ID: nht73-3.49

DATE: 04/04/73

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

TO: Wagner Electric Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 16, 1973, requesting an interpretation of paragraph S5.4.1 of Federal Motor Vehicle Safety Standard No. 105a.

Answers to your questions are as follows:

1. The reservoir configuration in your Sketch No. 1 would meet the requirements of S5.4.1 for compartmentalized reservoire. We have provided a similar interpretation to General Motors Corporation on this point, which is enclosed for your reference.

2. Since the configuration of your Sketch No. 1 conforms to S5.4.1, a single fluid level sensing device is acceptable.

3. The configuration shown in your Sketch No. 2 would not comply with volumetric requirements of S5.4.2 since your "reserve" fluid volume plus "protected" fluid compartments "A" and "B" volumes would not be equal to the total volume required by S5.4.2. S5.4.2 requires a volume for each reservoir equal to the fluid displacement resulting when all-wheel cylinders or calipor pistons serviced by the reservoir move from a new lining, fully retracted position (etc) to a fully worn, fully applied position. Thus, if this final condition existed on both subsystems, one subsystem would not have the specified fluid available.

4. The configuration depicted in your Sketch No. 3 would meet the requirements of S3.4.1 and S5.4.2 as well as S5.3.1(b) assuming the indicator lamp would be activated at or above the 25 percent level of fluid volume.

5. The configuration shown in your Sketch No. 4 would meet the requirements of S5.4.1 and S5.4.2 as well as the requirements of S5.3.1(b) with the same assumption that the lamp would be activated at or above the 25 percent fluid volume level.

ENC.

ID: nht73-3.5

DATE: 11/22/73

FROM: AUTHOR UNAVAILABLE; Claude S. Brinegar; NHTSA

TO: Honorable John E. Moss; House of Representatives

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 26, 1973, concerning our estimate of the time required by vehicle manufacturers to meet the adopted and proposed(Illegible Word) to Motor Vehicle Safety Standard No. 301, Fuel System Integrity.

Our basic approach to leadtime analysis in the automotive industry has been along the lines set forth in(Illegible Word) automotive engineering studies prepared in the early days of the highway safety program by Arthur Young and Company, and by Booz, Allen, and Hamilton. Over the years, we have found these studies to be accurate predictors of the time required to make substantial structural modifications to production vehicles.

On the basis of our preliminary crash tests, we concluded that to meet the 30 mile-per-hour, rear moving barrier crash test, the rear-end structure of a typical vehicle would have to be strengthened considerably. To accomplish such strengthening, the manufacturers may have to change the gauge of metal used, the configuration of the underbody and interior panels, and the location and design of interior braces and(Illegible Word). Any changes of this nature will require major tooling modifications, and tool modification has historically occupied a major portion of the leadtime needed to effect a change.

Our leadtime evaluation, based on our usual techniques, indicated that the tooling time and other production planning time required for the structural changes we expect to be necessary to meet the standard

be at least two years. To this time must be added the time required for us to complete the rulemaking process and present the manufacturers with a final standard to which they can design their vehicles. We were, therefore, obliged to conclude that there was not enough time remaining before September 1975 to allow manufacturers to meet the standard with their 1976 models.

In this as in most rulemaking actions, we are working without benefit of information from the manufacturers on their projected expenditures of funds and man-hours. I would like to be able to tell you, to the minute, what those projections are, but the best I can say is that we have no indications that the manufacturers' plans could place conforming cars in production in less than the time specified in our proposal.

I remain committed to the pursuit of this rulemaking action and assure you that it will be completed expeditiously.

ID: nht73-3.50

DATE: 04/04/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Young Windows, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 20, 1973, requesting clarification of the certification and labeling requirements of Motor Vehicle Safety Standard No. 205, "Glazing Materials", for persons who cut sections of glazing materials. You state your understanding is that such persons should add to the cut piece the DOT symbol and the manufacturer's code mark used on the larger piece from which the smaller piece was cut. Your understanding of these requirements is not correct. The labeling requirements of Standard No. 205 were most recently amended on November 11, 1972 (37 FR 24035, copy enclosed). These amendments become effective April 1, 1973. They require a person who cuts glazing material to mark it in accordance with section 6 of ANS Z26. This does not include the DOT symbol and the mark of the manufacturer of the larger sheet, and these items should not be included by persons who only cut the material. That person must also certify the material in accordance with section 114 of the National Traffic and Motor Vehicle Safety Act (15 USC 1403). One method by which this can be done is to affix a removable label to the glazing material which states that it conforms to the Federal safety standard.

You ask how the "AS12" and "AS13" marking should be affixed. The "AS" designation is part of the labeling required by section 6 of ANS Z26, and it should be applied in the manner that the other labeling items of that section are applied. We understand etching is the method ordinarily used, and it is appropriate.

ENC.

ID: nht73-3.6

DATE: 01/03/73

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

TO: Office of Operating Systems

TITLE: FMVSS INTERPRETATION

TEXT: Your memorandum of November 27, 1972, concerning non-tabulated values for tire inflation pressures.

In response to the above-captioned memorandum, we, in coordination with the Chief Counsel's office, have concluded that Standard No. 110 does not preclude the use of odd-numbered tire inflation pressures on the placard required by S4.3 of Standard No. 110, and that the standard does not prohibit interpolation of the load values of the Standard No. 109 tables for purposes of compliance testing.

The relevant language of Standard No. 110 is in paragraphs S4.3 and S4.3.1:

S4.3 Placard. A placard, permanently affixed to the glove compartment door or an equally accessible location, shall display the --

(c) vehicle manufacturer's recommended cold tire inflation pressure for maximum loaded vehicle weight and, subject to the limitations of S4.3.1 for any other manufacturer-specified vehicle loading condition . . .

S4.3.1 No inflation pressure other than the maximum permissible inflation pressure may be specified unless --

(b) The vehicle loading condition for that pressure is specified; and

(c) The tire load rating from Table 1 of @ 571.109 for the tire at that pressure is not less than the vehicle load on the tire for that vehicle loading condition.

There is nothing in the standard which specifically requires the inflation pressure to be one actually listed (even-numbered) in the Tables of Standard No. 109. While paragraph S4.3.1(c) of Standard NO. 110, in referring to the load rating found in the table, arguably implies such a requirement, we cannot, without more specific language, read into the standard that recommended inflation pressures must be even-numbered. The mere fact that the specific tire load rating will not be printed in the table, however, does not preclude enforcement of the placard requirement. Because interpolation of values in a table is accepted engineering practice, we conclude that it is reasonable to interpolate such values in the Tables of Standard No. 109, for purposes of enforcing Standard No. 110, where manufacturers have specified odd-numbered inflation pressures.

ID: nht73-3.7

DATE: 01/03/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Messrs. Carter and Carter

TITLE: FMVSR INTERPRETATION

TEXT: This is reply to your letter of December 14, 1972, to the Federal Highway Administration on behalf of your client, a snow plow dealer. You ask for verification "that the addition of a snow plow to a completed truck is considered the addition of a readily attached component and does not require recertification."

We confirm that a person adding a snow plow to a completed truck is not a final-stage manufacturer who is required by 49 CFR Part 568 to certify compliance of the vehicle with Federal motor vehicle safety standards. He is, however, responsible for insuring that the modified vehicle complies with Standard No. 108 before delivering it to its purchaser.

ID: nht73-3.8

DATE: 01/04/73

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

TO: Toyo Kogyo USA

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 28, 1972, asking for an interpretation of S5.2 of Safety Standard No. 105a.

The transmission you describe has a separate park position, and this position must be engaged before the ignition key can be removed. We confirm that a vehicle equipped in this manner may meet the parking brake system requirements of S5.2.2 rather than those of S5.2.1.

As for your second question, a vehicle with a manual transmission that must be placed in reverse gear before the ignition key can be removed would also meet the requirements of paragraph S5.2.2.

ID: nht73-3.9

DATE: 01/11/73

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

TO: Pilot, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of December 15, 1972, to the Department, you ask "Do the regulations require that the brake lite be activated prior to the onset on any brake pressure due to pedal travel can some brake pressure be on before the brake lite lights?"

Paragraph S4.5.4 of Motor Vehicle Safety Standard No. 108 Lamps Reflective Devices and Associated Equipment requires that "the stop lamps shall be activated upon application of the service brake." The standard does not state a specific time or brake line pressure at which activation shall occur so that some brake pressure is permitted at the activation point.

ID: nht73-4.1

DATE: 04/04/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Great Southern Equipment Company of Tampa

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 31, 1973, requesting "an application form and requirements for the mounting of hydraulic cranes behind the cab of . . . trucks".

Under NHTSA regulations, the operations you perform appear to make you a final-stage manufacturer who is responsible for the conformity of the completed vehicle to the Federal Motor Vehicle Safety Standards, and for certifying conformity in accordance with NHTSA Certification regulations (49 CFR Part 567), and regulations regarding Vehicles Manufactured in Two or More Stages (49 CFR Part 568). As a manufacturer you are also required to submit certain information required by Part 566, "Manufacturer Identification".

Copies of NHTSA regulations may be obtained as indicated on the enclosed, "Where to Obtain Motor Vehicle Safety Standards and Regulations". We have no requirements involving application to this agency. If after reviewing the regulations you have specific questions, we will be happy to answer them.

ENC.

ID: nht73-4.10

DATE: 04/11/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Gil-Mar Welding Corp.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of March 14, 1973, asking how to comply with NHTSA Certification regulations in cases where you supply a trailer chassis or frame only, and another manufacturer installs the body. In another example, you supply the vehicle without an axle assembly, which is, we assume, also installed by another party.

Based on your letter, the procedures to be followed in certifying vehicles such as these are those contained in NHTSA regulations for "Vehicles Manufactured in Two or More Stages" (49 CFR Part 568, copy enclosed). Briefly, these regulations require the incomplete vehicle manufacturer, who would be you in these cases, to furnish with the incomplete vehicle a document indicating the extent that the incomplete vehicle conforms to Federal standards, and what the final stage manufacturer must do in order that the completed vehicle will conform to all applicable standards.

If upon your review of these regulations you have further questions, we will be pleased to respond to them.

ENC.

ID: nht73-4.11

DATE: 04/17/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Habco Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letters of January 29 and March 20, 1973, concerning the application of the Federal motor vehicle safety standards to trucks to which you add railroad wheels, enabling the trucks to be driven on railroad tracks. In response to our letter to you of February 26, 1973, you enclosed in your letter of March 20 a picture representative of these vehicles, and provided us with certain information. Among other things you state that the vehicles are used on public highways approximately 50 per cent of the time, and that they are licensed under State laws.

Based on our examination of this picture, and the information provided with it, we are of the opinion that these vehicles are motor vehicles, specifically trucks, and are required to conform to all Federal motor vehicle safety standards applicable to trucks. This is true if the vehicles are new vehicles when you modify them, regardless of whether they are your own trucks or whether they are modified for customers.

The Certification requirement which you refer to is based on section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1403), and regulations issued by NHTSA (49 CFR Parts 567, 568, copy enclosed). Essentially, the regulations specify a means for manufacturers to certify their vehicles as conforming to all applicable Federal motor vehicle safety standards. Your responsibilities for Certification will depend upon whether you are an intermediate or final-stage manufacturer, as these terms are defined in the regulations. While it is your responsibility to determine which category applies to you, it appears to us that you are most likely an intermediate manufacturer. We base this opinion on the fact that the truck pictured Jacks a body, even though the railroad wheels have been added. It appears that some form of body will be added, as you state in your March 20 letter that the vehicles are

intended to be "spray trucks". If this is correct, your responsibilities for Certification are found at Part 568, "Vehicles Manufactured in Two or More Stages". Briefly, intermediate manufacturers are required to forward to the final-stage manufacturer the document the intermediate manufacturer received with the incomplete vehicle. If the intermediate manufacturer alters the vehicle so as to affect the validity of statements in the document, he is required to provide an addendum to the document indicating the changes he made.

If the vehicle is a completed vehicle before the rail wheels are added, your responsibilities are contingent upon the extent of the modification you perform. Because these modifications are significant with respect to the vehicle's intended use, we would consider section 567.4, "Requirements for Manufacturers of Motor Vehicles," the appropriate requirements for you to meet. The NHTSA has proposed requirements for vehicle alterers, which might apply to you in this case, but these requirements have not yet been issued in final form.

You may obtain copies of NHTSA requirements as specified on the enclosed form, "Where to Obtain Motor Vehicle Safety Standards and Regulations."

ENCLS.