ID: nht74-3.10

DATE: 01/08/74

FROM: RICHARD B. DYSON -- NHTSA ASSISTANT CHIEF COUNSEL

TO: DARROLL P. YOUNG -- PRESIDENT YOUNG'S MACHINE CO. MONTICELLO, UTAH 84535

TITLE: N40-30 (TWH)

ATTACHMT: LETTER DATED 12/26/73 FROM DARRELL P. YOUNG -- PRESIDENT YOUNG'S MACHINE COMPANY TO THE OFFICE OF CHIEF COUNSEL NHTSA U.S. DEPARTMENT OF TRANSPORTATION

TEXT: Dear Mr. Young:

In place of the two standards which you requested in your letter of December 26, 1973, I am providing the following discussion of what vehicles qualify as "motor vehicles" subject to our regulations. If your vehicles are not "motor vehicles" under this definition, they are not required to conform to Standards 105a and 121. Section 102(3) of the Act defines motor vehicle as:

any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails.

Thus, a motor vehicle is a vehicle which the manufacturer expects will use public highways as part of its intended function.

Tracked and other vehicles incapable of highway travel are not motor vehicles. Agricultural equipment is another non-motor vehicle category, because Congress clearly did not intend to include them in its coverage. In addition, vehicles intended and sold solely for off-road use (e.g. aircraft runway vehicles and underground mining vehicles) are not considered vehicles even if operationally capable of highway travel. They would, however, be considered motor vehicles if the manufacturer knew that a substantial proportion of his customers actually would use them on the highway.

Just as clearly, vehicles which use the highway on a necessary and recurring basis to move between work sites are motor vehicles. The primary function of some vehicles is of a mobile, work-performing nature and as such their manufacturer contemplates a primary use of the highway. Mobile cranes, mobile drill rigs, and towed equipment such as brush chippers and pull-type street sweepers are examples in this area. Even if the equipment uses highways infrequently, it is considered a motor vehicle on the same basis as is a "mobile structure trailer" which is often towed only once from the factory to the home site. All these motor vehicles qualify as trucks or trailers. As such they are subject to several of the motor vehicle safety standards, and their manufacturer must comply with other regulations in Chapter V of Title 49, Code of Federal Regulations.

There are some vehicles which are excepted from the motor vehicle classification despite their use of the highway. Highway maintenance and construction equipment such as lane stripers, self-propelled asphalt pavers, and other vehicles whose maximum speed does not exceed 20 miles per hour and whose abnormal configuration distinguishes them from the traffic flow are not considered motor vehicles.

From these guidelines you should be able to determine whether your equipment qualifies as a motor vehicle, and if so, as a truck or a trailer. Please write again if you are unable to make this determination. I have enclosed an information sheet that advises you how to obtain an up-to-date copy of the regulations which apply to motor vehicles and their manufacturers.

ENCLOSURE

Yours truly,

ID: nht74-3.11

DATE: 06/28/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Volkswagen of America, Inc.

COPYEE: ING. Hans-Jurgen Sassor -- AUDI NSU Auto Union Germany

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 22, 1974, question whether Volkswagen's passive belt system may be equipped with a "comfort clip," and whether an optional Type I lap belt may be offered in conjunction with the passive system. Your passive system consists of an upper torso restraint and, in place of a lap belt, knee padding under the dashboard.

A vehicle which satisfies Standard No. 208, Occupant crash protection, may be equipped, at the option of the manufacturer, with additional safety belts which conform to Standard No. 209, Seat belt assemblies. Additional belts, like any required belt, must conform to the S7.2 requirements for latch mechanisms.

S7.2 Latch mechanism. A seat belt assembly installed in a passenger car shall have a latch mechanism --

(a) Whose components are accessible to a seated occupant in both the stowed and operational positions;

(b) That releases both the upper torso restraint and the lap belt simultaneously, if the assembly has a lap belt and an upper torso restraint that require unlatching for release of the occupant; and

(c) That releases at a single point by a push-button action.

This requirement assures that the occupant crash protection provided under Standard No. 208 is not diminished by a complicated and slow series of belt latch mechanisms which could otherwise be introduced into the vehicle.

Volkswagens' passive upper torso restraint and a separate active lap belt do not violate S7.2(b) in combination. Simultaneous release is required only "if the assembly has a lap belt and an upper torso restraint that require unlatching for release of the occupant." As described, Volkswagen's upper torso restraint does not require unlatching for release of the occupant.

With regard to our regulation of "comfort clips", we approved the use of a clip in a March 9, 1973, letter to General Motors, to relieve belt tension in limited circumstances. A copy of that letter is enclosed. In that case, the lap belt provided could be independently and firmly adjusted to limit occupant movement, providing protection in the event of lateral and rollover crashes. Until we have further details on the functioning of the Volkswagen clips, however, which we urge you to submit, we are unable to determine whether it would conform to the adjustment requirements of S7.1.1 of Standard No. 208, Occupant crash protection.

May 22, 1974

Lawrence R. Schneider Chief Counsel National Highway Traffic Safety Administration

Subject: MVSS 208, Occupant Protection - Request for Clarification

With the publication of Docket 74-4, Notice 2 (39 FR 14593), Volkswagen believes that MVSS 208 now adequately addresses the basic requirements covering passive belt systems, such as the Volkswagen passive shoulder belt/knee bolster restraint described in our petition of October 1, 1973.

However, in the final development phase of our passive belt system the possible inclusion of two ancillary devices came under consideration:

(1) the addition of an active lap belt,

(2) the addition of a "comfort clip" to the passive shoulder belt to relieve the belt force against the occupant during non-impact conditions.

Volkswagen respectfully requests NHTSA clarification of the current Federal requirements covering each of these items, which are discussed in more detail below.

1. Additional Active Lap Belt

Here we are interested in the requirements for the installation of active lap belts together with passive restraints, where the requirements of MVSS 208 are met by the passive restraints alone.

To our knowledge, the last published NHTSA statement addressing this matter appeared in 35 FR 16928 (Preamble to Docket 69-7, Notice 7): "Under the standard as adopted manufacturers will be free to supply seat belts as optional or standard equipment, but may not use them to satisfy the requirements of the standard. Standard No. 210 will continue to require seat belt anchorages to be installed by manufacturers, so that persons who wish to have seat belts installed in their vehicles, for their own use or for use with child seating systems, will be able to do so."

Specifically, we would like to know if a Type 1 lap belt (conforming to MVSS 209) can be installed in addition to the Volkswagen passive shoulder belt/knee bolster system, under either of the following circumstances:

a) where a vehicle equipped with the passive belt system alone meets the requirements of S4.1.2.2 and S4.5.3 of MVSS 208 (second option for passenger cars manufactured from Sept. 1, 1973 to the time when this option expires);

b) where a vehicle equipped with the passive belt system alone meets the requirements of S4.1.3 (a) through (d) (1) proposed in Docket 74-14, Notice 1, and S4.5.3 of MVSS 208.

Our main area of concern in this matter is in regard to the latch mechanism. The passive shoulder belt would have a latch mechanism conforming to S7.2 of MVSS 208, as required under S4.5.3.3(a). If the active lap belt is not governed by MVSS 208, the application of S7.2(b) of MVSS 208 for simultaneous release of lap and upper torso restraint is questionable.

2. Addition of "Comfort Clip"

We are aware that certain vehicles equipped with upper torso restraints with emergency-locking retractors incorporate belt force relief devices ("comfort clips") to make wearing of the belt more comfortable. Although the specifications governing these devices have not been incorporated into the Safety Standards, we understand that correspondence between individual manufacturers and the NHTSA has addressed the guidelines for their use. Since such a "comfort clip" could be applied to the VW passive belt, NHTSA clarification of the regulations relating to this specific usage is requested.

Your early attention to these inquiries would be greatly appreciated, in view of the lead-time constraints we would be facing for possible incorporation of the described items in 1975 model vehicles.

J. W. Kennebeck

Manager

Emissions, Safety & Development

ID: nht74-3.12

DATE: 09/27/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Fairmount Press

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of August 19, 1974, inquiring as to the compliance of your MVF odometer disclosure form with the Federal odometer requirements.

The MVF form enclosed in your letter fails to comply with our regulation in several respects. The statement referring to the mileage indicated on the odometer at the time of the vehicle's transfer must be phrased to indicate that the disclosure document was executed at the moment of the vehicle's transfer, not at some later time. In addition, the statement must be written in such a manner that it is clear it is to be completed by the transferor alone. To satisfy these criteria the statement should read

"I, , state that the odometer mileage indicated on the vehicle described above, at the time of transfer to , is as follows:"

Instructions are necessary on your form to ensure that the section specified for the disclosure of mileage is completed in a consistent manner by all persons. This can be accomplished by inserting the following statement above the lines provided for stating the vehicle's mileage:

"(Complete line 1; and where applicable, complete line 2 and check line 3.)"

We urge you to reprint your disclosure forms to reflect the changes suggested above as they are not currently in compliance with Federal odometer requirements.

Your Interest is appreciated.

Yours Truly,

THE FAIRMOUNT PRESS

August 19, 1974

Richard B. Dyson

Ass't. Chief Counsel

NHTSA

Enclosed please find previously approved copies of our MVF form. They were approved on June 11, 1973.

We have been informed by one of our customers that there have been changes made. The customer was unaware of what changes had been made, but was advised by another New Car Dealer that indeed changes had been made.

We would appreciate your rechecking the forms enclosed and ascertaining if they are still in compliance with current regulations.

A prompt reply would be appreciated in that we are preparing for a new run of the MVF forms, and if there are any changes, we wish to include same.

Thank you for your cooperation and help in this matter.

Norman E. Salzman

General Manager

ODOMETER MILEAGE STATEMENT

Required Under Section 408, P.L. 92-573 USA Also Pursuant to Sect. 392-E, General Business Law, State of New York

Date of this Statement

Year Make Model

Body Type Color/s

Vehicle Ident. No.

No. Cylinders Last Plate No.

State Year

The mileage appearing on the odometer of the motor vehicle described above at time of transfer to:

was as follows:

1. miles

2. Total Cumulative Miles (If over 100,000)

3. [] The actual mileage differs from the odometer reading for reasons other than odometer calibration, error and that the actual or true mileage is unknown.

Seller's Name

Seller's Address

Seller's Signature

(Federal regulations require you to state the odometer mileage upon transfer of ownership. An inaccurate statement may make you, liable for damages to your transferee, pursuant to Section 409(a) of the Motor Vehicle Information and Cost Savings Act of 1972, Public Law 92-513.)

I/We (Transferee) hereby certify that I/We have received a copy of the above odometer mileage statement.

ID: nht74-3.13

DATE: 01/03/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 3, 1973, requesting clarification of paragraph S5.1(c) of Motor Vehicle Safety Standard No. 217, "Bus Window Retention and Release." Your letter, and attached photograph of a push-out window, suggest that the words "window frame" in S5.1(c) refer not to the window "sash", the structure immediately surrounding the glazing material, but to the side of the bus.

We do not agree. The words "window frame" in S5.1(c), with respect to the push-out window, refer to the component that interfaces with the glazing.

The intent of S5.1 is to require a window retention system to be strong enough to retain occupants in a crash, at least up to the strength limit of the glazing itself. Since there are no limits on movement of the window "sash" relative to the bus structure, the interpretation you suggest would allow a window system that provides no retentive properties at all, thus defeating one of the main purposes of the standard.

ID: nht74-3.14

DATE: 06/11/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: The Adams & Westlake Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 16, 1974, concerning an interpretation of the requirements of Motor Vehicle Safety Standard No. 217, "Bus Window Retention and Release" (49 CFR 571.217). You appear to ask whether bus windows containing tempered glass must meet the release requirements of paragraph S5.3.2 after (as well as before) the retention test required by S5.1 when the glass breaks during the retention test. You state that tempered glass, once broken, is easily removed from the entire lite by touch, implying that when this is the case there is no longer a need for any release mechanism to be further tested.

Paragraph S5.3.2 requires the release mechanism to meet specified requirements both before and after the window retention test of S5.1 irrespective of the glazing material used in the lite. Consequently, release mechanisms for windows of tempered glass must conform to the requirements even though the glass may be broken during the retention test

While your argument that the requirement seems unnecessary when tempered glass is used is not without some basis, it is also quite likely, in our view, that bus passengers in a crash may be ignorant of the quality of tempered glass to which you refer and thus still attempt to operate the emergency exit using its release mechanism.

Yours truly,

April 16, 1974 Larry Schneider Office of Chief Consul National Highway Traffic Safety Administration

In regards to Motor Vehicle Safety Standard No. 217, "Bus Window Retention and Release", please refer to S5.3.2 which states:

"When tested under the conditions of S6. both before and after, the window retention test required by S5.1, each emergency exit shall allow manual release of the exit by a single occupant using force applications each of which conforms, at the option of the manufacturer either to (a) or (b)"

In the design of our particular application, we use a single sliding lite in a vehicle less than 10,000 lbs. GVWR and have opted to meet the low force application described in (a). See attached drawing DM-8991-2.

Our question centers on the above quote from the specification particularly when tempered glass is used. We foresee no difficulty in meeting the release test before the retention test but does the tempered glass, once broken, qualify as an uncostructed opening due to the ease of removal of any glass that might remain in the opening. Tempered glass as you are probably well aware, once stressed to the point of breakage, crumbles into small cubes over the entire lite and may be easily removed by touch.

Your earliest reply will be appreciated.

Ronald J. Hansing Project Engineer

Attachment cc: H. C. Gildnor

C. M. Miller

R. Prey

E. V. Gordon

July 10, 1974

Office of Chief Consul National Highway Traffic Safety Administration

ATTN: Richard Dyson

Please find enclosed drawing DK-1553 which should have been sent with letter dated July 3, 1974.

Ronald J. Hansing Project Engineer

RJH:cpp Enclosure

ID: nht74-3.15

DATE: 02/27/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Excel Industries

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 14, 1974, inquiring whether Motor Vehicle Safety Standard No. 217, "Bus Window Retention and Release" (49 CFR 571.217), prohibits the use of sliding windows as emergency exits in buses. You refer to language in S5.3.1 and S5.4 of the standard which refers specifically to the use of push-out windows as emergency exits.

Standard No. 217 is not intended to prohibit the use of sliding windows as bus emergency exits, but such windows must comply with all of the standard's requirements for emergency exits.

Yours truly,

January 14, 1974

Lawrence Schneider

NHTSA

Excel Industries has, in the past few years, been in the production of a sliding window that is used in multi-purpose vehicles, motor homes, trailers, and other related recreational vehicles. With the energy crisis, some of our customers are attempting to convert these motor homes into people carriers, limousines, airport buses, ski lodge transportation, etc.

Under amendments to paragraphs (a), (b) and (c) of 393.61 and amendments to 393.63 of the Motor Carrier Safety Regulations as published in the Federal Register on June 10, 1972, "On a bus manufactured on and after September 1, 1973, having a seating capacity of more than 10 persons, each push-out window shall conform to Motor Vehicle Safety Standard No. 217, Part 571 of this title."

Furthermore, under Motor Vehicle Safety Standard No. 217, paragraph S5.2.1, it states that unobstructed opening requirements are to be provided which conform to S5.3 through S5.5 for vehicles with a GVWR of greater than 10,000 lb. Paragraph S5.2.2 states the unobstructed openings for buses with a GVWR of less than 10,000 lb. Under subparagraph (b) of this paragraph, it merely states, "Windows that can be opened manually to a position that provides an opening large enough to admit. . . ." etc. In reviewing these standards, we feel that our windows would definitely conform to the buses defined in S5.2.2 and, by meeting the window retention requirements in S5.1 and the emergency release requirements in S5.3, our window would conform to the definition of an emergency exit for buses defined in S5.2 except for the wording on push-out windows or other emergency exits, Paragraph S5.3.1 and S5.3.2, "The release mechanism or mechanisms shall require for release. . . . . of the initial push-out motion of the emergency exit (outward and perpendicular to the exit surface.)" In re-reading these specs, many references are made to windows as being push-out windows. However, in discussing this with Mr. Frank Bergsman of your Standards Office (ph. 202-426-2807), he feels that, if our sliding window can be opened to permit the 20x13 ellipsoid to pass through it, our window could conform as an emergency exit in both paragraphs; i.e., S5.2 for over 10,000 lb. buses and S5.2.2 for buses of 10,000 lb. or less.

Mr. Bergeman has said he has discussed this spec with you, and we would like a written reply on this interpretation as soon as possible.

S. A. Spretnjak

Chief Design Engineer

(Graphics omitted)

EXCEL INDUSTRIES

PARADE OF NEW PRODUCTS

FOR THE MOBILE HOME AND R.V. INDUSTRY

ROUND CORNERED BAGGAGE DOOR

SQUARE CORNERED BAGGAGE DOOR

MOTOR HOME SEAT PEDESTAL

ROUND CORNERED SLIDING WINDOW

VAN SCREENS

MOBILE & MODULAR SINGLE HUNG WINDOW

CAMPER TAILGATE SPRING LIFT ASSIST

ID: nht74-3.16

DATE: 08/19/74

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

TO: Meiji Rubber & Chemical Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 1, and July 30, 1974, request for approval of hydraulic and vacuum brake hose labeling. We have evaluated your examples based on the labeling requirements of the standard as amended by Notice 11 of Docket No. 1-5.

The hydraulic brake hose marking on "Face A" appears to conform to the requirements of S5.2.2, assuming that letter "size" refers to letter height. The interval between markings, represented by "--", also conforms. "Face B" is not regulated by our standard.

With regard to the markings for brake hose end fittings, the date (indicated by "XY") is not required. If you choose to add the date to your markings, it should not interfere with the legibility of the required markings. I would like to point out that under Notice 11, the marking requirements do not apply to end fittings "attached by deformation of the fitting about a hose by crimping or swaging." This means that hydraulic hose fittings for use in passenger cars need not be labeled.

The brake hose assembly markings you submit appear to conform to the requirements of the standard.

With regard to vacuum brake hose, your "Face A" appears to conform to S5.2.2 if letter "size" refers to letter height. S5.2.1 is not applicable and therefore the stripe is not required. "Face B" is not regulated by our standard.

We have placed "MRCC" on file as the manufacturer designation for your company.

Yours truly,

MEIJI RUBBER & CHEMICAL CO., LTD.

July 30, 1974

Docket Section National Highway Traffic Safety ADMIN.

Subject: Submission of Comments on Federal Motor Vehicle Safety Standards Docket No.1-5: Notice 10

By our letter (Our Ref. No. T-76) March 25, 1974, we asked for your approval of our hydraulic brake hose and Vacuum brake hose labeling.

However, [Docket No.1-5: Notice 10] has been issued, so we would like to ask for your approval of the attached application as corrected.

This was planned according to Federal Motor Vehicle Safety Standards [Docket No. 1-5: Notice 8] Federal Register, Vol.38, No. 218-Tuesday November 13, 1973 and [Docket No. 1-5: Notice 9] Federal Register. Vol. 39, No. 20 Tuesday January 29, 1974.

The places to be corrected are indicated by the symbol(SYMBOL ILLEGIBLE). The reason for each correction is indicated by the symbol (SYMBOL ILLEGIBLE).

H. Tsukano, Sub-manager

Technical Division

August 1, 1974

Richard B. Dyson Assistant Chief Councel -- NHTSA

We thank you very much for your sending Notice 11.

We apply again on July 30.

This Ref T-129 is the same contents as Ref T-85 which we sent on may 29, '74.

I remain for today

H. Tsukano Sub-manager

Technical Division

LABERING

1. HYDRAULIC BRAKE HOSE

1. Hydraulic brake hose (ID 1/8")

1-1. Printed parts

1-2. Face A (printed mark)

<--(symbol illegible) (every 4 inches-->

-- DOT MRCC 1o/74 1/8 HR -- DOT MRCC

Notes: The color of printed letters is white.

The size of a letter is 1/8".

The width of line is 1/16".

MRCC stands for Meiji Rubber & Chemical Co.

1-3. Face B (printed mark)

(SYMBOL ILLEGIBLE) MEIJI RUBBER JAPAN 1/8 NO57-1 1974 SAE J1401 (which is indication of the approval for the export to a northern state (pennsylvania).)

Notes: The white letters are printed continuously

The size of a letter is 1/8".

(SYMBOL ILLEGIBLE): The trade mark of Meiji Rubber & Chemical Co.

1/8: The inside diameter of hoses

1974: year of production

NO57-1: The approval number of RMA (Rubber Manufacturers Association) (444 Nadison Avenue, New York 10022, U.S.A.)

Line number 57

Yarn color code yellow-yellow-black

RMA assignment Meiji Rubber Company, Ltd. attained on March 1st, 1967

SAE JI401 Society of Automotive Hydraulic Brake Hose

2. Hydraulic brake hose and fitting

Dot MRCC (SYMBOL ILLEGIBLE) 1/8XY

Notes: Letters stamped

The size of a letter 1/16"

MRCC stands for Meiji Rubber and Chemical Co.

1/8: The inside diameter of hose

X is the figure of production that comes after 197

Y means the month of production

3. Hydraulic brake hose assembly

DOT MRCC 10/74

Notes: Letters stamped

The size of a letter 1/8"

Rubber band width 6mm

red colored

hypalon rubber MRCC stands for Meiji Rubber & Chemical Co.

II. Vacuum Brake Hose (ID 11/32)

1. Printed parts

(A) Face A (printed mark)

(every 5 inches)

--- DOT MRCC 10/74 11/32 VL --- DOT MRCC

Notes: The white letters printed

The size of a letter 4mm

The width of line 2mm

MRCC stands for Meiji Rubber & Chemical Co. 11/32 means the inside diameter of hose.

(B) Face B (printed mark)

(every 5 inches)

-- (SYMBOL ILLEGIBLE) Japan 11/32 LD GD2 SAE JI403 (SYMBOL ILLEGIBLE) ---

Notes: The white letters printed

The size of a letter 4mm

The width of line 2mm

(SYMBOL ILLEGIBLE) is the trade mark of Meiji Rubber & Chemical Co.

11/32 is inside diameter of hose.

LD is Light-Duty Type.

GD2 is the month and year of production code according to SAE specifications.

As our hose will be imported into the United States only as equipment used in Hond Civic or Mitsubishi Dodge Colt and other vehicles or as parts for the maintenance of these, you can get any further necessary details from the office of these corporation.

FOR INFORMATION

1. Hydraulic Brake Hose

(SYMBOL ILLEGIBLE) 1-2. "Every 6 inches" should be corrected to "every 4 inches".

(SYMBOL ILLEGIBLE) The reason: According to Notice 10 the interval 6" should be under 6". this hose is used in 4" lengths and can be printed in only one place.

(SYMBOL ILLEGIBLE) Hydraulic brake hose assembly Rubber band width 8mm should be corrected to 6 mm.

(SYMBOL ILLEGIBLE) The reason: To harmonize the letter size of 1/8" and to make it easier in printing.

II. Vacuum Brake Hose

(SYMBOL ILLEGIBLE) Inside diameter 3/8 inch should be corrected to 11/32 inch.

(SYMBOL ILLEGIBLE) The reason: The actual measurment is nearer 11/32" than 3/8".

(SYMBOL ILLEGIBLE) Every 6 inches" should be correct to "every 5 inches".

(SYMBOL ILLEGIBLE) The size of a letter should be corrected from "5 mm" to "4 mm".

(SYMBOL ILLEGIBLE)The width of line should be corrected from "3 mm" to "2 mm".

(SYMBOL ILLEGIBLE) The reason: To harmonize letter and hose size and to print more clearly. (every 6 inches)

--- M --- MRCC JAPAN ---

The above mentioned mark should be corrected as follows according to SAE specifications by National Highway Traffic Safety Administration (every 5 inches)

(SYMBOL ILLEGIBLE) JAPAN 11/32 LD, GD2 SAE JI403

(SYMBOL ILLEGIBLE) The size of a letter should be corrected from "5 mm" to "4 mm". 11/32 is inside diameter of hose.

LD is Light-Duty Type.

GD2 is the month and year of production code according to SAE specification.

As our hose will be imported into the United States only as equipment used in Honda Civic or Mitsubishi Dodge Colt and other Vehicles or as parts for the maintenance of these, you can get any further necessary details from the office of these corporation.

ID: nht74-3.17

DATE: 07/30/74

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

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 3, 1974, question whether the Standard No. 106-74, Brake hoses, labeling requirements for brake hose fittings (S5.2.3) permit labeling in addition to that required in the section.

Optional labeling is not prohibited by the standard as long as the additional marking does not confuse the required marking. We have already interpreted S5.2.2 to permit optional labeling on the opposite side of the hose from the required labeling. The required labeling must appear without additions to make it clearly legible.

Your illustration appears satisfactory as long as the "1/8" and the "lot number" are sufficiently separate for clarity.

NISSAN MOTOR CO., LTD.

July 3, 1974

Lawrence R. Schneider Chief Council National Highway Traffic Safety Administration

This is to confirm our telephone conversation of June 27th with Mr. Herlihy of your office regarding the brake hose end fitting labeling requirement of FMVSS 106, S.5.2.3.

We would like to employ additional labeling in block capital letters or numerals, as shown in the attached Figure 1, which is not requested in the Standard and which will constitute "Lot Numbers" by the fitting manufacturer.

We believe that it would be acceptable to have this additional labeling when considering the fact that the FMVSS 106 does not prohibit additional labeling and that we feel the need for additional labeling in order to identify problems more easily if something should happen. We do not think that this kind of additional labeling would cause any confusion with the labeling requested by the FMVSS.

Please advise us as to whether or not our understanding in the above matter is correct.

Thank you for your attention to our request.

Tatsuo Kato

Staff, Safety

Attachment

Example:

DOT OSK H 1/8 XXXXX

Manufacturer's Designation

NHTSA Requested Labeling

"LOT NUMBERS" by fitting manufacturer in block capital letters or numerals at same height as requested in the FMVSS labeling.

(Graphics omitted)

ID: nht74-3.18

DATE: 11/12/74

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

TO: Dana Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Dano Corporation's October 22, 1978, request for a statement by the National Highway Traffic Safety Administration that Standard No. 121, Air brake systems, does not require antilock systems on the axles of air-braked trailers subject to the standard, and, if antilock systems are provided, that the standard does not specify the number or location of the speed sensing or logic components which constitute the system.

Standard No. 121 requires that wheels not lock-up under certain conditions (S5.3.1, S5.3.2) but it does not require the use of an antilock system to prevent wheel lockup. If a manufacturer chooses to install an antilock system on his vehicle, the standard requires that an anti-lock warning signal be installed (S5.1.6), that electrical failure of the antilock system not increase the actuation and release times of the service brakes (S5.5.1), and that an antilock system on a trailer be powered through the stop lamp circuit (S5.5.2).

There are no other requirements for antilock systems used on air-brake equipped vehicles subject to Standard No. 121. This means that the manufacturer may choose the number of wheel speed sensors and logic modules that he includes in his antilock system. It should be noted, however, that the "controlled lock-up" exception of S5.3.1 (a) and S5.3.2(a) would not apply to a wheel which is not equipped with a wheel sensor that contributes to the control of the reduction of air pressure.

If the number and location of these components becomes a safety problem in the future, the NHTSA would consider appropriate specifications for them.

ID: nht74-3.19

DATE: 11/12/74

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

TO: The Flxible Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Flxible's October 11, 1974, petition to exempt the "trackless trolley coach" category of bus from the requirements of Standard No. 121, Air brake systems. You describe the vehicle as similar to your diesel bus but without the weight of the diesel engine, and with electrodynamic braking provided by the traction motor to a maximum of 2.0 mph per second in conjunction with brake operation.

I have enclosed a copy of our letter to Flyer Industries Limited on the same subject. The letter describes our position with regard to status of the trackless trolley as a motor vehicle, and also how it must be tested under Standard No. 121.

You have noted several difficulties in testing a vehicle which uses overhead electric lines as a source of power. I would like to point out that, as we interpret the National Traffic and Motor Vehicle Safety Act of 1966, we have established the policy that a manufacturer may conduct certification testing in any manner it chooses, as long as it is calculated, in the exercise of due care, to demonstrate that the vehicle would pass if tested as specified in the standard. Thus, you would be free to certify the vehicle based on tests without use of overhead lines and the benefit of electrodynamic braking. We understand from your letter that without the weight of the diesel engine the trackless trolley has better braking performance than the equivalent diesel engine.

At this time we have issued a proposal that would establish special test conditions for certain vehicles and limited exemptions for other vehicles, based on their configuration. We will consider your letter as a petition under this rulemaking action, and we invite you to make further comments to Docket 74-10; Notice 7, within the next 30 days.

We will advise you of our determination by letter or by notice in the Federal Register.

YOURS TRULY,

ENCLS.

THE Flxible CO.

OCTOBER 11, 1974

Mr. Richard Dyson, Acting Chief Counsel National Highway Traffic Safety Administration 400 7th. Street S.W. Washington, D.C. 20590

Dear Mr. Dyson: The purpose of this letter is to request a clarification concerning the certification of a trackless trolley coach to Federal Motor Vehicle Safety Standard #121, Braking System.

The Flxible Company is seeking certification of the trackless trolley coach without testing as a part of our family of vehicle of which the diesel powered buses are certified to FMVSS #121.

The trackless trolley coach will be on a forty (40) feet long by one hundred two (102) inches wide chassis. All brake system components, with the exception of the air compressor are the same ones used on the diesel coach. The air compressor, of necessity, is motor driven and of larger capacity than the compressor used on most diesel coach applications. Calculations, based on compressor capacity and reservoir volume, show that the compressor exceeds the requirements of Para. S5.1.1 of FMVSS #121 by 55-60 per cent.

While the chassis is the same as the diesel coach, the total vehicle weight will be slightly less than a diesel coach, powers by a V-8 diesel engine, due to component weight. The weight reduction is a plus factor in meeting the stopping distances as outlined in Table 11 of FMVSS #121.

In addition, electrodynamic braking will be provided by the traction motor to a maximum of 2.0 mile per hour per second (MPHPS) in conjunction with brake operation. This feature will most certainly aid the overall braking performance of the vehicle

One very important point must be made in requesting certification of the trackless trolley coach without testing. There is no test track available with 600 VDC overhead lines with which to run the vehicle. Cost for such an installation would be prohibitive especially considering the very limited use. Testing methods, such as a portable power system, would also be expensive and not at all practical due to the physical size and weight of components to produce 600 VDC at 550 amperes

Based on the above information, The Flxible Company requests deletion of testing and granting of certification to FMVSS #121 of the trackless trolley coach.

STANLEY C. FRYE -- Product Engineer-Advanced Design