ID: nht75-2.5

DATE: 11/25/75

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

TO: E. H. Wallace - Tire Division, OCA

TITLE: FMVSS INTERPRETATION

TEXT: Demonstration of Prototype Tires That are Not Certified as Complying with FMVSS No. 109

This is in response to your inquiry concerning the circumstances under which the demonstration of prototype tires would be permitted. I understand that representatives of Firestone Tire & Rubber Co. are visiting the NHTSA to discuss a newly designed passenger car spare tire which is not certified as complying with Standard No. 109. They wish to mount, on cars which have been driven to the DOT headquarters building on complying tires, samples of the spare tire and then to demonstrate the tire's performance on the local streets.

This demonstration would violate Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended, because use of such tires on the public roads would constitute an introduction in interstate commerce of an item of motor vehicle equipment which did not conform with an applicable motor vehicle safety standard. The alternative which you have suggested, mounting and demonstration of the tires on a runway at Bolling Air Force Base or other place out of the public traffic stream, is not prohibited by the Act or by our regulations.

ID: nht75-2.6

DATE: 09/16/75

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

TO: Kleber Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 3, 1975, asking whether it is permissible to import into this country a tire designed exclusively for racing purposes.

Tires designed to be used exclusively on racing vehicles, i.e., vehicles other than "motor vehicles" within the meaning of the National Traffic and Motor Vehicle Safety Act, are not regulated by the Federal motor vehicle safety standards, and may be imported. The labeling that you propose to use appears to be appropriate to warn users of their intended purpose. Manufacturers of such equipment should take all reasonable steps to ensure that their products are not misused.

YOURS TRULY,

June 3, 1975

OFFICE OF CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

Attention : Marc Schwimmer

First, let me briefly describe KLEBER CORP. KLEBER CORP. is a wholly owned subsidiary of KLEBER-COLOMBES of Paris, France. We are the second largest tire manufacturer in France after MICHELIN. All our tires are of radial concept. Since the beginning of this year, we are developing a distribution network in the U.S.A. Naturally, our passenger tires conform with Federal Standard 109.

In Europe, KLEBER manufactures tires that are designed for small formula cars (i.e.: Formula Ford). These tires are to be used exclusively on racing vehicles and not on regular automobiles. They do not bear the D.O.T. engravings.

We would like to import these tires in the U.S.A. and find that our sole competitor would be a GOODYEAR tire called "G-19". The "G-19" has no D.O.T. markings but on both sidewalls the caption "FOR RACING PURPOSES ONLY - NOT FOR HIGHWAY USE" appears in 1/4 inch letters.

We would like to know if it is legal to import and sell our tires (similar to the G-19) in this country, if, like GOODYEAR, we indicate "FOR RACING PURPOSES ONLY - NOT FOR HIGHWAY USE" on both sidewalls. As additional warning, we plan to print the same text on all invoices and literature related to these type tires.

On this subject, I contacted Mr. Diehl of the D.O.T. who feels that there should be no problem but suggested we check with you.

I am at your entire disposal for any further information you may need and remain,

KLEBER CORP.

Guy A. Catherine

General Sales Manager

ID: nht75-2.7

DATE: 11/03/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Walt Robbins, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 5, 1975, enclosing a copy of your patent for a tire described as a "Radial, Bias Ply Tire" and requesting an interpretation of the labeling requirements of Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires -- Passenger Cars. The tire would be constructed with three full body plies: two bias plies (angle 35 degrees) and one radial ply (angle 90 degrees).

S4.3(g) of the standard requires permanent molding of the word "radial" into or onto both sidewalls if the tire is a radial ply tire and, by implication, prohibits the use of the word "radial" if the tire is not a radial ply tire. In S3., "radial ply tire" is defined as:

a pneumatic tire in which the ply cords which extend to the beads are laid at substantially 90 degrees to the centerline of the tread.

The tire you have described is not within the scope of this definition because it includes ply cords extending to the beads which are not laid at substantially 90 degrees to the centerline of the tread. Therefore, the word "radial" must not appear on either sidewall.

SINCERELY,

Walt Robbins Incorporated

June 5, 1975

Mark Schwimmer National Highway Safety Administration Office of Chief Counsel

Enclosed is a copy of our patent #3,672,423. I would appreciate it if you would review this and notify me as to what the labeling requirements would be for the tire construction as shown in this patent, with reference to paragraph S4.3, subparagraph h, of MVSS100. As I interpret your labeling requirements, the radial designation would be adequate as this is a full radial ply. In addition to the radial ply, we have two bias plies, so my question to you is should this be designated radial or radial/bias.

I would appreciate an answer as soon as possible inasmuch as we have completed DOT testing and are ready for production. Your cooperation in this matter will be most appreciated.

VENTURE TIRE CORP.

Walter C. Robbins, Jr. President

United States Patent

Duduk

[15] 3,672,423

[45] June 27, 1972

[54] RADIAL, BIAS PLY TIRE

[72] Inventor: Alexander Duduk, 2300 S 24th Road Apt. #731, Arlington, Va 22206

[22] Filed: April 7, 1970

[21] Appl. No.: 26,411

Patent Omitted.

ID: nht75-2.8

DATE: 09/19/75

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

TO: Ben Perchik

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 29, 1975, concerning tire identification markings, received by this agency on August 29, 1975.

I have attached two diagrams that illustrate the meaning of the tire code markings on new and retreaded tires. Immediately following "DOT" is a two- or three-letter code (marked in red on the diagrams) that indicates the manufacturer or retreader of the tire. I have also attached a list of the tire manufacturers and retreaders using each code. Following the manufacturer's code are two numbers representing the tire size (marked in blue on the diagrams). Next, some tires will have three letters or numbers which represent an optional tire type code mainly of use to the manufacturer (marked in yellow on the diagrams). The last three numbers represent the date of manufacture (marked in green on the diagrams).

I hope this information proves useful to you.

ID: nht75-2.9

DATE: 11/19/75

FROM: AUTHOR UNAVAILABLE; William T. Coleman, Jr.; NHTSA

TO: Hon. J. L. Whitten - H.O.R.

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of October 3, 1975, for Mr. Charles Russell of WJLJ, regarding tire failures on ambulances in Tupelo, Mississippi.

Pursuant to the National Traffic and Motor Vehicle Safety Act of 1966, the Department's National Highway Traffic Safety Administration (NHTSA) has issued Federal Motor Vehicle Safety Standard No. 109, 49 CFR 571.109, which specifies performance and labeling requirements for new tires for use on passenger cars. Among the labeling requirements is that such tires must have their load ratings molded into or onto both sidewalls. Standard No. 119, 49 CFR 571.119, establishes similar requirements for new tires for use on trucks, buses, trailers, motorcycles, and multipurpose passenger vehicles (MPV's). The choice of standard applicable to a given tire depends on that tire's primary intended use. These standards apply to tires, and not to vehicles.

To ensure that new vehicles are equipped with proper tires, the NHTSA has also issued Standard No. 110 for passenger cars and a proposed new Standard No. 120 that would apply to vehicles other than passenger cars. Briefly, Standard No. 110 requires each new passenger car to be equipped with tires which meet Standard No. 109 and which are of sufficient load carrying capacity, as evidenced by the load ratings found on the sidewalls. As proposed, Standard No. 120 would require MPV's (including ambulances) to be equipped with tires which meet either Standard No. 109 or No. 119, and which are of sufficient load carrying capacity. In the case of Standard 119 tires, sufficiency of load carrying capacity would be calculated directly from the tires' load ratings. In the case of Standard 109 (passenger car) tires mounted on an MPV, sufficiency would be determined by dividing the tire load ratings by a 110 percent correction factor before comparing these ratings with the vehicle's weight ratings. The use of passenger car tires on new ambulances would thus not be prohibited by the new standard, provided this load rating correction factor is applied. This provision would recognize an established practice which has not been found to preserve a safety hazard. Passenger car tires generally provide a softer, more comfortable ride than truck tires, because the latter operate at higher inflation pressures, and thus may even be more desirable on ambulances, provided they are of adequate load carrying capacity. The NHTSA expects to issue Standard No. 120 in the near future.

For your convenience, I am enclosing copies of Standards Nos. 109, 110, 119, and the proposed Standard No. 120.

ID: nht75-3.1

DATE: 09/04/75

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

TO: Yamaha International Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 5, 1975, asking whether a prototype "stiff rubber supported turn signal" would comply with S4.3.1 of Motor Vehicle Safety Standard No. 108.

S4.3.1 requires lighting equipment to "be securely mounted on a rigid part of the vehicle." Your proposed turn signal lamp is mounted at the end of a stiff rubber bracket which is attached to the vehicle. The bracket must be considered part of the vehicle. Obviously, even with a metal mounting there will be some vibration transmitted from the motorcycle to the lamp when the engine is running. We would consider the prototype mounting to be sufficiently "rigid" to conform to the standard if the rubber mount is stiff enough so that there is little or no amplification of vibration when the engine is running.

Yours truly,

ATTACH.

August 5, 1975

Office of the Chief Counsel National Highway Traffic Safety Administration Washington, D.C.

Dear Sir:

We are considering using a stiff rubber supported turn signal on some of our future model motorcycles.

We are not sure, however, if this device complies with the requirement of S4.3.1 of FMVSS 108, which states each lamp must be mounted on a "rigid part of the vehicle".

We would like to request an interpretation of FMVSS 108 to determine if this stiff rubber supported turn signal complies with the requirement for mounting of the lamp on a rigid part of the vehicle, as specified in S4.3.1.

We are sending, under separate cover, a sample of the device in question.

If you require any additional information or materials please contact me.

Sincerely,

Russ Jura -- Legislative Analyst, Engineering Division YAMAHA INTERNATIONAL CORPORATION

ID: nht75-3.10

DATE: 06/02/75

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Tiger Tanks; Division of Faull Enterprises, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 28, 1975, concerning the manufacture and installation of replacement tanks for Dodge, Ford, and Chevrolet vans.

The National Highway Traffic Safety Administration has promulgated no motor vehicle safety standard relating to replacement fuel tanks. There is, however, a safety standard which imposes performance requirements upon motor vehicles with regard to their fuel systems (Standard No. 301, Fuel System Integrity). Thus, if installation of your replacement tank is accomplished prior to the first purchase of the vehicle for purposes other than resale causing the vehicle's fuel system not to be in compliance with the applicable safety standard, the person installing the tank or offering the vehicle for sale would be in violation of @ 108(a)(1) of the National Traffic and Motor Vehicle Safety Act (Pub. L. 89-563). That would make the installer or seller subject to civil penalties of up to $ 1,000 for each violation.

Recent amendments to the Traffic Safety Act (Pub. L. 93-492) prohibit any manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable motor vehicle safety standard (@ 108(a)(2)(A)). Therefore, even if installation of your replacement tank occurred after the first purchase of the vehicle, the vehicle's compliance with the fuel system integrity standard would still be mandatory where one of the above named persons performed the installation. If the replacement tank caused the fuel system to no longer comply with the safety standard, the installer would have rendered inoperative a system installed in compliance with Standard 301.

The Traffic Safety Act authorizes the Secretary of Transportation to make determinations as to whether items of motor vehicle equipment contain defects which relate to motor vehicle safety. If he finds that a safety-related defect exists, he may compel the manufacturer to remedy the defect and notify purchasers of the hazard. Therefore, even though replacement fuel tanks are not the subject of a standard, they still must be designed for safety.

In addition, the Bureau of Motor Carrier Safety regulates interstate carriers, including fuel systems for operational and auxiliary equipment. These regulations might be of interest to you and are enclosed. Your attention is directed to the section concerning fuel systems, pages 51 through 54.

SINCERELY,

April 28, 1975

National Highway Traffic Safety Administration Department of Transportation

We wish to be informed as to what information is required of us to obtain your approval on our replacement fuel tank for Dodge, Ford and Chevy vans.

We are currently approved by the State of California Air Resources Board for the manufacturing installation and distribution of our fuel tank. (enclosure)

Our replacement fuel tank does not alter or change any standard fuel system or structual entities of the vehicle.

We are only adding an additional fuel capacity.

We are currently negotiating a contract with a company who is placing quite a large order and they are requesting that we have your approval.

We have checked with Ford Motor Company, Chrysler Corporation and General Motors Corporation and they have informed us that we do not need any approvals from them.

Thanking you in advance.

Alfred H. Faull President

Tiger Tanks Division of Faull Enterprises, Inc.

A Division of Faull Enterprises, Inc.

REPLACEMENT FUEL TANKS FOR DODGE, FORD, CHEVY VANS AND MINI MOTOR HOMES

* Construction of long ternes steel-lead coated inside and out.

* Made of the same metal as the Ford Motor Company. The Chrysler Corporation and General Motors Corporation use on all original fuel tanks.

* Construction of heavy duty 16 guage steel.

* Seam welded.

* New sending unit and mounting hardware included.

* Connects back to original equipment.

* Pressure tested.

* No inside oil coating to dissolve.

* No plastic lining to peel and clog fuel lines and carburetors.

* No rusting to clog carburetors.

* No exterior paint to peel and cause rusting.

* Approved by the California Air Resourse Board. MODEL WHEELBASE YEAR APPROX. CAPACITY - DODGE ALL WHEELBASE 70-75 48 gallons net FORD ALL WHEELBASE 68-75 46 gallons net CHEVY/GMC ALL WHEELBASE 71-75 45 gallons nets

O.E.M. SUGGESTED RETAIL $ 79.00 not installed $ 125.00 not installed $ 105.00 installed $ 150.00 installed

F.O.B. Carson, Calif. Terms are C.O.D.

Prices subject to change without notice.

Orders of 10 or more units - $ 69.95 per unit.

State of California AIR RESOURCES BOARD

EXECUTIVE ORDER F-39 Relating to the Accreditation of Auxiliary Gasoline Fuel Tank Evaporative Loss Control System

TIGER TANKS DIVISION OF FAULL ENTERPRISES INC.

Pursuant to the authority vested in the Air Resources Board by Sections 39106.5 and 39175 of the Health and Safety Code; and

Pursuant to the authority vested in the undersigned by Section 39023 of the Health and Safety Code;

IT IS ORDERED AND RESOLVED: That Tiger Tanks auxiliary gasoline fuel tank evaporative loss control system is accredited for installation on vehicles subject to evaporative emission control requirements and originally equipped with activated carbon canister type control systems.

This accreditation is for systems serving up to 100 gallons of total fuel storage. For each 50 gallons of fuel storage capacity the vapors shall be vented to a 500 to 625 gram capacity activated carbon vapor storage canister.

This Executive Order shall, without further action by the Executive Officer, cease to be of effect if fuel evaporative loss emission standards more stringent than those in effect on the date of this Order are established and made applicable to any vehicle for which the manufacturer's system is hereby accredited, unless prior thereto the manufacturer applies for and obtains from the Executive Officer, based upon a showing that its system complies with such more stringent standards, an appropriate amendment to this Order or a new Executive Order.

The manufacturer must obtain prior approval from the Air Resources Board before any production changes are made on the gasoline fuel evaporative loss control system that would affect evaporative emissions, or before the system is sold, offered for sale, or advertised under a different name, whether by the manufacturer or any other person.

The Department of Motor Vehicles, the California Highway Patrol, and the Bureau of Automotive Repair will be notified by copy of this order and attachment.

Executed at Sacramento, California, this 10th day of December, 1974.

GEORGE J. TAYLOR

WILLIAM SIMMONS FOR Executive Officer

NET GALLONS 48

(Graphics omitted)

NET GALLONS 46

LONG WHEEL BASE ONLY

NET GALLONS 45

ID: nht75-3.11

DATE: 11/25/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Company Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of April 22, 1975, posing several questions relating to Standard No. 302, 49 CFR 571.302. We are sorry for the delay in responding, but unfortunately your letter was filed in the docket as a response to a notice of proposed rulemaking concerning Standard No. 302.

Your first question relates to the requirement that the surface of the specimen closest to the occupant compartment air space face downward on the test frame. This requirement is now found in S5.2.2 of Standard No. 302, as published on September 16, 1975 (40 FR 45746). Through error, S5.2.2 was not amended when the standard was first amended on March 31, 1975 (40 FR 14318). This requirement applies to all test samples regardless of their thickness.

Your second question lists five components and asks whether they are included within Standard No. 302 as amended by Docket No. 3-3, Notice 7, and whether they would be included within Standard No. 302 if the amendment proposed by Notice 8 is adopted. Our answers follow:

1. The wiring harness illustrated in your letter need not currently meet the requirements of the standard, but would have to meet the requirements if it was located within 1/2 inch of the surface of the floor covering and Notice 8 was adopted as presently proposed.

2. The roof lamp need not currently meet the requirements of the standard, but would have to meet these requirements if Notice 8 was adopted as proposed.

3 and 4. The door lock and door handle knobs need not meet the requirements of the standard, but would have to if Notice 8 was adopted.

5. The floor grommets need not currently meet the requirements of the standard, but would have to meet these requirements if Notice 8 was adopted and they were within 1/2 inch of the surface of the carpet.

You are correct, therefore, in your analysis of the effect of Notice 8 as stated in your letter.

Your third question relates to whether the air space located behind the instrument panel and underneath the seat will be considered as part of the occupant compartment air space if Notice 8 is adopted. Assuming that the air behind the instrument panel is sealed off from the passenger compartment, it would not be considered part of the occupant compartment air space. The air under the seat cushion would be considered part of the occupant compartment air space unless it too is sealed off from the passenger compartment.

We trust these answers will be helpful to you.

YOURS TRULY,

ID: nht75-3.12

DATE: 03/07/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: YKK Zipper (U.S.A.) Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of February 13, 1975, in which you ask whether zippers fall under the purview of Federal Motor Vehicle Safety Standard No. 302.

S4.1 of the standard states that the following components of passenger cars, multipurpose passenger vehicles, trucks, and buses must meet its requirements:

Seat cushions, seat backs, seat belts, headlining, convertible tops, arm rests, all trim panels including door, front, rear, and side panels, compartment shelves, head restraints, floor coverings, sun visors, curtains, shades, wheel housing covers, engine compartment covers, mattress covers, and any other interior materials, including padding and crash-deployed elements, that are designed to absorb energy on contact by occupants in the event of a crash.

To the extent that a zipper in a part of any of these components, it would fall within the ambit of the standard while recreational vehicles are not currently covered by Standard No. 302, the National Highway Traffic Safety Administration issued on November 15, 1974, a Notice of Proposed Rulemaking to extend the coverage of the standard to include recreational vehicles (copy enclosed).

You should also be aware that other rulemaking relevant to the coverage of the standard is underway and will soon be published in the Federal Register. For this reason, we recommend you subscribe to either the Government Printing Office Safety Standard subscription service or an equivalent commercial service as detailed in the enclosure.

SINCERELY,

YKK ZIPPER (U S A) INC

February 13, 1975

Chief Council NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

We are manufacturers and suppliers of zippers and zipper chain to the Recreational Vehicle Industry and are confronted with a problem regarding Specification FMVSS-302 - Flammability Act.

We need a legal interpretation as to whether or not zippers are exempt from this 302 Spec. . No one is the R.V.I. Industry seems to have a clear concept as to the exemption or the inclusion of zippers.

The zipper industry feels that zippers are exempt from 302 as they are also exempt in the important field of Infants Wear (DOCFF 3-71).

Since time is of the essence we would appreciate a clear and concise legal interpretation immediately. Your attention to this matter will be most appreciated.

Thank you.

VICE PRESIDENT, SALES

ID: nht75-3.13

DATE: 06/25/75

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Emmons Brothers

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 1, 1975, concerning Federal Motor Vehicle Safety Standard No. 302, Flammability, and in amplification of your telephone conversation with Mr. Schwartz of my office.

As Mr. Schwartz advised you, Standard No. 302 applies to passenger cars, multipurpose passenger vehicles, trucks, and buses. Thus, the standard would apply to mattresses used in trucks. Further, it has been proposed to extend Standard No. 302 to campers and trailers other than those sold exclusively for the transportation of cargo (copy enclosed). Consequently, as you requested, I have enclosed a copy of Motor Vehicle Safety Standard No. 302, a recent amendment to that standard, and a proposed amendment which may also be of interest to you.