ID: nht73-1.4

DATE: 08/10/73

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

TO: Dow Corning Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 27, 1973, asking if there is a conflict between S5.4.3 of Motor Vehicle Safety Standard No. 105a and S5.2.1 of Standard No. 116.

There is no conflict. S5.4.3 of Standard No. 105a requires a label to be affixed to a new motor vehicle with the warning to use brake fluid from a sealed container. S5.2.1 of Standard No. 116 requires containers to be provided with resealable closures. A container with a resealable closure is "sealed" within the meaning of S5.4.3 if it is resealed after initial opening.

I enclose copies of both notices as they appeared in the Federal Register.

Yours truly,

Enclosure

July 27, 1973

National Highway Traffic Safety Administration -- Office of Chief Council,

Attention: Larry Schneider

Dear Mr. Schneider:

I am a member of the Transportation Products Division Executive Board of the Chemical Specialties Manufacturers Association. As a member also of the Brake Fluid Committee, I have been asked to determine the following information from your office. We need an interpretation of the specific meaning of the wording of the Federal Register, Volume 38, Friday, May 18, 1973, page 13017, paragraph S 5.4 regarding master cylinder reservoirs specifically where the reservoir "must be filled from sealed containers."

There is an apparant conflict with Federal Register Volume 36, June 24, 1971, paragraph S 5.2.1 in the 116 motor vehicle brake fluid standards in brake fluids. This states. "contents of six ounces or more must be in containers with resealable closures."

The conflict with many of our members is if the 116 motor vehicle brake fluids standards requires that the material be packaged in a container with a resealable closure, how does this then fit the wording of the previous Register, Volume 38, that it must be filled from sealed containers?

Is it possible that the Federal Register, Volume 38, is referring to fill from original containers or containers that have been immediately resealed after they are opened and when reused are the same condition as a sealed container?

It is very necessary that our CSMA group have an interpretation from you as to the seeming conflict. Our members need to know exactly how we can comply properly with both of these Federal Register issues.

For my own records, may I please have a copy or a xerox copy of the total wording of each of these Federal Register numbers for presentation to the CSMA Brake Fluid Committee. I would appreciate an early response to this request.

Very truly yours,

C. W. Todd -- Market Supervisor, Fluids, Emulsions and Compounds, Dow Corning

cc: Grace Fay -- National Highway Traffic Safety Admin. Motor Vehicles Program;

Mike Baldwin -- Dow Chemical Company

ID: nht73-1.40

DATE: 06/19/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Mobil Oil Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 1, 1973 and confirms the telephone conversation with Mr. Vinson of my staff on June 14, 1973.

The amendments to Motor Vehicle Safety Standard No. 116 published on May 17, 1973 modified container labelling requirements only for silicone-based brake fluid and hydraulic system mineral oil (paragraph S5.2.2.3) and did not affect the requirements for conventional DOT 3 and DOT 4 fluids (paragraph S5.2.2.2) as you assumed. Therefore you appear to have no problem, and it is not necessary to consider your letter as a petition for reconsideration.

The sample label you enclosed appears to designate the contents as "Super Heavy Duty Brake Fluid", rather than "DOT 3 MOTOR VEHICLE BRAKE FLUID" as paragraph S5.2.2.2(e) requires. Otherwise, it is adequate compliance with paragraph S5.2.2.2.

Sincerely,

Mobil Oil Corporation

June 1, 1973

T. Vinson -- National Highway Traffic Safety Administration Department of Transportation

FEDERAL MOTOR VEHICLE SAFETY STANDARDS

MOTOR VEHICLE BRAKE FLUIDS

PACKAGE LABELING

DOCKET NO. 71-13

Dear Mr. Vinson:

You may recall that on May 23, we spoke about the Motor Vehicle Brake Fluid Standard No. 116, identified as 571.116, Docket No. 71-13; Notice 4 and previous Notices. I mentioned that there were some changes in labeling instructions in Notice 4 as compared to the instructions which appeared in the Federal Register on Thursday, June 24, 1971, page 11989. I also mentioned that it would be virtually impossible to comply with the new labeling outlined in the May 17, 1973 Federal Register by the effective date of July 1, 1973.

You suggested that we might like to file a Petition of Reconsideration mentioning the two items which we discussed. Would you, therefore, please consider this letter as a Petition of Reconsideration.

1. Since it would be virtually impossible to prepare new graphics and lithography and have material packaged between now and July 1, 1973, and since the wording does not seem to represent a substantive change, we would like to make the labeling change in an orderly way. I would estimate this could be done in six to eight months after we know the exact wording to be used on the package.

2. The June 24, 1971 Federal Register carried as a caution, "DO NOT REFILL CONTAINER, AND DO NOT USE FOR OTHER LIQUIDS." The May 17, 1973 Federal Register carries the caution, "Do not refill container or use other liquids." It seems to me that the former wording is better than the latter. There is also a difference in the various Notices with respect to the use of upper and lower case letters. We would like to know exactly which words should be used before changing the graphics and notifying the can manufacturers to use new lithography on future containers.

You may be interested to see the marking on our current 16-oz Mobil Super Heavy Duty Brake Fluid package, so here is a copy of the art. When we redo the graphics, we will, of course, change the text in the upper half of the rear panel to reflect the newest SAE Specification J-1703c and the newest Federal Specification VV-B-680-B. We will also change the wording in the lower part of the back panel when we find out exactly what is wanted with respect to the caution and the use of upper and lower case letters.

Very truly yours,

J. W. Lane, Manager --

Product Promotion, Technical

Publications and Packaging

Attachment

DRY BOILING POINT EXCEEDS 450 F (232 C)

Mobil Registered

super heavy duty brake fluid

Surpasses SAE Specification J-1703b, conforms to Federal Specification VV-B-680-A, and to Federal Motor Vehicle Safety Standard No. 116, DOT 3 Motor Vehicle Brake Fluid.

KEEP OUT OF THE REACH OF CHILDREN

A non-volatile super heavy duty fluid for use in all types of auto and truck hydraulic brake systems where vehicle manufacturer specifies SAE J-1703b or DOT 3 Motor Vehicle Brake Fluid. Mixes perfectly with any automotive hydraulic brake fluid approved by vehicle manufacturers or which meets SAE Specification J-1703b, Federal Specification VV-B-680-A, or Federal Motor Vehicle Safety Standard, No. 116, DOT 3. Minimum wet boiling point 284 F (140 C). Do not spill on vehicle finishes.

CAUTION -- COMBUSTIBLE MIXTURE N.Y.F.D.C. OF A. NO. 1095

1. FOLLOW VEHICLE MANUFACTURER'S RECOMMENDATIONS WHEN ADDING BRAKE FLUID.

2. KEEP BRAKE FLUID CLEAN AND DRY, Contamination with dirt, water, petroleum products or other materials may result in brake failure or costly repairs.

3. STORE BRAKE FLUID ONLY IN ITS ORIGINAL CONTAINER. KEEP CONTAINER CLEAN AND TIGHTLY CLOSED TO PREVENT ABSORPTION OF MOISTURE.

4. CAUTION: DO NOT REFILL CONTAINER, AND DO NOT USE FOR OTHER LIQUIDS.

Distributed By Mobil Oil Corporation, New York, N.Y.

ID: nht73-1.41

DATE: 06/28/73

FROM: Richard B. Dyson; NHTSA

TO: Transportation Sash Co., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 21, 1973, requesting that we clarify the certification and marking requirements for glazing materials. You indicate that you purchase block size glass and cut it to suit your customers.

The requirements to which you refer are found in Federal Motor Vehicle Safety Standard No. 205, "Glazing Materials" (49 CFR @571.205). They require each item of glazing material to be labeled with certain information, that specified in section [Illegible Number] of ANS @26.1-1966, which includes the manufacturer's trademark, the symbol AS or the words American Standard, a model number, and a reference, in the form of a number, that indicates the type of glazing material. All glazing materials for use in motor vehicles must be labeled with this information, which can be stencilled onto the material if it is removed during the cutting process.

In addition to these identifying markings, each item of glazing material must be certified as conforming to the Federal standard. Prime glazing material manufacturers (those who fabricate, laminate, or temper the glazing material) certify glazing that is designed for use in any specific vehicle by including with the above markings the symbol DOT and a code number assigned to the manufacturer by this agency. Glazing that is not designed for a specific vehicle is certified pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), which includes, as you indicate, the use of a label or tag affixed to the glazing material that states that the material conforms to all applicable Federal motor vehicle safety standards. Manufacturers other than prime glazing material manufacturers, such as those, like yourself, who cut larger sheets to size, are required to certify in the same fashion; that is, in accordance with section 114, and may certify by labels or tags affixed to the material.

I have enclosed a copy of the marking requirements of Standard No. 205 for your information. If you wish to obtain a copy of the American National Standard @@26.1-1966, you should write to the American National Standards Institute, 1430 Broadway, New York, New York 10018.

ID: nht73-1.42

DATE: 05/18/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Signum Plastics

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 26, 1973, requesting that you be assigned a "DOT" code number for purposes of Motor Vehicle Safety Standard No. 205, "Glazing Materials". You state that you purchase acrylic plastic sheet from Thailand and Japan, and indicate that you are sole importers of this material.

Under paragraph S6 of Standard No. 205, the assignment of a code number is restricted to prime glazing material manufacturers, who are those manufacturers who either fabricate, laminate, or temper the glazing material. As you import only acrylic sheet, you are not a prime glazing material manufacturer, and the assignment of a code number to you is not appropriate.

I have enclosed a copy of marking requirements for glazing materials. Paragraph S6.2 requires a prime glazing material manufacturer to apply a code number, which is obtained upon written request to this agency, to that glazing designed as a component of any specific motor vehicle or camper. The code number requirement does not apply to glazing sheets not designed for a specific motor vehicle or camper. If you plan to import glazing material that is designed for a specific motor vehicle or camper, the prime manufacturer of that material, whether foreign or domestic, must apply for and receive a DOT code number.

Yours truly,

Enclosure

April 26, 1973

Administrator National Highway Traffic Safety Administration

Gentlemen:

We are requesting assignment of a D O T number, relative to Standard No. 205.

We purchase acrylic sheet plastic from Thailand and Japan, and are the sole importers of this material, as evidenced by the enclosed labels.

We are in the process of getting a registered trademark for this label.

Very truly yours,

SIGNUM PLASTICS --

Jack Molesworth, Partner

Encl.

ID: nht73-1.43

DATE: 09/26/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Sekurit-Glas Union GmbH

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 19, 1973, requesting information regarding the marking requirements in FMVSS No. 205 for automobile safety glass.

With respect to your request for a copy of the marking requirements, they may be found in paragraph S6. of the enclosed copy of the standard, and in section 6 of American National Standard Z26.1 - 1966. The latter standard can be obtained by writing to the American National Standards Institute, 1430 Broadway, New York, New York 10018.

Information on various State requirements should be obtained from Mr. Armond Cardarelli, American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, D.C. 20036.

You ask whether marking requirements can be met using a specific format you include in your letter, and refer to "Approval" and "Supplemental" markings. It is not clear to us to what you refer, as we prescribe neither "approval" nor "supplemental" markings in the standard, and perhaps we will be better able to answer any questions you may have after you have had an opportunity to review the requirements.

Yours truly,

Enclosure

July 19, 1973

Administrator -- National Highway Traffic Safety Administration

Ref.: Markings of Safety Glass

Dear Sirs,

According to the FMVSS 205 all the safety glasses built in cars have to be marked. Beside the prescriptions of the Department of Transportation there are other special prescriptions for each state (for instance California). Please could you send us an exact list of all these special specifications.

Could you send us as well the concerned regulation or a list from which we can take the form and the contains of the markings.

Is it sufficient to write as Approval Markings

DOT . . . /M . . . /AS

and all other denominations, as for instance laminated, Kinonglas-Kristall-HI-BFG, plate in the Supplemental Markings?

We would be very grateful if you could answer our letter as soon as possible.

Yours sincerely,

SEKURIT-Glas Union GmbH

i.V. i.A.

ID: nht73-1.44

DATE: 07/16/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Philips Industries Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of June 4 and June 22, 1973, concerning Federal Motor Vehicle Safety Standard No. 205, "Glazing Materials". Your letter of June 4 asks which glazing materials may properly be used in motor homes under the Federal standard, and whether State laws which provide otherwise are invalid under the National Traffic and Motor Vehicle Safety Act. Your letter of June 22 asks what requirements apply for glazing materials used in travel trailers.

Our records indicate that we wrote on July 5, 1972, to Mr. Robert T. Sanders of Philips Industries, in response to a letter from him concerning glazing requirements for chassis-mount and slide-in campers, trailer, and motor homes. Standard No. 205 has been amended since that date (on November 11, 1972; 37 FR 24035) and this letter reflects some of the changes in the standard made by that amendment.

The requirements for glazing for use in motor homes, which under NHTSA definitions now includes chassis-mount campers as well as traditional motor homes, are essentially those specified in ANS Z26 for trucks, with certain exceptions. Thus, for windshields, AS 1 or AS 10 materials may be used. For windows to the immediate right and left of the driver, AS 1, AS 2, AS 10, and AS 11 materials may be used, and AS 3 may be used in the unusual situation where any such window is not requisite for driving visibility. All other windows may be AS 1, AS 2, AS 10, AS 4, and AS 8 materials. Additionally, windows other than windshields and those to the immediate right and left of the driver may be: AS 3, AS 5, AS 9, and AS 12 where not requisite for driving visibility; AS 6 where not forward-facing; AS 7 and AS 12 where neither at levels requisite for driving visibility nor forward-facing.

I would add that the term "forward-facing" is not limited to windshields or behind-the-cab windows, as your letter implies, but applies to any window that is mounted in a plane transverse to the longitudinal centerline of the vehicle. It includes as well, for example, windows placed above the windshield, and any transverse interior partition.

Section 103(d) of the National Traffic and Motor Vehicle Safety Act (15 USC 1392(d)) does prohibit, as you indicate in your letter, any State or political subdivision of a State from establishing or continuing in effect with respect to a motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of the vehicle that is not identical to the Federal standard. The question raised by your letter is whether a State law which prohibits the use of glazing materials in locations of motor vehicles where they are specifically permitted to be used by the Federal standard is violative of section 103(d). It is our view that such a law is violative of section 103(d), and is invalid, as we believe that the use of a particular glazing material in specific vehicle locations is an aspect of performance that is covered by Standard No. 205. You are correct in adding, however, that under section 103(d) a State (or subdivision thereof) may require a higher standard of performance than that established by the Federal standard in vehicles or items of motor vehicle equipment procured for its own use. You may, of course, refer to this letter in your discussions with any State authorities regarding these issues.

The interpretation in your letter of June 22 that Standard No. 205 does not apply to glazing materials for use in travel trailers is correct.

Yours truly,

June 4, 1973

Richard Dyson --

U.S. Department of Transportation

National Highway Traffic Safety Administration

Dear Mr. Dyson:

This has reference to the telephone conversation I had with Mike Pescoe, relating to the use of safety glazing materials in motor homes.

According to our interpretation of Federal Motor Vehicle Safety Standard, #205, with its recent amendment, any window except the forward facing windows (windshield) and behind-the-cab windows and side windows directly adjacent to the driver may be manufactured of any glazing materials AS-1 through AS-13 as specified in ANS Z26.1-1966.

It is also our understanding that since the Federal Motor Vehicle Safety Standard for safety glazing has been already established, no State or political sub-division of a State shall have any authority either to establish or continue in effect with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the same aspect of performance of such vehicle or item of equipment which is not identical to the Federal Standard.

It is also our understanding that the Federal or the government of any State or political sub-division can establish a safety glazing requirement applicable to motor vehicle equipment procured for its own use if such glazing imposes a higher standard of performance than that required to comply with the otherwise applicable Federal Standard.

I would appreciate your comments on the above.

Sincerely,

Krish Kudva --

Manager, Product Engineering, PHILIPS INDUSTRIES, INC.

June 22, 1973

Richard Dyson U.S. Department of Transportation National Highway Traffic Safety Administration Dear Mr. Dyson:

Further to my letter dated June 4, 1973, relating to the use of safety glazing materials, I would appreciate your comment on the following interpretation besides what has already been listed in that letter.

What is the correct interpretation of glazing requirements for travel trailers? I understand that travel trailers do not require safety glazing.

Thanking you,

Sincerely,

Krish Kudva -- Manager, Product Engineering, PHILIPS INDUSTRIES, INC.

ID: nht73-1.45

DATE: 02/05/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. Harvey E. Schock, Jr.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your memo of January 18, 1973, concerning glazing materials.

I am enclosing a copy of Federal Motor Vehicle Safety Standard No. 205,Glazing Materials.

Certification of conformance to Standard No. 205 is self-certification. No approval by the Federal Government is required.

If you are not aware of State approvals, you may want to contact Mr. Armand Cardarelli of the American Association of Motor Vehicle Administrators, Suite 500, 1828 L Street, N.W., Washington, D.C. 20036.

If I can be of further service, please do not hesitate to ask.

Sincerely,

Enclosure

No Control

M E M O

FROM: Harvey E. Schock, Jr.

To The Associate Administrator Motor Vehicle Programs National Highway Safety Administration

January 18, 1973.

RE:FR Docket 73-644 Prime Glazing Material Manufacturer Codes

Gentlemen:

I would appreciate information on the requirements and procedures for the certifying that glazing materials conform to Motor Vehicle Safety Standard No 205 "Glazing Materials"

I would appreciate a copy of the Standard and any additional information on this subject.

Thank you for your cooperation.

ID: nht73-1.46

DATE: 04/26/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Young Windows, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 27, 1973, requesting information on requirements for marking glazing materials for use in motor vehicles, and whether you must finish cleaning instructions for glazing you manufacture.

Your questions regarding marking requirements are similar to those raised by Mrs. Lewis Cook of your company, in a letter of February 20, 1973. We responded to that letter on April 4, 1973 (a copy is enclosed), and you should have received our response by this time. In that letter we stated that your responsibilities as a manufacturer who cuts glazing materials are to mark that material in conformity with section 6 of ANS Z26.1-1966. We should amplify our response in that letter by stating that if the glazing material as you receive it already contains the required markings, you may use those markings in meeting the requirements.

You indicate your question concerning requirements for cleaning instructions arises from a customer to whom you furnished Rohm and Haas Plexiglas. Paragraph S5.2.1.3 of Standard No. 205 provides that glazing materials designated AS-12 or AS-13 must be labeled (using a label that is removable by hand) with cleaning instructions. If the Rohm and Haas Plexiglas is of either of these glazing designations, it must be so labeled. If it is not, there are no requirements that cleaning instructions be furnished.

Yours truly,

Enclosure

March 27, 1973

Office of Chief Counsel National Highway Traffic Safety Administration

Dear Sirs:

We at Young Windows, Inc. are in the business of manufacturing custom windows for the transportation industry. Recently a few questions were raised that have sent me seeking the correct answers.

My questions concern certification of certain glazing materials we presently use in our windows. Before I go any farther, let me explain that we do not manufacture windshields for the automotive industry but rather windows for campers earthmoving equipment, marine windows, and some rear windows for the truck industry. Therefore, what type of certification is needed concerning Federal Standard Number 205 of the Safety Code. I have heard a label is needed on the window, a label could be placed on the outside of the box, or a tag,(Illegible Word) that the glass in the windows meets Standard 205. Since our glass comes in stenciled with all necessary markings, would this be sufficient? If not, what would we be required to do to meet and conform to Standard #205?

Another question has been brought to our attention by one of our customers. We recently shipped 360 windows to a manufacturer of food serving and ice cream vending trucks. We supplied the sliding serving window. Per customer request, we supplied the windows using Rohm and Haas Plexiglas. The material was branded with all the necessary marking. Our customer has now come back and ask for cleaning instructions on the Plexiglas. Are we required by any Federal Standard to supply cleaning instructions with these windows?

I would appreciate your kind and prompt reply, as we want to conform to all standards without delay.

Regards,

Yours truly,

YOUNG WINDOWS, INC.

Charles E. Smith,

Purchasing Manager

ID: nht73-1.47

DATE: 03/09/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Recreational Vehicle Institute, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 31, 1973, requesting several interpretations of Motor Vehicle Safety Standard No. 205, "Glazing Materials", as it applies to motor homes and campers.

We find the interpretations as to the use of item 3 glazing contained in your letter to be correct. Your interpretation of "levels not requisite for driving visibility" as meaning that other windows are available and more suited for driving visibility is reasonable, and acceptable for purposes of Standard No. 205.

We also find your interpretations on the use of items 4, 5, 8, and 9 glazing materials to be correct. We do not agree, however, with your suggestion of allowing items 5 and 9 glazing to be used in camper windows adjacent to the truck cab rear window without regard to driving visibility. We agree it is unlikely with respect to most vehicles that such windows will be requisite for driving visibility, and will accept a good-faith, reasonable judgment decision on the question by a camper manufacturer. Consequently we do not believe that the remaining "degree of uncertainty" will result in compliance problems for camper manufacturers.

Your conclusions regarding the application of items 6 and 7 glazing are correct. We do not agree, however, that it is necessary or desirable to use such materials in any forward-facing windows, including those adjacent to the rear window of the truck cab. We believe the possibility of impact into these windows precludes the safe use in them of these glazing items, and item 13 glazing as well.

Your conclusions regarding the application of item 12 and item 13 glazing are correct. We appreciate your pointing out the lack of continuity in subparagraph designations for items 6, 7, 8, and 9. This was unintentional on our part, and your conclusion that the added subparagraphs should be read as following immediately those existing, regardless of letter designation, is correct. Finally, you are correct in your conclusion that the amendments to Standard No. 205 should be seen as overriding the headings for the various glazing items in the ANS Z26 standard.

Yours truly,

January 31, 1973

Lawrence R. Schneider--

Chief Counsel,

National Highway Traffic Safety Administration

U.S. Department of Transportation

Dear Larry:

This letter seeks your confirmation of our interpretation of certain aspects of Standard No. 205, as amended on June 21, 1972 and November 11, 1972, or your advice as to proper interpretation if we are incorrect.

The language of the cited amendments leaves as a qualification on the use of various item of glazing materials the phrase "at levels not requisite for driving visibility" or a similar qualification slightly varied depending upon the item of glazing involved. Insofar as we are aware, there has not been an interpretation of this qualification and we have had member inquiries on its application to certain windows of our units. Our subsequent comments will refer to the questionable items of glazing as they are listed in ANSI Z.26.

Item 3. Paragraph S5.1.1.5 of the November 11 amendment prescribes that motor homes, as multipurpose passenger vehicles, will be treated as trucks where not otherwise specifically provided for in the standard. Thus we conclude that:

(1) Item 3 cannot be usedfor windows to the immediate right or left of the driver of a motor home unless such windows are at levels not requisite for driving visibility which we would take to mean windows not required for visibility to the right and left of the driver because other windows are available and more suited for that purpose.

(2) The rear window of a motor home, where so equipped, may utilize Item 3 where it is not in fact used for or designed for driving visibility because of the impracticability for doing so and where outside side view mirrors are provided in accordance with Standard No. 111. In this connection, we have reference also to the opinion by Mr. Francis Armstrong of April 16, 1971, advising that rearview mirrors are not required in motor homes of configurations which obstruct the view to the rear to such an extent it could not meet the requirements of the Standard No. 111; and the interpretation incorporated with Standard No. 111.

Items 4, 5, 8, 9:

(a) These items cannot be usedin windshields or windows of motor homes to the immediate rigth or left of the driver.

(b) These items can be usedIn all other windows and doors of motor homes including over-the-cab forward-facing windows in those configurations which have space over the vehicle cab and a forward-facing window therein; and including those relatively few configurations where there may be a window in the motor home and/or a window in the cab just behind the driving compartment. Some few configurations may use a truck chassis and cab without a passageway directly from the driving compartment into the living quarters.

(c) These items can be used in all windows and doors of slide-in-campers and pickup covers, including any over-the-cab forward-facing window and any window in the slide-in-camper or pickup cover immediately behind the driving compartment.

In connection with both (b) and (c) above, we note that Items 5 and 9 carry the qualification of use only "at levels not requisite for driving visibility". Items 4 and 8 are not so limited. Over-the-cab forward-facing windows in motor homes, slide-in-campers and pickup covers (these units are unlikely to have such windows) clearly are not at levels requisite for driving visibility. Windows in the slide-in-camper or pickup cover just behind the driving compartment of the pickup truck on which such units are temporarily mounted are not generally used for driving visibility since pickup trucks customarily carry outside side-view mirrors to provide requisite rearview capability in the light of their property carrying function when used separately from a slide-in-camper or pickup cover. Although pickup trucks are not required by a current standard to have side-view mirrors, it seems appropriate and consistent with the actual practice to recognize that, in fact, they do and thus the windows described are not "requisite to driving visibility", rather than leave a degree of uncertainty on the part of the manufacturer of slide-in-campers and pickup covers as to whether Items 5 and 9 can be used in such windows.

The conclusion with respect to motor homes is predicated on the same reasoning as applied under Item 3 above. These conclusions also seem consistent with the opinion rendered to Mr. Robert T. Sanders on July 5, 1972 by Mr. Dyson.

Items 6 and 7:

These items cannot be usedin windshields, forward-facing windows (including over-the-cab forward-facing windows), and windows to the immediate right or left of the driver in motor homes; similarly, they cannot be usedin forward-facing windows, including over-the-cab forward-facing windows of slide-in-campers and pickup covers.

We note that Item 6 is not limited by the qualification that the locations not be requisite for driving visibility but Item 7 is so qualified. For the same practical reasons as set forth in regard to Items 4, 5, 8 and 9, above, we would conclude that the small windows in slide-in-campers, pickup covers, and a few configurations of motor homes just behind the driving compartment of the pickup truck can use Items 6 and 7, except for the fact they are "forward-facing" in the directional sense; neither item requires compliance with a test related to penetration resistance; and the cited opinion of July 5, 1972 by Mr. Dyson. RVI still feels that safety does not require penetration resistance characteristics in these behind-the-cab windows and requests your reconsideration as to whether such windows must be considered as "forward-facing" windows in connection with the possible use of Items 6 and 7 in such behind-the-cab windows.

Items 12 and 13, Rigid and Flexible Plastics:

Both of these items, as authorized by the amendment of June 21, 1972 contain the limitation of use only at "specific locations at levels not requisite to driving visibility". Based on the reasoning and opinions above cited, we conclude that:

(1) Item 12 can be usedin over-the-cab forward-facing windows of motor homes, slide-in-campers, and pickup covers, and in all such units in the windows behind the cabs of motor homes which have such configurations and behind the cabs of pickup trucks on which slide-in-campers and pickup covers are mounted.

(2) Item 13 cannot be usedin over-the cab forward-facing windows of such units including windows behind cabs. However, for the same reasons as expressed in connection with Items 6 and 7, we request your reconsideration as to whether such behind the cab windows must be considered "forward-facing" windows.

Other matters of interpretation:

(1) We note that, in the process of the amendment of November 1, 1972, subparagraphs "j" and "k" were added to Items 6, 7, 8 and 9 of ANSI - Z.26 although the subparagraphs in those items do not go beyond "(d)", "(c)", "(e)" and "(c)", respectively. We interpret the amendments as adding paragraphs falling immediately after the numbering of the appropriate subparagraph.

(2) We note that the headings in the same items are generally descriptive of other units than motor homes, slide-in-campers, and pickup covers. We interpret the amendments as overriding the headings and as controlling in the case of these recreational units.

Very truly yours,

David J. Humphreys --

RVI Washington Counsel

ID: nht73-1.48

DATE: 11/08/73

FROM: JOHN G. WOMACK FOR RICHARD B. DYSON

TO: American Safety Equipment Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 5, 1973, concerning your proposed use of a tension reliever device in a seat belt retractor. As we understand the concept of the tension reliever, it allows a small amount of slack to be introduced into the webbing by a mechanism roughly similar to that of a window shade. If the webbing is pulled smoothly back and forth, the retractor exerts a normal retractive force. If, however, the retraction is halted at a certain point, as when the belt comes to rest against an occupant's shoulder, the reliever engages and the occupant is relieved of the active pull of the retractor until he moves forward by an inch or two and disengages the reliever.

Your initial question is whether a reliever-equipped retractor will be considered to meet the retraction force requirements of S4.3(j) (6) of Motor Vehicle Safety Standard No. 209. You state that it will meet the test so long as the procedures of S5.2(j) are strictly observed and no oscillations are introduced by the test apparatus. If the facts are as you state, it is our opinion that the retractor would meet. S4.3(j) (6).

Your other question, as clarified by telephone on November 1, 1973, is whether we have reservations about the concept of a tension reliever that would lead us to bar its use through amendment of Standard No. 209. Based on the information presently available, we have no such reservations.