ID: nht68-3.39

DATE: 07/09/68

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

TO: Mr. Philips B. Boyer

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 24 to the Department of Transportation asking if manufacturers of motor homes are "required to equip the seats in such units with seat belts."

The self-propelled motor home is classified as a "multipurpose passenger vehicle" for purpose of the Federal motor vehicle safety standards. Currently seat belt installations and seat belt assembly anchorages are not required for multipurpose passenger vehicles, but if a seat belt assembly is(Illegible Word) by the vehicle manufacturer it must meet the requirement of Federal standard No. 209.

On October 14, 1967 the Federal Highway Administrator established dockets to receive comments on possible requirements for seat belt installations and seat belt assembly anchorages in multipurpose passenger vehicles. These comments are now under evaluation.

ID: nht68-3.4

DATE: 10/03/68

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Deputy Chief Experimental

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 23, 1965, to Dr. William Haddon, Jr., concerning windshield washers.

Based upon the information you provided, your annually operated windshield washer system appears to meet the requirements of Motor Vehicle Safety Standard No. 104, Windshield Wiping and Washing Systems. You state your washer system will deliver the required 15 cc of fluid to windshiell (as specified in paragraph 2.11 of SAB Recommended Practice J942, November 1965) within a period of 3 seconds or less (as specified in paragraph 4.4.2(b) of J942). You also state your manual system will meet the washer system capability requirements of paragraph 3.1 and the durability requirements of paragraph 3.4 of J942.

Apparently your concern is that your annually operated system will not deliver 15 cc of fluid per stroke. However, if you can provide the required 15 cc of fluid by using additional strokes within a 3 second period and if this type of operation will clear 75% of the effective wipe pattern within 10 cycles, you meet the performance requirements we consider necessary for highway safety.

ID: nht68-3.40

DATE: 07/12/68

FROM: AUTHOR UNAVAILABLE; Joseph R. O'Gorman; NHTSA

TO: Western Body and Hoist Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 9, 1968, to the Federal Highway Administration, in which you requested clarification of the requirements for amber side marker lamps and amber side reflectors.

A copy of presently applicable standards, and some proposed standards are enclosed. Note that Federal Motor Vehicle Safety Standard No. 108, effective January 1, 1969, requires amber front side marker lamps, and amber front side reflectors for vehicles of less than 30 feet overall length, and 80 or more inches in overall width. When the overall vehicle length is less than 30 feet and the front side marker lamps and front side reflectors have been mounted on the cab by the chassis-cab manufacturer, an additional set of the foregoing lamps and reflectors is not required on the body when it is installed.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals 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 the standard.

I trust this answers your questions.

ID: nht68-3.41

DATE: 07/22/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Lodal, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 17, 1968, to the National Highway Safety Bureau, attention of Mr. Joseph R. O'Gorman, concerning the requirements for rear identification lamps and rear clearance lamps on your EVO Refuse Packer.

Since no mounting height restrictions are specified for rear identification lamps in Motor Vehicle Safety Standard No. 108, these lamps may be mounted on or below the cross member between the rear wheels. Shielding may be necessary to protect the lamps.

No clearance lamp may be combined optically with any tail lamp or identification lamps. Combination rear clearance and side marker lamps may be used providing the requirements for each are met.

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. 108.

ID: nht68-3.42

DATE: 07/22/68

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

TO: General Motors Technical Center

TITLE: FMVSS INTERPRETATION

TEXT: This is in reference to your letter of June 14, 1968.

Enclosed is the Grant of Approval for equivalent seat assembly attachment hardware as requested in your letter.

U.S. DEPARTMENT OF TRANSPORTATION FEDERAL HIGHWAY ADMINISTRATION NATIONAL HIGHWAY SAFETY BUREAU

General Motors Corporation General Motors Technical Center Warren, Michigan 48090

GRANT OF APPROVAL

In accordance with Paragraph S3. of Motor Vehicle Safety Standard No. 209, as amended, effective March 1, 1967, an interrupted thread bolt is an approved equivalent to the bolts specified in paragraph (f) of section 9.3 of Department of Commerce, National Bureau of Standards, Standards for Seat Belts for Use in Motor Vehicles (15 CFR 9) (31 F.R. 11528), provided it meets all other requirements of 15 CFR 9.

Sincerely,

William Haddon, Jr., M.D. Director

Issued in Washington, D. C. on July 22, 1968

ID: nht68-3.43

DATE: 07/25/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of July 2, 1968, to Mr. George C. Nield, Acting Director, Motor Vehicle Safety Performance Service, concerning requirements for combination clearance and side marker lamps.

Paragraph S3.3 of Motor Vehicle Safety Standard No. 108 permits the combination of two or more lamps providing the requirements for each are met. Table 1 in SAE Standard J592b gives the photometric requirements for both the clearance and side marker lamps, and Section J of the Standard permits their combination providing the combination complies with both clearance and side marker minimum candlepower requirements. Section J also defines the H-V axis of the combination as parallel with the longitudinal axis of the vehicle when checking clearance lamp test points, and normal to this vehicle axis when checking side marker test points.

Your table of minimum candlepower requirements for the Type 2 combination lamp meets J592b and therefore Standard No. 108 providing you define the H-V axis as that of the side marker lamp. The requirements for the Type 1 combination as specified in your table will not meet J592b or Standard No. 108 unless you change H-10, -20, -30, -45, -60, -80 and -90, both 1, and R to H-15, -25, -35, -45, -55, -65, -75 and -90, both L and R, and define the H-V axis as a line through the center of the lamp at a 45 degree angle to the longitudinal axis of the vehicle.

Your mounting instructions are considerably more restrictive than those implied in J592b and Standard No. 108. Actually, no additional mounting instructions are necessary, because any mounting which meets the minimum candlepower requirements of Table 1 in J592 and your table with the suggested revisions would meet the requirements of Standard No. 108.

ID: nht68-3.44

DATE: 07/26/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Toyota Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 27, 1968, in which you requested clarification of the term "optically combined" as applied to motor vehicle lights.

"Optically combined" in this context means that the same lens area is used for more than one function such as tail and stop lights or stop and turn signal lights or tail, stop and turn signal lights. The normal means used to accomplish this "optically combined" lamp has been to incorporate a single dual-filament bulb with a reflector and lens.

Since the design of your Toyota Crown combination stop, tail and turn signal lamp is such that a different part of the lamp area is used for the turn signal lamp, we do not interpret it to be optically combined with the tail and stop lamp.

The concurrence of the above interpretation with yours and that of the California Highway Patrol should not be construed to be an approval of your design. The results of recent research on lighting and signaling reviewed by this Bureau indicate that signal lights should be separated 4 1/2 to 5 inches minimum (centerline to centerline separation.) Although no dimensions are specified on your drawing it appears to be approximately full scale with a separation distance of 2 1/2 inches between the stop and turn signal lamps. The steady-burning stop lamp may therefore "wash out" or significantly reduce the effectiveness on the turn signal lamp. Federal Motor Vehicle Safety Standard No. 108 does not require a minimum separation distance between signal lights; however, upon completion of our present research contracts on rear lighting and signaling, we may consider such a requirement in the future.

ID: nht68-3.45

DATE: 07/29/68

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

TO: Lotus Cars Limited

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Bridwell has asked that I reply to your letters dated November 18 and July 3 which ask if Motor Vehicle Safety Standard No. 201 requires your company's "Elan Convertible" to have sun visors.

The National Highway Safety Bureau recognizes that the requirement for every passenger car to have two sun visors of energy-absorbing material with mountings that have no rigid material edge radius of less than 0.125 if statically contactable by a 6.5 inch diameter head form, may create a problem for manufacturers of certain types of vehicles. However, the requirement will, on balance, contribute to the safety of the general public.

Compliance with the requirement can and should be made in a manner so as to increase occupant protection.

LOTUS

JULY 3, 1968.

Lowell K. Bridwell, Federal Highway Administrator US Department of Transportation,

Federal Motor Vehicle Safety Standard Number 201: Sunvisors

We despatched a petition to you on 28th November 1967, requesting that we be permitted to substitute increased header padding for the sunvisors stipulated in F.M.V.S.S. 201 on our model: ELAN CONVERTIBLE.

On 19th January we sent further information to back up our earlier submission. We felt, for reasons given in our letter of 28th November 1967, that the spirit of F.M.V.S.S. 201 would be met, on this particular model, better, by increased padding, than by the addition of sunvisors.

We would be extremely grateful for some indication of your view of our petition.

B.A. Luff General Manager

ID: nht68-3.46

DATE: 07/31/68

FROM: AUTHOR UNAVAILABLE; J. R. O'Gorman; NHTSA

TO: Associazione Nazionale Fra Industrie Automobilistiche

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of June 3 to the National Highway Safety Bureau asking "whether the solution given in the enclosed drawing N. 591-1559 of Ferrari is in line with the requirements" of Federal motor vehicle safety standard No. 211.

This standard states that "wheel nuts, hub caps, and wheel discs for use on passenger cars . . . shall not incorporate winged projections". The Ferrari plan appears to incorporate such a projection, even though it is recessed. Accordingly the proposed solution by Ferrari does not meet the requirements of Federal standard No. 211.

ASSOCIAZIONE NAZIONALE FRA INDUSTRIE AUTOMOBILISTICHE

U.S. Department of Transportation Federal Highway Administration National Highway Safety Bureau

June 3 1968

Motor Vehicle Safety Standard n. 211

Reference is made to your letter of December 21st 1967 and we wish to thank you very much for the explanations about the standard N. 211.

Further we would appreciate it very much your letting us know whether the solution given in the enclosed drawing N. 591-1559 of Ferrari is in line with the requirements concerning "wheel nuts, hub caps and wheel discs".

Thanking you in advance, we remain

Faithfully Yours,

(Illegible Word) Direttore (Francesco Palazzi)

ID: nht68-3.47

DATE: 07/31/68

FROM: R.M. O'MAHONEY -- NHTSA; SIGNATURE BY MR. SCHMELTZER

TO: E.L. Mobley

TITLE: FMVSR INTERPRETATION

TEXT: Your letter of July 19 to Mr. Vinson of my staff presents your problem regarding two Volkswagens which have been conditionally admitted to the United States pursuant to 19 C.F.R. @ 12.80(b)(2)(iii) and (c). You state "we want to do whatever is necessary to secure an unconditional release of the cars."

As the Acting District Director of Customs informed you in his letter of July 18, @ 12.80(c) requires that the importer submit to the Bureau of Customs:

". . . a statement verified by the importer or(Illegible Word) that the vehicle . . . described in the declaration filed by the importer has been brought into conformity with applicable safety standards, and identifying the manufacturer, contractor, or other person who has brought such vehicle . . . into conformity with such standards and describing the nature and extent of the work performed."

Production of statements for the two Volkswagens containing the information required by @ 12.80(c) should allow a release of the vehicles and a termination of the bond. As Customs further informed you, these statements are forwarded to the Highway Administration for evaluation. This means that, if questions arise about the conformance work, you will be asked to provide us with the name and addresses of the owners of these vehicles.

I enclose a copy of the standards currently applicable to passenger cars. Two of the three items you mentioned are only a small portion of the overall requirements of the standards. With reference to these items you will note that "seat belts" are covered by three Federal standards: No. 208 requiring installation of upper torso and pelvic restraints, No. 209 specifying conformance of assemblies, and No. 210 specifying detailed requirements for anchorage points. The requirements of Paragraph S 3.1 of Standard No. 201 does not per se require a "padded dash"; conversely there is no assurance that the padding of a previously bare dash panel will bring a non-conforming vehicle into conformity. "Back-up lights" is a Federal requirement only for passenger cars manufactured on or after January 1, 1969.

I hope this answers your questions.