ID: nht68-1.18

DATE: 07/27/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Blaw-Knox Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your May 6, 1968, letter to the Director of the National Highway Safety Bureau concerning lighting and certification requirements on your concrete mixers.

Providing the combination rear clearance and side narear lamps meet the requirements for both as specified in SAE Standard J992b, April 1964 the lamps and reflectors shown on your drawing C-8450-911 dated April 3, 1968, and Service Bulletin 533 dated April 10, 1968, appear to be in fonformance with the requirements of Standard No. 103. With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approval on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only, and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 103.

Bules regarding classic-cabs and certification requirements which have been published in the Federal Register are enclosed for your reference. Please note that in order to comply with the certification requirements, we need the following additional information from you:

1. The locating on the vehicle at which the certification label or tag will be placed.

2. An actual sample certification label or tag.

3. The means by which the certification label or tag will be attached, e.g., wole, rivet, serev, or achoaive.

This information should is sent to the U.S. Department of Transportation, Federal Highway Administration, National Highway Safety Dureon, Washington, D.C. 23591 to the attention of Mr. Joseph R. O'Corman, Acting Director, Office of Performance Analysis, Motor Vehicle Safety Performance Service.

ID: nht68-1.19

DATE: 08/12/68

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

TO: Robert Bosch GMBH

TITLE: FMVSS INTERPRETATION

TEXT: The Bureau of Customs has forwarded to us for further reply a copy of your letter to them of May 21 asking whether lighting units for passenger cars, which do not conform to the requirements of Federal motor vehicle safety standard No. 108, may be admitted to the United States after January 1, 1969.

Amended Federal standard No. 108, effective January 1, 1969, specifies lighting requirements for various categories of motor vehicle including passenger cars manufactured on or after that date. It does not specify requirements for individual items, or lighting equipment. This means that these individual items, no matter what the date of manufacture, may be imported into the United States after January 1, 1969, because they will have been manufactured on a date when there were no standards in effect applicable to them.

I hope this answers your question.

Sincerely,

TREASURY DEPARTMENT

BUREAU OF CUSTOMS

JUN 25 1968

AIRMAIL

A. Hammerstein Robert Bosch Gmbh

Dear Mr. Hamorstein:

This will acknowledge receipt of your letter dated May 21, 1968 a copy of which was forwarded to the Secretary of Transportation, concerning the application of Federal Safety Standard 108 to lighting uniss that are now being manufactured by Robert Bosch Gmbh.

The joint regulations of the Bureau of Customs and the Department of Transportation, copy enclosed, provide in section 12.80(b)(2)(i) for the importation of a non-conforming vehicle or equipment item if they were manufactured on a date when there were no applicable safety standards in force. Therefore, these lighting units manufactured prior to January 1, 1969, and offered for importation into the United States do not have to be in conformity with Federal Safety Standard 108.

Since your inquiry concerns a specific safety standard not yet in effect, we are forwarding your letter to the Department of Transportation, Highway Safety Bureau, Washington, D.C., for their consideration and direct reply.

Sincerely yours,

John D. Roeison

Assistant Director

(Entry and Liquidation)

Division of Appraisement and Collections

Enclosure 50359

cc: Department of Transportation

ROBERT BOSCH GMBH

CC: Alan S. Boyd

Secretary of Transportation

Lester D. Johnson Commissioner of Customs Department of the Treasury Bureau of Customs

Subject: Title 19-Customs Duties (T.D. 68-16) - Part 12-Special Classes of Merchandise - Importation of Motor Vehicles and Items of Motor Vehicle Equipment - Federal Register Vol. 33, No. 6 of January 10, 1968

Gentlemen:

With the above mentioned publication, certain conditions are imposed for the importation of motor vehicle equipment into the United States.

In our opinion, one case occurring in practice is not covered by the exception granted under section (b). This is the case when replacement items are delivered for automotive vehicle manufactured before entering into force of a relevant Federal Safety Standard.

We are for instance to deliver lighting units equipped with white parking lamps for passenger cars, which are evidently not conforming to Federal Safety Standard 108.

The problem is now, whether it is possible and admissible to import such items and other ones into the United States after January 1, 1969. We add that it is well evident that such items are needed after this date, because vehicles are already equipped in such a manner and it would in our opinion to be too costly to replace two lighting units conforming to the rel;evant Federal Safety Standard, if only one replacement unit not conforming to the relevant Federal Safety standard is needed for a passenger car manufactured before January 1, 1969.

We should be very glad to have a rapid answer from you, since we have already now to care for corresponding replacement units. Leadtime is already now very scare.

Very truly yours,

A. Hammerstein

ID: nht68-1.2

DATE: 01/01/68 EST.

FROM: R. M. O'Mahoney; NHTSA

TO: Ontario Department of Transport

TITLE: FMVSS INTERPRETATION

TEXT: This is in confirmation of our telephone conversation of August 26, 1968, and in reply to your letter of July 22, 1968, in which you inquire as to the meaning of "manufacturer" in the Tire Standard, No. 109, particularly in light of the practice of concealing the identity of the real maker of the tires.

The term "manufacturer" employed in the labeling requirements section of that standard, by the rule set forth in 23 C.F.R. @@255.3, is used in the meaning defined in section 102 of the National Traffic and Motor Vehicle Safety Act of 1966, 15 U.S.C.@@1391:

"Manufacturer means any person engaged in the manufacturing or assembling of motor vehicles or motor vehicle equipment, including any person importing motor vehicles or motor vehicle equipment for resale."

The clear implication of this definition is that we are to be concerned with the company that is the actual maker of the tires in question, not retail outlets, suppliers who are not manufacturers, or other parties who may misleadingly appear to be the manufacturer.

We are not aware of any situation where the ownership or control of the tire manufacturing operation is so fragmented as to leave the relevant identity of the manufacturer unclear, within the meaning of the above. If such a case is brought to our attention, we will deal with it on its own facts.

We are happy to be of assistance.

ID: nht68-1.20

DATE: 06/10/68

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

TO: Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your telegram of May 23, 1968, which sought the views of the Acting Director, Motor Vehicle Safety Performance Service, NHSB, on four questions of interpreting Motor Vehicle Safety Standard No. 114. Our response to these questions is as follows:

1. We agree that paragraph S4.1(b) of the standard requires that removal of the key from the locking system must prevent steering or self-mobility of the car only under normal conditions. A steering or mobility lock which can be circumvented abnormally, as by disassembly of the locking mechanism or the application of excessive force, would not thereby violate the standard.

2. Paragraph S4.2, which provides that the "prime means" for deactivating the car's engine shall not activate either the steering or self-mobility lock, permits the use of the key to activate the lock and to deactivate the engine. The quoted words refer to the action necessary to perform either task, not to the mechanism which accomplishes it.

3. We agree that the warning device required by paragraph S4.4 is unnecessary when the locking system is in either the "on" or "start" positions. We are presently preparing an amendment to the standard which will clarify paragraph S4.4 by providing that the warning need not be activated when the key locking system is in either of those positions.

4. Your final question seeks an interpretation of the words "key left in the locking position." Since those words do not appear in paragraph S4.4, or elsewhere in the standard, we see no reason to provide an interpretation of them.

Sincerely,

WESTERN UNION TELEGRAM

MAY 23, 1968

G C NIELD, ACTING DIR MOTOR VEHICLE SAFETY PERFORMANCE SERVICE NATIONAL WHY SAFETY BUREAU FEDERAL WHY ADMIN DONOHOE BLDG 400 SIXTH ST SW WASHDC

OUR REVIEW OF STANDARD 114, THEFT PROTECTION, INDICATES THAT CONFIRMATION OF SEVERAL INTERPRETATIONS LISTED BELOW IS NECESSARY TO APPLY THE STANDARD WITH CERTAINTY. I WOULD APPRECIATE YOUR CONFIRMATION OF THE FOLLOWING INTERPRETATIONS

1. S4.1(B) CONSISTENT WITH THE ADMINISTRATORS COMMENTS AND SECTION

S4.1 (33 F.R. 6472) THAT REMOVAL OF THE KEY IS REQUIRED TO PREVENT ONLY "NORMAL" ACTIVATION OF THE CARE ENGINE, OUR INTERPRETATION OF SECTION S4.1(B) IS THAT A KEY LOCKING SYSTEM WHICH PREVENTS STEERING UNDER NORMAL CONDITIONS AND/OR PREVENTS NORMAL FORWARD SELF-MOBILITY WHEN THE KEY IS REMOVED, CONSITUTES CONFORMANCE WITH THE REQUIREMENTS.

2. S4.2 WE INTERPRET SECTION S4.2 TO ALLOW USE OF THE KEY TO ACTIVATE THE THEFT DETERRENT DEVICE PROVIDED THERE IS AN INTERMEDIATE POSITION OR MEANS TO DEACTIVATE THE ENGINE WITHOUT ACTIVATING THE DETERRENT,

3. S4.4 SINCE THE RUNNING ENGINE FURNISHES A CONTINUOUS WARNING WE INTERPRET SECTION S4.4 TO MEAN THAT THE WARNING DEVICE NEED NOT BE OPERATBLE WHEN THE DRIVERS DOOR IS OPEN AND THE KEY IS IN THE IGNITION-ON POSITION.

4. S4.4 WE INTERPRET "KEY LEFT IN LOCKING POSITION" TO MEAN THAT THE KEY IS INSERTED FULLY IN THE LOCKING SYSTEM TO THE POSITION PERMITTING OPERATION OF THE LOCKING DEVICE.

R O SORNSON FEDERAL SAFETY COORDINATOR CHRYSLER CORP.

ID: nht68-1.21

DATE: 04/26/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 19, 1968, to Mr. George C. Nield, requesting a clarification of paragraphs S3.4.4 and S3.4.4.1 of Motor Vehicle Safety Standard No. 108.

In your letter you listed possible brake combinations as follows:

1. A vacuum over dual hydraulic brake system and a hand operated mechanical brake are provided.

2. A full air brake system and a hand operated mechanical brake are provided.

3. A full air brake system with a spring loaded emergency stopping system which is actuated at a pre-determined low air pressure level and a hand operated mechanical brake are provided.

In accordance with the interpretation issued February 27, 1967 (32 F.R. 3390, copy enclosed), on "emergency brakes," the supplementary brake systems included in the above brake combinations are not emergency brakes. Therefore, paragraph S3.4.4 of Standard No. 108 does not require that the stop lamp be actuated upon application of these supplementary brakes.

Thank you for writing.

ID: nht68-1.22

DATE: APRIL 26, 1968

FROM: AUTHOR UNAVAILABLE; William H. Risteen; NHTSA

TO: Halfpenny, Hann and Ryan

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of February 6, 1968, to Mr. Lowell K. Bridwell, has been referred to me for reply.

In regard to your question, "Can a car dealer install equipment for which no standards have been established (such as air conditioning units) on a motor vehicle without violating the National Traffic Motor Vehicle Safety Act of 1966?", we are pleased to provide the following clarification.

The fact that there is not a standard directly applicable to air-conditioners or other items of equipment does not mean the dealer has no responsibility under the Act if he installs these equipment items. Any modification to the vehicle before the first purchase for purposes other than resale, must not alter the existing compliance of the motor vehicle with applicable standards.

In the case of an air-conditioner, if it is installed in the instrument panel or any other part of the interior of a passenger car covered by Standard No. 201, it would have to comply with the requirements of the Standard.

I hope this response clarifies the matter with you.

ID: nht68-1.23

DATE: 11/20/68

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Rolite, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 24, 1968, concerning glazing materials in your recreational vehicles.

FHWA Ruling 68-1, published in the Federal Register on March 26, 1969, (33 FR 5020) specified that campers must meet the requirements of Standard No. 205, Glazing Materials. Copies of FHWA Ruling 6S-1 and Standard No. 205 are enclosed.

We do not have any provision for exempting certain windows from the requirements of Standard No. 205 because of their foldaway position during transport. It is true, also, that your camper could be transported in the erected condition. Therefore, all glazing materials in the camper must meet the requirements of Standard No. 205.

Travel trailers are not included in the application of Standard No. 205; hence, do not have to meet the safety glazing requirements.

Sincerely,

Enclosures

October 24, 1968

Roy Dennison Motor Vehicle Safety Performance Service National Highway Safety Bureau Federal Highway Administration

Dear Mr. Dennison:

I have been in contact with Mr. Walter Peck, Standards Director for the Recreational Vehicle Institute, Inc. and he has recommended that I communicate with you in regards to National Highway Safety Standards on our pick-up camper.

I have enclosed a photograph of one of our trailers and I am sorry, but, we do not have a photograph of our pick-up camper, because this is our first run on a pick-up camper and we do not have our publications ready yet. This, print shows how our trailer collapses into the (down) position. All the windows in our travel trailer are inside and there are no visible outlets when the trailer is down because it was not designed for people to ride in when being towed.

On our pick-up camper the roof also folds to a height of approximately 16 inches over the cab, but we have provided 2 side windows that are of safety glass, which meets the National Highway Safety Bureau standards. The side walls on the camper that fold in have windows and I would like to have an opinion from you as to whether the folding windows, or the windows in the wall that fold in and are encased, would also have to be safety glass.

I realize that ours will be a special consideration, a case that will have to have a special reading from you or someone of your position, connected with the Highway Safety Bureau. I would appreciate any correspondence that you would be willing to offer on this matter. We need something on almost an urgent basis, as you can imagine, so that we comply with all regulations.

I will be waiting for your reply, and if you have any questions, do not hesitate to write.

Sincerely,

ROLITE, INC., Division of Larson Industries, Inc. --

Bob Dahlke Plant Manager

Enclosure

ID: nht68-1.24

DATE: 05/09/68

FROM: SIGNATURE UNAVAILABLE; NHTSA

TO: Counihan, Casey and Loomis

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of March 4, 1968, to Mr. Edwin L. Slagle, concerning Federal Motor Vehicle Safety Standard No. 205.

Standard No. 205 requires that glazing materials manufactured for use in passenger cars, multipurpose passenger cars, multipurpose passenger vehicles, trucks, buses, and motorcycles for sale in the United States on or after January 1, 1968, meet the requirements of ASA standard 226.1966. In addition, passenger cars, multipurpose passenger vehicles, trucks, buses, and motorcycles manufactured on or after January 1, 1968, for sale in the United States, must contain glazing materials that meet the requirements of ASA Standard 226.1-1966.

The following information is offered in answer to your qeustions:

Q. "We would appreciate your advice as to whether under Section (sic) 205, our members may install windshields manufactured prior to January 1, 1968, and containing a plastic interlayer of 0.015" subsequent to January 1, 1968?"

A. Yes, preformed or presized windshields manufactured prior to January 1, 1968, of 0.015 plastic interlayer may be used as replacement glass in used vehicles after January 1, 1968.

Q. "We would also appreciate your advice as to whether the fact that a glass dealer cuts a windshield to size from material manufactured prior to January 1, 1968, would alter your answer to our first question."

A. A dealer who cuts a windshield to size is considered a manufacturer, hence after January 1, 1968, 0.015 plastic interlayer

[Page 2 Is Missing.]

ID: nht68-1.25

DATE: 04/18/68

FROM: William H. Risteen; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letters of February 15 and March 8, l968, concerning application of Federal Motor Vehicle Safety Standard Number 205.

Glazing materials used in campers, pickup canopies, and covers must conform to the requirements of Federal Motor Vehicle Safety Standard Number 205.

I am enclosing a copy of [Illegible Word] Ruling 68-1 published in the Federal Register, Volume 33, Number 59 on March 26, 1968, and a copy of the Federal Motor Vehicle Safety Standards (with Amendments and Interpretations through February 15, 1968).

ID: nht68-1.26

DATE: 07/29/68

FROM: DAVID SCHMELTZER FOR ROBERT M. O'MAHONEY -- NHTSA

TO: Anadite Products Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 23, 1958, in which you ask that:

1) We "confirm in writing immediately that all forward facing windows in multipurpose passenger vehicles must be glazed with S-2 laminated with .030 plastic film [and] . . . etched as required in Z25."

2) We confirm that anything less than edges(Illegible Word) specified in J573 [Society of automotive Engineering Recommended Practice J573 'automotive glazing', June 1950] will(Illegible Word) a window with unbanded edges a non-complying article.

3) We forward "the proper instructions for manufacturers who are being undersold due to non-complying competitors."

With regard to your first request, we cannot confirm that all forward facing windows in multipurpose passenger vehicles must be glazed with S-2 laminated with .030 because windshields of multipurpose passenger vehicles must comply with the S-1 requirements. However, your request that slide-in campers be allowed to use S-1 liminated with an .030 plastic film in under consideration, and further reply will be made. You also ask for confirmation that the glazing be etched as required by Z25. This matter is also being considered as part of a rulemaking which would amend the glazing standard to provide for this type of etching.

With regard to your second request, Standard No. 205 presently requires that, except in school buses, expanded edges of glazing materials shall have an edge radius of between one half the nominal thickness of the material and inch. Exposed edges not meating these limits are not in compliance with the standard.

Finally, with the regard to your third request, if you have any additional information available concerning "non-complying competitors" please submit it to the National Highway Safety Bureau, Office of Motor Vehicle Safety Performance Service, 400 5th Street, S.W., Washington, D.C. 20591, and whatever action is considered appropriate will be taken.

Once again we wish to thank you for your active interest in the motor vehicle safety program.

Sincerely,

May 23, 1968

David Schmeltzer U.S. Department of Transportation Federal Highway Administration National Highway Safety Bureau Dear Dave:

This letter will serve as a formal request for information which we discussed in our telephone conversation of May 22.

Please confirm in writing immediately that all forward facing windows in multipurpose passenger vehicles must be glazed with AS-2 laminated with .030 plastic film. Also, confirm that each glass pane must be etched as required in Z26.

One question we did not discuss has to do with windows with exposed edges. At the present time, Standard 205 requires that in all except school buses, windows with exposed edges must be treated in accordance with Society of Automotive Engineering Recommended Practice J673, "Automotive Glazing", June 1960. This includes the window we refer to as a 4" Jalousie. It would be convenient if you could justify written instructions that the radii specified in J673 for edge treatment will be necessary for compliance with Standard 205. The reason for this is that we "webber" (grind to no specific radius but remove enough edge material so that you would not cut your finger if you rubbed it along the edge of each unbanded pane) 4" Jalousie panes and have for many years. The information available from SAE is a little confusing, for it looks like a webbered edge; however, it specifies a radius from 3/16" to 1/4". As you know by now, it is difficult to take some of this Automotive Engineering data and use it without expanding its meaning when concerned with pickup canopies and campers. We are not asking for you to give us any relief or to approve the webbered edge as satisfactory. We concur in your decision that an unbanded edge should have a close tolerance and responsible radius. We only want to ascertain that anything less than edges as specified in J673 will make a window with unbanded edges a non-complying article.

One last point -- please expedite if possible the proper instructions for manufacturers who are being undersold due to non-complying competitors. I have requested this previously.

Sincerely yours,

ANADITE, INC.

PRODUCTS DIVISION --

John E. Orr

Director of Marketing