ID: nht89-3.49

TYPE: INTERPRETATION-NHTSA

DATE: DECEMBER 1, 1989

FROM: THOMAS D. TURNER -- MGR., ENGINEERING SERVICES, BLUE BIRD BODY CO.

TO: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 3-20-90 TO THOMAS D. TURNER, BLUE BIRD BODY CO., FROM STEPHEN P. WOOD, NHTSA; [REDBOOK A35; STDS. 202 AND 208]

TEXT: Attached is an illustration of a typical seating arrangement for a small bus that we manufacture. The vehicle has a 10,000 pound GVWR. It is our understanding that the driver's seat is a outboard front designated seating position and that a passenger s eat if located in a similar position on the right side of the vehicle would be an outboard front designated seating position. However, as shown on the attached illustration, our vehicle has an entrance door and stepwell in the area on the right side oppo site the driver's seat. The forwardmost outboard passenger seating position on the right side is approximately in line (3 inches forward on the attached example) with the forwardmost outboard passenger seating position on the left side.

It is our understanding that these forwardmost attached passenger seating positions are not outboard front designated seating position for the purpose of the recently published final rule on Standard 202, 49CFR, Part 571, Docket Number 88-24; Notice 02, Federal Register Volume 54, Number 184, Monday, September 25, 1989 or for the occupant protection requirements of 49 CFR Part 571.208 Occupant Crash Protection.

We request your confirmation that our understanding is correct and that the forwardmoset outboard passenger seating positions of a bus, as shown on the illustration, are not outboard front designated seating positions.

attachment

(Graphics omitted)

ID: nht89-3.5

TYPE: INTERPRETATION-NHTSA

DATE: 09/28/89

FROM: MARK F. HOLMES

TO: STEVE WOOD -- ASST. CHIEF COUNSEL N.H.T.S.A.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 10/31/89 FROM STEPHEN P. WOOD -- NHTSA TO MARK F. HOLMES; REDBOOK A34-VSA 108[A][2][A]; STANDARD 108 LETTER DATED 09/28/89 FROM MARK F. HOLMES TO STEVE WOOD -- NHTSA; OCC 3980

TEXT: Dear Mr. Wood:

Prior to our phone conversation, enclosed please review a bit of information concerning two new multi-purpose products, THE STROBALARM, and THE SPOTLIGHT ALARM that may be of interest to your Company.

For a number of years, I have studied all the car alarm systems that are sold on the market today. During my studies, I have learned that all of these alarms are basically the same with just a bit of variation. There similarity begins with the sounding of a ordinary siren that cannot be seen or detected in a crowded parking lot, or on a dark street covered or uncovered by light. These sirens do very little to ward off a thief, and they offer no real protection for the vehicle, it's valuables, and it' s owner.

The Strobalarm, with it's bright strobe light and 12-volt filament, can be incorporated into any existing alarm system. This unique concept will easily ward off a potential thief by exposing him to the people in his immediate surrounding. The Strobalar m attracts attention like bees to honey. It allows the endangered vehicle to be seen by many in any given area during the course of an evening. It is just as effective in the rain, snow, and fog, as it is on sunny days!

*An example of just how powerful and noticeable a strobe light is can be seen by viewing an airplane in flight during the night. The unique feature of the Strobalarm is that it uses very little energy to produce it's flash.*

The Strobalarm has been reconstructed and redesigned a number of times with the automobile and it's owner in mind. The incorporation of a CAR LOCATOR with its remote control key case is evidence of that. The car locator will allow an owner to locate hi s or her vehicle from a far away distance of 400 feet. The 12-volt filament can be turned on and remain on with the same key case. This will allow the owner to see who may be standing around the vehicle.

The Carfinder, which is the latest device for finding cars, only allows the head lights to blink off and on. But in a crowded parking lot, and if you happen to have a small vehicle surrounded by larger vehicles these blinking lights will not be seen. T he blinking head lights may also be mistaken for something else such as, an alarm going off, someone parked with their headlights on, or the simple switching of headlights to high beams. The Carfinder does not work with vehicles that have hidden headlig hts, such as Corvettes, Porches 928, 944, and Texas AMs.

The DISTRESS EMERGENCY FLARE SIGNAL, would serve useful during emergencies, such as highway break-downs. With the use of pink color lens the Distress flare Signal will eliminate the danger of having to use those pink colored torches that are seen on hig hways at night. Most insurance companies offer premiums on cars equipped with passive alarm, the Strobalarm is such an alarm.

The Spotlight Alarm, which is designed for smaller vehicles with a little less headroom, is equipped with Halogen Beam Lights that blink off and on with the assistance of the key case control. The Spotlight, like the Strobalarm, can be used only as a ca r locator and/or it can be connected to any alarm system.

The STROBALARM and the SPOTLIGHT ALARM are ideas of today and with newer cars having more windshield, side and rear window, these ideas would certainly be items of interest in the future.

Mr. Wood, if you find the alarm or just the Car Locator with or without the built-in Distress to be of interest, feel free to notify me. I would be more than willing to come to your office at my own expense to present the technical drawing for the simpl e to use, easy to install and cost efficient alarm device. A device that is easy to build and does not exceed the cost of systems already on the market.

A preliminary patent search has already been concluded and a disclosure document has been filed with the U.S. Patent Office for Patentability of these concepts.

Sincerely,

ID: nht89-3.50

TYPE: INTERPRETATION-NHTSA

DATE: 12/05/89

FROM: RICHARD A. KULICS

TO: TAYLOR VINSON -- NHTSA

TITLE: REQUEST FOR RULING IMPORTING VEHICLES MODIFIED IN FTZ AS "CONFORMING"

ATTACHMT: ATTACHED TO LETTER DATED 02/22/90 FROM STEPHEN P. WOOD -- NHTSA TO RICHARD A. KULIGS; RE REQUEST FOR RULING IMPORTED VEHICLES - FTZ; REDBOOK A35; PART 591; VSA 108

TEXT: This letter is written on behalf of Mr. Peter DiBernardi, a principal of the entities "Liphardt Associates" and "Pierre Enterprises, Inc.", located at 15 Trade Zone Drive, Ronkonkoma, New York 11779. Liphardt Associates is an Independent Commercial Impo rter ("ICI") under the EPA regulations. The vehicles imported under Liphardt's certificate are modified at Pierre Enterprises, 15 Trade Zone Drive, Ronkonkoma, New York 11779. (Liphardt/Pierre Enterprises will be applying for status as "Registered Impo rters" under 49 CFR 592). The location is within the LI/MacArthur FTZ #52 (Islip FTZ Authority). Pierre Enterprises has been approved as a bonded cartman, i.e., a "Custodian" of bonded merchandise, by the U.S. Customs Service. (Exhibit 1)

The method of operation of Liphardt/Pierre Enterprises (hereafter "L/PE) is as follows: (1) Nonconforming vehicles are unladen from vessel; (2) Vehicles are transported directly into Foreign Trade Zone as "nonprivileged foreign" merchandise (Exhibit 2 , FTZ entry); (3) Appropriate modifications are performed on the vehicles in order to bring them into conformity with U.S. law; (4) Consumption entry filed (as "nonconforming" vehicle), bond posted, conformity package submitted to DOT; (5) After release by EPA and DOT, custody of vehicle given to owner.

REQUEST

L/PE requests you to rule that it be allowed to submit conformity packets to your agency prior to the submission of the consumption entry package, i.e., upon submission of the FTZ entry (step 2, above), so that it may enter the vehicles as "conforming ".

SUPPORT FOR REQUEST

The obvious reason for the request is to eliminate the costs associated with posting a special bond purely for DOT purposes. It would also have the effect of speeding up the process of importation, thus reducing the costs associated with storage.

The purpose of the bond is to "assure that he vehicle has been or will be brought into conformity." (DOT HS 807 144, rev. 12/87, at 3). It is a "promise that you will modify the vehicle to Federal Standards". (id., 5). In regard to DOT, the obligat ion of the importer is to bring the vehicle into conformity and submit an appropriate statement of conformity when it is due (id. 5). If this is not accomplished, Customs is required to issue a redelivery notice (id., 5).

It is apparent, then, that the obligation is to either conform the vehicle or return it to Customs custody. The bond is the method of enforcing that obligation. What L/PE proposes is that it be allowed to close out the obligation while the vehicle i s still in the custody of the Customs Service.

Though established under the Foreign Trade Zones Act (19 U.S.C. 81a), and generally under governed by 15 CFR 400 ("Foreign Trade Zones Board"), for purposes of this request, the appropriate regulatory language is contained in 19 CFR 146 ("Foreign Trad e Zones", i.e.. "admission of merchandise into a foreign trade zone, manipulation, manufacture, or exhibition in a zone; exportation of the merchandise from a zone; and transfer of merchandise from a zone into Customs territory).

146.2 states the "district director [of Customs] in whose district the zone is located shall be in charge of the zone as the representative of the Board. Section 146.4 outlines the criteria for supervision, storage and handling of merchandise by the o perator of the zone. He must permit any customs officer access to a zone, he must maintain records, he must scure the merchandise in accordance with Customs standards and specifications. He must provide guard service. He is also responsible for comply ing with all requirements for "admission, manipulation, manufacture, exhibition or destruction, shortage or overage . . . transfer to Customs territory, and "other requirements as spcified in this part."

146.10 provides:

The district director may cause any merchandise to be examined before or at the time of admission to a zone, or at any time thereafter, if the examination is considered necessary to facilitate the proper administration of any law, regulation, or instr uction which Customs is authorized to enforce.

146.31 Conditionally admissible merchandise provides "the admission of this merchandise into a zone is subject to the regulations of the Federal agency concerned.

There is no question, then, that should DOT want to physically inspect the vehicles on the premises of L/PE, they could readily do so.

It cannot be overemphasized that the entire time the vehicles are in the foreign trade zone, they are under the custody and control of the U.S. Customs Service. They cannot be moved out of the zone unless a consumption entry is filed or a special per mit allows movement for a particularized purpose. Even then they must be moved via a Customs bonded carrier.

Regulations are one thing, however, and sometimes reality is another. Please look at the established integrity of L/PE when reviewing this proposal. L/PE have been conforming vehicles for years. They have had no outstanding claims for liquidated da mages. They are one of the very few entities that is not required to post triple value bonds for nonconforming vehicles. This is because they have established a "track record". They are recognized as an ICI, permitted to import vehicles for EPA purpos es. They have qualified to be issued a warranty policy by their insurance company to meet their EPA obligations. Your own records should reflect that they have been conforming a huge number of vehicles in the most professional manner. They are able to withstand the most stringent scrutiny by the three government agencies with which they have constant contact-DOT, EPA and Customs.

PROPOSED METHODOLOGY OF OPERATION

The current method of operation would remain substantially intact, save for the following: L/PE would prepare an HS-7 at the time of filing the FTZ entry. Each HS-7 would have a unique number (provided by L/PE's Customhouse Broker), which would also b e placed in block 17 of the FTZ entry (Form 214). This number could probably be the same as the actual Customs Entry Number if you feel that is necessary. This HS-7 would be submitted to DOT along with a conformity package. DOT would then review the p ackage and issue a release letter, if appropriate.

When the actual consumption entry is filed, the vehicle would be entered as a "conforming" vehicle, with the release letter attached to the entry. No bond need be posted specifically for DOT purposes. (In most cases, save for an "informal" entry, a bond would be posted anyway, to assure compliance with all other requirements. There is quite a difference in cost, however, between a bond for a "conforming" as opposed to a "nonconforming" vehicle.

Please consider this request and issue a ruling as soon as possible. This is essentially a duplicate of a request I had prepared earlier which somehow became lost. Since L/PE fully intends to be a registered importer under your new regulations, we t rust any ruling you issue would have future application under the new regulations.

Please send any response to this office at the address indicated in the letterhead. [ATTACHED CUSTOMS BOND FORM OMITTED]

ID: nht89-3.51

TYPE: INTERPRETATION-NHTSA

DATE: 12/08/89

FROM: HOWARD KOSSOVER -- CMI TRAILER DIVISION

TO: TAYLOR VINSON -- LEGAL COUNCIL - FMVSS - 108 N.H.T.S.A.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 01/09/90 FROM STEPHEN P. WOOD -- NHTSA TO HOWARD KOSSOVER -- CMI TRAILER DIVISION; REDBOOK A35; STANDARD 108

TEXT: Dear Mr. Vinson:

I am writing to you in regard to the FMVSS Lighting Code. We are in process of building a semi-trailer for highway use and would like to know if we are in violation of the code with respect to the location of the rear stop, turn & tail lights.

This unit is a Rear Discharge trailer designed to haul hot mix asphalt. As the asphalt is discharged out it tends to build up on the rear components. We have recessed the lights approximately 27" from the rear so they will stay clean. I have enclosed some pictures.

Does this violate the lighting code? Please let me know.

Thank you,

PHOTOGRAPHS OMITTED

ID: nht89-3.52

TYPE: INTERPRETATION-NHTSA

DATE: 12/09/89

FROM: LOWELL W. SUNDSTROM

TO: OFFICE OF THE CHIEF COUNSEL -- NHTSA

TITLE: 571.302 STANDARD NO. 302; FLAMMABILITY OF INTERIOR MATERIALS.

ATTACHMT: ATTACHED TO LETTER DATED 3-22-90 TO LOWELL SUNDSTROM FROM STEPHEN P. WOOD, NHTSA; [A35; VSA 108 (A)(2); STD. 302]

TEXT: I am Lowell W. Sundstrom Jr., inventor of several products, one of which may require your approval. It is named the "HOOD LOCKER" (HL). Two pictures of the HL are enclosed.

The HL box will be made of Polyethelene or Polypropolene, the same plastics used in making a battery case. The unit has a tightly fitted lid to keep water and dust out of the box as well as to keep the unused tissue paper inside, dry and clean.

The purpose of the HLis to allow the consumer to have at his or her optimum location, a small tissue paper dispenser wherein the tissues may be used for wiping off the engine crankcase dipstick when checking the crankcase oil.

The HL can be mounted near or on the vehicle fender well, onto the under side of the hood, onto the side or top of the air cleaner, etc. in order to place the HL as conveniently to the crankcase oil dip-stick as is possible.

I have researched the NHTSAdmin., DOT: 571.302. It appears to me that it does not refer to this product because:

1- it will not be placed within the occupant compartments of motor vehicles.

2- it will not be placed within 1/2" of any occupants air space.

I hope your findings are similiar to mine as I feel this is a helpful and safe product that will give the consumer considerable convenience at little expence.

If you think, for any reason, that I can help to expedite your research of the HOOD LOCKER, please feel free to call any time.

(Graphics omitted)

ID: nht89-3.53

TYPE: INTERPRETATION-NHTSA

DATE: DECEMBER 11, 1989

FROM: JOE DABROWSKI -- VP ENGINEERING TMC/MCI, TRANSPORTATION MANUFACTURING CORP. TO: FRANK BERNDT -- ACTING CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 4-9-90 TO R. W. SCHREYER FROM STEPHEN P. WOOD; (A35; STD. 210). ALSO ATTACHED TO LETTER DATED 3-5-90 TO HARRY THOMPSON FROM R. W. SCHREYER, LETTER DATED 3-22-89 TO KEITH A. MCDOWELL FROM ERIKA Z. JONES, AND LETTER DATED 3-25-77 TO ROBERT B. KURRE, WAYNE CORPORATION, FROM FRANK BERNDT. TEXT:

During the 1989 SAE Truck & Bus meeting held in Charlotte, N.C., I met with a Dale Guthrie, Engineering Manager for Thomas Built Buses. During the course of our meeting, our conversation turned to seat belts and he advised me of a letter (copy attached) he received from you responding to his inquiry as to an interpretation of the requirements of Standard 210, Seat Belt Assembly Anchorages.

In particular, my inquiry addresses how much force must be used when testing seat belt anchorages in Intercity coaches to certify compliance with the standard and whether it is necessary to test simultaneously all seat belt assemblies as called out in St andard No. 207, Seating Systems.

If we can use the same interpretation that the referenced letter addresses, we would be able to comply with some of the requests we are receiving for seat belts in intercity buses.

Your attention to this matter and prompt reply are appreciated.

ID: nht89-3.54

TYPE: INTERPRETATION-NHTSA

DATE: 12/13/89

FROM: JIM EVANS -- QUALITY CONTROL DEPT., THE BARGMAN COMPANY

TO: STEVEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 02-26-90 TO JIM EVANS, THE BARGMAN CO., FROM STEPHEN P. WOOD, NHTSA; (REDBOOK) A35; VSA 103(D); STD. 108

TEXT: My company manufactures lighting products for the recreational vehicle industry and we are in need of an interpretation of the rules in FMVSS 108 concerning the use of reflex reflectors on the rear of vehicles. I can find in this standard where two (2) red reflex reflectors are required on the rear of a vehicle (Tables I, II, III, IV) but I cannot find anything in the standard that would prohibit the use of any other color reflectors that could be used in addition to the red reflectors.

Specifically, we manufacture a red taillight lens that has a reflex reflector area around the outer edge of the lens. The stop, turn and tail, as well as the reflex functions all exceed the minimum requirements for these functions.

One of our customers has asked us to mold this same lens in yellow so that it could be used for the turn signal function. It would be mounted side by side with the red unit which would now be used for only stop and tail functions. The problem now arise s where both the yellow and red lens would be visable to traffic approaching from the rear. I checked with a local State Police Post here in Michigan, and they were able to find a section in the State Code that clearly states that reflectors mounted on the rear of a vehicle shall reflect a red color (I am enclosing a copy of this section for your reference). As I stated in my opening paragraph, I cannot find an equivalent ruling in the National standard. I am hoping that your office may have already addressed this problem in the past and that a ruling is already in effect.

My questions are two-fold: First, is it legal to put any other color reflector on the rear of a vehicle as long as the red reflectors are also present? Secondly, if in fact this situation is illegal (which I believe it probably is), could the National st andard be amended to show this fact and eliminate future confusion? Whichever way is correct, I would like to request a written statement to that effect as well as any supporting documentation for the ruling.

I am looking forward to hearing from you as soon as possible so that we can clear this matter up once and for all. Thank you.

Enclosure

(d) On every trailer or semitrailer having a gross weight in excess of 3,000 pounds:

On the front, 2 clearance lamps, 1 at each side.

On each side, 2 side marker lamps, 1 at or near the front and 1 at or near the rear.

On each side, 2 reflectors, 1 at or near the front and 1 at or near the rear.

On the rear, 2 clearance lamps, 1 at each side, also 2 reflectos, 1 at each side, and 1 stop light.

(e) On every poletrailer:

On each side, 1 side marker lamp and 1 clearance lamp which may be in combination, to show to the front, side or rear.

On the rear of the poletrailer or load, 2 reflectors, 1 on each side.

(f) On every trailer or semitrailer weighing 3,000 pounds gross or less:

On the rear, 2 reflectors, 1 on each side if any trailer or semitrailer is so loaded or is of such dimensions as to obscure the stop light on the towing vehicle, then such vehicle shall (Illegible Words) with 1 stop light

(g) When operated on the highway, every vehicle which has a maximum potential speed of 25 miles an hour implement of husbandry, farm tractor or special mobile equipment shall be identified with a reflective device as follows:

An equilateral triangle in shape, at least 16 inches wide at the base and at least 14 inches in height, with a dark red border, at least 1 3/4 inches wide of highly reflective beaded material;

A center triangle, at least 12 1/4 inches on each side of yellow orange fluorescent materials.

The device shall be mounted on the rear of the vehicle, broad base down, not less than 3 feet not more than 5 feet above the ground and as near the center of the vehicle as possible. The use of this reflective device is restricted to use on slow movi ng vehicles specified in this section, and use of such reflective device on any other type of vehicle or stationary object on the highway is prohibited.

On the rear, at each side, red reflectors or reflectorized material visible from all distances within 500 to 50 feet to the rear when directly in front of lawful upper beams of headlamps.

Am. 1988, Act 383.

CI 257.689 Clearance and marker lamps and reflectors; color. [MSA 9.2389]

Sec. 689. (a) Front clearance lamps and those marker lamps and reflectors mounted on the front or on the side near the front of a vehicle shall display or reflect an amber color.

(b) Rear clearance lamps and those marker lamps and reflectors mounted on the rear or on the sides near the rear of a vehicle shall display or reflect a red color.

(c) All lighting devices and reflectors mounted on the rear of any vehicle shall display or reflect a red color, except the stop light or other signal device, which may be red or amber, and except that the light illuminating the license plate-shall be white.

CI 257.690 Same; mounting [MSA 9.2390]

Sec. 690. (1) Reflectors shall be mounted at a height not less than 15 inches and not higher than 60 inches above the ground on which the vehicle stands, except that if the highest part of the permanent structure of the vehicle is less than 15 inches , the reflector at such point shall be mounted as high as that part of the permanent structure will permit.

(2) The rear reflectors on a pole-trailer may be mounted on each side of the bolster or load.

(3) Any required red reflector on the rear of a vehicle may be incorporated with the tail lamp, but such reflector shall meet all the other reflector requirements of this chapter.

(4) Clearance lamps shall be mounted on the permanent structure of the vehicle in such a manner as to indicate its extreme width and as near the top thereof as practicable. Clearance lamps and side marker lamps may be mounted in combination if illumi nation is given as required herein with reference to both.

Am. 1988, Act 383.

CI 257.691 Same; visibility. [MSA 9.2391]

Sec. 691. (a) Every reflector upon any vehicle referred to in section 689 of this chapter shall be of such size and characteristics and so maintained as to be readily visible at nighttime from all distances within 500 to 50 feet from the vehicle when directly in front of lawful upper beams of headlamps. Reflectors required to be mounted on the sides of the vehicle shall reflect the required color of light to the sides, and those mounted on the rear shall reflect a red color to the rear.

(b) Front and rear clearance lamps shall be capable of being seen and distinguished under normal atmospheric conditions at the times lights are required at a distance of 500 feet from the front and rear, respectively, of the vehicle.

(c) Side marker lamps shall be capable of being seen and distinguished under normal atmospheric conditions at the times lights are required at a distance of 500 feet from the side of the vehicle on which mounted.

CI 257.692 Combination vehicles obstructed lights. [MSA 9.2392]

Sec. 692. Whenever motor and other vehicles are operated in combination during the time that lights are required, any lamp (except tail lamps) need not be lighted which, by reason of its location on a vehicle of the combination, would be obscured by another vehicle of the combination, but this shall not affect the requirement that lighted clearance lamps be displayed on the front of the foremost vehicle required to have clearance lamps, nor that all lights required on the rear of the rearmost vehicl e of any combination shall be lighted.

ID: nht89-3.55

TYPE: Interpretation-NHTSA

DATE: December 15, 1989

FROM: R.R. Chestnut -- Supervisor, Modified Vehicle Engineering Dept, Ford Motor Company

TITLE: Re Splicing Into The Stop Lamp Electrical Circuit

ATTACHMT: Attached to memo dated 6-6-90 from Tekonsha Engineering Company; Also attached to letter dated 8-31-78 from J.J. Levin, Jr. to L.F. Henneberger; Also attached to letter dated 5-2-84 from F. Berndt to L.F. Henneberger; Also attached to letter da ted 11-30-81 from F. Berndt to K.G. Moyer (A23; Redbook 3; Std. 108); Also attached to letter dated 9-10-90 from P.J. Rice to L.F. Henneberger (A36; VSA Sec. 103 (d); Std. 108); Also attached to letter dated 6-22-90 from L.F. Henneberger to P.J. Rice (OC C 4927)

TEXT:

Splicing Into The Stop Lamp Electrical Circuit

This bulletin emphasizes the importance of QVM Bulletin #8, issued October 13, 1989, which cautions builders concerning altering of connecting to stop lamp circuits. The stop lamp switch and related wiring not only control the stop lamps, but also provi de the brake on/off input to the electronic modules of the EEC, EAOD, speed control, and anti-lock brake systems. Splicing into a location that interrupts the signals to these modules can interfere with their proper functioning, including:

1. Affecting EFI engine idle speed quality 2. Preventing the EAOD torque converter clutch from applying at throttle openings less than half throttle 3. Deactivating anti-lock brake system operation 4. Preventing the speed control from disengaging upon braking

Attachments I, II, and III of this bulletin illustrate acceptable locations to splice into the stop lamp circuits of Econoline and F-Series vehicles.

Note that when stop lamps are installed in addition to the OEM stop lamps, the additional load must not exceed 6 amps (3 bulbs), yielding a total circuit draw not exceeding 10.4 amps (5 bulbs). Loads exceeding 10.4 amps can damage the stop lamp and/or t urn signal switch.

If you have any questions regarding this issue, please call the Body Builders Advisory Service Hotline on 1-800-635-5560.

ID: nht89-3.6

TYPE: INTERPRETATION-NHTSA

DATE: SEPTEMBER 29, 1989

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL, NHTSA

TO: DAVID G. GOULD -- LEGISLATION DEPT., LOTUS ENGINEERING, NORFOLK, ENGLAND

TITLE: N

ATTACHMT: LETTER DATED JULY 5, 1989 TO STEVE WOOD, NHTSA, FROM DAVID G. GOULD, LOTUS ENGINEERING

TEXT: Thank you for your letter asking whether a world manufacturer identifier (WMI) assigned ny the Society of Automotive Engineers (SAE) pursuant to a contract with this agency may be deleted from SAE's register of assigned WMIs upon request of a foreign nat ional governmental agency, but without the consent of the holder of the WMI. Absent some extraordinary circumstances, the answer to your question is no.

49 CFR Part 565, Vehicle Identification Number - Content Requirements, sets forth format and content requirements for vehicle identification numbers (VINs). Section 565.4(a) specifies that the first three characters of the VIN shall be the manufacturer' s WMI, which is "assigned in accordance with Section 565.5(c) of this part." Section 565.5(c) specifies that the SAE assigns WMIs to vehicle manufacturers under contract with the National Highway Traffic Safety Administration (NHTSA).

No provision in NHTSA's regulations sets forth any procedures for deleting assigned WMIs from the SAE register upon the request of any party, even the manufacturer assigned the WMI. Similarly, no provision in the contract specifically addresses the issu e of deleting assigned WMIs for any reason. In its contract with NHTSA, SAE has agreed to "furnish the facilities, materials, personnel and services necessary to accomplish the work..."

We contacted the SAE's WMI Coordinator to learn how they have handled this situation in the past. We were informed that the WMIs are assigned by the SAE for an indefinite period with no express provision for revo- cation of the assignment. There have b een a few isolated instances in which the party to whom a WMI was assigned has contacted SAE and asked that the WMI assignment be revoked. In those instances, the SAE has granted the manufacturer's request but the revoked WMI is never reassigned to anot her manufacturer. To date, SAE has never been asked to delete an assigned WMI by any party other than the manufacturer to whom the WMI was assigned. If a situation arose in which the SAE was asked to delete an assigned WMI without the knowledge and con sent of the manufacturer to whom the WMI was assigned; the SAE assures us that they would not act on the request without consulting this agency.

If and when we are ever consulted by ShE for our opinion on how to handle such a request, we would carefully consider the circumstances of the particular case before advising SAE on how to respond to the request. As a general matter, however, NHTSA does not favor the deletion of assigned "WMIs for any reason.

Sincerely,

ID: nht89-3.7

TYPE: INTERPRETATION-NHTSA

DATE: 09/29/89

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL NHTSA

TO: SHUICHI WATANABE -- MANAGER, AUTOMOTIVE LIGHTING HOMOLOGATION SECT. STANLEY ELECTRIC CO., LTD. JAPAN

TITLE: NONE

ATTACHMT: LETTER DATED 3/27/89 FROM SHUICHI WATANABE OF STANLEY ELECTRIC CO OF JAPAN TO ERIKA JONES OF NHTSA RE: MEASUREMENT OF INCIDENT LIGHT ANGLE

TEXT: Dear Mr. Watanabe:

This is in reply to your letter with respect to measurement of the incident light angle prescribed by Motor Vehicle Safety Standard No. 108 for license plate lamps. You have submitted six Figures for our consideration and reply. I regret the delay in r esponding.

Paragraph 6.5 (not 5.3.3) of SAE Standard J587 OCT81 License Plate Lamps (Rear Registration Plate Lamps) states:

"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, this angle be ing measured from the edge of the light emitting surface of the device farthest from the surface of the plate (see Fig. 3)."

With respect to your Figure A, you comment that, in order to determine the farthest point on the light emitting surface, "only the distance '1' between license plate and a plane runs parallel to it should be considered and not by distance 'm' nor 'n'".

In examining Figure 3 of SAE J587, you will note that the incident angle is measured by a line that extends from the edge of the light emitting surface of the lamp that is the farthest from the most distant point on the plate that the light can be expect ed to reach, to that point. With respect to your Figure A, the line "n" that extends from the edge of the lamp "p" to the bottom of the plate replicates the line shown in Figure 3, and thus is the correct one, not the perpendicular line "1".

Similarly, with respect to Figure B, a round license plate lamp, a line must be drawn from the bottom of the plate (such as line "n" in Figure A) to the farthest light emitting surface surface of the lamp (as shown in Figure 3, not your Figure B) in orde r to illustrate the farthest point.

With respect to Figures C and D, you have asked: "But if the farthest point can exist so may on a line or a plane . . . how could it be determined? Should it be for instance, left end, right end or center of them?" Figure C appears to depict an elongate d lamp in which "p"s are depicted at the left end, right end, and center. In this instance, "P2" is the edge of the light farthest from the surface of the plate, as represented by corner "Q". Though "Po" represents an edge of the lamp, at no place on t he plate is it the point "farthest from the surface of the plate". Thus, the measurement from "Q" to the tangent of the light emitting surface near "P2" is the line to be used to measure the 8 degree minimum angle.

Figure D appears also to represent an elongated lamp but one in which the lens area is directed more towards the plate. In this Figure, "P" is the edge of the lamp that is farthest from the plate. But because of the configuration of the lamp, light fro m this point is interrupted by a part other than a lens and cannot shine directly upon the plate. Your points "P1", "P0", and "P2" appear to indicate the points on the lamp surface where such interruption ceases and light shines directly upon the plate. Therefore, it is our opinion that in this instance "P2" is the edge of the lamp farthest from the plate, as represented by corner "Q".

You have also asked the same question with respect to Figures E and F. These Figures represent lamp designs with two light sources. However, in Figure E, the two light sources appear incorporated in a single lamp, and the requirements of paragraph 6.5 still apply. Thus, a line from Q, tangent to the light emitting surface of the lens near the point "P3" (and not your line "Q-"P3"), is the correct reference for angle measurement. Figure F, however, depicts the light sources as compartmentalized, and thus may be regarded as a two-lamp device. Paragraph 6.6 of SAE J587 establishes the requirement for two or more license plate lamps. It states:

"When two or more lamps are used to illuminate the plate, the minimum 8 deg incident light angle shall apply only to that portion of the plate which the particular lamp is designed to illuminate. The incident light angle shall be measured in the same wa y as provided in paragraph 6.5."

Under these circumstances the light emitting edge of the lamp farthest from the surface of the plate is the furthest edge of the lamp illuminating that portion of the plate, here represented by "P2". Thus, the angle to be measured would be determined wi th reference to a tangent line to the light emitting surface near "P2", from corner "Q".

I hope that this has answered your questions.

Sincerely,