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

ID: nht74-3.2

DATE: 07/02/74

FROM: ROBERT L. CARTER -- NHTSA MOTOR VEHICLE PROGRAMS

TO: J.M. CRAIG -- GATOR TRAILER CORPORATION

TITLE: NONE

TEXT: Dear Mr. Craig:

This is in reply to your letter of May 30, 1974, describing your pontoon boat trailer and asking if it is permissible to offer a ". . . clamp on light bar at the rear along with front side marker amber lighting for installation forward on the pontoon boat itself?" As you point out "This would mean that the user would have to install the lighting each time a rig is put on the highway."

Your proposed installation arrangement does not appear to be in conformance with paragraph S4.3.1 of Federal Motor Vehicle Safety Standard No. 108, which requires that lighting and reflective devices be securely mounted on a rigid part of the vehicle. If the cargo partially obscures the[Illegible Words] the required lighting devices on the trailer.[Illegible Words] regulations would govern any additional, temporarily attached lighting devices on the cargo.

We trust this answers your question.

Sincerely,

ID: nht74-3.20

DATE: 11/04/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Car and Truck Renting and Leasing Association

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your July 25, 1974, letter and our subsequent discussions which raise the question whether the construction of a truck using the power train (rear axle, suspension, drive line, and engine) of a damaged 1972 truck and all or part of a new glider kit constitutes the manufacture of a new motor vehicle, subject to Federal motor vehicle safety standards, including Standard No. 121 after March 1, 1975.

Re-use of components from an existing vehicle in the construction of another vehicle may or may not result in the manufacture of a new vehicle. The NHTSA has established that the addition of new components (such as a truck body) to the chassis of a used vehicle does not constitute the manufacture of a new vehicle. Conversely, the addition of used components to a new chassis constitutes the manufacture of a new vehicle, subject to the safety standards in effect for that vehicle class on the date of manufacture. This criterion has been relied on in the area of chassis-cab multistage manufacture.

Typically a "glider kit" is a truck chassis on which a cab and front axle system are mounted, which is purchased to permit the re-utilization of a power train from another vehicle. Since a glider kit typically incorporates a new chassis (as well as a new cab and front suspension), the NHTSA finds that the use of such a glider kit in the construction of a motor vehicle constitutes the manufacture of a new motor vehicle. To conclude otherwise would mean that a vehicle composed entirely of brand new components except the rear axle and perhaps the engine, would qualify as a used vehicle.

If answer to your question on the use of a portion of the kit: if the kit's chassis portion is used, we would consider the resultant vehicle to be a new motor vehicle. Conversely, use of only the cab portion would not be the manufacture of a new motor vehicle.

A new motor vehicle must conform to all applicable Federal motor vehicle safety standards. If it is not manufactured in two or more stages, the applicable standards are those in effect for the vehicle type as of the date of completion of the vehicle (15 U.S.C.@ 1397(a)(1)) (49 CFR 567.4). If the vehicle has been manufactured in two or more stages in accordance with part 568-(Vehicles manufactured in two or more stages, 49 CFR Part 568), it may be certified as of any date between the date of manufacture of the "incomplete vehicle" and the date of manufacture of the completed vehicle. For example, a truck-tractor constructed of a 1972 power train and a glider kit on some date prior to March 1, 1975, may be certified as of the date that it reaches the "incomplete" stage although its completion (such as by fifth-wheel installation) occurs after March 1, 1975.

The manufacturer responsible for certification under part 567 (49 CFR Part 567) will in many cases be the person who combines the used components with the glider kit. However, if he has manufactured only an "incomplete vehicle" as that term is defined in Part 568, he would provide documentation with the vehicle required under @ 568.4.

Although a glider kit manufacturer may use several serial numbers (e.g., body, engine) the NHTSA only requires one vehicle identification number to appear on the certification plate (@ 567(4)(g)(6)). The manufacturer may use the serial number on the glider kit or may create his own vehicle identification number. It is my understanding that the States have established various practices for the registration of a vehicle which is partially constructed from a formerly registered vehicle. These practices vary greatly and you should check with the individual States regarding them.

ID: nht74-3.21

DATE: 10/10/74

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

TO: Joseph Lucas North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of September 30, 1974, enclosing sample brake hose assemblies and requesting approval of Girling's labeling and banding techniques to meet the requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses, for labeling brake hoses and brake hose assemblies.

The NHTSA interprets a band as a label which encircles the hose completely and attaches to itself. To constitute labeling at all, of course, the band must be affixed to the hose in such a manner that it cannot easily be removed. From this discussion, you should be able to determine the compliance of your labeling method with the standard. The NHTSA does not approve specific designs in advance because the material, installation method, and underlying material can significantly affect the quality of specific design.

ID: nht74-3.22

DATE: 10/07/74

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

TO: Diamond Reo Trucks, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your August 13, 1974, question whether building a motor vehicle from a used power train (rear axle, suspension, drive line, and engine) and a new "glider kit" constitutes the manufacture of a new motor vehicle, subject to Federal motor vehicle safety standards, including Standard No. 121 after March 1, 1975. Typically, a "glider kit" is a truck chassis on which a cab and front axle system are mounted, which is purchased to permit the re-utilization of a power train from another vehicle.

Re-use of components from an existing vehicle in the construction of another vehicle may or may not result in the manufacture of a new vehicle. The NHTSA has established that the addition of new components (such as a truck body) to the chassis of a used vehicle does not constitute the manufacture of a new vehicle. Conversely, the addition of used components to a new chassis which has never been certified in a vehicle constitutes the manufacture of a new vehicle, subject to the safety standards in effect for that vehicle class on the date of manufacture. This criterion has been relied on in the area of chassis-cab multistage manufacture.

Since a glider kit typically incorporates a new chassis (as well as a new cab and front suspension), the NHTSA finds that the use of such a glider kit in the construction of a motor vehicle constitutes the manufacture of a new motor vehicle. To conclude otherwise would mean that a vehicle composed entirely of brand new components except the rear axle and perhaps the engine and transmission, would qualify as a used vehicle.

You noted that our decision could eliminate the use of glider kits because Standard No. 121 certification would prevent re-use of rear axles which do not meet 121-level performance requirements. We believe that our determination will contribute to motor vehicle safety by introducing more 121-type vehicles on the highway and will not interfere with the use of glider kits in the long term. Glider kits can be made to meet Standard No. 121 as soon as 121-type rear axles become available on the used market. Until that time, the rear axles of present vehicles may be utilized as replacement parts in used vehicles which are not required to meet Standard No. 121.

ID: nht74-3.23

DATE: 10/02/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Bendix Home Systems Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 21, 1974, asking whether the terms "loaded vehicle weight" or "rated cargo load" include the liquid for both water potable tanks and waste holding tanks in the case of motor homes and multipurpose passenger vehicles. You indicated in a phone conversation with Mike Peskoe of this office on September 4, 1974, that the purpose of your question is to determine whether the weight of this liquid would be included in a manufacturer's computation of gross vehicle weight rating. You also ask for definitions of "loaded vehicle weight" and "rated cargo load."

It is not required that a determination of gross vehicle weight rating include the weight of a full amount of liquid in both the potable and the waste holding tanks on the assumption, stated in your letter, that in actual use the holding tank is empty when the potable tank is filled, and the liquid is drawn gradually from one tank to the other. It should be placed in the potable tank for determining GVWR, for this more closely reflects a new vehicle configuration.

The term "loaded vehicle weight" is not defined in the Federal motor vehicle safety standards or regulations nor are we aware of its use therein. A related term, "maximum loaded vehicle weight," is defined in Motor Vehicle Safety Standard No. 110 (49 CFR 571.110), but this definition is not applicable to your question. "Rated cargo load" is also not specifically defined, but is used in the requirements for gross vehicle weight rating in 49 CFR 567 and as a test condition in Motor Vehicle Safety Standard No. (Illegible Word) It is intended to mean the manufacturer's good faith rating of the weight of a vehicle's full cargo.

ID: nht74-3.24

DATE: 10/01/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Northland Equipment Co. Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of August 19, 1974, which refers to our letter of July 17, 1974, to the Distributors' Association regarding the use of the incomplete vehicle manufacturer's gross vehicle weight rating by a final-stage manufacturer who adds an additional axle to the vehicle. Our position in that letter was that a gross vehicle weight rating which was so unrelated to vehicle capacity that it suggests a motive such as avoidance of an applicable standard could be construed as a false and misleading certification or a potential safety related defect. You point out that this result works a hardship on persons who customarily add axles because they are unable to determine an appropriate gross vehicle weight rating to use for Certification purposes.

The NHTSA's concern, and indeed the thrust of the Certification requirements, is that vehicles as manufactured will conform to all applicable safety standards when carrying expected loads. However, we are not unmindful, and do not wish to give the impression of ignoring, practical problems connected with compliance with the requirements. Our hope is that the industries involved could collectively resolve their mutual problems, preferably without, but possibly with, assistance from Government regulation. We would certainly consider any concrete proposals for amending the regulations applicable to incomplete and intermediate vehicle manufacturers to resolve this problem, as long as such proposals do not abrogate the primary purposes of the requirements. The use of the incomplete vehicle manufacturers weight ratings is not satisfactory in this respect. We would welcome any future communications you or the various associations might have with respect to possible solutions to this problem, and will be happy to meet with you at your request.