ID: nht76-5.75

DATE: JULY 14, 1976

FROM: WILLIAM K. ROSENBERRY -- ATTORNEY AT LAW

TO: GEORGE SHIFFLETT -- OFFICE OF STANDARDS, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED AUGUST 19, 1978 FROM FRANK BERNDT, NHTSA, TO WILLIAM K. ROSENBERRY

TEXT: It is my understanding that you are responsible for enforcement of the standards promulgated by the Department of Transportation pursuant to the National Traffic and Motor Vehicle Safety Act. The purpose in my writing is to request information concerning the standards promulgated by the Secretary of Transportation.

I have a client which is anticipating the formation of a business in which new pick-up trucks would be purchased from manufacturers and re-outfitted in the cab area by providing a different seat, new carpeting, and headliners, and then sold through dealers to the general public. It is my understanding that the provisions of the National Traffic and Motor Vehicle Safety Act apply to a company in the position of my client, and in particular, Standard #302 relating to flammability of materials and Standard #207 relating to seating requirements.

I would appreciate knowing if a company in the position of my client which is remodeling new automobiles may rely on the warranty of a fabric manufacturer that the fabric sold meets the requirements of Section #302. A fabric supplier has recently stated that they are required under Federal Regulations to test each lot of fabric for flammability purposes before certification can be given. Please advise whether in fact such certification per lot is necessary by a fabric supplier. I would also appreciate being placed on any mailing list which your Department may keep in order that I may be informed of any future standards or changes which relate to this Act and the standards promulgated by the Secretary of Transportation.

ID: nht76-5.76

DATE: 01/01/76 EST

FROM: Frank A. Berndt -- Acting Chief Counsel

TO: W.G. Milby -- Staff Engineer, Blue Bird Body Company

COPYEE: Truck Body and Equipment Association

TITLE: None

ATTACHMT: Attached to letter dated 3-18-77 from Frank Berndt to W.G. Milby; Also attached to letter dated 8-16-90 from Thomas D. Turner to Paul J. Rice (OCC 5110); Also attached to letter dated 1-14-91 from Paul J. Rice to Thomas D. Turner (A37; Std. 221)

TEXT:

This responds to Blue Bird Body Company's July 20, 1976, question whether the NHTSA's redefinition of "school bus" (illegible), December 31, illegible) includes buses designed for intercity transportation utilized in charter operation to transport school children to and from school or related events, and what constitutes "interstate commerce" as that term term is used in the redefinition. A second July 20, 1976, letter from Blue Bird Body requests reconsideration of two NHTSA interpretations of Standard No. 221, School Bus Body Joint Strength, that were issued in an April 26, 1976, letter.

The definition of school bus (affective April 1, 1977) states:

"School bus" means a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as common carrier in urban transportation.

The definition is not intended to include intercity type buses on regular common-carrier routes, although they may be used in some circumstances to transport school students to and from school or related events. This bus type has never been considered a school bus under existing motor vehicle safe standards on Pupil Transportation Standard No. 17 (43 CFR 1204). In light of the major standardizing activity undertaken by Congress for school buses under the Motor Vehicle and Schoolbus Safety Amendments of 1970 (the Act) (15 U.S.C. S 1392(i), it is unlikely that such a broad change of regulatory direction would be contemplated by Congress without explicit discussion in the legislative history. The boundaries of coverage of the redefinition are explicitly left by the statute to agency determination, and the agency did not include the intercity buses you describe in the redefinition.

The meaning "interstate commerce" in the redefinition is the same as for that term in S (illegible)(1)(A) of the Act, which states that no person shall "manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import non-complying vehicles. While the legislative history of the Act does not directly address the meaning of the term, the House of Representatives Committee report stated: . . . the purpose of this section is to prohibit the manufacture, sale, or importation into this country of vehicles . . . that fail to meet the Federal safety standards . . . (H.R. Rep. No. 1776,

(illegible) Cong., 2d Secs 22 (1966))

The agency adopts the existing construction of the term set forth in Ratzenback v McClurg, 379 U.S. (illegible) (1974). To answer your specific question, however, it should be clarified that only the classification of the bus as a school bus is determined by the (illegible) of "interstate commerce" in those infrequent cases were a sale does not occur. Blue Bird Body's responsibilities to conform to the standards arise directly from its manufacturing activities under (illegible)(1)(A). For example, a bus built in Georgia must conform to the school bus standards if it is sold to a Georgia school for use in transportation of school students, even it never leaves the state.

Your second July (illegible) letter requests reconsideration of the NHTSA's April 26, 1976, decision that the area of contact between headlining panels and the "header" over the windows qualifies as a body joint subject to the requirements of the standard. You assert that the area of contact is not such a joint because it is covered by a molding and therefore does not "enclose occupant space" and cannot be considered a "surface component".

"Body panel joint" is defined in the standard to mean, with several exceptions, the area of contact or close proximity between the edges of a body panel and another body component. Whether or not the joint itself it covered is not relevant to its status. The separate definition of "body panel" does refer to the surface of the exterior or interior of the bus and to use of the panel in enclosing the bus occupant space. Thus, it is the body panel and not the joint which must form part of the exterior or interior surface of the bus. In the case you describe, the headlining panel does enclose the bus occupant space and constitutes a part of the interior surface of the bus. Thus it does form a "body panel joint" at the point of contact with the header (a separate body component).

You also suggest that the requirements do not apply to a joint where the edges of the body panel join a body component at a point other than at the edge of the body component. Your interpretation is incorrect. In the case you describe, the floor panel's edges form a right angle that is attached to a central portion of the tag panel at some distance from its edges. The definition of "body panel joint" refers to contact between the edges of the body panel and another body component, without regard to the proximity of the edges of the body component.

You also request confirmation that a statement on rubrails in our April (illegible) letter is fulfilled by ensuring that, in testing a complex joint to which rubrails are fastened, the rubrails are modified so that they are not held by the gripping fixture of the tensile strength test machine. Your interpretation is correct.

In a related matter, the NHTSA would like to advise you of failure in our April 26, 1976, letter to respond fully to Blue Bird Body Company's February 13, 1976, letter. You asked if the cove molding that is attached at the border of the bus body floor against the sidewall of the bus body would qualify as a surface component whose edges form a joint

subject to the standard's requirements. From your description of the cove molding and its use at the edge of the floor, the agency considers that it does not have a function in enclosing the occupant space and is therefore not considered a body component for purposes of the requirements. A copy of your illustration of these component is attached for the benefit of interested persons.

Finally, I would like to acknowledge receipt of your July 28, 1976, letter to the Administrator, asking that the new definition of "school bus" become effective on April 1, 1977, instead of October 27, 1976. Your request has been granted by a recent notice of rulemaking.

ID: nht76-5.77

DATE: December 9, 1976

FROM: Frank A. Berndt -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA

TO: Leon W. Steenbock -- Engineering, FWD Corporation

TITLE: None

ATTACHMT: Attached to letter dated 5-6-93 from John Womack to Bob Brinton (A41; Std. 121); Also attached to letter dated 3-16-93 from Bob Brinton to NHTSA (OCC 8436)

TEXT: This responds to FWD Corporation's October 15, 1976, request to know whether a truck that complies with the requirements of Standard No. 121, AIR BRAKE SYSTEMS, would continue to comply after the addition or another parking brake system (hand-operated mechanical, operating on the driveline) or another service brake control (piped to either or both sides of a split system).

Standard No. 121's requirements for braking systems does not preclude the addition of an additional braking system. The agency would not consider the requirements of S5.6.4 to prohibit an additional parking brake control.

Standard No. 121 does not prohibit installation of more than one service brake control. The installation of a hand-operated control lever that your letter appears to describe would not of itself violate the standard's requirements. If the hand control were piped into both systems, however, a failure introduced into the control would probably result in violation of S5.7.1, which requires certain secondary braking performance following a single failure introduced into the service brake system.

ID: nht76-5.8

DATE: 12/03/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 3, 1976, in which you ask whether the label "Emergency Door," when placed on the glass near the top of a school bus emergency exit, complies with the requirements of Standard No. 217, Bus Window Retention and Release.

The positioning of this label will be regulated by S5.5.3 of Standard No. 217 in the case of school buses manufactured on or after April 1, 1977. That section, as it pertains to the location of the designation "Emergency Door," states in part that the designation shall be ". . .located at the top of or directly above the emergency exit. . ." The markings you describe, located at the top of the glass of the emergency door, would appear to be in compliance with the location requirements of S5.5.3 of Standard No. 217 (effective April 1, 1977).

SINCERELY,

BLUE BIRD BODY COMPANY

November 3, 1976

Frank Berndt Acting Chief Counsel National Highway Traffic Safety Administration

SUBJECT: EMERGENCY DOOR MARKING - FMVSS 217

We are considering a change in early 1977 to a double faced decal made of 3 mil Mylar with a pressure sensitive adhesive which would be applied to the upper inside of the emergency door glass as shown in the enclosed photograph reproductions. We plan to use the designation "EMERGENCY DOOR" two inches in height with black letters on a metallic silver background. We would like to make a location change at the same time.

This type application would be visible from the inside and outside and, of course, would be protected from the weather because of inside application. The viewing angle for a person standing on the ground would be much improved since the decal would be 8" lower than if applied on the header above the emergency door.

Since we need to make a decision as soon as possible, we would appreciate a ruling on whether the above proposal meets FMVSS 217 section S5.5.3 at your earliest convenience.

Thanks

W. G. Milby Manager, Engineering Services Interior

Exterior

(Graphic omitted)

ID: nht76-5.9

DATE: 05/28/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck Body and Equipment Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to the Truck Body Equipment Association's May 7, 1976, question whether S5.2.3.2 of Standard No. 217, Bus Window Retention and Release, requires that the engine starting system of a school bus not operate if an emergency exist other than an emergency door is locked. Section S5.2.3.2 applies to school buses manufactured on or after October 26, 1976.

Section S5.2.3.2 only specifies requirements for the relationship of the engine-starting system to the operation of emergency doors. Reference to "any emergency exit" in the first sentence of the section is in error, as the correct reference to "emergency door" in the second sentence of the section demonstrates. A correction of this error will be made in the text of the standard shortly.

SINCERELY,

TRUCK BODY AND EQUIPMENT ASSOCIATION, (Illegible Word)

May 7, 1976

Frank Berndt, Acting Chief Counsel NHTSA

A question concerning FMVSS 217 as it relates to "School Bus Emergency Exit Requirements" was discussed at our recent Engineering Meeting. Section S5.2.3.2 states:

"The engine starting system of a school bus shall not operate if any emergency exist is locked from either inside or outside the bus. For purposes of this requirement, 'locked' means that the release mechanism cannot be activated by a person at the door without a special device such as a key or special information such as a combination."

Our question concerns the use of the term "emergency exits" in this section with regards to the ignition interlock system.

Does this section require the installation of an ignition interlock system on push-out type emergency windows?

Thanking you in advance for your prompt reply.

Byron A. Crampton Manager of Engineering Services

ID: nht78-1.1

DATE: 12/12/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Thomas Built Buses, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. James Tydings Thomas Built Buses, Inc. P.O. Box 2450 High Point, NC 27261

Dear Mr. Tydings:

This responds to your November 7, 1978, question whether the National Highway Traffic Safety Administration's (NHTSA's) October 13, 1978, interpretation of the Ninth Circuit air brake ruling has revoked the exclusion of school buses from the "no lockup" requirements of Standard No. 121, Air Brake Systems. You also ask if a bus which is designed identically to a school bus qualifies for the exclusion from "no lockup" requirements if it is purchased and used for a purpose other than as a school bus.

The answer to the first question is no. The exclusion of school buses from the stopping distance requirements of Standard No. 121 (S5.3.1) remains in effect and was not altered by the October 13, 1978, interpretation.

The answer to the second question is also no. The exclusion from service brake stopping distance requirements (including the "no lockup" requirement) is limited to school buses, which are defined at 49 CFR S 571.3 as follows:

"School bus" means a bus that is sold, or introduced in interstate commerce, for purposes that include carrying students to and from school or related events, but does not include a bus designed and sold for operation as a common carrier in urban transportation.

The buses you describe would not qualify as "sold ... for purposes that include carrying students to and from school or related events." Therefore, they would not qualify for the school bus exclusion.

Sincerely,

Original Signed By

Joseph J. Levin, Jr. Chief Counsel

ID: nht78-1.10

DATE: 12/05/78

FROM: AUTHOR UNAVAILABLE; J. Levin, Jr.; NHTSA

TO: Yankee Metal Products Corp.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of September 18, 1978, requesting a clarification of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. The National Highway Traffic Safety Administration concurs in your interpretation of S5.3.1 that any hand operated control which is mounted on the steering column does not have to meet the illumination requirements of Column 4 of Table 1.

Sincerely,

ATTACH.

September 18, 1978

KATHLENE DEMETER -- OFFICE OF THE CHIEF COUNCIL, NHTSA/DOT

Dear Ms. DeMeter:

I have been referred to your office for clarification of paragraph 5.3.1 on page 27543, of FMVSS No. 101 -- Controls and Displays; Docket No. 1-18; notice 13; part 571. It is my interpretation of the first sentence of the above paragraph that a hand operated steering column mounted control does not have to comply with the illumination requirements of Column 4 of Table 1.

It is imperative that we receive your written reply to this interpretation as soon as possible, since it could affect the design of a turn signal/hazard warning switch which we are about to release for production.

Thank you very much.

Sincerely, YANKEE METAL PRODUCTS; Walter J. Kulpa

ID: nht78-1.11

DATE: 12/05/78

FROM: AUTHOR UNAVAILABLE; J. Levin, Jr.; NHTSA

TO: Volvo of America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of September 20, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.

Specifically, you asked whether the km/h label on Volvo speedometers could appear in upper case letters instead of the lower case letters appearing in Table 2 of the standard. The answer is yes.

Section 5.2.3 of the standard provides that "any such display for which no symbol is provided in Table 2 shall be identified by the word or abbreviation shown in column 3." There is no requirement that the identifying words or abbreviations be in the same type face, type size, or case as those printed in the Federal Register. Therefore, as long as the abbreviations are the same as those appearing in Table 2 and are visible, no problem arises because Volvo wishes to use upper case, rather than lower case letters.

SINCERELY

September 20, 1978

Joseph J. Levin, Jr. Chief Counsel Department of Transportation National Highway Traffic Safety Administration

Subject: Request for Interpretation, FMVSS No. 101-80

Dear Mr. Levin:

According to Federal Motor Vehicle Safety Standard No. 101-80, the speedometers of 1981 and later model year passenger vehicles are to be labelled "MPH" and "km/h". It is our understanding that it is the intent of this requirement, along with FMVSS No. 127, to encourage the use of metric units of speed and distance. It is also the intent of this standard to present information to the vehicle operator as clearly and unambiguously as possible.

Enclosed is a preliminary example of a Volvo proposed speedometer face. Picture A is the proposed 1981 model year speedometer. Note that in this case, the metric unit for speed is labelled "KM/H". In other words, we have used upper case letters, but in exactly the same configuration. We believe that using the upper case letters does not detract from the clarity of the information being conveyed, nor does it discourage use of the metric system. Thus, we interpret the use of "KM/H" to satisfy the requirement of FMVSS No. 101-80.

Please advise us as to whether you agree with our interpretation of this standard. If I can be of any assistance, please feel free to call.

VOLVO OF AMERICA CORPORATION Product Planning and Development

William Shapiro, P.E. Manager, Regulatory Affairs

ID: nht78-1.12

DATE: 12/29/78

FROM: AUTHOR UNAVAILABLE; J. Levin, Jr.; NHTSA

TO: R. E. Dietz Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of September 21, 1978, requesting interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays.

In your first set of questions, you ask about the application of the display requirements to trucks with a GVWR of 10,000 pounds or more. Those requirements do not apply to such trucks. Under S5 of the standard, the only trucks required by the standard to comply with the display requirements are those with a GVWR less than 10,000 pounds.

In your second set of questions, you pose various questions about the identification and illumination of controls. In the first question, you ask whether the turn signal control symbol must be placed on the control itself. The answer is "no." S5.2.1 provides that the symbol shall be placed on or adjacent to the control. You also ask if there is any size requirement. The answer is again "no." There are no size requirements for any of the control symbols.

In your second question, you ask about the size requirements for the hazard warning signal control. As indicated above, there are no size requirements. As to illumination, S5.3.1 provides that hand-operated controls mounted on the steering column are not required to be illuminated. Thus, neither the turn signal control symbol nor the hazard warning control symbol need be illuminated. With regard to the nonmandatory red lens between the turn signal control symbol, if that lens is intended to call attention to the location of the hazard warning control, we urge that it be triangular. If it is intended to call attention to the turn signal control, we urge that the shape be made less similar to the hazard warning symbol to avoid confusion.

In your third question, you asked about the relationship between the control and display requirements in FMVSS 101 and those in FMVSS 108. The agency will soon issue a notice dealing with this issue.

SINCERELY,

R. E. DIETZ COMPANY

September 21, 1978

Nelson Erickson Office of Motor Vehicle Programs

Dear Mr. Erickson:

This is a request for further information and clarification of new rule 49 CFR 571.101-80 Controls and Displays.

Our questions and concerns pertain principally to our new 16-35 turn signal switch (drawing enclosed), which went into production this year. This type of hang-on switch is used only on Class 7 trucks which are in the weight range of 26,001 to 33,000 pounds GVWR and Class 8 trucks which are over 33,000 pounds GVWR.

1. I understand that since Class 7 and 8 trucks exceed 10,000 pounds GVWR, display requirements of 55.1 in Column 1 of Table 2 do not apply. Is that correct?

2. If correct, then do Columns 3 and 4 apply?

3. If Column 3 applies, then FMVSS 108 sends us to SAE J-589 for turn signal switches which references J-588, which calls for an illuminated area (shape unidentified) equivalent to a 3/16" diameter circle. Is that correct?

4. Column 3 also sends us to FMVSS 108 which refers us to J-910 for hazard switches, which calls for an illuminated area (shape unidentified) equivalent to a 1/2" diameter circle. Is that correct?

If the above statements are correct, then 571.101-80 (in which "the agency has decided that vehicles over 10,000 pounds GVWR need not meet display requirements of this standard") seems to be retaining display requirements. It appears that the intent is that neither Column 3 nor 4 are meant to apply. Is that correct?

Regarding identification and illumination of controls -

1. Would you say that double arrows on the device meet the requirements? If not, is it necessary that they be printed on the lever itself? If so, can they be on the lever axis or must they be on the arc which a point on the lever travels when the lever is moved to the right or left turn position. If there any size requirement?

2. As you can see from our drawing, there is approximately 5/8" of hazard button which extends out from our lever. The thickness of the button varies from 3/16" at the bottom to 1/16" at the top. What size does the identifying symbol have to be? If we could find a plastic which would transmit some light out to the end, would that be considered meeting the specification? If we cannot find a design solution to this requirement, what recourse do we have short of a complete re-design and re-tooling?

3. Finally, I must ask again for clarification of the relationship between 571.101-80 and FMVSS 108. It appears that one could meet all of the requirements of 571.101-80 but be found failing to conform to FMVSS 108. Is it the intent of 571.101-80 to be an addition to the requirements of FMVSS 108.

Your earliest response to these questions would be appreciated since it appears that we may have some significant changes to make.

Donald W. Vescio, Sr. Director of Engineering

(Illegible Lines)

UNLESS OTHERWISE SPECIFIED THE FOLLOWING (Illegible Words)

THREE PLACE DECIMALS (Illegible Word) .006

TWO PLACE DECIMALS (Illegible Word)

DIETZ (registered) R.E. DIETZ CO. SYRACUSE N.Y.

TITLE: 16+35 TURN SIGNAL SWITCH ASSEMBLIES SHEET: 016-35600

3. 16-35 TURN SIGNAL SWITCH IS DESIGNED TO CONFORM TO SAE J 589(b), SAE J 910(b) AND SAE J 588 (e) PARAGRAPH 4.5. IT CONFORMS WITH FMVSS 108 AND IS DESIGNED TO MEET NEW PROPOSED FMVSS STANDARDS FOR PILOT INDICATORS.

HAZARD BUTTON (Illegible Word) PLASTIC

(Graphics omitted)

(Graphics omitted)

ID: nht78-1.13

DATE: 03/23/78

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

TO: Nissan Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: We refer to your letters of November 10 and December 2, 1977, to Mr. Joseph J. Levin, requesting an interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 106-74 Brake Hoses. You inquired as to its applicability to the two anti-skid system hoses "A" and "B" in the diagram you enclosed.

The anti-skid actuator apparently modulates the pressure to the rear brakes upon command from the computer module. You stated that the failure of the actuator would not prevent the brake system from meeting the requirements of FMVSS No. 105-75.

You also stated that the subject hoses carry mineral oil, and that such hoses might deteriorate if subjected to brake fluid. You further stated that standard hydraulic brake hoses would deteriorate if used with the mineral oil which is used in the power steering system.

In the preamble to Notice 11, Docket 1-5, published June 24, 1974, (39 FR 24012) all power steering type hoses that connected power steering pumps with accumulators were exempted from coverage by the standard. Hoses connecting accumulators with brake power boosters were also exempted if redundant boosters were provided. The National Highway Traffic Safety Administration (NHTSA) has reviewed this latter interpretation and determined that all power steering type hoses should be exempted from FMVSS No. 106-74, until appropriate requirements for such hoses are established.

After consideration of the information and the drawings in your letters, we have concluded that hose assemblies A and B connected to your anti-skid actuator are, in fact, power steering hose assemblies. Consequently those assemblies are exempt from the subject standard until suitable requirements for such assemblies are included therein.

Sincerely,

ATTACH.

November 10, 1977

Joseph J. Levin -- Office of the Chief Counsel, NHTSA

Dear Mr. Levin:

This letter is to ask your interpretation concerning FMVSS 106 - "brake hoses".

Attached is the schematic drawing of the brake system with the hydraulic anti-skid unit. Do hoses A and B in this drawing fall under the category of "brake hose" which is defined in S.4 of FMVSS 106? In other words, should those hoses meet FMVSS 106?

I look forward to hearing your reply to the above.

Very truly yours

NISSAN MOTOR CO., LTD.;

Tokio Iinuma -- Staff, Safety

Enclosure

December 2, 1977

Joseph J. Levin -- Office of the Chief Counsel; NHTSA

Dear Mr. Levin:

I asked for your interpretation with regard to FMVSS 106 - "brake hoses" in my letter of November 10, 1977.

I am afraid that my explanation concerning hoses used in the anti-skid unit was insufficient.

The following is the additional information necessary to make my explanation complete:

1. Even if the failure (ex: mineral oil leakage from hoses, inoperative of actuator or vane pump) occurs in the anti-skid unit, the vehicle is capable of meeting FMVSS 105 - "hydraulic brake systems".

2. Difference of material between hoses used in anti-skid unit (hose A, B and C in attachment) and hoses in ordinary brake system which is in compliance with FMVSS 106.

HOSES IN HOSES IN ORDINARY ANTI-SKID UNIT BRAKE SYSTEM outer rubber CR CR (or CR+NR) middle rubber NR NR inner rubber NBR SBR

(Graphics omitted)

3. Compatibility with mineral oil or brake fluid (DOT 3).

HOSES IN HOSES IN ORDINARY ANTI-SKID UNIT BRAKE SYSTEM mineral possibility of deterior- oil no problem ation of property and swelling at inner rubber brake possibility of fluid deterioration no problem (DOT 3) of property at inner rubber

Thank you for your attention to the above matter. I look forward to hearing your reply to my letter of November 10, 1977.

Very truly yours, NISSAN MOTOR CO., LTD.,

Tokoi Iinuma -- Staff, Safety

Enclosure

cc: Welfred M. Redler (NHTSA Office of crash avoidance)

Brake System with Anti-Skid Unit

(Graphics omitted)

NOTE: Hoses A, B and C does not make contact with brake fluid (DOT 3) because the flows of mineral oil for the power steering unit and brake fluid for brake systems are completely separate.