ID: nht72-2.50

DATE: 05/01/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Labelmaster

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 11, 1972, in which you ask whether four samples which you submit of labels for retreaded tires will meet the requirements of S6.2 and S6.3 of Motor Vehicle Safety Standard No. 117.

Each of the labels, with either the appropriate information filled in or clearly indicated by an "X" or other mark will meet the requirements of the standard. In the case of styles "C" and "D", however, either "2-ply" or "4-ply" will have to be deleted by the retreader, as one tire, of course, cannot be both a 2-ply and 4-ply tire. An alternative would be to eliminate the reference to plies, as stating the ply rating by itself is sufficient under the standard.

We are pleased to be of assistance.

ID: nht72-2.6

DATE: 11/02/72

FROM: F. ARMSTRONG FOR ROBERT L. CARTER -- NHTSA

TO: Pine Ridge Nursery

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 11, 1972, regarding the installation of LP gas tanks in a small van to serve as a "recreational vehicle."

There is no Federal regulation regarding installation of LP gas tanks on the exterior of recreational vehicles.

There is a voluntary standard on recreational vehicles issued by the National Fire Protection Association (NFPA), 60 Batterymarch Street, Boston, Massachusetts 02110. Identified as NFPA Standard No. (Illegible Word). This standard includes requirements for fuel supply systems based on the use of LP gas. You may wish to refer to the standard for safety guidance in installing your system.

I appreciate your interest in motor vehicle safety.

SINCERELY,

PINE RIDGE NURSERY

Oct. 11 1972

National Highway Traffic Safety Adm. Dept. of Transportation

Gentlemen:

I am equipping a small van as a "Recreational Vehicle".

I have been told by a commercial builder of these vehicles that a new Federal regulation will become effective Jan. 1, 1973 prohibiting installation of LP gas tanks on the exterior of such vehicles.

If he is correct, I will have to revise my plans.

Can you inform me if such a regulation exists or will be (Illegible Word)? If I can obtain a copy of the text or pertaient paragraph of such rule (if one exists) I shall take steps to comply.

Thank you.

Ray Brown.

ID: nht72-2.7

DATE: 10/16/72

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: North American Rockwell Automotive Technical Center

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of September 28, 1972, requesting an extension of the time allowable to petition for reconsideration of Federal Motor Vehicle Safety Standard No. 105a, Hydraulic Brake Systems.

You base your request upon the alleged necessity for testing to determine front axle capability under paragraph S5.1.16, Spike stops. This paragraph is substantially similar to paragraph S4.13 in the proposal published on November 11, 1970. You did not indicate in your comments to Docket No. 70-27 dated February 1, 1971, that the spike stop proposal needed further time for your evaluation. In our view, the 22 months that elapsed between issuance of the proposal and the final rule should have afforded you ample opportunity for testing. In any event, the time allowed for filing of petitions for reconsideration is fixed at 30 days by 49 CFR @ 553,35(a), and we generally do not extend this time.

We will, however, consider the substantive comments you submitted concerning paragraph S5.4.2 and respond to them in due course.

ID: nht72-2.8

DATE: 05/03/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Clark Equipment Company

TITLE: FMVSR INTERPRETATION

TEXT: This will serve to confirm the opinion which you were given by telephone on April 24, 1972, to the effect that the filing of timely petitions for reconsideration of Motor Vehicle Safety Standard No. 121 (37 F.R. 3905, February 24, 1972) will prolong the period within which Clark Equipment Company may seek judicial review of the standard until 60 days after the NHTSA's response to the petitions appears in the Federal Register. You may therefore wait until after disposition of the petitions without losing the right to judicial review as to each of the issues raised in your petition.

ID: nht72-2.9

DATE: 03/13/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Truck Equipment & Body Distributers Association

TITLE: FMVSR INTERPRETATION

TEXT: In your letter of February 23 you present a fact situation in which a final stage manufacturer (Illegible Words)a completed vehicle, such as a Ford Econoline and is instructed by the ultimate puchaser to add seats and seatbelts, flashing lights, etc. to transform the vehicle into a small school bus. You ask:

"Must this vehicle be certified as a bus, even though it had been certified previously by the chassis maker as a completed truck? How would a person to certify?

Where a completed, certified vehicle is altered after manufacture, the issue is whether sufficient modifications have been made to the original vehicle that the one who modifies it must be considered a manufacturer in his own right. Considering two scope of modifications you describe, and the change of vehicle type from "truck" to "bus" (if its carrying capacity is over 10 persons), or to multipurpose passenger vehicle (if it can carry 10 persons or less), this question would most likely be answered in the affirmative. In such a case the modifying manufacturer would have to certify the vehicle as complying with all applicable standards. He would have the responsibility of ensuring that his modifications did not affect the vehicle's original compliance with the standards, as well as full responsibility for any standards that became newly applicable because of the change of vehicle type.

Yours Truly,

ID: nht72-3.1

DATE: 01/25/72

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

TO: North Carolina Tire Dealers Retreaders Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for sending a copy of your December 1971 issue "Tarheel Tire Topics". In a note attached to these topics you asked Dr. E. H. Wallace to clarify whether a tubeless tire casing can be changed to a tube-type retread by identifying it as such during the process.

There is no prohibition of this practice mentioned in Standard No. 117 relating to retreaded tires. (Illegible Words) the rule is clear concerning the necessity for maintaining the highest quality in selection of materials and processings during the retreaded process. We would be interested in an explanation of the circumstances where it appears necessary to change a tubeless casing to a tubed tire. The circumstances which we visualize leading to this change seem to us to lead to rejection of the casing for any retread purposes.

We also would like to point out that, although not strictly prohibited, the manufacturer who changes a tubeless casing to a tubed tire is liable for penalties if the resulting tire will not perform on compliance tests.

ID: nht72-3.10

DATE: 09/07/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Kennedy, Holland, DeLacy and Svoboda, Attorneys at Law

TITLE: FMVSS INTERPRETATION

TEXT: Your letter dated July 27, 1972, to the Department of Commerce, regarding information pertaining to the National Traffic and Motor Vehicle Safety Act of 1966, initial standards, was referred to this office for reply.

The National Traffic and Motor Vehicle Safety Act of 1966, in establishing the legislative basin for the Federal Motor Vehicle Safety Standards, required that the initial standards, to the maximum extent possible, be based on existing safety standards. An Advance Notice of Proposed Rule Making, soliciting suggestions, opinions, and proposals for consideration in promulgating the initial standards, was published in the Federal Register on October 8, 1966. Paragraph S3.3(d) of the initial Motor Vehicle Safety Standard No. 201 was based on Paragraph S3.2.5 of Federal Standard No. 515/3a, which was published in the Federal Register on July 15, 1966, (31 F.R. 9628), after consideration of the comments received in response to the Advance Notice. I have enclosed a copy of Standard No. 515/3a.

Thank you for your letter. Your interest in automotive safety is appreciated.

ID: nht72-3.11

DATE: 04/03/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Pike Paint & Glass Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 15, 1972, requesting information on requirements for replacing broken glass in campers and trailers.

Federal regulations (Motor Vehicle Safety Standard No. 205, "Glazing Materials" (49 CFR 571.205, formerly 571.21)) require glazing materials for use in motor vehicles and motor vehicle equipment such as campers to meet the requirements of the American National Standards Institute Test Z26.1-1966 (July 15, 1966), and other requirements enumerated in the standard. In addition, manufacturers of such materials are required to certify, pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403) that the materials comply with the standard. This requirement applies to both prime manufacturers (those who either fabricate, temper, or laminate the material) and those who cut material from larger sheets.

The standard does not apply to trailers. With reference to campers, the standard requires that forward facing windows be constructed of glazing materials meeting tests for AS1, AS2, AS3, AS4, or AS5 glazing materials, which are described in ANS Test Z26.1-1966. Other camper windows may be of any glazing material that meets the requirements of the standard (AS1 through AS11). All of the materials which can be used under the standard are readily available. A notice of proposed rulemaking issued January 9, 1971, would allow additional materials to be used in campers, and the preparation of a final regulation regarding this matter is currently in process. The final regulation will, when issued, be published in the Federal Register.

A copy of Standard No. 205 is enclosed. The American National Standards Test Z26.1-1966, which is incorporated into the standard must, however, be obtained directly from the American National Standards Institute. Their address is 1430 Broadway, New York, New York 10018.

If you have further questions, please write.

ID: nht72-3.12

DATE: 06/09/72

FROM: ELWOOD DRIVER FOR ROBERT L. CARTER -- NHTSA

TO: S.P.A. Carrozzeria Pininfarina

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 25, 1972, inquiring about the applicability of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, and FMVSS No. 302, to the rear windows of convertible cars.

In FMVSS No. 302, the convertible top is not intended to refer to the rear window, but has reference only to the overhead material. Flammability of the transparent glazing material is regulated by FMVSS No. 205.

ID: nht72-3.13

DATE: 04/03/72

FROM: Robert L. Carter; NHTSA

TO: Fabrica Pisana S.P.A.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 10, 1972, concerning marking of your glazing materials intended for the American market.

The marking you propose to use satisfied the requirements of Standard No. 205, Glazing Materials.