ID: nht67-1.3

DATE: 08/17/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Fire Apparatus Manufacturers Association, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter addressed to Dr. Haddon, dated June 19, 1967, which has been referred to me for reply to your inquiry concerning the effect of Motor Vehicle Safety Standards on fire trucks.

The purpose of Standard No. 107 is to reduce the likelihood that unacceptable glare from reflecting surfaces in the driver's field of view will hinder the safe and normal operation of the motor vehicle. At present, paragraph S4, "Requirements," only covers windshield wiper arms and blades, inside windshield mouldings, horn ring and hub of the steering wheel, and inside rearview mirror frame and mounting bracket.

The initial Federal Motor Vehicle Safety Standards contain no mandatory requirement for seat belt installations or seat belt anchorages in trucks. However, if seat belts are installed in trucks they must conform to Motor Vehicle Safety Standard No. 209, effective March 1, 1967.

Sincerely,

FIRE APPARATUS MANUFACTURERS ASSOCIATION, INC.

June 19, 1967

William Haddon, Jr. Administrator National Traffic Safety Agency

Dear Dr. Haddon:

Our concern is about Motor Vehicle Safety Standard No. 107. In it view, glare, brightness, and reflection is set forth. Is the use of chrome prohibited because of its reflective qualities either inside the vehicle or on the outside of the vehicle? As you are aware, fire trucks have a considerable amount of chrome in their make-up.

One further question would be as to the seat belt assembly requirements. It is our understanding that only the anchoring point is necessary to be installed in the equipment as of March 1, 1967. The actual installation of the seat belt itself is an optional piece of equipment.

May we hear from you?

Very truly yours,

E.L. Koepenick Secretary-Treasurer

ID: nht67-1.30

DATE: 02/27/67

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA

TO: North America Seat Belt Council, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 16, 1967.

Motor Vehicle Safety Standard No. 209 applies to seat belt assemblies manufactured after February 28, 1967, for use in passenger cars, multipurpose passenger vehicles, trucks, and buses. Since Motor Vehicle Safety Standard No. 208, which provides that a Type 1 or Type 2 seat belt assembly that conforms to Motor Vehicle Safety Standard No. 209 shall be installed in each passenger car seat position, has an effective date of January 1, 1968, until that date seat belt assemblies installed in passenger cars need not conform to Standard No. 209 unless the seat belt assemblies have been manufactured after February 28, 1967.

Please do not hesitate to call upon us if we can be of further service to you.

ID: nht67-1.31

DATE: 09/21/67

FROM: AUTHOR UNAVAILABLE; SIGNATURE UNAVAILABLE; NHTSA

TO: Busby and Rivkin

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of July 13, 1967, you requested clarification of several issues relating to the location and size of turn signals as specified in the Initial Federal Motor Vehicle Safety Standards.

Initial Standard No. 108, entitled, "Lamps, Reflective Devices, and Associated Equipment - Multipurpose Passenger Vehicles, Trucks, Trailers, and Buses, 80 or More Inches Wide Overall," specifies that turn signal lamps shall conform to Class A of SAE Standard J588d. As stated in the enclosures to your letter, SAE Standard J588d specifies that the optical axis (filament center) of the front turn signal lamp shall be at least 4 inches from the inside diameter of the retaining ring of the headlamp unit providing the lower beam. This requirement of the SAE Standard is addressed to a single lamp with only one bulb. For a combination of lamps, such as that shown on the sketch enclosed with your letter, the intent of this requirement could be part if the optical center produced by the two bulbs is outside the 4-inch limit. The location of this optical center must be determined from laboratory test data, which was not presented in your letter.

Proposed Initial Standard No. 112, entitled, "Lamps, Reflective Devices, and Associated Equipment - Passenger Cars; Motorcycles; and Multipurpose Passenger Vehicles, Trucks, Trailers and Buses of Less than 80 Inches Wide Overall," would permit the use of Class A (SAE J588d) turn signal lamps until January 1, 1969. Under this provision, lamp No. 1 on your sketch would conform to the 4-inch spacing requirement. Combining lamp No. 1 and No. 2 to obtain a Class A area would again result in the situation previously described with respect to location of the optical center.

Since your letter makes frequent reference to "cars," we assume that you are primarily interested in the requirements of Standard No. 112. In this respect, we would caution you that the requirements specifies therein are presently only proposed requirements, and are subject to change prior to issuance of the final standard.

Thank you for your interest in the motor vehicle safety standards.

ID: nht67-1.32

DATE: 06/14/67

FROM: AUTHOR UNAVAILABLE; William Haddon, Jr., M.D.; NHTSA

TO: Mercedes-Benz of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of April 10, 1967, clarifying the intent of your petition for reconsideration of Federal Motor Vehicle Safety Standard No. 210, and seeking a review of Order No. 12, dated March 29, 1967, denying your petition.

At your request I have reviewed your petition for reconsideration and wish to(Illegible Word) for the record, as you have asked, that your company did not seek to be relieved from the requirements of Standard No. 210, but rather sought permission to provide upper(Illegible Word) restraint anchorages in addition to those required by the standard. After reviewing Order No. 12, I have concluded that with respect to your company the order was intended as a(Illegible Words) paragraph(Illegible Words) is unnecessary, however, for the reason that Standard No. 210(Illegible Words)(Illegible Word) anchorages in addition to those required in paragraph 4.1. The location criteria for the anchorages as outlined in accordance with paragraph 4.1, and not to any additional anchorages provided by the manufacturer.

I believe the foregoing interpretation will enable your company to continue its practice of furnishing additional(Illegible Word) restraint anchorages on the(Illegible Words) large persons(Illegible Words) you have further questions concerning the(Illegible Word) please do not(Illegible Word) to let me know. MERCEDES - BENZ OF NORTH AMERICA, INC.

Lowell K. Bridwell Federal Highway Administrator United States Department of Transportation

I have Dr. Haddon's letter of April 4, 1967, enclosing a copy of your order of denial regarding our petition for reconsideration of Standard No. 210, dated March 3, 1967.

It is important to indicate that it was not the intention of our petition to request relief from the requirement of Standard No. 210 (S 4.3.2.1) as stated in Order No. 12 issued on March 29. Our request was simply that Standard No. 210 be amended to allow a second upper torso restraint anchorage point -- in addition to an anchorage point complying with Standard No. 210 -- in order that such an additional point be available for persons of unuaually large body dimensions.

I think it important that the record clearly show that Mercedes-Benz of North America did not seek relief from Standard No. 210, but rather sought permission to comply with the Standard and at the same time provide for optimum restraint and comfort of persons of unusually large size. It has been standard practice in our company to furnish at least two upper torso restraint anchorages when they are mounted in the B--pillar of sedans and we sought in our March 3, 1967 petition to continue this practice.

Inasmuch as the relief denied in Order No. 12 is not the relief sought by Mercedes-Benz of North America, Inc., I would greatly appreciate your reviewing the Order in the hope that since we comply with Standard No. 210 the inclusion of an additional anchorage would be allowed to enhance the safety and comfort of unusually large persons.

Sincerely,

PEUGEOT, INC.

May 26, 1967

Mr. O'Mahoney National Traffic Safety Agency

Regarding our telephone conversation of May 26, I am in need of legal interpretation concerning Standards 208 and 210.

According to Standard 208, paragraph S3.1.1, Type 2 seat belt assembly should be installed in each outboard passenger car in the front seat position, including the windshield, within the impact area, which, in my mind includes the front seats only. Thus, the rear seats should have only Type 1 (lap belt).

From Standard 210, table 1, it seems to clearly indicate that we must have seat belt anchorages for a Type 2 seat belt in outboard seats in the rear, but it does not expressly state that the Type 2 seat belts should be installed in the outboard seats in the rear.

Would you kindly let me know if my interpretation is correct: on a 4-passenger car, we should have Type 2 seat belts in the front, Type 1 seat belts in the rear, but anchorages in the rear for Type 2 and Type 1 seat belts.

Thank you very much in advance for your reply.

Henri B. Combe Executive Vice President

ID: nht67-1.33

DATE: 03/18/67

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Petroleum Equipment Institute

TITLE: FMVSR INTERPRETATION

TEXT: The General Counsel of the Department of Transportation has asked that(Illegible Word) further to your letter of February 13, 1968 to the Department of Transportation.

Enclosed in a copy of the National Traffic and Motor Vehicle Safety Act of 1966, published Federal Motor Vehicle Safety Standards and a regulation and ruling issued December 29, 1967 pertaining to "chassis-cabs" and persons who combine "chassis-cabs" with motor vehicle bodies or other like structures.

Based on the limited information given in your letter it appears that members of your organization who affix a task to a chassis-cab, as defined in(Illegible Word) 5.3(b), will be responsible for "(1) compliance of the combined assemblage with. . .standards in effect in the date of(Illegible Word) of the chassis-cab. . .not already. . .certified to by the chassis-cab manufacturer, and (2) compliance with all applicable standards in effect on the date of manufacture of the chassis-cab to the extent that the addition of a body or other structure to the chassis-cab affects the chassis-cabs previous conformance with applicable standards."

As to the certification requirement, which is set forth in section 114 of the National Traffic and Motor Vehicle Safety Act of 1966 (copy enclosed) and amplified by a notice issued October 31, 1967, ((Illegible Words) than requirement as it relates to your organization members would be limited to a situation where your members combine a chassis-cab which has not been certified to be in conformance with Standard 108 with a body or other like structure and sells the combined assemblage to a distributor or dealer. In this case certification of compliance with the lighting standard (Standard No. 108) would be mandatory.

The Petroleum Equipment Institute(Illegible Word) will be added to the Federal Highway Administrator's Office of Public Affairs mailing list and it will(Illegible Words) published rulings and regulations relating to traffic safety. Additionally, enclosed is a copy of present regulations and rulings published to date.

I hope this letter adequately answers the question you raise.

ID: nht67-1.34

DATE: 12/13/67

FROM: AUTHOR UNAVAILABLE; Z. Taylor Vinson; NHTSA

TO: Metropolitan Cycle Association

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of December 4 to Mr. Boaz, Public Information Office, Federal Highway Administration, inquiring about the applicability to motorcycles and scooters of the proposed Department of Transportation-Department of the Treasury customs regulations.

The regulations do apply to motorcycles and scooters imported into the United States, but not to similar type vehicles imported into or manufactured in Canada for use in Canada. I am enclosing a copy of the regulations for your information.

ID: nht67-1.4

DATE: 08/22/67

FROM: AUTHOR UNAVAILABLE; William Maddon, Jr., M.D.; NHTSA

TO: The Anderson Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 30, 1967, to Mr. Bridwell concerning windshield wiper parts.

We recognize that it may be difficult to obtain reflectance values from all metal components on the windshield wiper assembly which come into the driver's field of view. For this reason, Motor Vehicle Safety Standard No. 107 includes reflectivity requirements for only the wiper arm and blade. As stated in your letter, the reflectivity of these components may be determined by using flat samples of identical material. Reflectivity requirements for the spring, rivets and other hardware items, which are attached to the wiper arm and blade, are not presently specified in Standard No. 107.

ID: nht67-1.5

DATE: 09/21/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Fire Apparatus Manufacturers Association Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 17, 1967, requesting clarification of several requirements specified in Motor Vehicle Safety Standard No. 108.

In answer to question No. 1 of your letter, the addition of a side mounted ladder would not be considered as an extension of the length of the vehicle.

Question No. 2 concerns the requirement for use of front identification lamps on open-cab fire trucks and trucks equipped with rotating red lights. We agree that the front identification lights might be slightly obscured while the emergency red lights are flashing. However, when these lights are not flashing, the identification lights would clearly identify a vehicle that is more than 80 inches in overall width. Therefore, identification lights will be required on the fire trucks which are depicted on the photographs enclosed with your letter.

With respect to question No. 3 regarding possible locations for rear identification lamps on fire trucks, it should be noted that Standard No. 108 does not specify a height requirement for location of these lamps. Therefore, a possible location for the lamps would be along the edge or under the edge of the rear step. In any event, the problem of providing the lamps does not appear to be a major one.

Question No. 4 relates to possible locations for clearance lamps on the front and rear of fire trucks. Standard No. 108 requires that clearance lamps be mounted as near as practicable to the upper left and right extreme edges of the vehicle. A provision is also included for mounting the rear clearance lamps at an optional height, when the rear identification lamps are mounted at the extreme height of the vehicle. We note from your photographs that (Illegible Word) lamps are normally mounted at approximately the extreme edges of the vehicle. It appears that a similar arrangement could be provided for mounting the clearance lamps.

Thank you for your interest in the motor vehicle safety standards.

Sincerely,

ATTACH.

FIRE APPARATUS MANUFACTURERS ASSOCIATION, INC.

July 17, 1967

George C. Nield, Acting Director -- Motor Vehicle Safety Performance Service, U.S. Department of Transportation

Dear Mr. Nield: The Technical Committee of our Association has reviewed the requirements of "Initial Federal Motor Vehicle Safety Standards, Volume 32, Number 23, Federal Register of February 3, 1967. The following questions have arisen and we request clarification.

1. Standard 108, Par. S3.1.1.2, page 2411. Your paragraph refers to 30 ft. overall length. The industry builds many pumpers that are less than 30 ft. length but occasionally the addition of a side mounted ladder will extend beyond the rear step and will increase the overall length beyond 30 ft. The Pirsch picture 5904 enclosed illustrates a ladder so mounted.

The question is - would this ladder addition be interpreted to mean a length greater than 30 ft.?

2. Standard 108, Par. S3.1.1.3, page 2411. Almost every fire truck will include a rotary type flashing red light and other flashing red lights which of necessity will impair the effectiveness of the front identification lights and would seemingly make (Illegible Word) lights (Illegible Word). Will these three front identification (Illegible Words) on a fire truck? See Pirsch picture 622 enclosed as (Illegible Words) please note Pirsch picture 6124 enclosed showing an (Illegible Words) is commonly used and advise if identification lights (Illegible Words) on this type.

3. Standard 108, page 2411, Trucks I and II. The (Illegible Words) lights do not appear to be (Illegible Word) to fire truck picture 5904, a rear step is included on the average fire truck with (Illegible Word) riding the rear step. As it is readily seen, there is no place for the three identification lights that could possibly be effective. We definitely feel that rear identification lights are not feasible on a fire truck.

4. The side clearance lights are specified to be mounted as near as possible to the upper right and left front edges and the upper right and left rear edges. Our pictures illustrate the problem of the extreme edges and we would like to know where lights should be placed on this type of vehicle.

Very truly yours, E. L. Koepenick -- Secretary-Treasurer

Encls.

ID: nht67-1.6

DATE: 09/12/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Your June 2, 1967, letter contained nine questions concerning several areas of Public Law 89-563 and Motor Vehicle Safety Standard No. 108. Answers to several of these questions are of common interest to many manufacturers and the National Highway Safety Bureau is developing and planning to issue appropriate policies, procedures and rules to guide manufacturers in respect to some of these questions. In the meantime, we are able to reply to questions 5, 7, and 8 of the June 2, 1967, letter and question 9 of the June 2, 1967, letter as amended by the corrected drawings furnished by your letter of July 18, 1967.

Question 5. Section 113 of Public Law 89-563

Will forms be furnished to us to use to notify the first purchaser, dealer, and Secretary of defects we might find? If not, will an example of an acceptable form be available? Will a more detailed procedure be made available on the action required under Section 113? What would be our liability if a component purchased by us and certified to us to be in conformance with the Motor Vehicle Safety Standards was found after manufacture and delivery not to be in conformance?

Answer

The Bureau is studying the requirements for procedures and forms on defect notification. At present a form is being considered for the manufacturers to report defect information to the Secretary. If after further study forms are also considered desirable for the manufacturer to report to his dealers and the purchasers, you will be advised as to what types of forms are acceptable via publication in the Federal Register.

It is not clear what you mean by "liability." If you refer to your obligations under Section III, this section defines the responsibilities of manufacturers in regard to motor vehicles or items of motor vehicle equipment determined not to be in conformance with applicable Federal motor vehicle safety standards. Section III also requires the immediate repurchase of the nonconforming vehicle or item of motor vehicle equipment, or that the required conforming part or parts of equipment be furnished to the dealer or distributor for installation and that financial renumeration be made for incoveniences involved. Additionally, the provisions of Section 108 would apply.

Question 7. Title 23, Section 255.7 Applicability:

"(b) Military vehicles. No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with Contractual specifications.

(c) Export. No standard applies to a vehicle or item of equipment in the circumstance provided in section 108 (b) (5) of the Act (15 U.S.C. 1397) (b) (5)."

We understand that the standard does not apply to military or export vehicles. Will we be allowed to drive on public roads export and/or military buses that do not meet the minimum standards to a port or other destination? If not, what will we have to do to them so that they can be driven on public roads?

Answer

Motor vehicles intended solely for military or for export use are specifically excluded from compliance with Federal motor vehicle standards, and therefore not subject to the provisions of the Act.

Question 8. Standard No. 108 S3.4.3

"Taillamps, license plate lamps, and side marker lamps shall be illuminated when the headlamps are illuminated."

This standard does not mention parking lamps. We would then assume that the parking lamps may or may not be illuminated when the headlamps are illuminated at our discretion or the chassis manufacturer's discretion. Is this correct?

Answer

The parking lamps may or may not be illuminated when the headlamps are illuminated.

Question 9. Standard No. 103 Table II Location of Equipment

These prints show the location of lamps and reflex reflectors we plan to supply to comply with Standard 108 Table II. Are these locations in compliance? If not, please mark one each of the prints with acceptable locations and return them to us.

Answer

The location of lamps and reflectors, as shown on the drawings dated July 17, 1967, appear to be acceptable.

Questions 1, 2, and 6 relate to the subject of "Incomplete vehicles" and questions 3 and 4 relate to labeling and record-keeping. We are currently working on the entire area relating to these other questions and you will be furnished with detailed answers as soon as possible.

Sincerely,

ATTACH.

June 2, 1967

George C. Nield -- Acting Director, Motor Vehicle Safety Performance Service, U. S. Department of Transportation

Dear Mr. Nield: Listed below are several areas of Public Law 89-563 and the Motor Vehicle Safety Standards that we are concerned about and need rulings and/or clarification. If at all possible, we need this information by June 12, 1967.

1. Section 108 of Public Law 89-563

It is quite possible that there might be new chassis at our plant January 1, 1968, to have new bodies mounted on them that do not meet the Motor Vehicle Safety Standards. Will we be able to mount bodies on these? From time to time it is a couple of months after a chassis arrives before a body is mounted on it. They also sometimes sit in our field for long periods of time finished before the end customer comes for them or arranges for delivery. I believe you can appreciate the situation we could find ourselves in if we are unable to mount or deliver chassis after January 1, 1968, that were received prior to January 1, 1968. Could we have your comments and a ruling on this?

2. Section 108 of Public Law 89-563 Paragraph (a) (1)

Will replacement parts for buses built prior to January 1, 1968, have to meet applicable Motor Vehicle Safety Standards? In some cases the conforming parts might not fit or work without a lot of rework, etc.

3. Section 108 of Public Law 89-563 (b) (5)

In what manner should we label or tag motor vehicles or items of motor vehicle equipment intended solely for export? Do you have examples or acceptable forms for this?

4. Section 112 of Public Law 89-563

What records, reports, technical data, performance data, and other information are we required to establish and maintain? Will we be required to give notification of performance and technical data to the Secretary and/or to the original purchaser? What will we be expected to do to satisfy this law?

Will we be able to have inspectors designated by the Secretary come here prior to January 1, 1968, to be sure we are in compliance with all applicable Safety Standards if we feel the need?

5. Section 113 of Public Law 89-563

Will forms be furnished to us to use to notify the first purchaser, dealer, and Secretary of defects we might find? If not, will an example of an acceptable form be available? Will a more detailed procedure be made available on the action required under Section 113? What would be our liability if a component purchased by us and certified to us to be in conformance with the Motor Vehicle Safety Standards was found after manufacture and delivery not to be in conformance?

6. Section 114 of Public Law 89-563

We mount bodies on three types of chassis. We build the Blue Bird Forward Control Chassis. The Conventional and Pusher Chassis are built by others, and we mount bus bodies we manufacture on them. It seems logical to me that the chassis manufacturer should certify the chassis by label or tag as stated in the law. Is this correct? We would then be required to certify what? The bus body or the complete vehicle? I don't see how we could certify items such as those cited in Standard No. 102 which we would not alter in any way or some of the equipment in Standard No. 108 that comes in on the chassis that we would not bother such as headlamps. What should the certification tag or label say? Do you have forms or acceptable examples for this?

7. Title 23, Section 255.7 Applicability:

"(b) Military vehicles. No standard applies to a vehicle or item of equipment manufactured for, and sold directly to, the Armed Forces of the United States in conformity with contractual specifications.

(c) Export. No standard applies to a vehicle or item of equipment in the circumstances provided in section 108 (b) (5) of the Act (15 U.S.C. 1397 (b) (5)."

We understand that the standard does not apply to military or export vehicles. Will we be allowed to drive on public roads export and/or military buses that do not meet the minimum standards to a port or other destination? If not, what will we have to do to them so that they can be driven on public roads?

8. Standard No. 108 S3.4.3: "Taillamps, license plate lamps, and side marker lamps shall be illuminated when the headlamps are illuminated."

This standard does not mention parking lamps. We would then assume that the parking lamps may or may not be illuminated when the headlamps are illuminated at our discretion or the chassis manufacturer's discretion. Is this correct?

9. Standard No. 108 Table II Location of Equipment

Enclosed are two prints of

34754 Layout, Lamps and Reflex Reflector Locations, 1968 Model, 74" Headroom Conventional Bus

34755 Layout, Lamps and Reflex Reflector Locations, 1968 Model, 77" Headroom Conventional Bus

34756 Layout, Lamps and Reflex Reflector Locations, 1968 Model, 74" Headroom All American and Pusher Bus

34757 Layout, Lamps and Reflex Reflector Locations, 1968 Model, 77" Headroom All American and Pusher Bus

These prints show the location of lamps and reflex reflectors we plan to supply to comply with Standard 108 Table II. Are these locations in compliance? If not, please mark one each of the prints with acceptable locations and return them to us.

We certainly appreciate your help and consideration on these matters.

Sincerely, David A. Phelps, Jr. Engineering Services

Enclosures

ID: nht67-1.7

DATE: 12/27/67

FROM: AUTHOR UNAVAILABLE; Howard A. Heffron; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: The Federal Highway Administrator has asked me to reply to your letter of November 24, 1967, in which you asked whether tow cars (as defined in the California Vehicle Code), "emergency vehicles, and other specially designed vehicles" come within the coverage of Motor Vehicle Safety Standard No. 108.

Standard No. 108 prescribes requirements for lamps, reflective devices, and associated equipment. It applies, by its terms, to "trucks . . . that are 80 or more inches overall." As you point out, the term "truck" is broadly defined in Subpart A of the Standards and includes any "motor vehicle with motive power . . . designed primarily for transportation of property or special purpose equipment." There is nothing in the definition, nor is there any other reason, to exclude vehicles designed to tow or otherwise assist other disabled vehicles from the coverage of the Standard. Moreover, paragraph S3.4.4.2 of Standard No. 108 provides that "stoplamps on a towing vehicle need not be actuated when service brakes are applied to the towed vehicle or vehicles only." The adoption of specific requirements pertaining to vehicles being towed would indicate that no exclusion for tow cars or tow trucks was intended.

We conclude, therefore, that tow trucks and tow cars that are 80 or more inches wide overall must comply with the provisions of Standard No. 108. That Standard applies to vehicles manufactured on or after January 1, 1968. State standards, if any, would continue to apply to tow cars or trucks manufactured prior to that date. I also wish to point out that, by a formal interpretation (published at 32 F.S. 8803), the term "overall width" in Standard No. 108 has been deamed to refer to "the nominal design dimension of the widest part of the vehicle, exclusive of signal lamps, market lamps, outside rearview mirrors, flexible fender extensions, and mud flaps. . . ." We are presently considering an amendment which would extend Standard No. 108 to trucks having a width of less than 80 inches, but the Standard in its prevent form is limited to the larger trucks.

In your letter, you refer to "emergency vehicles" and "special purpose vehicles" and ask whether such vehicles are covered by Standard No. 108. Since you did not further describe the vehicles you had in mind, we cannot tell whether they are of a type which must meet the requirements of the Standard. Since you mention the possibility that some of these vehicles may be deemed "truck tractors," we wish to call your attention to the fact that Standard No. 108, by its terms, does not apply to truck tractors.

If we can be of further assistance to you, please do not hesitate to call upon us.

Sincerely,

ATTACH.

DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

November 24, 1967

Lowell K. Bridwell -- Federal Highway Administrator, U.S. Department of Transportation

Dear Mr. Bridwell:

A question has arisen concerning the application of Federal Motor Vehicle Safety Standard No. 108 issued January 31, 1967, to tow cars.

A "tow car" is defined in the California Vehicle Code as "a motor vehicle which has been altered or designed and equipped for and exclusively used in the business of towing vehicles by means of a crane, hoist, tow bar, tow line, or dolly or is otherwise exclusively used to render assistance to other vehicles."

Although the definitions for "truck" and "truck tractor" included in Subpart A of Initial Motor Vehicle Safety Standards are broad, there appears to be a number of special purpose vehicles such as tow cars, emergency vehicles, and other specially designed vehicles which may not be included.

Will you please clarify for us the definition of "truck" and "truck tractor" with relation to the above special purpose vehicles.

Very truly yours,

H. W. SULLIVAN -- Commissioner