting information.

We would also like to receive a copy of the NHTSA Regulation concerning the use of brake fluids for automobiles. We are also looking for any other information you may have on the use of silicones in automobiles.

Thank you very much for your assistance.

Very truly yours,

R. W. Lillie

ID: nht73-5.19

DATE: 03/09/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 8, 1973, concerning the use of a "comfort clip" on the shoulder belt portion of GM's 1974 seat belt system.

In response to questions from other manufacturers concerning the use of high friction buckles in continuous loop belt systems, we have indicated that the requirement of Standard 208 that the belts adjust to fit specified occupants precludes the use of such buckles. In the case of systems with separate lap and shoulder belt retractors, however, the shoulder belt does not affect the tension in the lap belt and therefore does not present the risk of submarining that exists with the single loop systems. Accordingly, we are of the opinion that a comfort clip would be acceptable under S7.1.1 of the standard, so long as the shoulder belt is otherwise capable of adjustment as required by S7.1.1.

At a meeting with you on this subject on January 24, 1973, the NHTSA expressed its concern about possible reductions in shoulder belt effectiveness due to excessive belt slack. On the whole, we find that this possibility is more than offset by the prospects of greater usage due to the added convenience of the system with the clip. However, we strongly support your proposal to include instructions for the use of the clip both on the clip itself and in the owner's manual.

ID: nht73-5.2

DATE: 08/30/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Multinational Industries

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 12, 1973, concerning gas tank caps. You state that you are considering marketing imported gas tank caps for trucks, and you want to know whether there is a Federal standard to which such caps must conform. The answer is that there is not.

Multinational Industries

July 12, 1973

National Highway Traffic Safety Administration

Attention: Chief Counsel, Lawrence Schneider

We are considering the marketing of Gas Tank caps manufactured in Japan for use on trucks in the United States.

As there may be some problems importing these items, I would like your opinion on the following questions:

Is there any current Federal Standard to which gas tank caps must conform?

If so, how is such compliance established?

Must the gas tank cap bear any symbols mentioning this compliance?

If so, please be specific.

Thank you for your valuable time.

Richard Kuskin, President

ID: nht73-5.20

DATE: 01/15/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 14, 1972, concerning the acceptability, under S7.4 of Standard 208, of a time delay device in a belt interlock system.

As described in your letter, the delay device would permit an occupant who has operated the belt in the correct sequence to lift off the seat while buckled for a brief period before attempting to start the vehicle. Under S7.4 as presently constituted, this action by the occupant would result in the belt's being buckled before the seat is occupied. The occupant would therefore have to unbuckle the belt and rebuckle before starting the car. A time delay device, in short, would not be allowable.

We make no comment that this situation is desirable or undesirable, but it is, however, required by the language of S7.4.

NISSAN MOTOR CO., LTD.

December 14, 1972

Lawrence R. Schneider National Highway Traffic Safety Administration

This is to request your interpretation of MVSS 208, S7.4, Belt Interlock System.

QUESTION 1

Would a belt interlock system utilizing a time delay device, which works as shown in the enclosed illustration, in order to avoid the following situation meet MVSS 208, S7.4?

SITUATION

If a front seat occupant, after buckling his seatbelt, were to move in such a way as to lift himself from the seat for any reason before starting the engine, that person would be required to unbuckle and rebuckle in order to start the engine. This situation is not only inconvenient to the customer but also may alarm him as he may not realize why the engine does not start although he has done the proper process.

QUESTION 2

Should the abovementioned interlock system meet MVSS 208, how many seconds (3 or 5) delay ("t" see illustration) will be acceptable?

Due to a very short lead time a prompt reply would be greatly appreciated.

Satoshi Nishibori Engineering Representative Liaison Office in USA

FUNCTION OF TIME DELAY DEVICE

(Graphics omitted)