ID: nht78-1.42

DATE: 01/27/78

FROM: AUTHOR UNAVAILABLE; Joan Claybrook; NHTSA

TO: Winsconsin School Bus Association

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your October 16, 1977, letter requesting again that the National Highway Traffic Safety Administration (NHTSA) reinterpret its 20-inch measurement of occupant seat spacing in Standard No. 222, School Bus Passenger Seating and Crash Protection.

Mr. Levin indicated in an earlier response to your letter that seat spacing is measured at the point of greatest distance separating the seats. This measurement is used to ensure that impact forces do not exceed the forces the seat is designed to sustain or absorb. To measure as you suggest would require redesigning school bus seats to ensure their ability to sustain or absorb increased impact loads.

The NHTSA has received a number of complaints on seat spacing in school buses manufactured in compliance with the subject regulations. We have met with most of the major school bus manufacturers discussing production seat spacings and the Federal requirements. The agency has found that manufacturers are producing buses with seat spacings which are, in some cases, 3 inches less than the maximum specified by the regulations. These large reductions in seat spacing result principally from manufacturers' choices in designing the seats. Such seat spacing reductions are not found in all seats designed to meet the regulations.

Through its monitoring of the standard's implementation, the NHTSA has discovered that manufacturers are not achieving the maximum seat spacing that the agency had contemplated at the maximum seat spacing that the agency had contemplated at the time the regulation was issued. The installation of seats in school buses cannot be done with the precision that the NHTSA had anticipated. Accordingly, manufacturers in their attempts to ensure they do not violate the 20-inch space requirement must design seat spacing as much as an inch short of the 20-inch spacing allowance. The result is seat spacing which is less than the agency contemplated. The NHTSA has taken expeditious action to alleviate this problem.

On December 20, 1977, NHTSA issued an Interim Final Rule amending Federal Motor Vehicle Safety Standard No. 222 by increasing the maximum allowable distance from the seating reference point to the seat back from 20 to 21 inches. The agency intended that the measurement be approximately 20 inches. A seat spacing specification of 21 inches permits 20-inch spacing by taking manufacturing tolerances into account. A Notice of Proposed Rulemaking (NPRM) proposing this change in the rule was also issued on December 20, 1977.

SINCERELY,

Wisconsin SCHOOL BUS Association

October 16, 1977 Administrator Joan Claybrook Nat'l Hwy. Traffic safety Adm. 400 7th St. S.W.

REFERENCE: NOA-30

Dear Ms. Claybrook:

We are in receipt of a letter from NHTSA Chief Counsel Joseph J. Levin Jr., in response to our request for an interpretation of Standard No. 222, School Bus Passenger Seating and Crash Protection.

In his letter of October 7, 1977, Mr. Levin advises us of a similar request for an interpretation on the measurement of school bus seat spacing by Gillig Bros., Hayward, California, (manufacturers of school buses) on September 13, 1976. Gillig Bros. were informed that, according to an interpretation of Standard No. 222 by the NHTSA, the measurement of seat spacing must be made from the seating reference point to the surface of the seat back - exclusive of portions which protrude from the basic contour of the surface.

We would suggest that this query by Gillig Bros. to the NHTSA was a very typical request by a manufacturer wishing to receive a clarification on a specification or regulation. We are not aware that manufacturers, users of school buses, or the NHTSA envisioned, at that time in 1976, that a very serious problem in seat spacing would be created by the performance standards of Standard 222 which control seat design . . . . and in that light suggest the possibility that the NHTSA responded to the 1976 Gillig Bros. query with a clarification of the measurement for seat spacing, rather than a formal interpretation on the subject.

In this intervening period since September of 1976, seat designs have been established, conforming to the criteria of Standard No. 222. School buses, built to the federal construction standards effective April 1, 1977, began to appear in the marketplace.

Prospective purchasers throught the Nation were appalled by the restricted knee-room available to the seated passengers. Widespread opposition to this restricted seat spacing has mounted rapidly as more and more school district administrators and school bus contractors view the "new school bus" for the first time and endeavor to seat the upper-grade students in the confined seating.

The immediate effects have been that school boards have recinded local ordances limiting the age of equipment used for pupil transportation; school bus contractors have revised operational policies and, instead of adhering to their normal vehicle replacement programs, intend to obtain longer utilization of school buses in their fleets by upgrading maintenance programs; and school bus passengers are resisting any but the shortest of rides in those seats with their cramped, restricted seating space.

The result is that school boards, school bus contractors, and school bus body manufacturers are recognizing that the new school bus seating will discourage, to a great extent, the transportation of other than children in the lower/middle grades. Passengers will shun these vehicles like the plague for extra-curricular activities and field trips. The opposition to these seats will force school boards to look elsewhere for other types of transportation for these activities. Manufacturers of school bus bodies recognized this possibility long ago, as they viewed the seat spacing mandated by Standard 222, and submitted a petition to the NHTSA for a special sub-classification of school bus - an activity bus with greater seat spacing - that would replace the conventional school bus for these and other activities.

Our school districts - our communities - cannot withstand the tremendous expense of another separate bus fleet this "activity bus" petition would create. Our school districts will not be able to withstand the opposition they will experience against utilization of the "new" school bus with its restrictive seat spacing; but at the same time, their budgets will be incapable of withstanding the alternative . . . . separate bus fleets, taxicabs, payment for pupil transportation by parents.

Our industry realizes that the seats designed to conform to Standard 222 have thicker cushioning; that the same number of seats as was installed in a "pre-April 1, 1977" school bus requires a longer bus body on the new bus. Our industry realizes that allowing a greater seat spacing may require an even longer bus body, or perhaps fewer rows of seats in the bus . . . . but the alternatives are far beyond our school district budget's ability to underwrite.

It is for these reasons that we suggest the questions facing you today are far different than those posed to the NHTSA in September of 1976. It is for these reasons that we respectfully suggest that the NHTSA, recognizing that the question of seat spacing today has far greater implications than in 1976, may wish to allow an immediate relief from the problem through the expediency of a permissive interpretation that would permit school bus manufacturers to measure the knee-room distance at a point where the seat back components are the closest.

May we once again request your considerations for this prmissive interpretation? It is the opinion of the Wisconsin School Bus Association, representative of Wisconsin's pupil transportation industry - and other pupil transportation industry members and representatives throughout the Nation - that this permissive ability would be an important and immediate interim answer to this perplexing and serious problem.

Dick Rechlicz Executive Secretary

ID: nht78-1.43

DATE: 06/22/78

FROM: AUTHOR UNAVAILABLE; H. Dugoff for Joan Claybrook; NHTSA

TO: Illinois Department of Transportation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 10, 1979, letter asking questions about the applicability of Standard No. 222, School Bus Passenger Seating and Crash Protection, to buses with gross vehicle weight ratings (GVWR) of 10,000 pounds or less.

First you ask whether seat spacing must be maintained at a maximum of 21 inches in these vehicles. The answer to your question is no. As you correctly point out in your letter, section S5.2 of the standard that regulates maximum seat spacing does not apply to buses with GVWRs of 10,000 pounds or less. Maximum seat spacing is limited in larger buses as a means of compartmentalizing students to prevent injury in crashes. Compartmentalization, and therefore maximum seat spacing, is not necessary in smaller buses since they are required to be equipped with seat belts which afford significant protection in accidents.

Your second question asks whether it is permissible to have one large seat belt in a school bus seat that might wrap around two students or whether each designated seating position must have an individual belt system. The agency concludes that the use of one large belt to cover more than one designated seating position violates section S5 of the regulation. That section states that each seating position must comply with seat belt requirements. To meet this requirement, each seating position in a small bus must be equipped with its own belt system.

If we can be of further assistance, do not hesitate to contact us.

SINCERELY,

Illinois Department of Transportation

May 10, 1979

Joan Claybrook Administrator National Highway Traffic Safety Administration

Dear Ms. Claybrook:

This letter requests answers to questions concerning federal requirements for seats and seat belts in school buses with a 10,000 pound or less gross vehicle weight rating (GVWR).

The Illinois standards for construction of school buses include the applicable federal motor vehicle safety standards (FMVSS) by reference. This establishes a ready means for school districts, transportation contractors, and others to include the FMVSS in bus purchase orders or contracts, thereby making a violation of them a breach of contract. Inclusion also tends to enhance the ability of State safety inspections and enforcement. These latter activities have generated two questions.

1. Does FMVSS 222 prohibit introduction into interstate commerce a new school bus, GVWR 10,000 pounds or less, with seats located so there is more than 21 inches between the rear surface of one or more forward facing passenger seats and the closest seating reference point of the forward facing passenger seat to the rear?

This question arises in connection with buses transporting (mostly) the larger sizes of high school age pupils, "activity buses", and "special education buses" (those carrying handicapped pupils). These school buses are purchased by government agencies (such as school districts) and by private parties (such as churches, contractors, etc.). Because S5.2 of FMVSS 222 does not apply to 10,000 pound or lighter buses, we believe the proper answer is "NO".

2. Does FMVSS 222 allow a manufacturer or alterer to install only one lap belt (Type 1 seat belt) on each passenger seat in a new school bus with 10,000 pounds or less GVWR: i.e., one lap belt, with two anchors, to go around 2, or 3, or more passengers properly in a seat?

We believe the proper answer is "NO" -- especially so since publication of your notification (43 FR 21893) and discussion (44 FR 23229 et seq) concerning designated seating positions, with your emphasis on the need for a restraint at each position where a passenger is likely to sit. We do not believe that 1 relatively long lap belt with its 2 anchors spaced sufficiently far apart to accommodate 2 or more properly seated passengers will safely restrain one passenger sitting somewhere in a 2-passenger or wider seat -- especially when that passenger is a relatively small pupil. Also, we do not believe that seat belt anchors spaced closely enough for properly restraining one passenger will allow a long lap belt to restrain 2 or more passengers properly, or without generating excessive belt-induced crash injury. As we read FMVSS 222, its only change of the "restraint standards" included by reference (FMVSS 208, 209, & 210) is the use of a 10 inch pelvic body block (depicted in FMVSS 222) in place of a 16 inch pelvic body block (depicted in FMVSS 210).

If your answer to either questions is "YES", we probably will need other answers. Therefore, we will appreciate an early response to each question in order that our instructions to field personnel and inspection stations may be firmed up in the near future.

If, in the preparation of your response, you feel that more details are needed or that you have questions which need answering, please feel free to contact the following members of my staff: Mr. Larry F. Wort, Chief of the Bureau of Safety Operations, 217/782-4974; or Mr. Madison Post, Standards Engineer, 217/782-2920.

Karsten J. Vieg, Director Division of Traffic Safety

ID: nht78-1.44

DATE: 09/21/78

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

TO: West Seneca Central School District

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your May 4, 1978, letter asking whether you can modify several buses that you have purchased by adding stanchion bars near the front door to facilitate the loading of smaller school children.

The National Highway Traffic Safety Administration does not prohibit the use of stanchion bars in school buses. Some manufacturers, however, have discontinued putting them in buses because it is difficult to pad them sufficiently such that they comply with the head impact zone requirements when the bars fall within the head impact zone.

The National Traffic and Motor Vehicle Safety Act of 1966 (the Act) prohibits modification of vehicles by repair businesses, dealers, or manufacturers that would render inoperative compliance with safety standards (section 108(a)(2)(A)). Therefore, if a dealer, repair business, or manufacturer were to install stanchion bars in your school buses, it would be required to ensure that the installation does not render inoperative compliance with the head impact zone requirements. The Act does not prohibit, however, modifications by individuals of their vehicles even when such modification would not comply with Federal safety standards. Accordingly, a school district could itself install stanchion bars that do not comply with the head impact zone requirements.

SINCERELY,

May 4, 1978

National Highway Traffic Safety Administration

Reference: Code of Federal Regulation, Part 571.222 School Bus Passenger Seating & Crash Protection

Gentlemen,

Recently we purchased 20 65-passenger buses. These buses, according to your regulations, had crash pads near the entrance way but the stanchion bars for help in boarding and leaving the buses were removed. Our Board of Education is not objecting to the crash pads but there is a strong feeling that some protection has been removed in the process of getting on and off the buses, particularly for small children.

We checked this matter out with the New York State Department of Transportation and this agency suggested that we write to you to see if we could get your approval. The question is this; may we install one or two stanchion bars at the entrance steps on the recently purchased 20 buses. If this meets your approval please write us a letter accordingly. It certainly would not be our intent to remove the pad.

Thank you for your early attention to this matter.

J. W. Yarbrough Assistant Superintendent for Business

ID: nht78-1.45

DATE: 03/10/78

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

TO: Recreation Vehicle Industry Association

TITLE: FMVSS INTERPRETATION

TEXT:

MAR 10 1978

Mr. Edmund C. Burnett Recreation Vehicle Industry Association 5272 River Road, Suite 400 Washington, D.C. 20016

Dear Mr. Burnett:

This responds to your January 18, 1978, letter asking several questions about the applicability of Standard No. 302, Flammability of Interior Materials, to several vehicle components that you submitted.

First you ask whether padded material used for the top portion of a dashboard would be considered to fall within the ambit of the standard. As you stated in your letter, the National Highway Traffic Safety Administration has determined that a dashboard is considered a front panel and is included within the components subject to the standard. Therefore, since the padding you propose to use on the top of the dashboard constitutes part of the dashboard it is required to comply with all of the requirements of the standard.

In your second question you ask whether the same material mentioned in question 1 would be required to comply withe the standard when used as a seat cushion. Paragraph S4.1, which lists the components covered by the standard, specifically includes seat cushions. Therefore, any material used for this purpose is required to comply with the standard.

In regard to both of the above questions, you ask whether a dashboard or seat cushion consisting of vinyl stitched at varying intervals to padding would be subject to two tests - one for the vinyl and one for the padding. Paragraph S4.2.1 states that: "any material that does not adhere to other material(s) at every point of contact shall meet the requirements of S5.3 when tested separately." When the vinyl is stitched to the padding in the manner outlined in your letter, the vinyl does not adhere to the material at every point of contact. Accordingly, the materials must be tested separately.

Your questions 3 and 4 require no response since the materials to which you refer must be tested separately, not as composite materials.

In your question 5, you correctly state that the two top materials would be required to be tested separately. If as installed in the vehicle the third layer of material would fall within 1/2 inch of the occupant compartment, then it too would be tested in accordance with the requirements. It does not matter that this material would not be within 1/2 inch of the surface when the stitching is removed for testing of each component separately. In a related question you ask whether the stitching itself would be tested. Since the stitching is part of the seat cushion, it is subject to the requirements and since it does not adhere at every point of contact, it should be tested separately. From the standpoint of practicality, however, the stitching cannot be tested separately in the prescribed manner, and is usually simply tested as part of the material itself.

Finally you submitted a section of headlining material and question whether it would be required to comply with the requirements. This material falls within the list of components covered by the standard and, therefore, must comply with all of the requirements. The material that you submitted is composed of two layers joined at every point of contact and would be tested as a composite material.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

ID: nht78-1.46

DATE: 12/05/78

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

TO: Mack Trucks, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

December 5, 1978 NOA-30

Mr. T. F. Brown Mack Trucks, Inc. P.O. Box 1761 Allentown, Pennsylvania 18105

Dear Mr. Brown:

This responds to your October 10, 1978, letter asking whether you are permitted to mark the certification documents of some of your incomplete vehicles as MACK TRUCKS, INC./RVI. These incomplete vehicles will be manufactured abroad by Renault Vehicules Industriels and imported into the United States by Mack Trucks, Inc.

Part 568, Vehicles Manufactured in Two or More Stages, requires an incomplete vehicle manufacturer to furnish with the incomplete vehicle certification its name and mailing address. Section 102(5) of the National Traffic and Motor Vehicle Safety Act states that the term manufacturer includes any person importing motor vehicles or motor vehicle equipment. Since your company will be importing these incomplete vehicles and an importer may be considered a manufacturer, it is permissible for you to label incomplete vehicles assembled by Renault with the MACK TRUCKS, INC./RVI designation.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

October 10, 1978

Ms. Joan Claybrook, Administrator National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Ms. Claybrook:

SUBJECT: Vehicle Certification MACK TRUCKS, INC./RVI

Mack Trucks, Inc. and Renault Vehicules Industriels (RVI) are negotiating an agreement whereby Mack would market Saviem trucks in the United States and Canada under the Mack name. Our current plan is to have the vehicles manufactured by RVI with the "MACK" letters on the front of the cab and shipped to the U.S. After their arrival at a U.S. port, the vehicles will be shipped to Mack branches and distributors throughout the U.S. and Canada. Mack Trucks will not perform any manufacturing operations on these vehicles.

It is our desire to furnish all certification documents with "MACK TRUCKS, INC./RVI" listed as the incomplete vehicle manufacturer. The incomplete manufacturer's address, when required, would be listed as:

MACK TRUCKS, INC./RVI Box M Allentown, Pa. 18105

We would appreciate your comments on this proposed practice.

Very truly yours,

MACK TRUCKS, INC.

T. F. Brown Executive Engineer Vehicle Regulations and Standards

vy

ID: nht78-1.47

DATE: 11/20/78

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

TO: Burke & Burke

TITLE: FMVSR INTERPRETATION

TEXT:

November 20, 1978

Mr. Michael Pinto Burke & Burke 30 Rockefeller Plaza New York, New York 10020

Dear Mr. Pinto:

This is in response to your letter of October 25, 1978, requesting approval of the tread labels Atlas Supply Company proposes to use in satisfaction of the labeling requirements of the Uniform Tire Quality Grading Standards (UTQGS) (49 CFR 575.104(d)(1)(i)(B)). You propose to include the applicable UTQGS grades for a particular tire on a tread label identifying the tire brand, type and size. All possible traction and temperature grades would be depicted with the grades applicable to the specific tire indelibly circled. A separate label would contain the general grading information from Figure 2 of the rule.

Part 575.104(d)(1)(i)(B) requires that each passenger car replacement tire, other than a snow tire or temporary use spare tire, have affixed a tread label containing both the specific UTQGS grades for the tire and an explanation of the grades in the form illustrated in Figure 2. While the National Highway Traffic Safety Administration (NHTSA) has no objection to the inclusion of the required UTQGS information on the same label with other data such as tire size and brand name, failure to provide the required explanations on the same label with the applicable tire grades is not permitted by the regulation.

While Atlas' proposed tread labels do not meet the present requirements of Part 575.104(d)(1)(i)(B), NHTSA now has under consideration a petition for rulemaking requesting amendment of the UTQG regulation to permit greater flexibility in tread labeling.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

October 25, 1978

Mr. Richard Hipolit Office of Chief Counsel National Highway Traffic Safety Administration 400 7th Street, S.W. Washington, D.C. 20590

Dear Mr. Hipolit:

Uniform Tire Quality Grading Standards

This letter is in response to our telephone conversation of October 23, 1978.

Atlas Supply Company (Atlas) is a trademark licensing organization which licenses the nationally known mark "ATLAS" for use on tires, batteries and other automobile accessory items.

In anticipation of the March 1, 1979 effective date for bias ply tires, Atlas is preparing revisions to its tire labels to bring them in compliance with the above referenced standards. Attached hereto as Exhibit "A" is a proposed layout of a tire label (in two parts) which contains the treadwear, traction and temperature grades of the tire required by 49 C.F.R, 575.104(d)(1)(B) as well as other pertinent information. The other part of the label contains other information in the form illustrated in Figure 2 of the standards.

Due to the amount of information required to be printed and the space limitations of the tire tread surface, Atlas is of the opinion that all of the requirements can best, if not only, be met by the use of a two-part label. Atlas will specify to the tire manufacturers that the information illustrated in Figure 2 must be immediately adjacent to the tire grading information.

We request your concurrence in our conclusion that this arrangement fully complies with the aforesaid standard.

Very truly yours,

Michael Pinto

MP:jg

Enc.

cc. Mr. F. F. Messier Mr. G. V. Cambeis

ID: nht78-1.48

DATE: 12/29/78

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

TO: Ford Motor Co.

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION Dec. 29, 1978

NOA-30

Mr. J. C. Eckhold, Director Automotive Safety Office Ford Motor Company The American Road Dearborn, Michigan 48121

Dear Mr. Eckhold:

This is in response to your letter of August 29, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80. The answers to your specific questions are as follows:

(1) You requested an interpretation that a single telltale which monitors both the oil pressure and coolant temperature gauges could be identified by the word "Engine." You indicated that it has been Ford's practice to combine the monitoring of these two functions into a single telltale because the response by the driver to either malfunction is the same. The standard does not require that any of the displays listed in S5.1 be provided or that two or more displays, if provided, be provided separately. It is the interpretation of the NHTSA that the multipurpose telltale which monitors the two functions specified above may be identified by the word "Engine."

(2) You asked whether the NHTSA intended that the display identification requirements of FMVSS 208 would be met by use of the symbol required by FMVSS 101-80. The answer is no. However, the agency will issue shortly a notice which will provide for the use of the FMVSS 101-80 symbol for the purposes of that standard and those of FMVSS 208.

(3) You asked that the identification requirements of FMVSS 105-75 be deleted from that standard and those in FMVSS 101-80 be retained. No conflict exists between the two standards. Nevertheless, we will address this issue in the same notice mentioned in the immediately preceding paragraph.

Sincerely,

Joseph J. Boyin, Jr. Chief Counsel

Ms Joan B. Claybrook Administrator National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Ms. Claybrook:

Re: Request for Interpretation of Federal Motor Vehicle Safety Standard No. 101-80

Ford Motor Company requests clarification of three of the provisions in Federal Motor Vehicle Safety Standard (FMVSS) 101-80, Controls and Displays, as amended (Fed. Reg. 27541, et seq., June 26, 1978). The need for such clarification became evident to Ford following a review of the final rule and its implications to future model designs.

1. Engine Coolant Temperature and Oil Pressure

Ford believes that the words in S5.1 of the Standard; ". . . each of the following displays that is furnished . . ." (emphasis added) were incorporated to distinguish between those descrete and distint displays required to use a specific word(s) or symbol and "others", such as a single telltale covering both engine coolant temperature and oil pressure, not covered by the regulation. This conclusion is consistent with Ford's comments in Attachment 1 of its response to Docket No. 1-18; Notice 12 (41 Fed. Reg., 46460 et. seq.) where Ford noted that for several years it has, with satisfactory results, combined the display for adverse conditions of either of these functions with a single telltale labeled with the word *Engine". In our 1978 Fairmont and Zephyr vehicle lines we are using a symbol instead of the word "engine" (see attachment). When the "engine" telltale glows steadily, the advice given in our Owners Manual is the same for either low oil pressure or high coolant temperature: "Pull off the road and stop the engine immediately and determine the cause. If the engine is not stopped immediately, severe damage could result."

We request confirmation of our belief that a telltale, with a single symbol or word, monitoring both the engine coolant temperature and the oil pressure may be used.

2. Seat Belt Warning System

S5.2.3 of FMVSS 101-80 requires the use of the symbol for the seat belt warning telltale shown in Column 4 of Table 2, while the requirement of S4.5.3 and S7.3 of FMVSS 208 is for a warning system displaying the words "Fasten Seat Belts" or "Fasten Belts". Because the preamble to the amended 101-80 Standard states that "It is also proposed to consolidate the control and display requirements of other standards in one regulation. This notice takes final action on that proposal...." Ford believes that the Administration intended that the identification requirements of FMVSS 208 would be met by the symbol required in FMVSS 101-80 -- and use of the words "Fasten Seat Belts" or "Fasten Belts" is optional. Ford, therefore, requests confirmation of its belief and recommends that FMVSS 208 be amended to delete the labeling requirements for seat belt warning indicators in order to remove this inconsistency.

3. Brake warning System

For the same reason noted in 2 above, a clarification of the warning lamp requirements for brake systems in FMVSS 105-75 is requested. FMVSS 105-75, Section 5.3., et seq., requires a warning lamp for brake system failure, brake light proveout and parking brake "ON". In addition, FMVSS 105-75 specifies the manner in which this warning lamp must be displayed, i.e., a red lens and the word "BRAKE". Telltale requirements are also specified in FMVSS 101-80. Ford believes that the identification requirements of the brake system warning lamp should be deleted from FMVSS 105-75 and retained in FMVSS 101-80. This method of requiring the presence of a warning lamp in a system standard and specifying the form of the display in FMVSS 101-80 Would then be consistent with other standards requiring warning lamps.

In reviewing Table 2 of FM7SS 101-80, we have identified certain minor anomalies. Column 3 of Table 2 incorrectly references FMVSS 105 instead of FMVSS 121 for brake air pressure. In addition, Brake System only references FMVSS 121 in Column 3 but should also include FMVSS 105-75.

Finally, to be consistent with other reference ????????? standards, we suggest a reference to FMVSS 127 to be ???????? the speedometer and odometer displ ???????? Very truly yours,

J. C. Eckhold Director Automotive

**INSERT ATTACHMENT** FORD SYMBOL USED ON A SINGLE TELL-TALE FOR ENGINE OIL PRESSURE AND COOLANT TEMPERATURE

ID: nht78-1.49

DATE: 12/08/78

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Conco Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

December 8, 1978 NOA-30

Mr. O. R. Schmidt Conco Inc. Mendota, Illinois 61342

Dear Mr. Schmidt:

This is in response to your letter of October 27, 1978, concerning the application of Motor Vehicle Safety Standard No. 115 to final stage manufacturers and in confirmation of your telephone conversation with Mr. Schwartz of my office.

The National Highway Traffic Safety Administration has amended Standard No. 115 to shift the responsibility for assigning the vehicle identification number for vehicles manufactured in more than one stage from the final stage manufacturer to the incomplete vehicle manufacturer (copy enclosed). We appreciate your desire to comply fully with the standard but, with this recent amendment, compliance will not be required by final stage manufacturers.

In response to your question concerning the "model year" to be used for trailers, the calendar year is acceptable as the "model year." Should you have any other questions concerning your responsibility for assigning VINs to the trailers you manufacture, please do not hesitate to contact me.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

Enclosure

October 27, 1978

Mr. Nelson Erickson Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Subject: Revised Standard No. 115 Vehicle Identification Number

Dear Sir:

The O'Brien Division of Conco Inc. is a small manufacturer of truck mounted and trailer mounted sewer cleaning equipment which is sold predominately to municipalities, counties, etc., and in some cases to private contractors. So far this year we have built 15 truck mounted units and 52 trailer mounted units.

With reference to the revised Standard No. 115 on Vehicle Identification Numbers, we presently have no major questions in regard to its application to our trailer mounted equipment, since we control the manufacture of these units from start to finish. We are, however, confused about its application to our truck mounted units, particularly as regards the second section of the VIN. Enumerated below are items that hopefully you can clarify for us:

1. The majority of truck chassis-cab units that we use are Fords, but we have used Chevrolet, GMC, and International trucks. Among these four truck manufacturers there are more than 40 different truck models that potentially we can use to mount our equipment on. (As a matter of information, our equipment is mounted on the truck chassis frame without making any alterations to the truck chassis, in the same way that a farmer would mount his own grain box on a similar truck chassis.) Some of these truck chassis we buy, and some are furnished to us or specified by our customers. The only thing we have concerned ourselves with to date is the appropriateness of the axle ratings and the GVWR. Since we don't always know in advance what truck we will be using, we have to anticipate in our coding of the second section of the VIN all of the potential truck models that we might be using. The second section has five characters available for deciphering eight items of information, including the identification of the incomplete vehicle manufacturer as spelled out in S4.5.2. In order to do this, it is necessary to combine some attributes into one character. Our intention would be to combine (1) the incomplete vehicle manufacturer, (2) the model or line, and (3) the series. Our first question - how is it possible to code a potential of 40 plus models of truck chassis into a single character that has available only 33 numbers and letters (Table III of S4.6) for identification purposes? Our second question - will the incomplete vehicle manufacturer such as Ford, Chevrolet, GMC, or International furnish us with a coded second section in their incomplete vehicle document that we could use in conjunction with our first and third section portions of the VIN, assuming, of course, that the attributes of the second section have not been altered? If this were the case, the first question would be resolved, and our only concern would be to furnish you data for the first and third sections of the VIN.

2. Is it permissible for the Vehicle Identification Number as specified in the revised Standard No. 115 to appear in the space provided on the certification label for "Vehicle I.D.", or is it mandatory for the VIN to appear on a separate label? This issue is confusing as regards trailers and trucks with a GVWR of over 10,000 lbs.

3. In the case of trucks, do we, as a final stage manufacturer, represent the model year as being the model year of the truck chassis, or the calendar year of final stage manufacture? Assume that on September 10, 1980 we mount one of our units on a 1981 model Ford truck. This would require the use of the code letter "B". Further assume that two weeks later, on September 24, 1980, we mount a unit on a 1980 model Ford truck which is a new truck that a dealer has left over from the previous model year inventory. In this case we would have to revert back to the code letter "A". This is inconsistent with the natural chronology of events. The above example represents a very real possibility and, therefore, as a final stage manufacturer, we would prefer to use the calendar year of manufacture where the sequence would be totally under our control. There is no way that we could control the model year sequence as illustrated in the above example.

Also, in the case of trailers such as we manufacture, the model year as used by auto and truck manufacturers is absolutely meaningless since we do not have annual model changes. Here again we would prefer to use the calendar year of manufacture as the basis for the code.

We would appreciate your comments and any clarification you can give us on the above listed items.

Yours very truly,

CONCO INC.

O. R. Schmidt Manager of R & D

ORS:jn

ID: nht78-1.5

DATE: 03/22/78

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

TO: J. Kawano

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. J. Kawano 1099 Wall Street, West Lyndhurst, New Jersey 07071

Dear Mr. Kawano:

This responds to your January 23, 1978, letter asking whether Safety Standard No. 205, Glazing Materials, would be applicable to tempered glass mounted on the outside panel of a vehicle "B-pillar" for ornamental purposes.

The answer to your question is no. Since there would be no danger that vehicle occupants would contact the ornamental glass, it would not have to comply with the performance and location requirements of Standard No. 205. This interpretation assumes, of course, that the glass is used only on the outside panel of a solid "B-pillar". Standard No. 205 would be applicable, for example, if the glass were used in a cut-out section of a "B-pillar", such that there was an interface of the glass with the vehicle occupant compartment.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

January 23, 1978

Mr. Joseph Levin, Chief Council National Highway Traffic Safety Adm. 400 Seventh Street, S.W. Washington, D.C. 20590

Interpretation Request of FMVSS 205

Dear Mr. Levin:

This is to confirm your interpretation as to whether tempered glass mounted on the outside panel of a B-pillar for ornamental purposes, as shown in Fig.1, falls into the application of FMVSS 205, "Glazing Materials."

The glass will be adhered, at every point, to the garnish which is bolted to the B-pillar outer panel. This can be observed in Fig.2 which shows the A-A section of Fig.1. In cases where the glass is broken into pieces, even though the glass has AS 3 performance equivalency, the fragment will not come out from the garnish because of the adhesion.

As we understand, FMVSS 205, "Glazing Materials," would not apply to such glass that is mounted simply for the purpose of ornamentation, as we mentioned above. However, your confirmation of our understanding will be very much appreciated.

Since this is an urgent matter, we would appreciate your expeditious interpretation.

Sincerely yours,

TOYOTA MOTOR SALES, U.S.A., INC.

J. Kawano Director/General Manager Factory Representative Office

JK:gc

ID: nht78-1.50

DATE: 12/06/78

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

TO: Palmer Machine Works

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Dick Palmer Palmer Machine Works Old Round House Road Amory, Mississippi 38821

Dear Mr. Palmer:

This is in response to your letter of November 10, 1978, concerning Federal Motor Vehicle Standard No. 115, Vehicle identification number, and in confirmation of your telephone conversation with Mr. Schwartz of my office.

Unfortunately, we do not have a simplified version of the standard which applies only to trailers. We have also modified the standard somewhat since the August 1978 version you referred to in your letter. I have attached a copy of the modification as well as a proposed further modification. I realize this is a complex standard, and, therefore, offer the following comments:

1. Since you produce less than 500 vehicles per year, characters 1, 2, 3, 11, 12 and 13 of the VIN will represent your manufacturer identifier. The date by which your manufacturer identifier must be submitted to the NHTSA has been changed to September 1, 1979. It is our understanding that the Society of Automotive Engineers will be willing to help you determine your manufacturer identifier. You should contact: Mr. Leo Ziegler, Society of Automotive Engineers, 400 Commonwealth Drive, Warrendale, Pennsylvania 15096, (412) 776-4841.

2. The 4th, 5th, 6th, 7th, and 8th characters of the VIN represent descriptive information about your vehicles. In the case of trailers, the type of trailer, series, body type, length and axle configuration must be represented. Since your model number can be associated with all these characteristics, you may want to incorporate it into the vehicle descriptor section.

3. The 9th character of the VIN represents the model year of the vehicle, and should be determined from Table II which appears in the standard.

4. The 10th character of the VIN represents the plant of manufacture. Since your firm has only one plant, you may choose any character you desire except one specifically precluded by the standard.

5. Since your firm manufacturers less than 500 vehicles each year, the last three characters of the VIN represent the number that is sequentially assigned to a vehicle in your production process.

6. The check digit which immediately precedes the third character of the VIN is determined by the mathematical operation described in section S5 of the standard. Since most characters in your VIN will be standarized, the check digit should be fairly easy to determine.

Please contact me if you have any further questions. Any trade associations to which you belong should also be helpful in establishing your VIN procedures.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

November 10, 1978

Administrator, National Highway Traffic Safety Administration 400 Seventh Street S W Washington, D. C. 20590

Attention: VIN Coordinator

Gentlemen:

I have just read pages 36448 through 36454 of Federal Register, Vol. 43, No. 160 - Thursday, August 17, 1978. This is of course concerning the new VIN Standard No. 115. I am very confused as to how this affects our company as a manufacturer.

Dump trailers are the only product manufactured by the company. All of the trailers are manufactured at the same facility. Between 250 and 300 trailers are manufactured annually.

In S6.1 I notice that I am required to submit the unique identifies for each vehicle by January 1, 1979. Can you please send me a more simplified explanation of this standard that would pertain to trailers only? Please let me hear from you as soon as possible. Thank you.

Sincerely,

PALMER MACHINE WORKS, INC.

Dick Palmer