ID: nht88-1.15

TYPE: INTERPRETATION-NHTSA

DATE: 01/13/88

FROM: L.F. ROLLIN -- COMMANDER COMMERCIAL AND TECHNICAL SERVICES SECTION DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

TO: THOMAS A. COZ -- LAW DEPARTMENT NORTH AMERICAN VAN LINES

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/24/89 FROM STEPHEN P. WOOD -- NHTSA TO THOMAS A. COZ -- NORTH AMERICAN VAN LINES; REDBOOK A34; STANDARD 108; LETTER DATED 04/28/89 FROM THOMAS A. COZ -- NORTH AMERICAN VAN LINES TO NHTSA, RE HIGH MOUNTED TRAILER STOP LAMPS/TURN SIGNALS; OCC 3469

TEXT: Dear Mr. Coz:

This is in response to your December 30, 1987, letter requesting an "Experimental Devices Permit" for high mounted stop lamp/turn signals which are installed on some North American Van Lines trailers.

No experimental device permit is necessary since these supplemental lamps are currently permitted by the California Vehicle Code. However, these lamps are in violation of Federal Motor Vehicle Safety Standard 108 (FMVSS 108). FMVSS 108 specifies mounti ng heights for brake lights (not less than 15 inches nor more than 72 inches) and turn signals (not less than 15 inches nor more than 83 inches) above the level roadway surface. Both the trailer specifications and the trailer picture you provided show t he lamps to be mounted above the mounting heights specified in FMVSS 108.

The National Highway Traffic Safety Administration (NHTSA) confirmed that all brake lights and turn signals installed by a manufacturer of vehicles must conform to the FMVSS 108 mounting requirements. NHTSA does not differentiate between required or "su pplemental" lights on trailers. The FMVSS 108 restrictions on mounting do not apply to equipment installed by the owner.

If you have any questions, please contact Mr. Ellis Hirst our staff engineer for clarification.

Very truly yours,

ID: nht88-1.16

TYPE: INTERPRETATION-NHTSA

DATE: 01/14/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Nissan Research & Development, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Toshio Maeda Executive Vice President & Chief Operating Officer Nissan Research & Development, Inc. P.O. Box 8650 Ann Arbor, Michigan 48104

Dear Mr. Maeda:

This is in reply to your letter of June 30, 1987, asking for an interpretation of paragraph 54.1.1.36(b)(3) of Motor Vehicle Safety Standard No. 108.

That paragraph specifies in pertinent part that a replaceable bulb headlamp shall be designed to conform to Section 6.1-Aiming Adjustment Test, of SAE Standard J580 AUG79 Sealed Beam Headlamp Assembly. Section 6.1.1 states that "when the headlamp assembl y is tested in the laboratory, a minimum aiming adjustment of +/-4 deg. shall be provided in both the vertical and horizontal planes." You have asked whether the aiming adjustment is to be achieved by the headlamp assembly, or by both the headlamp assemb ly "and by the headlamp when it is mounted on the vehicle."

SAE J580 applies to the design of headlamp assemblies, including the functional parts other than the headlamps, such as aiming and mounting mechanisms and hardware. The assembly may include one or more headlamps. Although the headlamp assembly is tested in the laboratory, its design must be identical to the headlamp assembly used on the vehicle. Thus, if the aiming adjustment requirement is met by the headlamp assembly in the laboratory, it should also be met when the assembly is installed on the vehicl e. An individual headlamp installed on the vehicle need not meet the aiming adjustment test unless that headlamp is part of a headlamp assembly comprising only one headlamp.

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

June 30, 1987 Ref: W-253-H

Ms. Erika Jones Chief Counsel National Highway Traffic Safety Administration 400 7th St., S.W. Room 5219 Washington, D.C. 20590

Dear Ms. Jones:

Nissan Research & Development, Inc., on behalf of Nissan Motor Company, Ltd. of Tokyo, Japan, hereby submits this request for an interpretation relating to the replaceable bulb headlamp aiming provisions in Federal Motor Vehicle Safety Standard 108, "Lam ps, Reflective Devices and Associated Equipment."

Among its requirements, S4.1.1.36(b) (3) of Standard 108 stipulates that the replaceable bulb headlamp shall be designed to conform to Section 6.1 - "Aiming Adjustment Test" of SAE J580 AUG79, "Sealed Beam Headlamp Assembly.

Item 6.1.1 of the above-referenced "Aiming Adjustment Test" states that, "when the headlamp assembly is tested in the laboratory, a minimum aiming adjustment of + 4 deg. shall be provided in both the vertical and horizontal planes."

Nissan's question is whether this minimum aiming adjustment requirement is to be achieved:

1. by the headlamp assembly (by the component unit) itself, or

2. by both the headlamp assembly (as a component unit)

and by the headlamp when it is mounted on the

vehicle?

Erika Jones June 30, 1987 Page Two

Thank you very much for your assistance. Please contact Mr. Tomoyo Hayashi of my Washington staff at (202) 466-5284, if you have any questions or require further details. I would appreciate it if you would please also notify Mr. Hayashi when your respons e has been issued.

Sincerely,

Toshio Maeda Executive Vice President & Chief Operating Officer

ID: nht88-1.17

TYPE: INTERPRETATION-NHTSA

DATE: 01/15/88

FROM: ALICE COLLINS

TO: ERIKA Z JONES -- CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/01/88 TO ALICE COLLINS, FROM ERIKA Z. JONES, REDBOOK A32, PART 571.3

TEXT: Dear Ms Jones,

I am behind, to say the least, in writing you.

I am a parent of three children. Two of school age. Plus I do a lot of volunteer work for two school. Part of my volunteer work is driving for field Trips.

I checked out my new vehicle for over 1 year before buying. I chose a 1986 (new) Ply. Voyger mini-van and then in the 1986-87 school year your dept. decided they were unsafe. But in your letter to Mr. Larry H McEntire Administrator, School Transport ation - Fl. Dept. of Education, Dated Aug 7, 1986.

2 I noted that Ply. Voyger was not listed. And the classification of M.P.C. was used on all mini vans, are not these classification made for several reason - and $ having one big reason for foreign vehicle.

Anyway, I am sure you have had many letter, phone calls etc in the past year over parent using vans to transport children for school trips So please review the papers enclose, I feel you see that the Ply. Voyger meet more requirements of a passenger c ar than a truck.

Please review this Mini Van. I feel my children and family are safe in my voyger than a car. No one wants to have an accident. And even the school buses that have been in accident lately have had had injurys - crush tops & sides. Where are the seat Belts?

3

I feel your Department is closing the doors to a better answers to transport our children on short field trips.

You know the driver counts for more than just the kind of vehicle. The driver should be $99[Illegible Word]

Our children are missing out on alot of short educational trips. The schools can not afford to use schools buses for the short trips.

Will Amy Ukey please read enclosed papers and let me know if there is any way to change the Department decision on the Ply. Voyger Mini-Van.

Thank you

Do you have a toll free Phone Number?

(Attachments omitted.)

ID: nht88-1.18

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable William Broomfield

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable William Broomfield United States House of Representatives Washington, DC 20515

Dear Mr. Broomfield:

Thank you for your letter, cosigned by Congressmen Bob Carr and Carl Pursell, urging favorable consideration of a petition for reconsideration of Standard No. 208, Occupant Crash Protection. This petition was filed by C and C, Incorporated, and asked us to reconsider our decision to treat convertibles just like all other passenger cars for the purposes of Standard No. 208, as of September 1, 1989. Further, the petition asked us to change our long-standing interpretation that T-top vehicles are not conve rtibles.

We have not yet completed our analysis and response to this petition. We will consider your views, as well as the arguments presented in the petition, in reaching our final decision. I will see that you are informed of our response to this petition as so on as the analysis is completed.

I have placed a copy of your letter and this response in the public docket for this petition. If you have any further comments or need additional information on this subject, please let me know.

Sincerely,

Diane K. Steed

cc: The Honorable John D. Dingell The Honorable William Lehman

Congress of the United States House of Representatives Washington, DC 20515

January 11, 1988 The Honorable Diane K. Steed Administrator National Highway Traffic Safety Administration Department of Transportation 400 Seventh St., S.W. Washington, DC 20590

Dear Ms. Steed:

We understand that on April 29 and October 19, 1987, C and C, Incorporated of Michigan filed a petition for reconsideration (Docket No. 74-14, Notice 51) of a Notice published in the March 30 Federal Register (52 F.R. 10122). We am also aware of your age ncy's notice of October 17, 1986 (51 F. R. 37028, 37029) wherein you concluded that a "vehicle with a T-bar roof would not be considered a convertible." In the March Notice, we understand NHTSA declined reconsideration of a Toyota petition "to exclude T- bar roof vehicles from the automatic restraint requirement." Your Notice explains:

Toyota said that "due to the lack of a door frame or a roof side rail structure, it is impossible to install an automatic belt that is acceptable to customers to the T-bar roof vehicles in view of current technology." Toyota said it will have to disconti nue T-bar roof vehicles after September 1, 1989, unless those vehicles are excluded from the automatic restraint requirement.

NHTSA has decided to retain its current interpretation of the term convertible and thus, is not adopting the proposed revision requested by Toyota. As discussed earlier in this notice, driver-side air bags and automatic safety belt systems will be availa ble for use in convertibles. Since those systems are available for convertibles, Toyota and other manufacturers of cars with T-bar roofs can use those same systems to comply with the performance requirements of the standard.

We observe that C and C's April 29 letter takes issue with the basis for this conclusion, such as your reference to an Alfa Romeo device.

We understand that you have not acted on the C and C petition which raises factual and economic issues unique to this firm and not to Toyota. Those issues, particularly the potential job loss, are not addressed in your March 30 Notice. They would probabl y not be significant in the case of Toyota. They are very significant for this firm. We understand that one manufacturer, Ford Motor Company', has canceled a T-roof contract. That may or may not be related to this matter, but it bodes badly for this firm and its workers.

We point out also that C and C is not seeking a permanent exemption from the 208 rule.

We urge favorable consideration of this petition for reconsideration and development of a proposal that will not cause a job loss at this firm.

Sincerely,

WILLIAM BROOMFIELD BOD CARR CARL PURSELL Member of Congress Member of Congress Member of Congress

cc: The Honorable John D. Dingell, Chairman Committee on Energy and Commerce

The Honorable William Lehman, Chairman Subcommittee on Transportation and related Agencies Committee on Appropriations

ID: nht88-1.19

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Bob Carr

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Bob Carr United States House of Representatives Washington, DC 20515

Dear Mr. Carr:

Thank you for your letter, cosigned by Congressmen William Broomfield and Carl Pursell, urging favorable consideration of a petition for reconsideration of Standard No. 208, Occupant Crash Protection. This petition was filed by C&C, Incorporated, and ask ed us to reconsider our decision to treat convertibles just like all other passenger cars for the purposes of Standard No. 208, as of September 1, 1989. Further, the petition asked us to change our long-standing interpretation that T-top vehicles are not convertibles.

We have not yet completed our analysis and response to this petition. We will consider your views, as well as the arguments presented in the petition, in reaching our final decision. I will see that you are informed of our response to this petition as so on as the analysis is completed.

I have placed a copy of your letter and this response in the public docked for this petition. If you have any further comments or need additional information on this subject, please let me know.

Sincerely,

Diane K. Steed

cc: The Honorable John D. Dingell The Honorable William Lehman

Congress of the United States House of Representatives Washington, DC 20515

January 11, 1988

The Honorable Diane K. Steed Administrator National Highway Traffic Safety Administration Department of Transportation 40O Seventh St., S.W. Washington, DC 20590

Dear Ms. Steed:

We understand that on April 29 and October 19, 1987, C and C, Incorporated of Michigan filed a petition for reconsideration (Docket No. 74-14, Notice 51) of a Notice published in the March 30 Federal Register (52 F.R. 10122). We am also aware of your age ncy's notice of October 17, 1986 (51 F. R. 37028, 37029) wherein you concluded that a "vehicle with a T-bar roof would not be considered a convertible." In the March Notice, we understand NHTSA declined reconsideration of a Toyota petition "to exclude T- bar roof vehicles from the automatic restraint requirement." Your Notice explains:

Toyota said that "due to the lack of a door frame or a roof side rail structure, it is impossible to install an automatic belt that is acceptable to customers to the T-bar roof vehicles in view of current technology." Toyota said it will have to disconti nue T-bar roof vehicles after September 1, 1989, unless those vehicles are excluded from the automatic restraint requirement.

NHTSA has decided to retain its current interpretation of the term convertible and thus, is not adopting the proposed revision requested by Toyota. As discussed earlier in this notice, driver-side air bags and automatic safety belt systems will be availa ble for use in convertibles. Since those systems are available for convertibles, Toyota and other manufacturers of cars with T-bar roofs can use those same systems to comply with the performance requirements of the standard.

We observe that C and C's April 29 letter takes issue with the basis for this conclusion, such as your reference to an device.

We understand that you have not acted on the C and C petition which raises factual and economic issues unique to this firm and not to Toyota. Those issues, particularly the potential job loss, are not addressed in your March 30 Notice. They would probabl y not be significant in the case of Toyota. They are very significant for this firm. We understand that one manufacturer, Ford Motor Company, has canceled a T-roof contract. That may or may not be related to this matter, but it bodes badly for this firm and its workers.

We point out also that C and C is not seeking a permanent exemption from the 208 rule.

We urge favorable consideration of this petition for reconsideration and development of a proposal that will not cause a job loss at this firm.

Sincerely,

WILLIAM BROOMFIELD BOB CARR CARL PURSELL Member of Congress Member of Congress Member of Congress

cc: The Honorable Jon D. Dingell, Chairman Committee on Energy and Commerce

The Honorable William Lehman, Chairman Subcommittee on Transportation and related Agencies Committee on Appropriations

ID: nht88-1.2

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/88 EST

FROM: SAF-TEE SIPING & GROOVING INC.

TITLE: NONE

ATTACHMT: ATTACHED TO DECEMBER 30, 1988 LETTER FROM JONES TO SPRUNK, OCTOBER 8, 1987 LETTER FROM SPRUNK TO JONES, 1978 NSC WINTER TEST REPORT, AUGUST 19, 1986 LETTER FROM KEIL TO SPRUNK, ARTICLE FROM AUGUST 1986 ISSUE OF "SCHOOL BUSINESS AFFAIRS," ARTICL E ENTITLED "SLASHING TIRES FOR SAFETY AND SAVINGS" FROM DECEMBER 1984 "NATIONAL SCHOOL BUS REPORT," MARCH 20, 1985 LETTER FROM GIFFORD TO SPRUNK, OCTOBER 15, 1982 LETTER FROM PALMER TO MARCY MANUFACTURING, AND APRIL 1983 AND APRIL 1984 ARTICLES FROM "GW SAFETY TALK"

TEXT: For SIPING mounted passenger car tires & light duty truck tires

Our model SP Saf-Tee siper is designed specifically for passenger and light duty tires which are mounted on wheels. The machine comes equipped with 12 blades along with the 4 lead screws for siping depths of 5/32", 7/32", 9/32" and 11/32", a wrench for changing the lead screws and a file for sharpening the blades. The machine also comes standard with the Universal Passenger Adapter that will accommodate any wheels that have an opening of 1.75" up to 5 1/2" center hole. This machine has recently been redesigned and the lifting height of the tire has been lowered. It is fast, easy to operate and takes less than 3 minutes to mount, sipe and dismount the tire. The machine requires very little room and operates with 110 power and air.

This machine is an excellent profit builder for a tire operation or anyone who services automobiles and light duty vehicles. With the advent of high performance tires siping is becoming increasingly popular as a way to offer these tires traction and sta bility on wet and slippery surfaces, in addition to extending the tire life.

FEATURES:

* Fast . . . entire siping process takes less than three minutes.

* Exclusive spiral cut creates "tie bars" that strengthen tread components to reduce chunking.

* 90 degrees angle cut across tire gives most traction opposite to the line of travel and desired braking vector.

* Sipes remain sharp and gripping -- can be accomplished only by siping after tire is manufactured.

* Profitable. You get repeat business from satisfied customers. You give them increased safety, reduced operating costs and better tire performance.

SPECIFICATIONS: Height 38"

Width 27"

Side Width 34"

Weight 200lbs.

Motor 1 HP, 110 (standard)

The concept of siping was first patented in the 1920s by John Sipe, who made a series of small cuts in his shoes to give him better traction. The idea is not new, but modern technology has developed siping machines to a high level of sophistication. Siping cannot be duplicated during manufacturing because it leaves a small void of rubber between the sipes. After a short period of time it becomes round and ineffective. Saf-Tee sipes cut into the tire, remove no rubber and the edges remain sharp an d gripping.

Saf-Tee siping machines cut slits at a 90 degrees angle across the tire tread, from 5/32" to 11/32" deep. These slits create thousands of sharp, gripping edges to provide extra traction, safer braking and actually extend the life of the tire as a res ult of dissipation of heat on highway travel. Siping across the tire gives the most traction opposite to the line of travel and desired braking vector.

RUNNING

Under normal road conditions: The ribs flex, responding to bumps and pits in the road, reducing shock to carcass and sidewalls. The tire runs cooler. Under wet, icy snow conditions: The ribs flex, the sharp, exposed edges cut through the hazard squeege eing the water out of the way.

ACCELERATION

Positive traction starts and acceleration in all weather conditions . . . spin on snow and ice is drastically reduced: The ribs separate and expose the sharp squeegee edges to cut to the road surface and channel the hazard out of the way. And . . . sipin g reduces tread wear, extending tire life.

BRAKING

Straight line braking: Without jacknifing, fishtailing or skids. The ribs separate, squeegeeing the hazard or road film away, giving the tire a sure-footed grip on the road surface. Siped tires greatly reduce heat buildup in braking and reduces tire we ar. Siped tires greatly reduce the distance needed to stop.

TESTS

Tests conducted by the National Safety Council on the performance of siped vs. unsiped tires on ice resulted in a 64% increase in breakaway traction and an increase of 28% spinning traction. In stopping distance tests, the reduction was from 200 feet to 155.6 feet -- a 22% improvement.

Major airline engineers tested the use of siping on ground equipment vehicles at O'Hare Field. They recorded a 25.72% increase in drawbar pull on a wet ramp flooded with glycol from deicer. They also show a 33.96% increase in braking under the same conditions. Tests were made before and after siping. As a result of these tests, they have saved thousands of dollars by reducing the need for chains on all vehicles.

The winning car in the Uniroyal One Lap of America auto rally was equipped with siped B. F. Goodrich tires. The 8,800 mile, eight-day endurance race began in Detroit, traveled through 28 states, and ended back at Detroit. Even though the driver enco untered near-blizzard conditions with snow and ice in the mountains, he had no trouble with traction. After the rally the siped tires were just like new.

Saf-Tee sipers employ a circular knife to make slits around the circumference of the tire. This causes the bottom of the sipe to form a scallop pattern, providing a varied depth and strength tie between adjoining sipes. Unlike the uniform depth cut of other siping processes, these scalloped "tie bars" reinforce tread components.

WHAT THEY SAID:

"At the present time we operate three retail stores all dealing in passenger and light duty vehicles. We have a siping machine in each of these stores and in the last twelve months our income has been $ 28,000 from siping."

-- Earl Springer, VP

Roemers Tire Centers, Missoula, MT

"On three sets of our logging tires siped at 11/32 deep the results were 40% less useage of chains, less abrasive damage to tread area and 7%-10% more mileage."

-- Larry Gifford, Service Rep.

Yokohama Tire Corporation

"Increased safety and reduced operating cost don't always go together but with Saf-Tee siped tires, they do. There is no way that I would go back to running without them."

-- Bob Beach

Beach Bus Service, Missoula, MT

"We experienced severe handling problems on snow and ice with police vehicles. In an effort to improve this performance we siped tires on several of these vehicles and ran tests. We found we could negotiate 90% comers safely on ice at 25-30 miles per ho ur after siping where previously we could control the car only at 10 miles per hour. Braking was increased in all cases by 30%."

-- Lynn L. Keil City of Billings, Billings, MT

"The improved safety record of our 44 trucks has earned lower insurance rates."

-- Jim Palmer Trucking, Missoula, MT

"Our truck and trailer tires have 20% better wear after siping."

-- Holland Trans. Co., Fargo, ND

"The traction on ice/snow covered surfaces was much improved."

-- Wayne County Sheriff, Wooster, OH

"Since the tires were siped on our tank truck, we find that braking is better. Tires last longer too."

-- Terreberry Septic Service Ltd.

Port Colborne, Ontario

Call for more information, test results, testimonials, specifications and prices.

For SIPING mounted tires from 12" to 24.5"

The Model ST is our most popular siping machine because it is a multi-purpose unit -- it can sipe any tire from 12" to 24.5". with the adapters available. It's easy to run: operators can be trained in 15 minutes. It's fast: the process takes only 3 to 4 minutes per tire to perform. Any type of tire can be siped -- new, re-cap, or used -- as long as it has 5/32" of tread left. Twelve cutting blades are furnished with the ST, along with four lead screws for siping depths of 5/32", 7/32", 9/32" and 11/3 2", a file, and a wrench for switching lead screws.

FEATURES:

* Fast . . . three to four minutes per tire.

* Versatile. Depth and width of sipe can be changed in seconds. Five depths: 5/32", 7/32", 9/32", 11/32" and 13/32". Two widths: 4 to the inch, 5 to the inch. Five angles: 90 degrees standard, and optional 45 degrees right or left, 60 degrees right o r left.

* Reliable. Machines have been in operation for over 15 years, trouble free. Siping does not affect the tire warranty of major tire manufacturers.

* Profitable. Permits servicing wide range of customers. Truckers buy their tires from dealers who offer siping services.

* Exclusive spiral cut creates "tie bars" at bottom of scalloped sipe to strengthen tread components.

* Marketing assistance. A factory-trained rep will set up the machine, instruct operators, and provide a complete promotional package to help sell siping services to your customers.

SPECIFICATIONS:

Height 42"

Width 34"

Side Width 36"

Weight 250 lbs.

Motor 1 HP,110(standard)

For HIGH VOLUME SIPING before mounting on wheels

The Model STE Siper is designed for use by a retreader, large retailer or wholesaler of tires for volume siping before tires are mounted on wheels. The STE is fast. The rim inflates in about five seconds after the operator positions the tire. The whol e process, including the siping, takes less than three minutes.

The Model STE is equipped with an expandable hub to handle rims to fit tire sizes from 13" to 24.5". Four different size rims are needed to accomodate these sizes -- one from 13" to 16", 17" to 20", 20" to 22.5" and 22.5" to 24.5". Rims are optional equ ipment to be selected depending on the tire sizes you most frequently sipe.

Twelve cutting blades are furnished with the STE, along with four lead screws for siping depths of 5/32", 7/32", 9/32" and 11/32" and a wrench for changing the lead screws.

FEATURES:

* Fast . . . entire siping process takes less than three minutes.

* Exclusive spiral cut creates "tie bars" that strengthen tread components to reduce chunking.

* 90 degrees angle cut across tire gives most traction opposite to the line of travel and desired baking vector.

* Sipes remain sharp and gripping -- can be accomplished only by siping after tire is manufactured.

* Profitable. You get repeat business from satisfied customers. You give them increased safety, reduced operating costs and better tire performance.

SPECIFICATIONS:

Height 45"

Width 42" Side Width 40"

Weight 450 lbs.

Motor 1 HP, 110 (standard)

Blades Available from Saf-Tee Siping & distributors

AVIATION GROUND EQUIPMENT SHOWS NEARLY 34% INCREASE IN PERFORMANCE AFTER SAF-TEE (registered) SIPING

This chart shows documented proof of the dramatic increase in draw bar pull that can be expected with the use of "Siped" tires. Siping can reduce the need for tire chains on all your vehicles. Chains are costly and dangerous especially on airport surfa ces. The outlawing of sludded tires made our need even greater. At United where I managed the ground equipment maintenance, we Siped all drive wheel tires, and also some front tires depending on application.

Thousands of dollars were saved by United at O'Hare by reducing the need for chains on all vehicles. They have been using Siped tires for 6 years. For economy and safety I see Siping as a must in all Airport operations.

C.N. HOSTERT

Equipment Maintenance Manager-Retired

O'Hare Field

United Airlines

TIRE SIPING TEST

GATOR TRACTOR 30500# AT 55

TEST ACCOMPLISHED USING DIGAL READOUT DYNAMOMETER ATTACHED TO REAR HITCH OF GATOR AND FRONT HITCH OF T800 WHICH WAS USED FOR LOAD. A. DRAWBAR PULL BEFORE DRY CONCRETE RAMP SIPING AFTER SIPING % INCREASE TEST 1: 14250 15000 5.26% TEST 2: 14200 15300 7.75% TEST 3: 14350 15800 10.10% AVG. 7.70% WET RAMP (FLOODED WITH RUNNING WATER) TEST 1: 11800 13200 11.86% TEST 2: 11900 12800 7.56% TEST 3: 11650 12500 7.30% AVG. 8.91% WET RAMP GLYCOL (FLOODED WITH GLYCOL FROM DEICER) TEST 1: 9750 12400 27.18% TEST 2: 9700 12160 25.36% TEST 3: 9550 11900 24.61% AVG. 25.72%B. BRAKING TEST ACCOMPLISHED STATIC BY LOCKING BRAKES ON GATOR AND DRAGGING WITH T800 BEFORE DRY CONCRETE RAMP SIPING AFTER SIPING % INCREASE TEST 1: 13000 13800 6.15% TEST 2: 13100 14000 6.87% TEST 3: 13200 13950 5.68% AVG. 6.23% WET RAMP (FLOODED WITH RUNNING WATER) TEST 1: 10700 13450 25.70% TEST 2: ? 13600 ? TEST 3: 11200 13900 24.11% AVG. 24.90% WET RAMP . GLYCOL (FLOODED WITH GLYCOL FROM DEICER) TEST 1: 8700 12270 41.03% TEST 2: 9500 12380 30.32% TEST 3: 9500 12400 30.53% AVG. 33.96%

Test conducted by United Airlines Engineers

ID: nht88-1.20

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Frank S. Perkin -- Assistant General Counsel, The Budd Company

TITLE: FMVSS INTERPRETATION

ATTACHMT: 9/22/86 letter from Erika Z. Jones to Steven R. Taylor; 2/7/83 letter from Frank Berndt to H.J. Lindekugel

TEXT:

Frank. S. Perkin, Esq. Assistant General Counsel The Budd Company Law Department 3155 West Big Beaver Road Box 2601 Troy, Michigan 48084

This responds to your letter expressing concern about a statement in one of our interpretation letters, which you believe could be read as condoning the practice of rebuilding wheels by processes which include heading and welding. As discussed below, our letter's reference to remanufacturing wheels was made only to serve as an illustrative example. and was not intended to address either the safety of such processes or the relevant regulations of other Federal agencies.

The interpretation letter in question is one that we sent on September 22, 1986, to Steven R. Taylor, responding to a request concerning regulations that apply to manufacturers of reconditioned brake drums. The letter included the following paragraph:

NHTSA has in the past considered the issue of what types of operation; bake a person a manufacturer with respect to retreaded tire; and remanufactured wheels. A person who retreads tires is considered to be a manufacturer under the Vehicle Safety Act. Th e retreading process involves significant manufacturing operations, which do not differ substantially from those of manufacturing new tires. By contrast, a person who remanufactures wheels is not considered to be a manufacturer under the Vehicle Safety A ct. The process of remanufacturing wheels consists of such things as straightening, re-welding parts, and repairing cracks by welding. These types of actions are not significant manufacturing operations, but instead are the type of operations commonly pe rformed in repair shops.

You stated that all of the things mentioned in our letter, i.e., straightening, re-welding parts and repairing cracks by welding, are specifically prohibited by the OSHA standard applicable to truck wheels, both multi and single piece. You also stated th at the "out of service" criteria adopted by the Bureau of Motor Carrier Safety mandate that a vehicle be placed out of service if welded repairs are found on certain disc wheels. According to your letter, any significant changes made after the manufactur e of a steel truck wheel, especially involving bending, heating or welding, carry a significant risk of rendering the wheel unsafe.

As is indicated from the context of our September 22, 1986 interpretation letter, the reference to remanufacturing wheels was made solely for the purpose of providing an illustrative example and was not intended to address either the safety of such proce sses or their permissibility or impermissibility under the relevant regulations of other Federal agencies. I would note that NHTSA has long taken the position that remanufactured wheels are considered to be used wheels instead of new wheels for purposes of Federal motor vehicle safety standards. See, for example, our November 28, 1973 letter addressed to Mr. L. Clinton Rich and February 7, 1983 letter to Mr. H. J. Lindekugel (copies enclosed). Again, however, these letters do not purport to address the safety of remanufacturing wheels or the relevant regulations of other Federal agencies.

We appreciate your bringing to our attention your concern about the safety of remanufactured wheels. Copies of this correspondence are being placed in the public docket.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

Erika Z. Jones Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation Washington. D.C.

Dear Ms Jones:

Reference is made to a letter you wrote to Steven Taylor dated Sept. 22, 1986, which was distributed by the TTMA to its members. A copy is enclosed for your convenience.

The Budd Company, as a wheel manufacturer. is seriously concerned by a comment in the next to last paragraph of your letter which could be read as condoning the practice of rebuilding wheels by processes which include heating and welding same.

While I am sure that this was not your intent, I believe it is appropriate to note that all of the things mentioned in your letter, i.e. straightening, re-welding parts and repairing cracks by welding, are specifically prohibited by the OSHA standard app licable to truck wheels, both multi and single piece. See 29 CFR 1910. I further note that the "out of service" criteria adopted by the Bureau of Motor Carrier Safety of the DOT mandate that a vehicle be placed out of service if welded repairs are found on certain disc wheels.

The basis for all of this is that the manufacture of a steel truck wheel is a complex process involving carefully calculated cold forming of its components to produce the required strength, followed by controlled welding or other joining processes, I fol lowed again by elaborate testing to verify the integrity and efficacy of the final product. Any significant changes made later, especially involving bending, heating or welding carry a significant risk of rendering the wheel unsafe.

For the above reasons I hope you will consider advising anyone who may have received the referenced or any similar letter from your agency that such practices are not condoned and may be unlawful. Very truly yours

Frank S. Perkin Asst. General Counsel

cc: Truck Trailer Mfgrs Assn 1020 Princess St Alexandria Va 22314

ID: nht88-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Automotive Safety Testing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Billy S. Peterson President Automotive Safety Testing, Inc. Product Liability-Testing-Certification at TRC of Ohio East Liberty, OH 43319

Dear Mr. Peterson:

This is in reply to your letter of September 23, 1987, with respect to positioning of rear mounted lamps and reflectors in accordance with Federal Motor Vehicle Safety Standard No. 108. Your client has designed a vehicle in which the backup lamps and rea r reflex reflectors would be mounted on the deck lid, and you have asked whether there are any current or contemplated prohibitions that would preclude this design.

The lamps in question will be mounted on a rigid part of the vehicle as required by paragraph @4.3.1 of Standard No. 108, and the deck lid will be closed and the lamps and reflectors in full view under normal operating conditions. The visibility requirem ents of lamps and reflectors in Standard No. 108 are predicated on the normal driving or closed deck lid position. Since the use of motor vehicles, including driving with deck lids open or otherwise having the lamps and reflectors obscured by a particula r load on the vehicle is under the jurisdiction of the individual States, we do not anticipate rulemaking on this subject. Thus, this design is not prohibited by Standard No. 108.

Sincerely, Erika Z. Jones Chief Counsel

September 23, 1987 Administration National Highway Traffic Safety U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Ms. Steed:

Our client, Hyundai Motor Company, has asked us to inquire regarding the positioning of rear mounted lamps and reflectors in accordance with FMVSS 108 for a new model currently in the final design stages. The rear lighting design for the new model provides for mounting some of the lighting on the bottom edge of the trunk lid, similar to a design currently used on the Audi 5000.

Although FMVSS 108 Table IV only calls for paired lamps and reflectors that are required on the rear to be at the same height on each side of the vertical centerline and "...as far apart as practicable," Hyundai would like to know if there are any curren t specific prohibitions or future anticipated changes that would preclude or limit the mounting of rear lamps or reflectors on the trunk lid. A schematic of the rear lighting configuration for the new model is enclosed.

Sincerely,

Billy S. Peterson President

BSP/PLS/plm

Enclosure

ID: nht88-1.22

TYPE: INTERPRETATION-NHTSA

DATE: 02/01/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Jaguar Cars, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

C.D. Black, Engineering Manager Legislation, Compliance Product Development 600 Willow Tree Road Leonia, NJ 07605

Dear Ms. Black:

This is in reply to your letters of June 8 and October 17, 1987, with respect to an electrically-operated headlamp leveling system that Jaguar intends to offer on passenger cars beginning with the 1989 model year. Such a device is required by EEC regulat ions. You have informed us that the system does not allow lamps to be adjusted above the "zero" position, only downward to compensate for rear end loading of the vehicle. There is no provision for automatic return to the "zero" position when the engine i s turned off. Further, there will be no indication to the driver from the vehicle instrumentation that re-aim is necessary when the headlamps are adjusted downward. You have concluded, for the six reasons given in your letter of June 8 that "no aspect of FMVSS 108 . . . is contravened by this proposed installation."

The sole restriction that Standard No. 108 imposes upon an item of motor vehicle equipment not covered by the standard but which a manufacturer wishes to add to a vehicle as original equipment is that it not impair the effectiveness of the lighting equip ment that the standard requires (S4.1.3). If a manufacturer concludes that the unrequired equipment would not impair the effectiveness of the required lighting equipment, it may certify that the vehicle complies with Standard No. 108. Based on our unders tanding of your system, it does not appear to impair the effectiveness of the required equipment. However, we urge you to consider the possible consequences if the driver forgets to return the system to the "zero" position from either of the two adjustme nt positions. These possibilities are a concern because the system does not automatically return to that position, and no warning is provided to the driver that the headlamps are not in their original design position. On the other-hand, if properly used, the system could enhance headlighting effectiveness by ensuring that the headlamp provides the same lighting performance under all conditions of vehicle load.

We hope the information is helpful.

Sincerely,

Erika Z. Jones Chief Counsel

June 8, 1987

Ms. Erika Z. Jones, Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street SW Washington, D.C. 20590

REQUEST FOR INTERPRETATION FMVSS 108 DRIVER ADJUSTMENT OF PASSENGER CAR HEADLAMPS

Dear Ms. Jones:

Jaguar Cars Ltd. of Coventry, England, manufactures passenger cars for worldwide markets. For UK and European road vehicles of all types it will be required, by EEC Directive 76/756 (as amended) Paragraph 4.2.6, to fit a system for maintaining headlamp d ip beam (passing beam) vertical alignment. If this is not achieved by power operated suspension levelling, then either an automatic lamp-levelling system or a control operable from the driving seat must be provided.

Jaguar will fit an electrically operated lamp-levelling system, operable from the drivers seat, to the XJ-S model range on all cars for the United Kingdom and for Europe from Job 1 1989 model year. Jaguar would like to fit this system to cars supplied fo r the USA market.

Jaguar believes that this will not contravene or compromise any aspect of compliance with FMVSS 108 for the following reasons:

1. In a front-engine passenger car, the only adjustment required after the initial aim in the "driver only" condition is downward. (This may not be valid for rear engine cars or for heavy trucks).

2. The lamps will be compatible with the use of mechanical aimers as defined in FMVSS 108 and the sub-referenced SAE J.602. New semi-sealed light units for the USA models will conform with all applicable requirements of FMVSS 108. (Distinct conditions of light units will be used for U.S. and for Europe but they will be designed to fit commonised mountings and therefore will enable use to be made of the lamp levelling feature.)

3. The lamp mounting will be designed to meet the torque deflection test of SAE J.580.

4. A mechanical adjustment facility for manufacturing tolerances and an initial alignment will be fitted to each lamp and will be operable in the manner required by SAE J.580.

5. Subsequent to the initial alignment as defined in lighting inspection code SAE J.599, the only adjustment operable from the driving seat will be downward. Because the lamp provides both passing and driving beams this will enable the driver to adjust t he beams downward if necessitated by heavy rear seat, trunk, or trailer hitch loading. It is impossible to adjust the beams to a higher position than the datum setting by the operation of the control from the drivers seat.

Even if the driver does not use the control under the conditions outlined above, then the dazzle problem would never be worse than that created by conventionally mounted lamps. What the lamp levelling system would provide is the opportunity to eliminate dazzle that would otherwise occur.

6. Jaguar will explain in the owner literature the correct use of the control by the driver. Jaguar will also instruct dealers and servicing outlets of the need to zero the drivers control before checking or adjusting beam alignment.

For the foregoing reasons, Jaguar believe that no aspect of FMVSS 108 or the subreferenced SAE standards is contravened by this proposed installation. However, because of design and manufacturing leadtimes we request your confirmation that our interpreta tion is correct.

We believe we have explained all relevant features of the system but if further information or clarification is required, please contact me by telephone.

Sincerely,

C.D. Black CDB:as Engineering Manager Legislation, Compliance, Product Development

ID: nht88-1.23

TYPE: INTERPRETATION-NHTSA

DATE: 02/01/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Bureau of Economic Analysis

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Edgar G. Meyer Bureau of Economic Analysis Florida Department of Commerce 407 Fletcher Building Tallahassee, FL 32399-2000

Dear Mr. Meyer:

This responds to your November 24, 1987 letter asking about the applicability of Federal Motor Vehicle Safety Standard No. 302, Flammability of Interior Materials, to the manufacture of automobile seat cushions and seat backs. Specifically, you asked whether it would be permissible if the fabric (i.e., felt) from which the seat cushions and seat backs would be manufactured were made from "old clothes and rags." Standard No. 302 neither specifies nor prohibits any particular type of raw material used to manufacture seat backs and seat cushions. The felt must meet the flammability requirements of the standard if it is used for cushions and seat backs for new motor vehicles. Also, felt used to manufacture seat cushions and seat backs for new and used motor vehicles must contain no safety related defects.

The National Traffic and Motor Vehicle Safety Act and NHTSA regulations require manufacturers of new motor vehicles to certify that their vehicles comply with all applicable Federal motor vehicle safety standards, including Standard No. 302. Standard No. 302 specifies burn resistance requirements for materials used to manufacture seat cushions and seat backs on new passenger cars, multipurpose passenger vehicles, trucks and buses. Thus, any person manufacturing a new vehicle with seat backs and seat cus hions made from the felt material you described must ensure that the seat backs and cushions possess the burn resistance characteristics required by Standard No. 302. If the felt can meet those requirements, it may be used in new motor vehicles in satisf action of Standard No. 302, regardless of the felt's raw materials.

The felt manufacturer should also be aware that the Vehicle Safety Act requires all vehicle and equipment manufacturers to ensure that their products contain no defects relating to motor vehicle safety. If it were determined by the manufacturer or this a gency that the seat cushions and seat backs had a safety related defect, all purchasers of the vehicle containing the defective equipment would have to be notified and the defective item repaired or replaced without charge.

If the felt material is used to manufacture items of motor vehicle equipment that are sold to vehicle owners for use in used vehicles (i.e., vehicles previously purchased in good faith for purposes other than resale), the felt need not meet Standard No. 302. In general, it would not violate Standard No. 302 to add aftermarket seat cushions to used vehicles, even if the addition of the seat cushions caused the vehicles to no longer comply with the standard.

This general rule is, however, limited by the application of the provisions of section 108(a)(2)(A) of the Safety Act. That section specifies: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative vehi cle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard ..." The flammability resistance of the original vehicle is an element of design installed in a motor vehicle in compliance with Standard No. 30 2. Thus, any person in the aforementioned categories that installed a seat cushion which did not comply with the flammability resistance requirements of Standard No. 302 would be rendering inoperative that element of design, and thereby violating a secti on 108(a)(2)(A). Section 109 of the Act specifies a civil penalty of up to $1,000 for each violation of section 108.

Again, the manufacturer of the aftermarket seat cushions would be obligated to recall and remedy cushions that are determined to contain a safety related defect, even if the cushions were installed by the vehicle owners themselves.

You asked about other Federal laws that might have a bearing on the manufacture of the felt material. You might wish to contact the Occupational Safety and Health Administration at (202) 523-8148 and the Environmental Protection Agency at (202) 475-8040 for information about the applicability of any of their statutes and regulations.

Sincerely, Erika Z. Jones Chief Counsel

STATE OF FLORIDA DEPARTMENT OF COMMERCE Division of Economic Development

November 24, 1987

Ms. Erika Z. Jones Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W., Room 5219 Washington, D.C. 20590

Dear Ms. Jones:

We have a British prospect who is considering moving to Florida to manufacture felt for car seat cushions and seat backs. He will be using old clothes and rags as raw materials.

Pursuant to our telephone conversation with Ms. Deidre Hom of Your office, it is our understanding that Standard No. 302: Flammability of Interior Materials (Vol. 49, Section 571.302 Code of Federal Regulations) applies to seat cushions and seat backs.

We would appreciate if you could provide us with a legal interpretation addressing the prospect's question: Is it legal in the U.S. to manufacture felt for car seat cushions and seat backs using old clothes and rags as raw materials?

The prospect will visit Florida in early December. We would like to be ready with an answer at that time. Our telefax number is 904/487-1407. If you have any questions please call me at 904/487-2971.

Thank you for your cooperation.

Sincerely, Edgar G . Meyer Economist EGM/mw cc: Deidre Hom