ID: nht87-2.17

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

AIR MAIL

Mr. T. Chikada Manager, Automotive Lighting Engineering Control Department Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Chikada:

This is in reply to your letter of March 4, 1987, with reference to aiming adjustment of fog lamps. We understand that Stanley is developing a fog lamp and replaceable bulb headlamp with a common lens and housing. Since the portion of the housing also fu nctions as a reflector, the fog lamp moves simultaneously with the headlamp in aiming adjustment. In your view, it will not impair the effectiveness of the headlamp, and you ask for confirmation that the lamp "is acceptable in the U.S.A."

Federal Motor Vehicle Safety Standard No. 108 contains no requirements for a fog lamp, and would prohibit it only if it impaired the effectiveness of any other lamp mounted on the front of a vehicle that is required by the standard. Assuming that the fog lamp does not impair the effectiveness of the headlamp, its installation would not create a noncompliance with Standard No. 108. However, in the absence of a Federal standard on fog lamps, the individual States may establish their own requirements for f og lamps. We are unable to advise you whether this design would be acceptable in each of the 50 States, and other jurisdictions in which the Federal standards must be met; we can only advise you that it does not appear prohibited by Federal law.

The American Association of Motor Vehicle Administrators (AAMVA), 1201 Connecticut Avenue, N.W., Washington; D.C., 20036 may be able to advise you as to state laws relevant to your design.

Sincerely,

Erika Z. Jones Chief Counsel

March 4, 1987

Ms. Erika Z. Jones Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones,

Re : Aiming adjustment of Front fog lamps

We are now developing a new fog lamp, which has a common lens and housing with a replaceable bulb headlamp. (See attached drawing.)

Since the portion of housing also functions as a reflector, this new fog lamp moves simultaneously with headlamp in aiming adjustment.

This fog lamp is designed to satisfy the requirements of SAE Standard J583. So it will not impair the effectiveness of the headlamp, or rather, it will promote the function of headlamp. We Think this new fog lamp is acceptable in the U.S.A.

Please give your advice whether our understanding is right or not.

Sincerely yours,

Stanley Electric Co., Ltd.

T. Chikada Manager, Automotive Lighting Engineering Control Dept.

SEE ATTACHMENT

ID: nht87-2.18

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Jim Ross

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Jim Moss President, Auto Mark Corp. 3901 Atkinson Drive Suite 220 Louisville, Kentucky 40218

Dear Mr. Moss:

This responds to your letter to Ms. Barbara Kurtz of our Office of Market Incentives. In your letter, you posed several questions about a stencil your company would like to offer to direct importers for marking their vehicle parts in compliance with 49 C FR Part 541, Federal Motor Vehicle Theft Prevention Standard. Before responding to your specific questions, I would like to briefly explain the parts marking requirements of Pact 541 as they apply to direct importers.

Direct importers are required to inscribe an identifying number on the specified parts for each passenger car subject to Part 541 that they import: @541.5(a). The identifying number inscribed on the parts must be the original vehicle identification numbe r assigned to the car by its original manufacturer in the country where the car was assembled or produced: @54l.5(b) (3). The identifying number inscribed on the parts must satisfy the size and style requirements specified for vehicle certification label s: @54l.5(c). Finally, the identifying number inscribed on the parts must comply with the three requirements of @54l.5(d) (2). These requirements are:

1. Removal or alteration of any portion of the number must visibly alter the appearance of the section of the vehicle part on which the identification is marked:

2. The number must be placed on each part in a location that is visible without further disassembly once the part has been removed from the vehicle: and

3. The number must be placed entirely within the target area specified by the original manufacturer for that part.

There are no other requirements for marking direct importers' vehicles. Once the direct importer determines that its vehicle complies with these requirements, it certifies that compliance by affixing a label to the vehicle, as specified in 49 CFR S567.4( k). This certification label must be affixed to the vehicle before it is imported into the United States.

To respond to your specific questions, you stated that you advise direct importers to leave your stencil on each part after etching it. You then posed three questions:

1. Must the initials DOT appear on the stencil?

ANSWER: No. Part 541 does not require that the DOT symbol appear as a part of or in conjunction with inscribed markings on parts.

2. May we leave our name (logo) printed on the stencil? ANSWER: Yes. Using the same principles we have applied in the case of labeling requirements in our safety standards, manufacturers may label information in addition to that which is required by the theft prevention standard, provided that the additional information does not obscure or confuse the meaning of the required information or otherwise defeat its purpose. The purpose of requiring the vehicle identification number to be inscribed on specifi ed parts is to allow law enforcement officials to quickly and conclusively establish whether a vehicle or major part is stolen. We do not believe it is possible that law enforcement officials will be distracted from examining the markings inscribed on th e parts by the presence of a stencil with your company name on it. Therefore, you are free to leave your company name on the stencil.

3. Do you have any suggestions or objections to offer?

ANSWER: Our only concern is that direct imports comply with the requirements of Part 541. Assuming that your stencil is a means for direct importers to comply with those requirements, we have no additional advice to offer.

If you have any further questions or need more information on this subject, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Erika Z. Jones Chief Counsel

ID: nht87-2.19

TYPE: INTERPRETATION-NHTSA

DATE: 06/19/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Ted Stevens

TITLE: FMVSS INTERPRETATION

TEXT: The Honorable Ted Stevens United States Senate Washington, DC 20510

Dear Senator Stevens:

Thank you for your April 23. 1987 letter on behalf of your constituent, Ms. Nadra L. Angerman of Wrangell, who is concerned that there is no Federal requirement for safety belts on school buses. Your letter has been referred to my office for reply, since the National Highway Traffic Safety Administration (NHTSA) is responsible for administering Federal programs relating to school bus safety.

I appreciate this opportunity to respond to Ms. Angerman 's concerns. As explained below, NHTSA does not require large school buses to have safety belts for passengers because we require those buses to provide an alternate form of passenger crash protect ion. Our safety standards are directed at improving the interior of large school buses so that passengers will be provided adequate crash protection even if safety belts are not used.

I Would like to begin with some background information on our school bus regulations. NHTSA is responsible for developing safety standards applicable to all new motor vehicles, including school buses. In 1977, we issued a set of motor vehicle safety stan dards for various aspects of school bus safety. Included in that set is Federal Motor Vehicle Safety Standard No. 222, School Bus passenger Seating and Crash Protection. Standard No. 222 requires large school buses--i.e., those with gross vehicle weight ratings over 10,000 pounds--to provide passenger crash protection through a concept called "compartmentalization." Compartmentalization refers to designing the interior of large buses so that children are protected regardless of whether they have fasten ed a safety belt. The key features include higher hnd stronger seat backs, additional seat padding, and better seat spacing and performance.

Our safety standards require a safety belt for the school bus driver since the driver's position is not compartmentalized. We also require safety belts for passengers in smaller school buses because those buses experience greater crash forces than do lar ger buses.

However, because large school buses already offer substantial protection to passengers, we believe a Federal requirement for safety belts in those vehicles is unnecessary. Large school buses are very safe vehicles not only because they meet Federal schoo l bus safety standards, but also because of their size and weight, the training and experience of their drivers and the extra care that other road users employ in the vicinity of school buses. NHTSA does not prevent States and local jurisdictions that wi sh to order safety belts on their own large school buses from doing so. Such a decision is a matter for the officials of the particular State or local jurisdiction, who are best able to assess their own preferences regarding pupil transportation.

A June 1985 NHTSA publication entitled, Safety Belts in School Buses, discusses many of the issues relating to safety belts in large school buses. I have enclosed a copy of the report for your information.

I hope you have found this information to be helpful. If you or your constituent have any further questions, please do not hesitate to contact me.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

Edward Babbitt, Director Office of Congressional Relations Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Babbitt:

One of my constituents/ Ms. Nadra L. Angerman of Wrangell( Alaska, has recently informed me of her concern about the need for mandatory seat belt installation laws for school buses nation-wide. I've enclosed a copy of her letter on this subject for your reference.

I would greatly appreciate any information you could provide on recent proposals or assessments relating to possible national requirements to install seatbelts in school buses. Thank you for your assistance in addressing my constituent' s concerns. With best wishes,

TED STEVENS

Enclosure

April 13 1987

The Honorable Ted Stevens United States Senate Washington, D.C. 20515

Dear Senator Stevens:

Automobile safety is becoming one of the most common concerns of Americans. Automobiles traveling at excessive speeds, unsafe road conditions, and the risks of drunk drivers almost makes me want to stay off the highways.

With recent bills pertaining to mandatory use of seat belts I can say that use of seat belts is a very good idea for everybody. Senior citizens, adults, teenagers, and small children should all be protected by such devices.

My main concern is that there are no seat belts school buses. School buses serve as a major source of transportation for children ranging from grades K through 12. In event of an accident there is nothing to keep a child in his/her seat. This fact should be looked at more seriously.

Thank you for your time, please keep my concerns with automobile safety and seat belts on school buses a priority in your busy schedule.

Sincerely,

Nadra L. Angerman

ID: nht87-2.2

TYPE: INTERPRETATION-NHTSA

DATE: 06/08/87

FROM: ROSE TALISMAN -- JOAN FABRICS CORP

TO: DOUG COLE -- NATIONAL VAN CONVERSION ASSOC., INC.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A32, STANDARD 302; LETTER DATED 06/29/87 FROM JONATHAN JACKSON TO DOUG COLE; LETTER DATED 06/22/87 FROM ROSE M. TALISMAN TO DOUG COLE; LETTER DATED 06/23/87 FROM DOUG CO LE TO STEVE KRANTZKE

TEXT: Dear Mr. Cole:

In accordance with our understanding from Mr. Irving Brown of C.M.I. Automotive, we are sending to your attention the specifications from both Ford Motor Company and General Motors in Detroit regarding the specific testing procedures required for meeting their codes for fire retardancy.

As you are well aware, we have run correlation studies on our pattern Passport with your recommended testing agency, Commercial Testing Company of Dalton Georgia. The test results have indicated a specific difference in correlation depending on the test method utilized. The method utilized and recommended to us by both Ford Motor Company and General Motors which requires the use of heat resistance support wires as stated on the attached specification are the direct guidelines we utilized in testing al l fabric designated for motorized product from our mill.

We certainly would be happy to discuss the rational and our specific methods for testing based on Detroit's specific requirements. Do not hesitate to call if you have any questions or need additional information.

Ford Laboratory Test Methods;

FLAMMABILITY TEST FOR AUTOMOTIVE INTERIOR MATERIALS

II. Small Parts (contd.)

A surrogate test plaque specimen made with a composition identical to that of the component material(s) shall be produced in the shape of a rectangle 4 inches (100 mm) wide, 14 inches (356 mm) long and the minimum thickness of the component up to 1/2 inch (12.7 mm) maximum, employing the same or equivalent process as used to produce the component part. The thickness of the plaque is that of the material as utilized in the vehicle except where it exceeds 1/2 inch (12.7 mm). In those applications, th e plaque is to be reduced to a uniform thickness of 1/2 inch (12.7 mm) to include the surface material exposed to the occupant compartment air space.

Test Procedure 1. Prior to testing, each specimen is conditioned for 24 hours at a temperature of 73.4 +/- 3.6 degrees F (23.0 +/- 2.0 degrees C) and 50 +/- 5% relative humidity and the test is conducted under those conditions.

2. Material is placed in the specimen holder as indicated below and tested in the direction (transverse or longitudinal) that produces the most adverse results. The specimen is oriented so that the surface closest to the occupant compartment air spa ce faces downward on the test frame.

(a) The standard test specimen (4 x 14 in (100 x 356 mm) x thickness) is inserted between two matching U-shaped frames (specimen holder) so that both sides of the specimen are held by the frames. The temperature of the frame in Figure 4 at the start of each test shall not exceed the conditioned temperature as stated above in Paragraph 1 of Test Procedure.

(b) Where the maximum available width of the specimen is 2 in (50 mm) or less so that the sides of the specimen cannot be held in the two matching U-shaped frames, it is to be supported by the use of 10 mil (0.25 mm) wires spanning the top surface of the bottom U-shaped frame at 1 in (25 mm) intervals, keeping such specimens from bending away from the horizontal at the flaming end, thereby allowing a more uniform and constant burn rate (see Figure 5). The bottom U-shaped frame shall always be positi oned so that the wires are "sandwiched" between the top and bottom frames.

(c) Samples tested with support wires: Flexible specimens, such as genuine leather, supported and unsupported vinyls, textile and backing fabrics, foams, textile padding[Illegible Word] compounds, etc., that frequently soften and bend at the flaming e nd so as to cause a non-uniform, uneven burn rate.

Samples tested without wires: Less flexible materials such as paperboard, carpets, rigid plastics, etc., seldom soften and bend at the flaming end; therefore, do not justify or necessitate support wires.

(d) Adjust ventilation hood door opening to approximately 23 in (580 mm) and regulate ventilation up to 110 CFM (0.052 m<3>/s) maximum air flow to prevent smoke and fumes from entering room.

ID: nht87-2.20

TYPE: INTERPRETATION-NHTSA

DATE: 06/22/87

FROM: ROSE M. TALISMAN -- JOAN AUTOMOTIVE INDUSTRIES TESTING LAB

TO: DOUG COLE -- NATIONAL VAN CONVERSION ASSOCIATION, INC.

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A 32, STANDARD 302; LETTER DATED 06/08/87 FROM ROSE TALISMAN TO DOUG COLE; LETTER DATED 06/23/87 FROM DOUG COLE TO STEVE KRANTZKE; LETTER DATED 06/29/87 FROM JONATHAN JA CKSON TO DOUG COLE

TEXT: Dear Doug:

As I stated earlier correspondence Joan Automotive Industries conducts its flammability testing according to Federal Motor Vehicle Safety Standard No. 302. This includes the use of heat resistant support wires as indicated in paragraph S5.1.3, "A specime n that softens and bends at the flaming end so as to cause erratic burning is kept horizontal by supports consisting of thin, heat resistant wires, spanning the width of the U-shaped frame under the specimen at 1-inch intervals."

It is our belief that this method satisfies the requirements of FMVSS 302 testing and is the standard industry procedure for testing automotive bodycloth.

Please keep us informed as to what the Department of Transportation's response is to your inquiry.

ID: nht87-2.21

TYPE: INTERPRETATION-NHTSA

DATE: 06/23/87

FROM: DOUG COLE -- NATIONAL VAN CONVERSION ASSOCIATION INC

TO: STEVE KRANTZKE -- NHTSA/

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 FROM ERIKA Z JONES TO DOUG COLE; REDBOOK A32, STANDARD 302; LETTER DATED 06/29/87 FROM JONATHAN JACKSON TO DOUG COLE; LETTER DATED 06/22/87 FROM ROSE M TALISMAN TO DOUG COLE; LETTER DATED 06/08/87 FROM ROSE TAL ISMAN TO DOUG COLE

TEXT: Hi Steve!

It was a pleasure talking with you and thanks again for a speedy returned call. George Shiflett recommended I contact your office about an issue that has arisen from a Certification program that National Van Conversion Association (NVCA) sponsors. The i ssue surrounds the question of "compliance with FMVSS #302".

A part of NVCA's Certification includes the physical gathering of random samples of fabrics, foams, carpets, and other flammable items that van conversion firms use in vehicles. These samples are then channeled to an accredited testing firm for destruct ive testing to verify compliance with FMVSS #302. NVCA has found many samples, according to the tests performed, not to be in compliance with FMVSS #302. The manufacturers of these samples vehemently oppose NVCA's findings and insist that their samples are indeed in compliance with FMVSS #302.

In an effort to double check NVCA's test procedures, I contacted four major testing laboratories recommended by the American Association of Motor Vehicles Administrators. Half of those contacted suggested that NVCA's test methods were correct and the ot her half disagreed. Each half was quite certain they were right. The issue appears to be about when to use (or not to use) support wires in conjunction with the FMVSS #302 test. NVCA doesn't use any support wires in its test; some fabric manufacturers use support wires in their tests. In many (not all) instances, these support wires are an influence on whether a material passes or fails the FMVSS #302 test. Will you please clarify for us whether to use or not to use the support wires?

I have enclosed copies of test procedures from NVCA's testing lab, a fabric manufacturer, Ford, and Fisher Body Division of GM for your review. Also enclosed is a copy of a letter NVCA will include with its communications with conversion firms (in the c ase of a FMVSS #302 failure, per NVCA's current test methods). If you see anything that we need to alter immediately, please contact me; if not, I realize your interpretations, comments, opinions, rulings, or whatever may take some time to formulate and NVCA will proceed as normal until we hear from you. Your assistance in this matter will be greatly appreciated by many involved. If I can provide any additional data or be of service in any way, please call on me.

ENCLOSURE

ID: nht87-2.22

TYPE: INTERPRETATION-NHTSA

DATE: 06/24/87

FROM: DIETMAR K. HAENCHEN -- VOLKSWAGEN OF AMERICA, INC.

TO: ERIKA Z. JONES -- NHTSA

TITLE: REQUEST FOR INTERPRETATION - FMVSS 205

ATTACHMT: ATTACHED TO LETTER DATED 11/03/88 FROM ERIKA Z JONES TO DIETMAR K HAENCHEN; REDBOOK A32 (2), STANDARD 205

TEXT: Dear Ms. Jones:

The design of passenger cars has changed in recent years to reduce aerodynamic drag and increase fuel efficiency. Volkswagen is planning to improve interior comfort and reduce energy consumption in future car models by introducing selected areas with re duced energy transmission via ceramic dots on the car's glazing. The reduced energy radiation into the interior increases driver's and passenger's comfort and results in increased active safety. We believe that the application of shaded areas on the wi ndows complies with the applicable safety standards. Different methods exist for shading those areas; the glass may be tinted like shade bands applied to windshields, or small ceramic dots can be applied on the glass surface having the same effect on th e reduction of energy transmission. The sections of glass selected for the application of the ceramic paint could, if not for styling aesthetics, be covered with sheet metal in order to avoid questions of interpretation of FMVSS 205. However, the styli ng incentive is compelling and driver visibility with the proposed configuration is better than total blockage with sheet metal, which would clearly be allowable. We are, therefore, seeking the agency's opinion of this concept which we are considering fo r the next new model line. While the agency does not give advance approval of specific product designs, the agency's opinion of whether the configuration proposed herein appears to comply with the applicable Federal Motor Vehicle Safety Standards will a id manufacturers in determining whether the numerous variations of the concept applied to various vehicles will comply with the standards.

Volkswagen has reviewed Standard 205 which in turn refers to ANS z26.1 (1980) which establishes requirements for safety glazing material for use in passenger cars. In Section 4.2 of ANS z26.1, specifications for items 1 and 2 glazing which VW intends to apply to the windshield and side/rear glass respectively refer to footnotes 1 and 3 when specifying Test 2 - Light Transmittance. Those footnotes allow areas of the glazing to have less than 70% light transmittance if the areas are not within the "leve ls required for driving visibility".

The term "levels requisite for driving visibility" has been used by the agency in interpretations and on several occasions has been addressed more precisely such as the interpretation to Mr. G. Nield on 15 February, 1974 as follows: "We (the agency) cons ider the word 'levels' in Standard 205 to mean vertical heights in relation to driver's eyes." To our knowledge the agency has not gone beyond the above interpretation in further defining "levels requisite for driving visibility".

In order to comply with FMVSS 205 Volkswagen deems it appropriate to use engineering judgement, applicable standards and technical recommendations to define these "levels" so that driving visibility is properly maintained with the installation of glazing material having areas within a single sheet of less than 70% light transmittance.

Footnote 1 of ANS z26.1 - 1980, although not expressively stated, refers mainly to shade bands and has been so construed and treated by the industry. The automobile industry so far has determined which areas are "requisite for driving visibility" and ha s marked the shaded areas as required. In these cases the industry determined how far shade bands can extend donward from the upper edge of the window and still be in compliance with FMVSS 205.

SAE J100 (passenger car glazing shade bands) also refers to ANS z26.1 when defining "glazing shade band" as "an area of the vehicle glazing through which light transmission is less than required for use at levels requisite for driving visibility by USAS z26.1". The SAE recommends shade bands above the 95th eyellipse only, but acknowledged at that time that substantial research to establish the driver's field of view did not exist. Volkswagen also believes that these data do not exist currently.

Guidelines for a determination of "levels" which extend upward from the bottom edge of the vehicle glazing are addressed in Directive 77/649 as amended in 81/643 of the European Economic Community (EEC). The directive specifies levels requisite for driv ing visibility in the driver's 180 degrees forward direct field of vision. Section 5.1.3 specifies the boundaries for the driver's forward direct field of vision by a horizontal plane through V[1] (upper boundary) and by three planes at downward angles of 4 degrees through V[2] (lower boundary). The latter describes the minimum field of view for small persons through the lower portion of the glazing.

The EEC in its effort to set angular limits for the driver's forward direct field of vision used anthropometric data of horizontal head and eye movement to arrive at the 180 degrees limit. The SAE in its information report J985 arrives at the same figur e when the angles of "maximum head movement (is) 60 degrees left and 60 degrees right" and "the eyes can turn 30 degrees to the right in one rapid, smooth movement", are combined.

For the rear visibility in the U.S., the "levels requisite for driving visibility" are not specified if a passenger side rearview mirror is used according to FMVSS 111. Technically, the complete rear glazing can be blocked by a vehicle manufacturer if a passenger side rearview mirror is installed as standard equipment. Volkswagen intends to install a passenger side outside mirror as standard equipment in conjunction with the subject shading configuration and also to provide an area in the rear glazing with transmissability of greater than 70%.

With this background, Volkswagen is planning to include either tinted bands or ceramic dots on glazing as described in Attachments I and II. Volkswagen believes that this concept clearly allows light transmittance in excess of 70% in the areas requisite for driving visibility and consequently should adequately satisfy the safety needs for overall driving visibility.

Volkswagen has tested these boundaries according to the specifications of 77/649/EEC and concluded that ceramic dots in the area defined in 5.1.3 very well cover the vertical heights in relation to even small driver's eyes, which are "requisite for drivi ng visibility". In addition we have designated the area adjacent to the right and left hand outside mirrors as requisite for driving visibility.

This proposal has been approved by the German government (KBA) as recommended by the Technical Service Hannover. This approval was based on the fact that it complies with the driver's direct field of view (forward 180 degrees) and that unobstructed outs ide rearview mirrors are used on both sides to supplement the inside rearview mirror for the driver's indirect field of view. This approval is based on compliance with the applicable EEC Directive and therefore will likely be acceptable to all Common Ma rket countries.

Volkswagen requests the agency's opinion of this proposal and an interpretation of whether the markings described in Section 6 of ANS z26.1 would be required to show the limits of the area that is intended to comply with the 70% transmittance requirement . If required, Section 6 states that the glazing "shall be permanently marked at the edge of the sheet to show the limits of the area that is intended to comply with Test No. 2" (70% transmissability). Interpretation is requested of where these markings should be placed for the configurations shown in Attachments I and II if they are required. Since this is under consideration for the next model year, a timely response is requested.

ATTACHMENTS

ATTACHMENT I

Lichtdurchlassigkeit zwischen 75% and 82% LIGHT TRANSMITTANCE BETWEEN 75% AND 82%

Lichtdurchlassigkeit von 30% , 70% LIGHT TRANSMITTANCE FROM 30% TO 70%

Lichtdurchlassigkeit 30% LIGHT TRANSMITTANCE 30%

Lichtdurchlassigkeit zwischen 75% und 77% LIGHT TRANSMITTANCE BETWEEN 75% AND 77%

Lichtdurchlassigkeit von 30% > 70% LIGHT TRANSMITTANCE FROM 30% TO 70%

Lichtdurchlassigkeit zwischen 72% und 75% LIGHT TRANSMITTANCE BETWEEN 72% AND 75%

Warmeschutzverglasung HEAT ABSORBING GLASS

E/KK - AA 87.01.

ATTACHMENT II

Lichtdurchlassigkeit zwischen 75% und 82% LIGHT TRANSMITTANCE BETWEEN 75% AND 82%

Lichtdurchlassigkeit von 30% > 70% LIGHT TRANSMITTANCE FROM 30% TO 70%

Lichtdurchlassigkeit 30% LIGHT TRANSMITTANCE 30%

Lichtdurchlassigkeit zwischen 75% und 77% LIGHT TRANSMITTANCE BETWEEN 75% AND 77%

Lichtdurchlassigkeit von 30% > 70% LIGHT TRANSMITTANCE FROM 30% TO 70%

Lichtdurchlassigkeit zwischen 72% und 75% LIGHT TRANSMITTANCE BETWEEN 72% AND 75%

Warmeschutzverglasung HEAT ABSORBING GLASS

E/KK - AA 87.01.

ID: nht87-2.23

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 25, 1987

FROM: MARY F. BARRAS -- SALES ASSISTANT, CONTRACT ADMINISTRATION, M.A.N. TRUCK & BUS

TO: MICHAEL W. VORIS -- BUS PROCUREMENT SUPERVISOR, METRO

TITLE: CONTRACT NO. T/F 19-83 REAR EMERGENCY WINDOW

ATTACHMT: MEMO DATED 2-23-88, TO JAY COSTA, FROM ERIKA Z. JONES, STD 271, REDBOOK A31; MEMO DATED 6-18-87, CONTRACT NO. T/F 19-84 REAR EMERGENCY WINDOW; MEMO DATED 7-21-87, TO ERIKA Z. JONES, FROM JAY COSTA

TEXT: Further to my letter of June 18, 1987 pertaining to the subject matter, this letter is to serve as clarification in regard to our position, the manufacturer, of the subject contract trolley buses.

* The trolley bus, as manufactured and delivered to Metro Seattle, more than exceeds the standards set forth by FMVSS 217.

* Paragraph S5.2.1 of the information previously submitted, states that at least one (1) rear exit shall be provided unless the bus configuration precludes the installation of an accessible rear exit. The trolley bus design of the subject, contract d oes not preclude the installation of an accessible rear exit; therefore, because of this requirement and our interpretation of FMVSS 217, a rear exit is provided.

Considering the above, M. A. N. Truck & Bus Corporation recommends that the rear window, as delivered to Seattle Metro, should remain as designed.

ID: nht87-2.24

TYPE: INTERPRETATION-NHTSA

DATE: 06/26/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Bill Schuette

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Bill Schuette U.S. House of Representatives P.O. BOX 631 Midland, MI 48640

Dear Mr. Schuette:

Thank you for your June 4, 1987, letter on behalf of your constituent, Mr. Dale Lighthill of Owosso. Mr. Lighthill owns a semi-trailer which he has converted into a travel home. He wishes to know whether there is any law which prohibits him from carrying persons in his travel trailer.

Our agency is responsible for promulgating safety standards for the manufacture and sale of new motor vehicles. We have no jurisdiction over the use of motor vehicles and thus have no regulation prohibiting Mr. Lighthill from carrying people in his trave l home trailer. However, many states have enacted provisions in their vehicle codes for occupying moving trailers. Some states prohibit persons from occupying a moving trailer or operating a motor vehicle which is towing an occupied trailer, and some per mit occupying a moving trailer only under certain circumstances. I am certain that the officials of the states your constituent plans to visit will be happy to provide information on their laws for transporting persons in moving trailers. In addition, Mr . Lighthill night find it helpful to contact the American Association of Motor Vehicle Administrators (AAMVA) for general information on state requirements. The AAMVA may be reached at: Suite 910, 1201 Connecticut Avenue, N.W., Washington, D.C., 20036. T elephone: (202) 296-1955.

Thank you for contacting our office. Please contact me if you or your constituent have any questions.

Sincerely,

Erika Z. Jones Chief Counsel

Erika Jones Chief Counsel NHTSA 400 7th Street, SW Room 5219 Washington, D.C. 20590

Dear Erika:

I am writing with a request from my constituent, Dale Lighthill, of Owosso, Michigan. Mr. Lighthill owns a semi-trailer which has been converted into a travel home. He would like to know if there are any laws prohibiting carrying someone in the trailer s ection of this travel home anywhere in the continental U.S.

I would appreciate it if you could research this question and advise me at my Midland District Office of your findings. Thank you very much for your time and attention to this matter.

Sincerely,

Bill Schuette Member of Congress

ID: nht87-2.25

TYPE: INTERPRETATION-NHTSA

DATE: 06/29/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Hisashi Tsujishita

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Hisashi Tsujishita Chief Co-ordinator Technical Administration Department 1. Diahatsu-cho, Ikeda City Osaka Prefecture JAPAN

Dear Mr. Tsujishita:

Thank you for your letter requesting an interpretation of the requirements of three of our safety standards. This letter responds to your question concerning Standard No. 101, Controls and Displays. A response to your question concerning Standard No. 219 was sent to you earlier, and we expect to respond to your question concerning Standard No. 201 shortly.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the"National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable safety standards. The following represents our opinion based on the facts provided in your letter.

You asked whether Standard No. 101's illumination requirements apply to controls and displays not otherwise regulated by the standard. You quoted section S5.3.3's requirements for the light intensities of informational readout systems and asked whether t hose requirements apply to the following such items: digital clock using liquid crystals; radio employed digital frequency indicator using liquid crystals; and miscellaneous illuminations for conventional analog clock, cigar lighter, ashtray, and radio c ontrol switches, etc., which are lighted only when the headlights or parking lights are activated.

I would like to note that Standard No. 101's requirements for light intensities were amended in a final rule published in the Federal Register (52 FR 3244) on February 3, 1987. An effective date of March 5, 1987, was adopted for most of the amendments. S ubsequently, in response to petitions for reconsideration, NHTSA amended 49 CFR Part 511 to permit compliance with either the earlier version of the standard, reissued as Standard No. 100, or the amended standard until September 1, 1989. 52 FR 7150, Marc h 9, 1987. I have enclosed copies of those notices for your convenience.

In answering your question, I will separately discuss the requirements for vehicles manufactured on or after September 1, 1989, and vehicles manufactured before that date.

Vehicles manufactured on or after September 1, 1989

Vehicles manufactured on or after September 1, 1989, must meet the requirements of the current version of Standard No. 101. Section S5.3.5 provides:

S5.3.5 Any source of illumination within the driver's forward field of view which is not used for the controls and displays regulated by this standard, and which is capable of being illuminated while the vehicle is in motion, must have either a variable intensity, a single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or a means of being turned off. This requirement shall not apply to buses that are normally operated with the passenger compartment i lluminated.

As noted in your letter, the items you listed are not among the controls and displays generally regulated by Standard No. 101. However, if sources of illumination for those items are within the driver's forward field of view and are capable of being illu minated while the vehicle is in motion, they must meet the requirements of section S5.3.5.

Vehicles manufactured before September 1, 1989

Standard No. 100, i.e., the earlier version of Standard No. 101, applies only to vehicles manufactured before September 1, 1989. The application sections of Standards Nos. 100 and 101 make it clear that manufacturers have the option of meeting the requir ements of either standard for any control, display or illumination until September 1, 1989. Also, the application section of Standard No. 101 provides that if no requirements are specified in Standard No. 100 for a control, display, or illumination, none need be met as a result of Standard No. 101 for motor vehicles manufactured before September 1, 1989.

Section S5.3.3 of Standard No. 100 provides:

Light intensities for controls, gauges, and their identification shall be continuously variable from: (a) A position at which either there is no light emitted or the light is barely discernible to a driver who has adapted to dark ambient roadway conditio ns to (b) a position providing illumination sufficient for the driver to identify the control or display readily under conditions of reduced visibility. Light intensities for informational readout systems shall have at least two values, a higher one for day, and a lower one for nighttime conditions. The intensity of any illumination that is provided in the passenger compartment when and only when the headlights are activated shall also be variable in a manner that complies with this paragraph. (Emphasis added.) In considering manufacturer options under Standards No. 100 and 101, for vehicles manufactured before September 1, 1989, the following points should be noted:

(1) Some illuminations covered by the highlighted language of Standard No. 100 are not covered by section S5.3.5 of Standard No. 101. An example is a control located in the rear seating area that is illuminated only when the headlights are activated. Sin ce a manufacturer may meet the requirements of either Standard No. 100 or Standard No. 101 for any illumination and no requirement is specified for such illuminations in Standard No. 101, no requirement need be met for such illuminations.

(2) Some illuminations not covered by the highlighted language of Standard No. 100 are covered by section S5.3.5 of Standard No. 101. An example is a clock, located in the driver's forward field of view, which is always illuminated as a result of utilizi ng light emitting diodes. No requirement need be met for such illuminations (for vehicles manufactured before September 1, 1989).

(3) Some illuminations covered by the highlighted language of Standard No. 100 are also covered by section S5.3.5 of Standard No. 101. For these illuminations, the requirements of section S5.3.5 of Standard No. 101 are more flexible. While the highlighte d language of Standard No. 100 provides that such illuminations must, depending on the illumination, be either continuously variable or have at least two values, one for day and one for night, section S5.3.5 of Standard No. 101 provides three options for all such illuminations. Such illuminations must have either a variable intensity, i.e., at least two levels of intensity; a single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions; or a means of being t urned off.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

Dec. 24 , 1986

Ms. Erika Z. Jones Chief Counsel Office of the Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones:

The purpose of this letter is to respectfully inquire NHTSA's interpretations with regard to the Federal Motor Vehicle Safety Standards (FMVSS) Nos. 101, 201, and 219.

We wish we could have your early and kind response to the questions on the following pages.

We thank you in advance for your kind attention to this matter.

Sincerely yours,

H.Tsujishita Chief Co-ordinator of Technical Administration Dept. Head Office

Enclosure : QUESTIONNAIRE (1),(2),(3) cc: Mr. R. Busick, Olson Engineering Inc.

QUESTIONNAIRE (1)

FMVSS No. 101 ; Controls and Displays

Paragraph S5.3.3 of FMVSS No. 101 provides that;

"Light intensities for informational readout systems shall have at least two values, a higher one for day, and a lower one for night time conditions. The intensity of any illumination that is provided in the passenger compartment when and only when the h eadlights are activated shall also be variable in a manner that complies with this paragraph."

However the applicable items(illuminations) of the above provision are not necessarily definitely for us.

We believe that these provisions are applied only to the illuminations for the controls or gauges which are somehow regulated otherwise in FMVSS No. 101, and are not applied to the illuminations which are optionally equipped and are not otherwise mention ed in the standard, such as following illuminations in concrete;

(1) Digital clock using liquid crystals (2) Radio employed digital frequency indicator using liquid crystals

(3) Miscellaneous illuminations for conventional analog clock, cigar lighter, ashtray, and radio control switches, etc. which are lightened only when the headlights (parking lights) are activated.

We would like to confirm that the above items are not applied the variable illumination requirements. Please advise us in detail in this matter.

QUESTIONNAIRE (2)

FMVSS Ho. 201 ; Occupant Protection in Interior Impact

Paragraph S3.5.1(c) of FMVSS No. 201 provides the dimensional requirements for armrests as follows;

"Along not less than 2 continuous inches of its length, the armrest shall, when measured vertically inside elevation, provide at least 2 inches of coverage with the pelvic impact area."

Our concern, however, centers on how to measure the armrest vertically in side elevation.

We believe that this provision does not necessarily require completely plain area of 2 in. x 2 in. on the armrests such as Ill.1 below, and that the armrests which have, to some extent, rounded inside surface, such as Ill.2, shall be deemed in compliance with this provision.

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And we also believe that no matter how the armrests have more than 2 in. side elevation considerably sharply projected armrests such as Ill.3 shall be deemed in noncompliance with the provision.

However, we can not be sure the criteria for distinguish Ill.2 from Ill.3. Though we think the most important point to be concerned is its contactability by the occupant , we can not necessary surely know the procedures to prove the contactability.

Therefore we would like to ask your kind favor of showing us ' the guideline to how to measure armrests to decide the compliancy to S3.5.1(c).

And further, as we are designing a little more complicated shape such as shown on the next page, we wish you would advise us about the compliancy of the armrest.

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FMVSS No. 219 ; Windshield Zone Intrusion

Paragraph S5 of FMVSS No. 219 provides:

"When the vehicle ......, no part of the vehicle outside the occupant compartment, except windshield molding and other components designed to be normally in contact with the windshield, shall penetrate the protected zone template, ...."

In the case that the windshield wiper penetrate the protected zone template ( by some reason such as pushed by the deformed cowl , or accidentally turned-on of wiper switch as a result of contact with test dummy), we would like to confirm whether the veh icle is deemed in compliance or not. (Refer to the illustration below)

We believe the penetration of wiper blades shall be deemed in compliance because the wiper blades are designed to be normally contact with the windshield. The wiper arms, however, only contact with the windshield though the wiper blade. Please advise us about the exemption of wiper arms from this intrusion provision.

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