ID: nht78-1.1

DATE: 12/12/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Thomas Built Buses, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. James Tydings Thomas Built Buses, Inc. P.O. Box 2450 High Point, NC 27261

Dear Mr. Tydings:

This responds to your November 7, 1978, question whether the National Highway Traffic Safety Administration's (NHTSA's) October 13, 1978, interpretation of the Ninth Circuit air brake ruling has revoked the exclusion of school buses from the "no lockup" requirements of Standard No. 121, Air Brake Systems. You also ask if a bus which is designed identically to a school bus qualifies for the exclusion from "no lockup" requirements if it is purchased and used for a purpose other than as a school bus.

The answer to the first question is no. The exclusion of school buses from the stopping distance requirements of Standard No. 121 (S5.3.1) remains in effect and was not altered by the October 13, 1978, interpretation.

The answer to the second question is also no. The exclusion from service brake stopping distance requirements (including the "no lockup" requirement) is limited to school buses, which are defined at 49 CFR S 571.3 as follows:

"School bus" means a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation.

The buses you describe would not qualify as "sold ... for purposes that include carrying students to and from school or related events." Therefore, they would not qualify for the school bus exclusion.

Sincerely,

Original Signed By

Joseph J. Levin, Jr. Chief Counsel

ID: nht78-1.10

DATE: 12/05/78

FROM: AUTHOR UNAVAILABLE; J. Levin, Jr.; NHTSA

TO: Yankee Metal Products Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of September 18, 1978, requesting a clarification of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. The National Highway Traffic Safety Administration concurs in your interpretation of S5.3.1 that any hand operated control which is mounted on the steering column does not have to meet the illumination requirements of Column 4 of Table 1.

Sincerely,

ATTACH.

September 18, 1978

KATHLENE DEMETER -- OFFICE OF THE CHIEF COUNCIL, NHTSA/DOT

Dear Ms. DeMeter:

I have been referred to your office for clarification of paragraph 5.3.1 on page 27543, of FMVSS No. 101 -- Controls and Displays; Docket No. 1-18; notice 13; part 571. It is my interpretation of the first sentence of the above paragraph that a hand operated steering column mounted control does not have to comply with the illumination requirements of Column 4 of Table 1.

It is imperative that we receive your written reply to this interpretation as soon as possible, since it could affect the design of a turn signal/hazard warning switch which we are about to release for production.

Thank you very much.

Sincerely, YANKEE METAL PRODUCTS; Walter J. Kulpa

ID: nht78-1.11

DATE: 12/05/78

FROM: AUTHOR UNAVAILABLE; J. Levin, Jr.; NHTSA

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of September 20, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.

Specifically, you asked whether the km/h label on Volvo speedometers could appear in upper case letters instead of the lower case letters appearing in Table 2 of the standard. The answer is yes.

Section 5.2.3 of the standard provides that "any such display for which no symbol is provided in Table 2 shall be identified by the word or abbreviation shown in column 3." There is no requirement that the identifying words or abbreviations be in the same type face, type size, or case as those printed in the Federal Register. Therefore, as long as the abbreviations are the same as those appearing in Table 2 and are visible, no problem arises because Volvo wishes to use upper case, rather than lower case letters.

SINCERELY

September 20, 1978

Joseph J. Levin, Jr. Chief Counsel Department of Transportation National Highway Traffic Safety Administration

Subject: Request for Interpretation, FMVSS No. 101-80

Dear Mr. Levin:

According to Federal Motor Vehicle Safety Standard No. 101-80, the speedometers of 1981 and later model year passenger vehicles are to be labelled "MPH" and "km/h". It is our understanding that it is the intent of this requirement, along with FMVSS No. 127, to encourage the use of metric units of speed and distance. It is also the intent of this standard to present information to the vehicle operator as clearly and unambiguously as possible.

Enclosed is a preliminary example of a Volvo proposed speedometer face. Picture A is the proposed 1981 model year speedometer. Note that in this case, the metric unit for speed is labelled "KM/H". In other words, we have used upper case letters, but in exactly the same configuration. We believe that using the upper case letters does not detract from the clarity of the information being conveyed, nor does it discourage use of the metric system. Thus, we interpret the use of "KM/H" to satisfy the requirement of FMVSS No. 101-80.

Please advise us as to whether you agree with our interpretation of this standard. If I can be of any assistance, please feel free to call.

VOLVO OF AMERICA CORPORATION Product Planning and Development

William Shapiro, P.E. Manager, Regulatory Affairs

ID: nht78-1.12

DATE: 12/29/78

FROM: AUTHOR UNAVAILABLE; J. Levin, Jr.; NHTSA

TO: R. E. Dietz Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of September 21, 1978, requesting interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.

In your first set of questions, you ask about the application of the display requirements to trucks with a GVWR of 10,000 pounds or more. Those requirements do not apply to such trucks. Under S5 of the standard, the only trucks required by the standard to comply with the display requirements are those with a GVWR less than 10,000 pounds.

In your second set of questions, you pose various questions about the identification and illumination of controls. In the first question, you ask whether the turn signal control symbol must be placed on the control itself. The answer is "no." S5.2.1 provides that the symbol shall be placed on or adjacent to the control. You also ask if there is any size requirement. The answer is again "no." There are no size requirements for any of the control symbols.

In your second question, you ask about the size requirements for the hazard warning signal control. As indicated above, there are no size requirements. As to illumination, S5.3.1 provides that hand-operated controls mounted on the steering column are not required to be illuminated. Thus, neither the turn signal control symbol nor the hazard warning control symbol need be illuminated. With regard to the nonmandatory red lens between the turn signal control symbol, if that lens is intended to call attention to the location of the hazard warning control, we urge that it be triangular. If it is intended to call attention to the turn signal control, we urge that the shape be made less similar to the hazard warning symbol to avoid confusion.

In your third question, you asked about the relationship between the control and display requirements in FMVSS 101 and those in FMVSS 108. The agency will soon issue a notice dealing with this issue.

SINCERELY,

R. E. DIETZ COMPANY

September 21, 1978

Nelson Erickson Office of Motor Vehicle Programs

Dear Mr. Erickson:

This is a request for further information and clarification of new rule 49 CFR 571.101-80 Controls and Displays.

Our questions and concerns pertain principally to our new 16-35 turn signal switch (drawing enclosed), which went into production this year. This type of hang-on switch is used only on Class 7 trucks which are in the weight range of 26,001 to 33,000 pounds GVWR and Class 8 trucks which are over 33,000 pounds GVWR.

1. I understand that since Class 7 and 8 trucks exceed 10,000 pounds GVWR, display requirements of 55.1 in Column 1 of Table 2 do not apply. Is that correct?

2. If correct, then do Columns 3 and 4 apply?

3. If Column 3 applies, then FMVSS 108 sends us to SAE J-589 for turn signal switches which references J-588, which calls for an illuminated area (shape unidentified) equivalent to a 3/16" diameter circle. Is that correct?

4. Column 3 also sends us to FMVSS 108 which refers us to J-910 for hazard switches, which calls for an illuminated area (shape unidentified) equivalent to a 1/2" diameter circle. Is that correct?

If the above statements are correct, then 571.101-80 (in which "the agency has decided that vehicles over 10,000 pounds GVWR need not meet display requirements of this standard") seems to be retaining display requirements. It appears that the intent is that neither Column 3 nor 4 are meant to apply. Is that correct?

Regarding identification and illumination of controls -

1. Would you say that double arrows on the device meet the requirements? If not, is it necessary that they be printed on the lever itself? If so, can they be on the lever axis or must they be on the arc which a point on the lever travels when the lever is moved to the right or left turn position. If there any size requirement?

2. As you can see from our drawing, there is approximately 5/8" of hazard button which extends out from our lever. The thickness of the button varies from 3/16" at the bottom to 1/16" at the top. What size does the identifying symbol have to be? If we could find a plastic which would transmit some light out to the end, would that be considered meeting the specification? If we cannot find a design solution to this requirement, what recourse do we have short of a complete re-design and re-tooling?

3. Finally, I must ask again for clarification of the relationship between 571.101-80 and FMVSS 108. It appears that one could meet all of the requirements of 571.101-80 but be found failing to conform to FMVSS 108. Is it the intent of 571.101-80 to be an addition to the requirements of FMVSS 108.

Your earliest response to these questions would be appreciated since it appears that we may have some significant changes to make.

Donald W. Vescio, Sr. Director of Engineering

(Illegible Lines)

UNLESS OTHERWISE SPECIFIED THE FOLLOWING (Illegible Words)

THREE PLACE DECIMALS (Illegible Word) .006

TWO PLACE DECIMALS (Illegible Word)

DIETZ (registered) R.E. DIETZ CO. SYRACUSE N.Y.

TITLE: 16+35 TURN SIGNAL SWITCH ASSEMBLIES SHEET: 016-35600

3. 16-35 TURN SIGNAL SWITCH IS DESIGNED TO CONFORM TO SAE J 589(b), SAE J 910(b) AND SAE J 588 (e) PARAGRAPH 4.5. IT CONFORMS WITH FMVSS 108 AND IS DESIGNED TO MEET NEW PROPOSED FMVSS STANDARDS FOR PILOT INDICATORS.

HAZARD BUTTON (Illegible Word) PLASTIC

(Graphics omitted)

(Graphics omitted)

ID: nht78-1.13

DATE: 03/23/78

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

TO: Nissan Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: We refer to your letters of November 10 and December 2, 1977, to Mr. Joseph J. Levin, requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 106-74 Brake Hoses. You inquired as to its applicability to the two anti-skid system hoses "A" and "B" in the diagram you enclosed.

The anti-skid actuator apparently modulates the pressure to the rear brakes upon command from the computer module. You stated that the failure of the actuator would not prevent the brake system from meeting the requirements of FMVSS No. 105-75.

You also stated that the subject hoses carry mineral oil, and that such hoses might deteriorate if subjected to brake fluid. You further stated that standard hydraulic brake hoses would deteriorate if used with the mineral oil which is used in the power steering system.

In the preamble to Notice 11, Docket 1-5, published June 24, 1974, (39 FR 24012) all power steering type hoses that connected power steering pumps with accumulators were exempted from coverage by the standard. Hoses connecting accumulators with brake power boosters were also exempted if redundant boosters were provided. The National Highway Traffic Safety Administration (NHTSA) has reviewed this latter interpretation and determined that all power steering type hoses should be exempted from FMVSS No. 106-74, until appropriate requirements for such hoses are established.

After consideration of the information and the drawings in your letters, we have concluded that hose assemblies A and B connected to your anti-skid actuator are, in fact, power steering hose assemblies. Consequently those assemblies are exempt from the subject standard until suitable requirements for such assemblies are included therein.

Sincerely,

ATTACH.

November 10, 1977

Joseph J. Levin -- Office of the Chief Counsel, NHTSA

Dear Mr. Levin:

This letter is to ask your interpretation concerning FMVSS 106 - "brake hoses".

Attached is the schematic drawing of the brake system with the hydraulic anti-skid unit. Do hoses A and B in this drawing fall under the category of "brake hose" which is defined in S.4 of FMVSS 106? In other words, should those hoses meet FMVSS 106?

I look forward to hearing your reply to the above.

Very truly yours

NISSAN MOTOR CO., LTD.;

Tokio Iinuma -- Staff, Safety

Enclosure

December 2, 1977

Joseph J. Levin -- Office of the Chief Counsel; NHTSA

Dear Mr. Levin:

I asked for your interpretation with regard to FMVSS 106 - "brake hoses" in my letter of November 10, 1977.

I am afraid that my explanation concerning hoses used in the anti-skid unit was insufficient.

The following is the additional information necessary to make my explanation complete:

1. Even if the failure (ex: mineral oil leakage from hoses, inoperative of actuator or vane pump) occurs in the anti-skid unit, the vehicle is capable of meeting FMVSS 105 - "hydraulic brake systems".

2. Difference of material between hoses used in anti-skid unit (hose A, B and C in attachment) and hoses in ordinary brake system which is in compliance with FMVSS 106.

HOSES IN HOSES IN ORDINARY ANTI-SKID UNIT BRAKE SYSTEM outer rubber CR CR (or CR+NR) middle rubber NR NR inner rubber NBR SBR

(Graphics omitted)

3. Compatibility with mineral oil or brake fluid (DOT 3).

HOSES IN HOSES IN ORDINARY ANTI-SKID UNIT BRAKE SYSTEM mineral possibility of deterior- oil no problem ation of property and swelling at inner rubber brake possibility of fluid deterioration no problem (DOT 3) of property at inner rubber

Thank you for your attention to the above matter. I look forward to hearing your reply to my letter of November 10, 1977.

Very truly yours, NISSAN MOTOR CO., LTD.,

Tokoi Iinuma -- Staff, Safety

Enclosure

cc: Welfred M. Redler (NHTSA Office of crash avoidance)

Brake System with Anti-Skid Unit

(Graphics omitted)

NOTE: Hoses A, B and C does not make contact with brake fluid (DOT 3) because the flows of mineral oil for the power steering unit and brake fluid for brake systems are completely separate.

ID: nht78-1.14

DATE: 03/20/78

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

TO: Alfred Teves GMBH

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of June 23, 1977, to Mr. W. M. Radler, you asked if Federal Motor Vehicle Safety Standard (FMVSS) No. 106-74, Brake Hoses, would apply to a special hose assembly intended for use with your Hydrobooster system. The diagram you enclosed showed the hose assembly interconnecting the charging valve with the brake booster unit. Power steering fluid is fed through it under pressure.

Your representative, Mr. Paul Utans, has presented two rubber hose assemblies in the recent past. On October 5, 1977, he submitted what we assume to be the design to be used with your Hydrobooster. It is stamped with the date 10/8/77.

In the preamble to Notice 11, Docket 1-5, published June 24, 1974, (39 FR 24012) all power steering type hoses that connected power steering pumps with accumulators were exempted from the standard. Hoses connecting accumulators with boosters were also exempted if redundant boosters were provided. The National Highway Traffic Safety Administration (NHTSA) has reviewed this latter interpretation and determined that all power steering type hose should be exempt from FMVSS 106-74, whether or not redundant boosters are present.

Brake power booster systems must meet the applicable performance requirements of FMVSS 105-76, "Hydraulic Brake Systems" which does not require a redundant booster. Further, the requirements in FMVSS 106-74 are not appropriate for power steering hoses. The interpretation in Notice 11 is therefore modified to permit the exemption of all power steering type hoses and tubing assemblies used with hydraulically operated brake power boosters until performance requirements for them are established.

After consideration of the sample and the information you have supplied, we have concluded that the subject hose assembly must be classified as power steering hose. Consequently, your Hydrobooster hose assembly is considered exempt from coverage by FMVSS 106-74 until appropriate requirements for such hose assemblies can be included in the standard. A plastic tube assembly used in the same system would also be exempt.

Sincerely,

ATTACH.

Welfred M. Redler, P.E. -- Office of Crash Avoidance, NHTSA

June 23, 1977

Subj.: Request Dear Mr. Redler,

for one of our customers, a central hydraulic system is being installed since the beginning of production of the 78 model range; the wiring diagram of this system is attached. The tube which is presently mounted between accumulator and hydrobooster is to be replaced before long by a plastic hose for reasons of noise transmissions. Mr. Utans has already informed you that we cannot use a rubber hose with the required dimensions (internal dia. 10 mm) for this specific purpose. Since, however, we are not sure about the requirements the hose will have to meet in the U.S.A., we kindly ask you to inform us about them.

The following hose characteristics should be taken into consideration:

a) When installed in the system, the hose must withstand a permanent pressure of 36 - 52 bar (522 - 754 psi).

b) In the case of a failure of this hose, the system will still meet the requirements as per FMVSS 105-75, S 7.10.

c) Since it is a plastic hose, the requirements as per FMVSS 106-74, S 6.3, Whip Test, cannot be met. However, we hold the view that this is not necessary since the hose is used as a connection for two units attached to the same vehicle part (frame) where no important vibrations will occur. As has been mentioned before, this hose will be exclusively used as a noise deadening hose.

d) If, contrary to our expectations, you decide that our plastic hose is a hydraulic brake hose as defined by FMVSS 106-74, we should like to ask you to release us from the obligation to meet the requirements of sections 5.2 Identification and 6.3. Whip Test.

When taking a decision, please bear in mind that similar hoses are presently installed in production vehicles in the U.S.A.

Thanking you in advance for your kind assistance we remain,

Yours sincerely, Alfred Teves GmbH

P.P.9

(Graphics omitted)

(Graphics omitted)

ID: nht78-1.15

DATE: 01/20/78

FROM: F. BERNDT FOR J. J. LEVIN -- NHTSA

TO: Nichirin Rubber Industrial Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter dated November 29, 1977, asking about the procedures for obtaining approval of hydraulic brake hoses. Your company is altering the labeling on some of its hose and asks whether the hose must be retested and whether notice of the changes must be given.

The National Highway Traffic Safety Administration (NHTSA) does not approve in advance motor vehicles or motor vehicle equipment. It is up to manufacturers to certify that their products comply with all applicable safety standards and regulations. The NHTSA conducts compliance testing for purposes of enforcement.

It is, therefore, up to your company to decide whether to test its hose according to the procedures specified in Safety Standard No. 106, Brake Hoses. The NHTSA only requires that you determine in the exercise of due care that the hose meets all requirements specified in the standard. Further, you do not have to give the NHTSA notice when you change the labeling information on your hose, unless you change the designation identifying your company. In that case, the new designation would have to be filed with the NHTSA according to the specifications of paragraph S5.2.2(b) of Standard 106.

You will have to contact the American Association of Motor Vehicle Administrators directly to determine their requirements for approval and notification following your labeling changes.

Please contact me if our office can be of any further assistance.

Sincerely,

ATTACH.

NICHIRIN RUBBER INDUSTRIAL CO., LTD.

November 29, 1977

Richard B. Dyson -- Acting Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Dyson,

Subject: Inquiry about the procedure for equipment approval for hydraulic brake hose assembly

This company is a maker of brake hoses, and has received the following certificates of equipment approval from the American Association of Motor Vehicle Administrators as the equipment approval of its products now. Certification No. Dated 741092 November 27, 1974 750423 April 8, 1975 750449 April 22, 1975 761132 November 12, 1976 761133 November 16, 1976

This company implements the labeling of brake hoses prescribed in FMVSS No. 106, S5.2, according to the following two ways.

a. One side: DOT NCRN (date) 1/8 HL

Other side: (stripe)

b. One side: DOT NCRN (date) 1/8 HR

Other side: NCRN 1/8 (date) SAE J1401

Other side: NICHIRIN RUBBER JAPAN 1/8 SAE J1401 AAA

(private lot No.)

In this connection, please instruct us in the procedure for this change.

1. In case of changing the indication of labeling from HR (Regular expansion hydraulic hoses) to HL (Low expansion hydraulic hoses),

(1) Is it necessary to obtain again the original report by the approval test organization?

(2) Or, is it enough to obtain the appendix report by undergoing the test of the concerned test item only (expansion test)?

(3) Or, the test report is not required, and is it enough only to submit the notice about the change?

2. In the FMVSS No.106, S5.2.1, of labeling on the other side, when the labeling prescribed as the additional information at the manufacturer's option is changed, this company interprets that the test is not required, but is it right?

Moreover, also in case of changing the content of labeling on the other side, is some notice required?

Would you please instruct and answer us in the above-described points?

Sincerely yours, Takashi Shimoda -- Technical department

ID: nht78-1.16

DATE: 02/14/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: M. H. Hollaway

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your September 16, 1977, letter asking whether it is illegal to mount a tire labeled "Farm Tire" on a passenger car.

Tires manufactured for use on passenger cars or other motor vehicles designed principally for highway use must comply with all Federal regulations applicable to those tires. Tires designed for use on farm vehicles, on the other hand, are not required to comply with the Federal motor vehicle safety standards.

Under section 108 of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563) a dealer may not "knowingly render inoperative" a device installed on a motor vehicle in compliance with a safety standard. A dealer who removes properly certified passenger car tires from an automobile and replaces them with tires that are specified for farm use would be in violation of section 108 in that the complying tires would have essentially been rendered inoperative by his actions. Section 108 does not apply to private individuals. Thus, a car owner would not be in violation of the law if he accomplished the tire replacement himself. Such action would be highly inadvisable, however, since these restricted use tires are not constructed in compliance with standards that ensure a minimum safe level of performance for highway operation.

Sincerely,

ATTACH.

September 16, 1977

Department of Transportation Washington, D. C. 20013

Gentlemen;

Will you please answer the following question?

Is it unlawful to use tires on a passenger car that are marked "Farm tires"?

These tires are passenger car type tires with white sidewalls. However, a local tire store refused to install them because of the markings.

Thank you for your assistance.

Yours Truly,

M. H. Hollaway

MARCH 7, 1978

M. H. Holloway

Dear Mr. Holloway:

This is in further reply to your September 16, 1977, letter asking whether it is illegal to mount a tire labeled "Farm Tire" on a passenger car.

We inadvertently neglected to point out in our February 14, 1978, response to your letter that any tire which is marked with a Department of Transportation (DOT) symbol is presumed to meet all Federal Motor Vehicle Safety Standards that apply to it. Any tire with such a symbol may therefore be mounted on a motor vehicle without violation of Section 108 (a)(2)(A) of the National Traffic and Motor Vehicle Safety Act when the former tires are removed, regardless of the appearance of words associating the tire with farm use.

Sincerely,

Joseph J. Levin -- Chief Counsel, NHTSA

ID: nht78-1.17

DATE: 02/17/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Mr. Wirtz

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of October 17, 1977, inquiring about tire endurance tests.

The tire endurance test proposed in Docket No. 74-2, Notice 1, has not been adopted by this agency. Comments received in response to the notice were generally critical of the suggested amendment. The agency found the comments essentially meritorious and, thus, is at this time contemplating closing the docket on the proposed revision. The tire endurance test currently prescribed in Standard 109 remains in effect and should be regarded as establishing the performance level necessary for compliance.

If you wish to obtain copies of the SAE standards, you should contact the SAE directly at the following address:

Society of Automotive Engineers, Inc. 400 Commonwealth Drive Warrendale, Pennsylvania 15096

Sincerely,

ATTACH.

Docket Section -- National Highway Traffic Safety Administration

October 17, 1977

Standard No. 109 (49 CFR 571.109) - Registration No. 74-2 notice from January 10, 1974

Passenger car tires which shall be labeled with the symbol DOT must among others be subjected to the tire endurance test. In the notice No. 1, registered under No. 74-2, the proposal was made to replace the tire endurance test defined in MVSS 109 by a new SAE-procedure showing some changes in the testing conditions compared with the test method defined in MVSS 109.

Would you be kind enough to inform me whether the new SAE test procedure (published under registration No. 74-2) was put into force for the performance of the tire endurance test according to MVSS 109, and which of both test methods is obligatory for the proof of tires to conform to the requirements of MVSS 109.

At the same time I ask you to place to my disposal all SAE standards regarding tire test procedures.

Sincerely Wirtz -- General manager

ID: nht78-1.18

DATE: 06/19/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of May 1, 1978, to Mr. Tilton of this office requesting our interpretation of the requirement of Standard No. 110, Tire Selection and Rims, that a placard displaying specified information be "permanently affixed to the glove compartment door or an equally accessible location." (S4.3) Specifically, you inquire whether the back side of the lid of the center console box is an acceptable location for the placard within the meaning of S4.3.

We have interpreted "equally accessible location" as requiring a location where the placard (1) can be referred to easily, as it can when located on the glove compartment door; and (2) will be relatively free from exposure to substances which may destroy it or render it illegible, as it is when located on the glove compartment door. The back side of the lid of the center console box as depicted in the diagram attached to your May 1 letter fulfills these two requirements, and is therefore an "equally accessible location" within the meaning of S4.3.

Sincerely,

ATTACH.

NISSAN MOTOR CO., LTD.

May 1, 1978

Roger S. Tilton -- Office of the Chief Counsel, NHTSA

Dear Mr. Tilton:

This letter is to request your interpretation concerning a location of the tire placard which is specified in S.4.3. of FMVSS 110 "Tire selection and rims". We are planning to affix the tire placard to the back side of the lid of the center console box in one of our future models as shown in the attachment.

We would like to know whether this location is acceptable or not under the requirement of "A placard, permanently affixed to the glove box compartment door or an equally accessible locations" in S.4.3.

We would appreciate your reply as soon as possible

Thank you.

Very truly yours, Tokio Iinuma Staff, Safety

Enclosure

(Graphic omitted)