ID: nht69-1.9

DATE: 02/01/69 EST

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Hucck and Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 11, 1969, to Mr. David A. Fay, concerning your request for an interpretation on Standard No. 108.

Subsection (d) of Section 103 of the National Traffic and Motor Vehicle Safety Act of 1966 states "Whenever a Federal Motor vehicle safety standard established under this title is in effect, no State or political subdivision of a State shall have any authority either to establish, or to continue in effect with respect to any motor vehicle or item of motor vehicle equipment any safety standard applicable to the name aspect of performance of such vehicle or item of equipment which is not identical to the Federal standard . . ."

Since Federal Motor Vehicle Safety Standard No. 108 is now in effect, and permits red or amber rear turn signal lamps, the States cannot restrict these lamps to be red only.

ID: nht69-2.1

DATE: 03/28/69

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: The Hail Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of February 24, 1969, to the Office of Standards Preparation, concerning the proposed lighting equipment on your dump trailers.

The lamps and reflectors shown on your drawing 701b1907 dated February 20, 1969, appear to be in conformance with the requirements of Standard No. 108 with the following exceptions:

1. The required license plate lamp is not shown.

2. The minimum mounting height for reflectors is 15 inches.

3. With respect to maximum mounting zones for lamps and reflectors, the limiting dimensions of 16, 30, and 24 inches indicated on your drawing appear to be too liberal for a trailer with essentially square corners.

With reference to Notes 2 and 3 on your drawing, certain restrictions as specified in paragraph S3.3 of Standard No. 108 are applicable for combination lamps.

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 (Illegible Word) responsibility for certifying that the assembled vehicle meets the requirements of Standard No. 108.

ID: nht69-2.10

DATE: 06/04/69

FROM: AUTHOR UNAVAILABLE; Howard A. Heffron; NHTSA

TO: Concrete Plant Manufacturers Bureau

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 27, 1969, in which you submit information and photographs of mobile concrete plants, and ask whether they are "motor vehicles" within the meaning of the National Traffic and Motor Vehicle Safety Act, with a view to determining whether comments should be submitted to Docket 1-11, Rear Underride Protection.

The matter of whether pieces such as the subject concrete plants are motor vehicles within the meaning of section 102(3) of the Act, and also "trailers" within the meaning of the proposed underride standard, is presently under consideration by this Agency.

We encourage your organization and its members to submit to the docket any materials that they consider relevant to the subject.

ID: nht69-2.11

DATE: 02/07/69

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

TO: Messrs. Tanaka and Walders

TITLE: FMVSR INTERPRETATION

TEXT: In response to your letter of September 19, I attach an interpretation of the applicability of the National Traffic and Motor Vehicle Safety Act of 1966 to the Heads Mini-Trail and other similar vehicles ("mini-bikes"), which has been prepared for publication in the Federal Register.

This interpretation reiterates the opinion rendered American Honda Motor Co. Inc. on August 8 that mini-bikes are motor vehicles subject to the Act, must comply with applicable Federal Motor Vehicle Safety Standards, and must bear an appropriate certification of compliance.

Publication of this interpretations will insure that the Federal requirements will be understood equally by all manufacturers of mini-bikes, domestic and foreign.

ID: nht69-2.12

DATE: 01/28/69

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

TO: House of Representatives

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your January 8 letter concerning comments by Mr. Jackson Decker of the E. D. Ptnyre Company, which was addressed to the National Highway Safety Bureau on December 20, 1968. I regret that Miss Claybrook of my staff was unable to locate Mr. Decker's letter after the call from your office requesting a copy of my response to Mr. Decker.

Mr. Decker's letter consists of comments to the Federal Highway Administration Dockets on the pending proposed regulations under which information would be supplied by manufacturers to consumers about various safety performance characteristics of motor vehicles. My staff was unaware of this letter because it was addressed to the Docket and was sent by the mail room directly to the legal office which maintains all dockets. The dockets contain much of the source material which serves as the basis for final rule making on proposed standards and regulations.

In addition, letters such as this are seldom answered not only because it is not appropriate to debate the substance of pending rulemaking actions, but also because the purpose of such correspondence is to provide information to the Government in the development of rulemaking. It is not treated as routine correspondence with the agency. In addition, the volume of such comments frequently reaches such vast proportions that it would be virtually impossible to answer them. For example, in response to a recent Federal Highway Administration proposed regulation some 4,000 comments were submitted.

Mr. Decker, incidentally, does not indicate he expected a specific answer to his letter but, rather, in his last paragraph, asks that his views "be given serious consideration before proceeding with the issuance of part 275 of the Federal Motor Vehicle Safety Standards."

On December 30, 1968, the Federal Highway Administrator issued a notice extending for 60 days the time for filing comments on a number of the proposed regulations for consumer information. This notice also specified that the proposed regulations would not apply to vehicles produced in two or more stages. I am enclosing a copy of this notice with the appropriate section marked for your information.

I regret that we had to ask you to supply a copy of Mr. Decker's letter, but I trust that the above information resolves the issues he raised.

ID: nht69-2.13

DATE: 07/17/69

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: U.S. Suzuki Motor Corporation

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of July 8, 1969, in which you ask whether a form that you enclose satisfies the requirements of Consumer Information section S75.106, Acceleration and Pusint Ability.

Your placement of the words "not capable" in the figure conforms to the requirements of the section. It is not necessary to include the words in the diagram also. In reference to your question concerning line spacing: In presenting the information "in essentially the form illustrated in Figure 1" (section 375.106(c)), it is not necessary that the manufacturer's presentation be an exact copy of the figure in respect to type face, line spacing, and so forth. The presentation in your enclosure would be adequate in those respects.

In answer to your question about teduction of the figure. The regulation did not specify a type size, but the information is required to be exactly legible. The size in which the figure appeared in the Federal Register would appear to approximate the minimum in this regard.

Finally, I should note that the "Description of Vehicles to which this Table Applies" is required by section 375.106(c)(1) to be "in the(Illegible Word) by which they are described to the public by the manufacturer". This would normally be in terms of the model designation,(Illegible Word) equipment, or other common description, not the regulatory type of "motor-driven(Illegible Word) as you indicate (unless, of course, this is your company(Illegible Word) designation of this type).

I am pleased to be of assistance.

ID: nht69-2.14

DATE: 07/18/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Ward School Bus Manufacturing Incorporated

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 28, 1969, in which you request approval of an alternative to the label locations specified in Section 367.4(c) of the Certification Regulations that will be effective as to vehicles manufactured on or after September 1, 1969.

The label location, on the panel ovay the driver's window, as shown in your enclosed photograph is acceptable.

Your cooporation is appreciated.

ID: nht69-2.15

DATE: 12/16/69

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

TO: Fiat Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 20, 1969, to Mr. Francis Armstrong, concerning your proposed windshield wiper system.

We assume your new windshield wiping system will meet the requirements of S4.1.1.3 of Motor Vehicle Safety Standard No. 104, based upon your description of its operation. Note that S4.1.1.3 states "the highest and one lower frequency" -- the fact that you have even a lower frequency, to cycles per minute, does not conflict with this requirement. The main thing is you do offer a frequency differential of at least 15 cycles per minute measured from a low frequency of at least 20 cycles per minute.

With respect to the requirements of Standard No. 104, I must point out that this Bureau does not issue approvals of windshield wiper systems 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.

ID: nht69-2.16

DATE: 09/30/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Honorable John A. Blatnik

COPYEE: FHWA LEGAL 26-30; CONG. LIA.; MR. HITCKCOCK; OFF ACCIDENT AVOIDANCE, MVSPS

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of September 9, 1969, in reference to the motor vehicle safety items discussed in Mr. Frank L. Van Alstine's letter of July 2, 1969, to Mr. H. M. Jacklin, Jr., Acting Director of our Motor Vehicle Safety Performance Service. I am enclosing a copy of our reply to Mr. Van Alstine's letter.

As we indicated in our reply, Federal Motor Vehicle Safety Standard No. 107, "Reflecting Surfaces - Passenger Cars, Multipurpose Passenger Vehicles, Trucks and Buses," affects only original installation; it does not apply to replacement windshield wiper arms, such as those referred to in Mr. Van Alstine's letter.

Federal Standard No. 210 specifies strength and general location requirements for lap and shoulder belt anchorages in passenger cars. Even though vehicles such as Mr. Van Alstine's 1969 Plymouth Valiant must meet this standard, some degree of discomfort may be experienced with certain(Illegible Word) positions and/or certain occupant sizes. As our reply stated, we are not aware of any significant injuries resulting from the present belt anchorage locations.

Based on the information supplied by Mr. Van Alstine, it does not appear that the two situations described represent violations of Federal Motor Vehicle Safety Standards.

It is most helpful to our efforts to improve highway safety when concerned citizens such as Mr. Van Alstine take the time to bring their safety experiences to our attention and that of their elected representatives.

Enclosure

ID: nht69-2.17

DATE: 10/16/69

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

TO: E.T.R.T.O.

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your recent submittal of data to the National Highway Safety Bureau, concerning the addition of the belted-bias tire construction as a new category within Table I of Appendix A of Federal Motor Vehicle Safety Standard No. 109. Your submittal was not accompanies by a cover letter.

The National Highway Safety Bureau realizes that this construction of motor vehicle passenger car tires warrants consideration within Standard No. 109. We do not believe, however, that the introduction of additional tables to the standard is needed to cover belted-bias tires. The tables within the standard are becoming voluminous and the variety of size designations are confusing to the consumer.

During the recent ISO/TC 31 meetings in Rome, Mr. W. W. Jordan, Chief of the Tire Branch discussed briefly with members of your organization our philosophy on the standardization of the tire size designations and load inflation schedules. We have been working closely with the American Tire and Rim Association in further developing the alphanumerical system for tire size designations. We believe we are approaching a workable, standardized solution to the problem. In this light, we understand that members of E.T.R.T.O. visit the United States at regular intervals and we would like to extend an invitation to your organization to have a representative meet with us to review this matter and your petition in detail.

The National Highway Safety Bureau, at the present time, does not plan to differentiate belted-bias type tire construction from other constructions, consequently, we will delay action on your petition until we have the opportunity to discuss it with your representative.