ID: nht68-4.9

DATE: 09/03/68

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

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 19, 1968.

You state that you do not find any provision which would permit temporary mounting of lighting devices on mobile homes and ask that we inform you what provision in Public Law 89-563 or the Federal motor vehicle safety standards permits installation of temporary devices. There is no provision in P.L. 89-563 or the standards which either permits or prohibits the temporary mounting of devices. The National Highway Safety Bureau has taken the position that, insofar as mobile homes are concerned, temporary lighting devices may be used if they meet the requirements of Standard No. 108.

With respect to your request for a copy of Docket No. 26, I enclosed a copy of the notice of request for comments recently issued and published in the Federal Register. This docket was opened several months ago and contains several hundred pages of documents. The docket is scheduled to remain open, for the receipt of additional comments, until September 10, 1968. Our rules require us to charge 50 cents per page, payable in advance for copies of docket material. should you want a copy of the complete docket, please let us know and we will advise you, after September 10, of the fee for this service.

Thank you for your continuing interest in motor vehicle safety.

ID: nht69-1.1

DATE: 01/27/69

FROM: AUTHOR UNAVAILABLE; H. M. Jacklin, Jr.; NHTSA

TO: American Honda Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of November 18, 1968, and your subsequent telephone conversation of December 4, 1968, with a member of the Tire Branch, requesting the addition to Federal Motor Vehicle Safety Standard No. 110 of the 3.50B alternative rim size for use with the 145-10 redial tire size designation.

On the basis of the data submitted indicating compliance with the requirements of Federal Motor Vehicle Safety Standards No. 109 and No. 110 and other information submitted in accordance with the procedural guidelines set forth in the Federal Register, Volume 33, No. 195, page 14969, dated October 5, 1968, the 3.503 alternative rim size for the 145-10 tire size designation will be listed within Table I of Appendix A to Standard No. 110.

The addition of this alternative rim size to the table in accomplished through an abbreviated procedure consisting of the publication in the Federal Register of the petitioned alternative rim size. If no comments are received, the amendment becomes effective 30 days after the date of publication. If comments objecting to amendments are received, additional rule making pursuant to Part 216 of the Procedural Rules for Motor Vehicle Safety Standards will be considered.

ID: nht69-1.10

DATE: 12/28/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Asplundh Chipper Company

TITLE: FMVSS INTERPRETATION

ID: nht69-1.11

DATE: 01/27/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: THE NEW YORK AIR BRAKE COMPANY

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 30, 1968, regarding location of reflex reflectors and side marker income relative to trailer envelope dimensions. From your subsequent phone conversation on October 18, 1968, with Mr. Zolley of our office, I understodd that you are concerned about the possible obstruction of visibility of those devices by the trailer body.

Federal Motor Vehicle Safety Standard No. 168 specifies that side marker lamps must be in accordance with SAS Standard(Illegible Words) to end reflect reflectors in accordance with SAS Standard JS94c. These standards specify photo-metric requirements for side marker lamps at angle 45o to the right and left of the lamp vertical axis and for reflex reflectors at angles 20o to the right and left of the reflector vertical axis.

Although Standard No. 108 does not specify that these devices provide the test photometrics when installed on the vehicle, it should be noted that Tables II and IV of the standard do require that the devices be located "on the side" of the car vehicle. Therefore, devices that are recessed to an extent that would impair their effectiveness would not(Illegible Words) the requirements of Standard No.(Illegible Words).

Section S3.1.1.S of Federal Motor Vehicle Safety Standard No. 108, as amended effective January 1, 1989, specifics that for trailers less than 89 inches overall wide and less than 30 feet overall length, the photometric requirements specified in SAE J502, why be(Illegible Words) or inboard less points at a distance of 15 feet from the vehicle and on a vertical plane that is perpendicular to the longitudinal axis of the vehicle and located midway between the front and rear side marker lamps. For vehicles less than 20 feet in overall length, this establishes a point less than 45o on one side of the side marker lamps. This is the only sets of relief from the requirements of SAS J592b.

I trust this information will be helpful to you. If you should have my further questions concerning safety standards, I would be most happy to discuss them with you.

Sincerely,

September 30, 1968

Office of Motor Vehicle Performance Service National Highway Safety Bureau

Attention: Bruce A. Kelley --

Room 8213A Subject: Federal Motor Vehicle Safety

Standards - May, 1968

Dear Sir

In reply to my letter concerning an interpretation of the Federal Motor Vehicle Safety Standards, Mr. John A. Hanson, Regional Federal Highway Administrator suggested that I contact your office.

The point that I would appreciate clarification on is as follows:

1. Table IV, under Columns 2 and 4, for trailers less than 80" overall width clearly defines the location of the Reflex Reflectors and Side Marker Lamps as to vertical height above the road surface and that they appear on a horizontal level plane.

2. The question arises in determining the location of said lights in relation to the trailer envelope dimensions.

Mr. Kelley suggested that SAE Standards J594c and 592b are more specific and may answer my question.

Any comment you may have to clarify this situation would be greatly appreciated.

Very truly yours,

KINNEY VACUUM DIVISION,

The New York Air Brake Company --

D. F. Rusconi --

Project Engineer

ID: nht69-1.12

DATE: 03/16/69

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

TO: Corporation Commission of Oaklahoma

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 15, 1969, in which you inquire about Federal regulation of brake fluid.

Brake fluid performance is regulated under the National Traffic and Motor Vehicle Safety Act by Federal Motor Vehicle Safety Standard No. 116. Copies of the Act and the current standards are enclosed.

Under the Vehicle Safety/Act, manufacturers of motor vehicles and equipment (including brake fluid) that are covered by standards are fully responsible for ensuring that all of their products conform to the standards. The National Highway Safety Bureau conducts conformity tests of vehicles and equipment, either through its own personnel and facilities or under contract with other public or private testing organizations, but these are for enforcement purposes only.

The Bureau is conducting a continuing series of tests on brake fluid, that has included samples from a majority of the major manufacturers, and will include the remainder is the near future. If you need more detailed information concerning this testing program, I suggest that you contact Mr. Francis Armstrong, Director, Office of Performance Analysis, National Highway Safety Bureau, Federal Highway Administration, Washington, D.C. 20591.

In answer to your Final question, Standard No. 116 applies to all brake fluid manufactured or sold in the United States, and is not Limited to that sold by automobile manufacturers or distributors.

ID: nht69-1.13

DATE: 02/26/69

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Mr. T. Sudderth

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of January 22, 1969, concerning safety glazing in your motor home.

We do not know what is meant by the description "Windows-Double Density - glass - set."

Glasing materials in a motor home must be in accordance with Federal Standard No. 205. Glass in the windshield must be AS1, not AS2 as your letter states. The windows on either side of the driver's compartment may be AS2, and AS2 may be used in the balance of the windows when needed for driver visibility or AS3 may be used in the balance of the windows when not needed for driver visibility.

The markings of glazing materials cited in your letter indicate that the materials used in your motor home are in accordance with Federal Standard No. 205, with the exception that you state that AS2 is marked on the windshield.

Please advise me if AS1 is not installed in the windshield of your motor home.

Sincerely,

January 22, 1969.

The National Highway Safety Bureau Department of Transportation

Gentlemen:

A few months ago I bought a new Dodge Motor Home (Travco) and it was ordered out from production with a number of option equipment items. One was identified as -

"Windows - Double Density - glass - Set

As of this date I am not too sure that this was included in the assembly and I have no way to identify the item and judge if I have paid a fair price.

Will you please assist me - The glass in the windshield and two side of driver compartment are marked as

Guardian Safety Glass As 2-67

Tempalite Solid Tint GG M 66

The glasses on the side walls are market's as follows - TWI-Lite Safety-Lite AS 3 M 21

The rear window is marked -

AT Asorbing Safety Glass

Solid Tempered M " 286

I am unable to see any identification on the two small glasses in the entrance doow assembly.

Your prompt comments will be appreciated.

Yours very truly

T. Sudderth

PO Box 757 - Laurens 29360

ID: nht69-1.14

DATE: 03/03/69

FROM: DEAN F. NIEDERNHOFER FOR CLUE D. FERGUSON -- NHTSA

TO: Splintex Belge

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of January 16, 1969, and February 3, 1969, concerning safety glazing in motor vehicles.

Referring to your request to use marking as described in the second paragraph of your letter, I believe you have confused the two-digit manufacturer's code number specified in Docket 23 with the model number specified in Section 6 of USASI Standard 226.1-1965.

Federal Motor Vehicle Safety Standard No. 205, Glazing Materials incorporates USASI Standard 226.1-1955 by reference. Marking of the glazing materials must comply with Section 6, Marking of Safety Glazing Materials. Included in this marking is the requirement for a model number related to a detailed description of a specific glazing material. The example,(Illegible Word), is a model number assigned by you in accordance with foot note #24 at the bottom of page 29 of(Illegible Word) Standard 226.1-1986.

The two-digit manufacturer's code number that follows the "LOT" symbol is used, at the option of the glass manufacturer, as an alternative method of complying with that certification requirements specified in Standard No. 205. This "DOT" symbol followed by a two-digit manufacturer's code number should be added to the marking you should in your letter.

Following are my answers to the questions asked in your letters

Question (1) Must we add the symbol "DOT" somewhere in the above marking"?

Question (2) Can you agree with the proposed marking without taking into consideration that our clear laminated M.I.B glass has been approved, or are was compelled to submit our coloured glass to a laboratory and ask for a new approval?

Question (3) If you extend our AS.1-M.11 approval to the said AS3-26 type, as we hope, is this extension valid for all the American States, including those affiliated to the A.A.M.V.A.? If so, do you advise all the States of this extension or shall we do it?

Answer to Question (1) Only if you wish to avail yourself of the alternative method of certification specified in Standard No. 205 Amendment (33 P2 14152).

Answer to Questions (2) and (3) The approval of glazing materials to which you refer is a State approval independent of the U.S. Federal government. Those questions should be directed to the individual States or A.A.N.V.A. for answer.

I am taking the liberty of assigning a two-digit manufacturer's code number to your company on the assumption that you wish to avail yourself of the alternative method of certification.

Splintex Balge S.A. is assigned number 24. This number should appear after the characters "DOT" when you certify your glazing materials by the alternative means published in the Federal Register, Vol. 33, No. 183 - Thursday, September 19, 1968, (enclosed).

I am sorry for the delay in answering your initial letter.

Sincerely,

Enclosure

SPLINTEX BELGE

Societe Anonyme

January 16, 1969

Director of the National Highway Safety Bureau.

FEDERAL HIGHWAY ADMINISTRATION

Department of Transportation.

Gentlemen,

We are manufacturers of safety glass, namely for the automobile industry, and have had several safety glass types approved, the last ones being:

1/4" mm thick H.I. laminated: Splintex Gilly HI/AS1-M11.

7/32" mm thick H.I. laminated: Splintex Gilly HI/AS1-M12.

We supply a constructor of busses with laminated glass pieces placed along edges of the roof, as shown on the attached picture. This laminated glass is 1/4" thick and is composed of a H.I. interlayer but also two coloured ones with finally just 2 light transmittance. We have in hand information you sent to our customer (Title 23 - Chapter II/Dockets n degree 23 and 29 - Notice(Illegible Word) May we beg you, on this ground, if we may use, for the described glass, an AS3-28 marking with a two digit code number, for example M15; if so, our marking would be

SPLINTEX Height in accordance with U.S.A.S.I.

GILLY Height in accordance with U.S.A.S.I.

AS.3-26-M.15 requirements.

LAMINATED

Our other questions are:

1) Must we add the symbol "DOT" somewhere in the above marking?

2) Can you agree with the proposed marking without more, taking in consideration that our clear laminated H.I. 1/4" glass has been approved, or are we compelled to submit our coloured glass to a laboratory and ask for a new approval?

3) If you extend our AS.1-M.11 approval to the said AS3-26 type, as we hope, is this extension valid for all the American States including those affiliated to the A.A.M.V.A.? If so, do you advise all the States of this extension or shall we do it?

As this is a very important and urgent question, we beg you for a prompt air-mail answer and hope you will give us full details about the other steps we should have to undertake.

Awaiting your kind news and thanking you beforehand for all your help, we remain, Gentlemen,

Very truly yours.

LINTEX BELGE

Societe Anonyme

Director of the National Highway Safety Bureau,

FEDERAL HIGHWAY ADMINISTRATION

Department of Transportation.

Gentlemen,

We beg to remind you our letter dated 16th. January concerning the marks we should put on safety glasses for roof of busses and an eventual approval of this glass material.

As we have an order from a customer, bus constructor who exports vehicles to the U.S.A., it is of the utmost urgency for us to be able to answer our client's questions and requirements.

We apologize for our insistance but hope you will understand our trouble and answer us promptly.

We thank you again and remain, Gentlemen,

Very truly yours.

ID: nht69-1.15

DATE: 03/04/69

FROM: DEAN F. NIEDERNHOFER FOR CLUE D. FERGUSON -- NHTSA

TO: P.O.B. Manufacturing Company

COPYEE: R. O'MAHONEY

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 21, 1960, concerning glazing materials.

I am enclosing a copy of Federal Motor Vehicle Safety Standard No. 205 and, since you manufacture and distribute sealing compounds, a copy of Federal Motor Vehicle Safety Standard No. 212.

ASA Standard Z26.1-1966, incorporated by reference in Standard No. 205, can be obtained at a cost of $ 3.50 from the United States of America Standards Institute, 10 East 40th Street: New York 10016.

SAR Recommended Practice J673A, August 1967, incorporated by reference in Standard No. 205, can be obtained from the Society of Automotive Engineers, Inc., Two Pennsylvania Plaza, New York, New York, 10001.

We are in the process of changing paragraph S.3.2 of Standard No. 205. You may want to keep up with future amendments to these and other standards, therefore, I am enclosing a copy of form HS-13, Mailing List Questionnaire and subscription information for the Federal Register. Either or both of these will enable you to receive information in your areas of interest in all future motor vehicle safety rulemaking actions.

Sincerely,

February 21, 1969

Federal Highway Administration

Dept. of Transportation

Attention: Standards Dept.

Gentlemen:

We are manufacturers and distributors of sealing and glazing compounds for the transportation industry.

In view of this we would appreciate receiving a copy of Standard 205 (glazing materials) or information as to where and how we may obtain some.

Thank you for your courtesies and cooperation.

Sincerely, Jack Flyn--

P.O.B. Manufacturing Company

ID: nht69-1.16

DATE: 05/21/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Amorada Glass Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 25, 1969, forwarded to me by the Federal Trade Commission.

A windshield classified as a second by the manufacturer must nevertheless meet the requirements of Motor Vehicle Safety Standard No. 205 (Glazing materials).

If you have any information indicating that windshields marked seconds do not comply with the standard I would appreciate your sending me such information with the names of the manufacturers and dealers selling the windshields so that the Bureau can further investigate the matter.

Sincerely,

National Highway Safety Bureau, Federal Highway Administration, Department of Transportation,

Attention: Robert Brenner,

Acting Administrator.

Gentlemen:

The enclosed copy of a letter, dated April 22, 1969, from Mr. Richard R. Miller, President, Amerada Glass Company, Elk Grove Village, Illinois, referring to the installation of unsafe windshield glass is forwarded for appropriate consideration by your Bureau under applicable motor vehicle safety standards.

Mr. Miller has been advised of this referral.

With best wishes, I am

Sincerely yours,

Hugh B. Helm --

Chief, Division of Advisory Opinions,

Bureau of Industry Guidance,

Federal Trade Commission

Enclosure

April 22, 1969

Federal Trade Commission

Gentlemen:

Having received a copy of Steven John Fellman's letter of April 7, 1969, directed to your offices, regarding the installation of "seconds" windshields by members of the National Glass Dealers Association, I wish to advise the availability of further information on this matter for your immediate consideration.

"B" line insurance firms in many parts of the country are well aware of the availability of "seconds" and prepare their purchase orders accordingly. It is a known industry fact that the three largest independent manufacturers of curved windshields allow sales of "seconds" windshields only to their largest and preferred customers, those giving them the major share of the replacement business in their area.

This practice definitely discriminates against the small, legitimate buyer unable to buy the lower cost "second" from the independent manufacturer, distributing only through his selected distributor.

I feel very strongly that the Department of Transportation should be advised that the installation of rejects deceives the public, and provides unsafe windshields due to distortion, double vision and imperfections in the glass which would normally be considered rejects and destroyed by those original equipment windshield manufacturers who do not sell windshields considered to be unsuitable for original equipment or replacement installation sales.

A thorough review of practices indicated above should be made without delay. Your reply will be awaited with genuine interest.

Very truly yours,

AMERADA GLASS COMPANY --

Richard R. Miller, President

ID: nht69-1.17

DATE: 04/18/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Auto Test Division, Consumers Union of U.S., Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letters of March 17, 1969, and March 26, 1969, pertaining to certain child restraint devices and whether or not they are covered by Federal Motor Vehicle Safety Standard No. 209. Your specific questions and our corresponding answers are as follows:

Question No. 1: Which of the commercially available devices must comply with the Type 3 requirements of Standard No. 209, which must not?

Answer No. 1: Child restraint devices must comply with the Type 3 requirements of Standard No. 209 if, by visual examination of the design and the advertising thereof, they are sold as being a Type 3 seat belt assembly. By definition, a Type 3 seat belt assembly is a combination pelvic and upper torso restraint for persons weighing not more than 50 pounds or 23 kilograms and capable of sitting upright by themselves, that is children in the approximate age range of 8 months to 6 years.

Question No. 2: How does one tell whether a given device is covered or not?

Answer No. 2: If the manifested purpose of any belt, strap, webbing or similar device is to secure a person in a motor vehicle in order to mitigate the results of any accident, then the belt has to comply with the applicable portions of Standard No. 209. There is a distinct difference between a "child seating system" and a seat belt used to restrain a child. "Child seating system" means an item of motor vehicle equipment for seating and restraining a child being transported in a passenger car. This child seating system is not covered by Standard No. 209, but will be covered by a future standard No. 209, but will be covered by a future standard.

Question No. 3: Is the criterion (that a given device must comply) whether or not the maker claims that the device offers protection against impact injury?

Answer No. 3: Whether or not the maker of a child restraining belt claims that the device offers protection against impact injury is not the criterion upon which the compliance interpretation is based. (Reference Answer No. 2.)

Further investigation is needed before we can provide an answer to your question pertaining to which specific manufacturers of the belts that you tested are in violation.

To assist you in your project on child restraint devices, we are enclosing the latest copy of Federal Motor Vehicle Safety Standard No. 209 and the copy of the Notice of Proposed Rule Making on child restraint systems.

We trust that we have been of assistance to you.

Sincerely,

Enclosures: F-38 and 49 C.F.R. Part 371, Docket No. 2-15, Notice No. 2

March 17, 1969

Frank Armstrong Office of Performance Analysis National Highway Safety Bureau U.S. Department of Transportation

Dear Frank:

Consumers Union has under way a project on child restraint devices. As I told you briefly on the phone a couple of weeks ago, the question has come up, which of the commercially available devices must comply with the Type 3 requirements of Standard 209, which must not? How does one tell whether a given device is covered or not? Is the criterion whether or not the maker claims that the device offers protection against impact injury? I talked to Joe O'Gorman about this problem at some length, but he was not able to provide an answer.

I hope that you, or someone in your office, can throw some light on this question for us.

Sincerely yours,

CONSUMERS UNION OF U.S. INC.

Auto Test Division--

Joseph N. Ulman Jr.

Automotive Safety Engineer

cc: Morris Kaplan

March 26, 1969

Frank Armstrong Office of Performance Analysis National Highway Safety Bureau U.S. Department of Transportation

Dear Frank:

On March 21, I received a phone call from Joe O'Gorman in response to my letter of March 17 to you requesting advice on how to tell whether any given child restraint device is governed by the Type 3 requirements in Standard 209. I believe Joe now has a clear understanding of our question, and he is trying to obtain an answer.

In the meantime, we would like to amplify for you the information on child restraint devices that appeared on pages 169 and 170 of our April issue. The 15 devices listed as failing to meet the 2000-pound load requirement were sold with safety claims as follows: DEVICES WITHDISCLAIMER:

Penney's No. 0858

Sears No. 1507

Tommee Tippee WP 207

Tommee Tippee WP 205 SP

DEVICES MAKING NO SPECIFIC SAFETY CLAIM:

Auto Babe

Ward's No. 6053 "Tiny World Safety Belt"

Wizard No. 5480 "All Purpose Safety Strap. . ."

DEVICES MAKING SOME CLAIMS:

Hollywood 495 C

497 C "1000-lb. test." "Secures against sudden stops." ". . .allows for. . .with perfect safety."

Kiddie King KKB-1 "Child's Auto Safety Belt." "Protects your child against sudden stops."

Kiddie King KKB-2 "Child's Safety Harness and Belt." "Protection. . .in Autos. . ." ". . .Maximum of safety."

Safety Guard B 12 "Auto Safety Strap." "For protection, comfort, safety." "Will protect children on short stops."

Safety Guard B 112 "Child's Auto Safety Strap." "Exceeds SAE Safety Specifications." "Protection against short stop danger."

Safety Guard B 1212 "Safety Harness Strap." "Protect your child from short stops." ". . .exceeds S.A.E. Safety Specifications."

Toidey SC-3 "Auto Harness." "Keeps little explorers safe." ". . .webbing withstands over 2000 pounds pull."

Our question: Which of these devices are Type 3 restraints; and thus which of them are, according to our static tests, in violation of Standard 209?

We shall appreciate any information you can supply us.

Sincerely yours,

CONSUMERS UNION OF U.S. INC.

Auto Test Division-- Joseph N. Ulman Jr.

Automotive Safety Engineer

cc. Morris Kaplan

David Tallman