ID: nht78-2.24

DATE: 07/27/78

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: Niles Parts Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: We refer to your letter of March 15, 1978, concerning the testing of hazard warning and turn signal operating units (switches) in accordance with Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment.

The purpose of requiring 3-inch wire leads on any operating unit during testing is to permit the measurement of any voltage drop across a connector in the circuit. Since the connector is an integral part of your type of operating unit with its "terminal-direct" connection system, the wire leads are not necessary. We, therefore, interpret the society of Automotive Engineers Standards J589 and J910, covering Hazard Warning and Turn Signal Operating Units respectively, to require 3-inch wire test leads only on those units that are supplied with integral wire leads. During the prescribed tests, voltage measurements on units such as those that you provide shall be made at the electrical contacts on the units.

ID: nht78-2.25

DATE: 03/20/78

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

TO: General Cable Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 3, 1978, concerning placement of the rear identification lamps on a truck. Because the truck has a mast assembly located on the longitudinal axis of the vehicle and center of the rear axle, you have asked whether the lamps should be mounted "on the mast as high as possible or on the rear face of the rear floor decking."

Table II of Federal Motor Vehicle Safety Standard No. 108 requires rear identification lamps to be mounted "as close as practicable to the top of the vehicle. . . ." If placement on the mast interferes with the operation of the lift, or if the lamp would be easily damaged in that location, that location would not appear to be "practicable" within the meaning of Standard No. 108, and the deck location would fulfill the practicability requirements.

You have also asked which is more important in locating identification lamps: "(1) . . . as high as possible on a stationary surface and face the lights toward the rear, or (2) to locate to the most rearward surface and then as high as possible on that surface". Your first choice is the correct one. The purpose of the three lamp cluster is to identify large and frequently slow moving vehicles under conditions of reduced visibility. Therefore, it is more important for the lamps to be located high than it is for them to be at the rear end of the vehicle, for example, on the cab rather than at the deck end. However, the decision as to what is "practicable" is initially that of the manufacturer and we have generally found those decisions to be correct.

SINCERELY,

General Cable

February 3, 1978

Department of Transportation c/o Bradley E. Marks

Dear Mr. Marks:

We, at General Cable, primarily design and manufacture vehicles with aerial lifts for personnel to service electrical utilities. For this type of equipment, we seem to have a problem truly defining a section of F.M.V.S.S.108 for our application.

The particular section in question is the location of the rear identification lights.

Since we design a lift whose mast assembly is located approximately on the longitudinal axis of the truck and centerline of the rear axle, should we mount the cluster of lamps on the mast as high as possible, or on the rear face of the rear floor decking? The definition of the exact location is rather vague for our industry.

Also, Mr. Marks, we have a secondary problem. Standardization of the lighting location. This mast assembly may, at some time in the future, be located further forward, just behind the truck cab. This would require the turret, boom, boom rest and basket to be positioned towards the rear of the vehicle.

The way I've interpreted the law for this particular configuration would have us locating the cluster of lights on the rear face of the rear floor decking. This due in part to the photometric interference from the basket and/or boom and boom rest assemblies.

At this point in time I must now ask, which is more important in locating these lights: (1) to locate as high as possible on a stationary surface and face the lights towards the rear? or (2) to locate to the most rearward surface and then as high as possible on that surface?

We would like a ruling on this matter as soon as possible as production of this unit is scheduled within the coming weeks.

Thank you very much, Mr. Marks, for your co-operation in this matter. Any response to this problem may be addressed either to myself or my superior, Mr. Bill Hensley, Chief Engineer.

Garry Williams Body Designer Telsta Group

cc: Bill Hensley; Van Walbridge

ID: nht78-2.26

DATE: 04/05/78

FROM: AUTHOR UNAVAILABLE; M. M. Finkelstein; NHTSA

TO: C. S. Ullman

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 28, 1978, to Mr. A. P. Uccello, regarding Federal Motor Vehicle Safety Standard No. 202, Head Restraints (copy enclosed).

In this Standard, under section 4(b)(1), the minimum height of the head restraint shall not be less than 27.5 inches above the seating reference point which is determined with a three-dimensional H Point Machine per SAE Standard J826B placed on the seat. Thus, we have specified a minimum dimension that the car builder must comply with, but we have no limit on the maximum dimension of the head restraint. This latter dimension is set by the builder to suit his requirements.

Certainly your height is a problem in this case and for future rulemaking actions along this line we are placing your letter and the Buick reply in the appropriate docket.

SINCERELY,

February 28, 1978

A.P. Uccello Transportation Dept.

Dear Sir:

You are impossible to get on the phone so I will resort to writing.

I have nothing but plaudits for my '77 Buick but I have written to them about the height of the head restraint (head rests). I am 6' 7" tall and the head rest probably would not prevent whip lash in my case. Previously the head rest was made so it could lock in at least three positions-the highest position was correct for me. Now the head rest only tranerses about 1 inch and does not lock so people getting in the back seat could depress the head rest.

Enclosed please find copy of my reply from Buick. I call your attention to the second paragraph. I would like to know what safety standard effects the head rest? If there is such a standard, then it should be corrected.

I welcome your comment and advice.

THANK YOU.

Charles S. Ullmann

BUICK MOTOR DIVISION, GENERAL MOTORS CORPORATION January 31, 1978

S. C. Ullmann Associates, Inc. 94 Highland Road Scarsdale, NY 10583

Att: Mr. Charles S. Ullmann

Dear Mr. Ullmann:

Thank you for your recent note of January 23, 1978 addressed to our Zone Manager, Mr. R. G. Royer, and we appreciate the interest you have shown in bringing to our attention the characteristics of the front seat head rest supports in your 1977 Buick Electra Limited.

As you probably realize, your car was manufactured in compliance with many vehicle safety standards, and one of these considerations is the head rest suitability throughout the range and size of the car occupants.

However, since we welcome comments from all of our owners, it is with this thought that we are forwarding your letter to the attention of those parties responsible for these design caracteristics.

Thank you again for writing, and please be assured of our interest.

K. J. Mariano Manager, Zone Service Operations

ID: nht78-2.27

DATE: 08/16/78

FROM: A. MALLIARIS FOR M. M. FINKELSTEIN -- NHTSA

TO: Department of Radiology and Nuclear Radiology

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 21, 1978, regarding the height of head restraints in U.S. manufactured cars.

Federal Motor Vehicle Safety Standard No. 202, Head Restraints, Passenger Cars, copy enclosed, requires that when the head restraint is adjusted to its fully extended design position, the top of the head restraint shall not be less than 27.5 inches above the seating reference point. The 27.5 inches approximates the distance from the hip point to the occiput of a 95% percentile anthropometric male figure. The seating reference point in turn corresponds to the hip point. Therefore, head restraints would be expected to be adjustable to the normal sitting height of 95 percent of the male population.

On March 10, 1978, the National Highway Traffic Safety Administration (NHTSA) issued a notice of a draft plan for rulemaking, copy enclosed. Plans for rulemaking concerning head restraints are noted on page 11106 under Docket 74-13. To support future rulemaking regading the height of head restraints we would appreciate any data that you may have in your possession regarding cervical spine injuries in rear impact accidents. It may be forwarded to NHTSA, Docket 74-13.

A copy of your letter is being forwarded to the docket as a matter for the public record.

SINCERELY,

Orlando General Hospital

U.S. Department of Transportation National Highway Safety Administration Office of the Rule Making

July 21, 1978

Dear Sir:

It is my opinion that the headrest on U.S. manufactured cars are designed to prevent injury to the cervical spine and the skull. Through personal experience and experience as a Radiologist, I find that the maximum height of these headrests are not high enough to prevent injury to taller people.

I strongly encourage that the headrests installed in U.S. manufactured automobiles be adjustable by the occupant so that people over 6 foot 2 inches tall may have the benefit of safety. At the present time, the maximum height sometimes encourages more traumatic injuries of the cervical spine rather than preventing them in regards toward tall people.

Bodo E. Pyko, D.O. Chairman Department of Radiology and Nuclear Radiology

ID: nht78-2.28

DATE: 01/17/78

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

TO: Hendrickson Mfg. Co.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your November 21, 1977, letter asking whether a school bus that is propelled by a propane-fueled engine is required to comply with Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity (49 CFR 571.301-75).

Paragraph S3 of Safety Standard No. 301-75 specifies that the standard applies to school buses that have gross vehicle weight ratings greater than 10,000 pounds and use fuel with a boiling point above 32 degrees F. Since the boiling point of propane is below 32 degrees F, Safety Standard No. 301-75 would not be applicable to a school bus propelled by a propane engine.

Please contact us if you have any further questions.

SINCERELY,

November 21, 1978

Chief Counsel National Highway Traffic Safety Administration

Ref: 571.301 Standard No. 301: Fuel system integrity

Dear Sir:

Hendrickson Manufacturing Company, as a manufacturer of custom school bus chassis over 10,000 GVWR pounds, requests a ruling that would determine if a school bus propelled by a propane fueled engine is required to comply with Standard 301, fuel system integrity.

HENDRICKSON MFG. CO.

Kenneth R. Brennan Engineer Mobile Equipment Division

CC: M. A. SIGNA; T. F. CRAMER; A. TABB

ID: nht78-2.29

DATE: 08/04/78

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Quinn Cuzzone & Geremia

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of June 29, 1978, concerning the requirements for designating an agent pursuant to section 110(e) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1399(e)).

Title 49 CFR @ 551.45 specifies the procedural requirements for service of process on foreign manufacturers and importers. The purpose of these requirements is to enable the Department of Transportation to effectuate service of process on manufacturers who are outside the jurisdictional limits of the United States. It is not necessary for manufacturers or importers located within the United States to designate an agent for service of process. Therefore, the New York corporation which you represent need not make such designation.

This letter also confirms Ms. DeMeter's statement that Sprinter Moped Incorporated has not designated an agent. They will have to do so prior to the importation of the mopeds. Since the corporation you represent is the importer, it may be desirable for Sprinter to appoint that corporation or one of its officers as the agent.

The National Highway Traffic Safety Administration does not impose any requirements on domestic importers. However, they may want to make sure that the manufacturer complies with the regulations regarding manufacturer identification, certification, and applicable safety standards. I have enclosed two information sheets on the "Application of Federal Motor Vehicle Safety Standards" and "Where to Obtain Motor Vehicle Safety Standards and Regulations."

If you have any further questions, please do not hesitate to write.

Enclosures

ID: nht78-2.3

DATE: 12/13/78

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

TO: Mack Trucks, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

December 13, 1978 NOA-30

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

Dear Mr. Brown:

I regret the delay in responding to your August 31, 1978, letter requesting an interpretation of S5.3 of Federal Motor Vehicle Safety Standard No. 120. In that letter, you stated that you had been contacted by an employee of this agency's enforcement office and advised that the certification labels for Mack trucks did not comply with the requirements of that section. The reason given for this conclusion was that the labels used the word "on" between the tire and rim information instead of the comma shown in the example following S5.3.3.

S5.3 requires that the labeling information specified in S5.3.1 -S5.3.3 must appear in the format shown in the truck example following S5.3.3. This requirement does not mean that certification labels must be identical to the example in every respect. Minor variations are permitted. By "minor variations", I mean such things as a slight difference in punctuation or the substitution of a word for a punctuation mark that do not change or obscure the meaning of the label. Mack's substitution of "on" for a comma is such a minor variation and, accordingly, is permissible under the standard.

The label enclosed with your letter shows spaces to provide information for the front, rear and three intermediate axles. When this label is used on vehicles with fewer than five axles, you should stamp "Not applicable", or words of similar import, in the spaces provided for axles which do not exist on the particular vehicle which is being labelled.

Without this indication, the label could be confusing and so would fail to clearly provide the required information for that vehicle. An indication of nonapplicability would alert the reader to that fact.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

August 31, 1978

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

Dear Sir:

SUBJECT: Request for Interpretation GAWR-Tire-Rim Labeling Requirements FMVSS 120 - Vehicle Certification Labels

Mack Trucks, Inc, a manufacturer of heavy duty diesel trucks of 26,000 pounds GVWR and greater, is requesting an interpretation of the specific GAWR-tire-rim labeling requirements of FMVSS 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.

We were advised, by telephone, by a member of the NHTSA's Office of Vehicle Safety Compliance staff that there were several minor discrepancies found on one of our vehicle certification labels. Four items were noted as being incorrect. Three of these four items were well-taken, and steps to avoid a reoccurrence of these errors have been taken. The fourth item, however, is the reason for this letter.

Our certification labels set up the gross axle weight ratings, tire, and rim information as follows:

FRONT AXLE WITH TIRES ON RIMS AT COLD SINGLE

We were advised that we could not use the word "ON" as shown above, but should instead use a comma as is illustrated in the "Truck example" shown following Paragraph S5.3.3 of FMVSS 120.

Paragraph S5.3 oF FMVSS 120 states that the information shall appear in the "format" set forth in the example following Section S5.3.

It is our contention that the GAWR and associated information on our certification labels, including the word "ON", does comply with the format set forth following Section S5.3 of FMVSS 120. The word "ON" actually makes the meaning of the statement clearer.

If you look closely at the attached sheet showing one of our labels and the "Truck example" from FMVSS 120, you will note that they are not exactly identical. Therefore, we wonder why only our use of the word "ON" was singled out. (NOTE: The other three items noted in the telephone conversation dealt with information that had been added to the certification label on the vehicle inspected by NHTSA.)

We believe we are presenting all the required information in a form substantially identical to that illustrated in the "Truck example", and that we are in compliance with the applicable regulations. Therefore, we are requesting an interpretation of the specific GAWR-tire-rim labeling requirements of FMVSS 120.

If further discussion of this subject is necessary, please contact the writer at 215-439-3877.

Very truly yours,

MACK TRUCKS, INC,

T. F. Brown Executive Engineer- Vehicle Regulations and Standards

vy Attach.

Insert attachment here (FMVSS 120) found in card copy file.

ID: nht78-2.30

DATE: 09/22/78

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

TO: Fiat Research & Development - U.S.A. Branch

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your June 16, 1978, letter asking whether a manufacturer is permitted to list on the certification label required by Part 567, Certification, the gross axle weight rating (GAWR) in kilograms as well as pounds. The National Highway Traffic Safety Administration has permitted the use of kilograms on the certification label as long as the label continues to list the GAWR in pounds also.

ID: nht78-2.31

DATE: 02/27/78

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

TO: Mercedes-Benz of N.A.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 1, 1978, letter asking whether your certification label complies with the requirements of Part 567, Certification.

Your certification would state the gross vehicle and axle weight ratings in both pounds and kilograms. In the past, the agency has permitted this approach for the purpose of international harmonization of measurements. Therefore, your proposed label appears to comply with the requirements.

ID: nht78-2.32

DATE: 04/05/78

TO: Truck Body and Equipment Association Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your February 21, 1978, letter asking whether section 567.5(c)(7) of Part 567, Certification, requires a manufacturer to use all of the described statements on its certification label.

The answer to your question is no. That section provides that the listed certification statements are to be used as appropriate. Therefore, it is anticipated that a manufacturer will select for inclusion on its certification labels only those certification statements in subparagraph (c)(7) that are appropriate for the certification of its vehicles.