ID: nht73-3.18

DATE: 01/30/73

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 4, 1973, in which you ask for our confirmation of your interpretation of Part 567 and Part 568 of Title 49 of the Code of Federal Regulations that would place the responsibility for certification on the user in those instances where he is the final-stage manufacturer.

Paragraph 567.5 of Title 49 of the Code of Federal Regulations Requirements for Manufacturers of Vehicles Manufactured in Two or More Stages, specifies that(Illegible Words) final-stage manufacturer, . . . of a vehicle manufactured in two or more stages shall affix to each vehicle a label . . . ." Therefore, and users who are also manufacturers would be required to affix the label.

If you have further questions, we will be pleased to answer them.

ID: nht73-3.19

DATE: 02/06/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mr. Robert L. Scates

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 6, 1973, requesting information on requirements regarding the manufacture of truck-mounted campers. You specifically mention requirements dealing with wiring.

There are several Federal requirements applicable to campers. Campers are items of motor vehicle equipment under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) and are required to conform to certain motor vehicle safety standards and regulations. Briefly, each camper must meet requirements applicable to the glazing materials (glass and plastics used in windows, doors, and interior partitions) used in the camper (Federal) Motor Vehicle Safety Standard No. 205, "Glazing Materials", 49 CFR 571.205). Each slide-in camper must, in addition, have affixed to it a label that indicates among other things its loaded weight. (Federal Motor Vehicle Safety Standard No. 126, "Truck-Camper Loading", 49 CFR 571.126). All campers must also be certified in accordance with Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403) as conforming to applicable standards. Each camper manufacturer must submit certain information concerning his company pursuant to NHTSA regulations, "Manufacturer identification" (49 CFR Part 566). You may obtain copies of NHTSA standards and regulations as explained on the enclosure.

We understand that certain states also have requirements, including requirements for wiring, that apply to campers. Information regarding these requirements should be obtained from State authorities. Trade associations that represent recreational vehicle manufacturers may be of help in obtaining this information.

ENC.

ID: nht73-3.2

DATE: 12/03/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mercedes-Benz of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 24, 1973, concerning the conformity of an emergency feature of Mercedes-Benz's interlock system to S7.4.3 of Standard No. 208.

The feature you describe would permit the engine starting system to be operated without belt use for a period of 3 minutes after an activation knob inside the engine compartment is depressed. If the vehicle stalls, the driver would have to leave his seat, open the hood, depress the knob, close the hood, and return to his seat, at which point the interlock would be deactivated for the 3-minute period. This bypass feature would apparently supplement other convenience aspects provided pursuant to S7.4.3.

After review of the Mercedes system we have determined that it would not result in bypassing the interlock in situations where that would not be permissible under S7.4.3 or S7.4.4. We therefore conclude that it is an allowable system and that it may be installed.

Yours truly,

MERCEDES-BENZ OF NORTH AMERICA, INC.

September 24, 1973

National Highway Traffic Safety Administration Dr. James B. Gregory, Administrator

Subject: Request for Interpretation of S7.4.3 of Federal Motor Vehicle Safety Standard 208

As previously reported to motor vehicle program engineers, Daimler-Benz AG., the parent company of Mercedes-Benz of North America, Inc., intends to install an engine-starting system operable without interference from the belt interlock system after the engine has stopped as provided in S7.4.3 of Standard 208. We are of the opinion that the by-pass device is in conformity with Standard 208, but we seek this interpretation of the referenced section for clarity. However, if the administration interprets S7.4.3 so as to not allow the below-described Mercedes by-pass system, then we request that this letter be considered as a petition for rulemaking to amend FMVSS 208 to allow incorporation of such a system in order to deal with the problem of a simultaneous engine stallout at a busy intersection and failure in the interlock system logic sequence. Obviously, such an occurrence could create a hazardous situation for the operator and occupants of a vehicle.

The Mercedes-Benz by-pass device will be tied in with the three minutes free starting period and would operate as follows:

In case of simultaneous engine stall and failure in the logic of the interlock system, the driver will have to open the front hood from inside the vehicle, leave the vehicle, and activate the system by depressing an activation knob located in the

2 engine compartment. The hood is then closed and the driver returns to his position within the vehicle at which point the interlock logic system becomes inoperative for a maximum of three minutes thus permitting repeated starting of the engine even though the driver and front seat passenger are not belted.

We feel this system addresses an important problem which can be encountered in normal driving especially in urban centers and would be in conformity with the present requirements of the standard. Needless to say, there is some urgency to this request for interpretation considering the rapidly approaching introduction date for 1974 model Mercedes equipped with the interlock belt system. Your favorable attention to this request would be most deeply appreciated.

Very truly yours,

H. W. Gerth Assistant Vice President

ID: nht73-3.20

DATE: 02/07/73

FROM: AUTHOR UNAVAILABLE; R. L. Carter; NHTSA

TO: Michael J. Long

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 30, 1973, concerning acrylic headlamp covers.

Federal Motor Vehicle Safety Standard No. 108 Incorporates Society of Automotive Engineers (SAE) Standard J580a, which prohibits the use of acrylic headlamp covers as original equipment. The requirements of SAE Standard J580a have also been incorporated in a number of State regulations, which are applicable to vehicles in use. Copies of Standard No. 108 and SAE Standard J580a are enclosed for your information.

A Notice of Proposed Rule Making (Docket 69-19; Notice 3) on Standard No. 108 was issued on October 16, 1972. This Notice includes a provision for optional use of headlamp covers which conform to certain performance requirements. Such requirements are specified in paragraph S7.9 of the Notice (copy enclosed). Acrylic Industries Pty. Ltd. may be interested in commenting on this proposed revision of Standard No. 108. The closing date for comments is April 18, 1973.

If you have any questions on the enclosed documents, please do not hesitate to contact me.

ID: nht73-3.21

DATE: 02/07/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mr. Satoshi Nishibori

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of December 15, 1972, and January 3, 1973, concerning paragraph S7.4.3 of Standard 208.

As I understand the question, you are positing a situation in which the occupants have correctly operated their belts, thereby permitting the engine starting system to operate, but in which the cranking of the engine by the starter motor does not start the engine and the key is returned to the "on" position. Your question is whether the ignition can thereafter be turned from "on" to "start" in repeated efforts to start the engine, without interference from the interlock.

Our reply is that S7.4.3 permits a system in which the initial correct operation of the belts, followed by operation of the starting system, places the system in a "free-start" mode so long as the ignition is not turned to "off". Repeated efforts to start the engine would therefore be permitted, regardless of the status of the belts.

If the ignition has been turned off and if the system is not in another of the "free-start" modes allowed by S7.4.3, then the engine starting system will not be operable with an unbelted driver on the seat unless an engine compartment switch is operated pursuant to S7.4.4.

ID: nht73-3.22

DATE: 02/08/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: United States Senate

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 26, 1973, which was forwarded to the National Highway Traffic Safety Administration (NHTSA) by National Transportation Safety Board Chairman John H. Reed, regarding the position of the shoulder harness on the Toyota Corona purchased by Mr. John McCauley of Mattapan, Massachusetts. A copy of the constituent's letter is enclosed.

Federal Motor Vehicle Safety Standard No. 208, Occupant(Illegible Word) Protection, requires that all cars made after January 1, 1972, have lap and shoulder belts which fit specified occupant sizes. Our Office of Standards Enforcement has made telephone contact in order to obtain more detailed information on Mr. McCauley's vehicle and the exact nature of the safety belt problems which he experienced.

I appreciate Mr. McCauley's interest in motor vehicle safety and his bringing this situation to our attention. As we had recently received a similar complaint on another model Toyota automobile, our Office of Standards Enforcement is conducting an investigation of the entire matter.

ID: nht73-3.23

DATE: 02/12/73

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Rubber Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 5, 1973, to Dr. Edward H. Wallace, concerning your objections to the informal rulemaking procedures employed by NHTSA in adding new tire sizes and rims to the Appendices to Federal Motor Vehicle Safety Standards Nos. 109 and 110 (49 CFR 571.109, 110). You enclose two form letters sent to you by NHTSA which indicate that certain tire sizes and rims will be included in the Appendices, and object to the delay that appears to occur between your receipt of these letters and the time the amendment to the Appendices is published in the Federal Register.

Your letter indicates a possible misunderstanding of the requirements applicable to rulemaking procedures, and how these requirements affect the publication of new tire sizes and rims in the Appendices of the two safety standards.

The NHTSA is required, under the Administrative Procedures Act (5 U.S.C. 551 et seq.), to amend all motor vehicle safety standards (amendments to the appendices of Standards Nos. 103 and 110 are amendments to the standards) by publication in the Federal Register. The submittal of documents to the Federal Register is governed by regulation (Title 1 of the Code of Federal Regulations, Parts 1 - 40) which the NHTSA must follow in submitting documents for publication. Simply stated, these regulations would not permit the NHTSA to merely send to the Federal Register copies of these acknowledgment letters, for publication, as you suggest. Documents must be prepared utilizing a specific format. We have recently modified the method by which NHTSA amends the Appendices in a way that permits these documents to be prepared in a shorter time. Moreover, normally notice of proposed rulemaking and opportunity to comment is required to be published before such amendments can become effective. The procedures about which you complain actually shorten the time that would otherwise be necessary for these changes to take effect. The form letter which you refer to as providing approval is

no more than an acknowledgment and indicates only that the tire size designations and rim sizes in question will be included in the next amendment to the Appendices, under the special procedures which allow their use in 30 days if objections are not received.

For these reasons, we have not found it administratively practicable to publish notices of additional tire sizes whenever they may be received. We have indicated our intention to publish amendments quarterly. While we have not met this schedule as consistently as we hoped, we expect to improve our efforts in this regard in the future.

ID: nht73-3.24

DATE: 02/14/73

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Orin D. Miner

TITLE: FMVSS INTERPRETATION

TEXT: Contact 6 of Milwaukee, Wisconsin has sent us a copy of your letter asking that we respond to your questions.

In your letter you inquire as to the distribution of fines collected from tire manufacturers as a result of their manufacturing tires that do not comply with the requirements of the Federal standard for passenger car tires (Standard No. 109).

Monies collected as settlement offers are transmitted to the general funds of the United States Treasury.

The Federal Motor Vehicle Safety Standards, including the passenger car tire standard, are minimum standards vehicle manufacturers and equipment manufacturers are required to meet. They are issued to give assurance that if the product in question meets the standards the public will have some protection against unreasonable risk of death or injury.

In addition to the question of civil penalties, manufacturers of non-conforming vehicles or tires are usually required to issue a defect notification and are urged to replace the defective equipment. Your complaint does not appear to be concerned with a safety related problem but rather with tires that you believe have not given you adequate treadwear. This is not an area covered by existing standards, however, this agency has under consideration a quality grading regulation which would include grading requirements for the treadwear life of each tire manufactured after a given date.

Concerning your recommendation that Federal inspectors be placed in tire manufacturers' plants, this has been considered at various times and the agency's present thinking is that the cost and manpower involved would not warrant this course of action.

Thank you for your interest in auto safety and your views in this area.

ID: nht73-3.25

DATE: 02/14/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 23, 1973, concerning the sequence of manual switch operation under S7.4.4 of Motor Vehicle Safety Standard No. 208. Your question is whether S7.4.4 requires the manual switch and ignition switch to be operated in a specific order.

S7.4.4 does not require any specific sequence. After the ignition has been turned off, it can be made operable either by turning the ignition switch on, then operating the manual switch, or by operating the manual switch and then turning the ignition on.

ID: nht73-3.26

DATE: 02/14/73

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: Commonwealth of Pennsylvania

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of December 27, 1972, concerning the absence from Motor Vehicle Safety Standard No. 208 of requirements for seat belts after the passive restraint requirements become effective.

Our aim in the last three years has been to improve the protective capabilities of the autombile so that it will automatically protect its occupants from serious injury and death. We do not intend in the least to disparage seat belts -- to the contrary, we are making every effort to encourage their use. However, as passive restraints are installed, the marginal benefits to be gained from belts do not appear to be great enough to justify keeping them as required equipment.

The impacts that particularly concern you -- those occurring between 90 degrees and 270 degrees -- are partially covered by the lateral impact test of Standard 208. Impacts in which the force is more nearly rearward are the subject of continuing investigation by our Research Institute, with a view toward possible improvements in the rear-end structure. If standards are proposed concerning rear impact protection, they will probably focus on improved seat structure or on rear-end modifications rather than on seat belts.

We think the course we are following will result in significantly increased protection for the motoring public.