ID: nht70-2.28

DATE: 09/29/70

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Aractho Motors Distributors

TITLE: FMVSR INTERPRETATION

TEXT: I wish to express my apology for the fact that you have not received a response to your letter of August(Illegible Words) of our correspondence records does not indicate that it ever reached my office.

From information available on the Bureau Mini-bike, it would appear that it would fall within the scope of the Mini-Bike interpretation,(Illegible Words)(Illegible Word) -- October 3, 1969), a copy of which is enclosed for your information and guidance.

Each manufacturer must decide whether his vehicles are manufactured primarily for off-the-road use. This is usually determined by the manufacturer after his review of the aforementioned interpretation.

Your attention is directed to the fourth paragraph of that document which states in part, "Thus, if a vehicle is operationally capable of being used on the public thoroughfares, and in fact, a substantial proportion of the consuming public actually view it that way, it is a 'motor vehicle' without regard to the manufacturer's intent, however(Illegible Word)."

At this time, the Bureau would have no reason to challenge your off-the-road(Illegible Word) only" classification.(Illegible Word) on the other hand, we find that the vehicles are in fact being used for other than the intended purpose, your classification could be questioned by the Bureau.

Thank you for your letter and I trust this will answer your question.

ID: nht70-2.29

DATE: 10/07/70

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Automobili Lamborghini

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 23 informing us of Lamborghini's continued progress towards compliance with Federal motor vehicle safety standards.

I want to remind you that Standard No. 211 precludes the use of wheel nuts, wheel discs, and hub caps that incorporate winged projections, such as the one shown in the(Illegible Word) photograph which I enclose. We have seen several(Illegible Word) manufactured in 1969 with wheels identical to this one, and were informed in one instance that the winged projections had been shipped from Italy with the car. Such a shipment violates the spirit, if not the letter, of Standard No. 211.

There is no charge for the "Program Plan for Motor Vehicle Safety Standards", enclosed at your request.

ID: nht70-2.3

DATE: 04/20/70

FROM: AUTHOR UNAVAILABLE; Douglas W. Toms; NHTSA

TO: Ford Motor Company

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of March 19, 1970, with which you submitted for our examination a sample format for consumer information produced by a computer.

The sample that you submitted does deviate from the requirements of the consumer information regulations in that the required warnings and explanations are placed on a sheet that is separate from the numerical data. The regulations generally require that the information be presented in the form illustrated by the published figures, with the explanatory matter in proximity to the numerical data. I believe that computer printing is flexible enough to allow you to accomplish this.

ID: nht70-2.30

DATE: 10/19/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: By letter of October 1, 1970, you asked for the opinion of this office as to whether the State of California, in specifying approval procedures for seat belts to be sold within the State, must require seat belt manufacturers to produce data showing that they have performed the exact tests specified in Federal Motor Vehicle Safety Standard No. 209.

The Federal motor vehicle safety standards are not instructions for, or descriptions of, manufacturer tests, nor do they specify types and numbers of tests. They are statements of requirements that each vehicle or item of equipment must meet when tested by the Bureau. Manufacturers are required to exercise due care to ensure that their vehicles will meet the standards if tested by the Bureau, and they are at their own discretion in devising an appropriate testing program for that purpose.

If a seat belt manufacturer presents data of tests conducted on webbing taken from rolls, rather than from individual assemblies, and if you are satisfied that such data demonstrates that the webbing would comply with Standard No. 209 when tested according to the procedures of that standard, you may, in our opinion, accept such data for purposes of State approval.

I trust that your question has been adequately answered. If you need further clarification we will be glad to provide it.

ID: nht70-2.31

DATE: 10/23/70

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: American Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 12, 1976, to Mr. Charles A. Baker of this office in which you requested an interpretation of the phrase "affective projected illuminated area."

Class A turn signal lamps are required by Section S3.1 of Federal Motor Vehicle Safety Standard No. 108, which references SAE Standard J588d in Tables I and III for there lamps. The requirements for the illuminated area of a turn signal lamp are specified in J588d as follows:

"The effective projected illuminated area measured on a plane at right angles to the side of the lamp must not be less than 12 sq. in. for Class A and 36 sq/ in. for Class B."

In the 45 degree visibility requirements, this standard further states "To be considered Visible, the lamp must provide an instructed projected illuminated area of outer less surface, excluding reflex, . . .".

Our interpretation of affective projected illuminated area follows; The affective projected illuminated area is that area of the lent measured on a plane as that angles to the axis of the lamp, excluding reflex reflector, noted is not obstructed by an opaque object such as a mounting(Illegible Words)

The above interpretation allows the area of rings or other configurations ((Illegible Word) portions) applied in the lane to be considered part of the total effective from, even if this area does not contribute significantly to the total light output.

ID: nht70-2.32

DATE: 10/29/70

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: Leaseway Transportation Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 14, 1970, to Mr. Douglas W. Toms, Director, National Highway Safety Bureau requesting an interpretation on the "marker blink switch" relative to Federal Motor Vehicle Safety Standard No. 108.

The use of this switch does not violate the requirements of paragraph S3.5 of Standard No. 108, and is permitted by paragraph S3.1.2.

Flashing lights for signaling purposes in a highly controversial subject with many proponents for, and many against, their use. This aspect is being clarified in a soon-to-be-published amendment to Standard No. 108, and will be addressed further in a forthcoming notice of proposed rule making on the same standard.

ID: nht70-2.33

DATE: 10/29/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Juno Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of August 26, 1970, concerning the compliance of your cut-van motor home with Federal Motor Vehicle Safety Standard No. 206 - Door Locks and Door Retention Components, has been forwarded to this office for reply.

You state that the door in the camper body is located so that no portion of a manikin in any designated seating position would project into the door opening in the side view. If, as it appears, you are correct, the door locks and door retention components on that door are not required to comply with Standard No. 206.

You also state that you believe that the doors on the cab comply with Standard No. 206. As a manufacturer of multipurpose passenger vehicles, you are responsible under the National Traffic and Motor Vehicle Safety Act of 1966 for the compliance of the cab doors with Standard No. 206. Although the van may have been manufactured as a truck, it must, when subsequently converted to a multipurpose passenger vehicle, comply with all multipurpose passenger vehicle standards in effect on the date of manufacturer of your motor home. Therefore, you should(Illegible Word) either from the van manufacturer or by your own tests, that the cab doors comply with Standard No. 206.

Please let us know if we can be of further assistance.

ID: nht70-2.34

DATE: 11/03/70

FROM: R. A. DIAZ -- NHTSA; SIGNATURE BY GEORGE C. NIELD

TO: B. Borisoff

TITLE: FMVSR INTERPRETATION

TEXT: Reference is made to your letter of October 14, 1970 to Secretary Volpe regarding our Consumer Information publication.

Concerning your comments on stopping distance, the wording used on page 4 is the exact wording of this regulation. The category "Stopping distance in feet with emergency brakes (partial service brake system)" is a generalization of the regulatory wording meant to convey the sense of this requirement to a consumer who may have no engineering background. The paragraph on page 193 paraphrases the regulatory wording. The title "Partial Failure on One System" is, again, meant to convey the meaning to an otherwise uninformed consumer. I trust this clarifies the situation for you.

The reason many motorcycles are not listed is the fact that the data was not received in time to be included in the book. I am enclosing copies of the data available for U.S. made motorcycles as you requested.

Volume 2, covering the 1971 makes and models will be available approximately November 15, 1970 and can be obtained from the Government Printing Office at a cost of $ 2.00. In addition two (2) new Consumer Aid publications entitled "BRAKES - A Comparison of Braking Performance for 1971 Passenger Cars" and "TIRES - A Comparison of Tire Reserve Load for 1971 Passenger Cars" will also be available at a cost of $ .40 each.

Many thanks for your kind words and your interest in our motor vehicle safety program.

ID: nht70-2.35

DATE: 11/12/70

FROM: AUTHOR UNAVAILABLE; R. H. Compton; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of October 21, 1970, to the National Highway Safety Bureau, concerning environmental tests for sealed beam headlamps used on motocycles and motor-driven cycles.

Federal Motor Vehicle Safety Standard No. 108 requires that motorcycle and motor-driven cycle headlamps conform to SAE Standard J584. This SAE Standard, in turn, permits optional use of "one 7-in. sealed beam unit or one 5 3/4-in. Type 1 and one 5 3/4-in. Type 2 sealed beau units meeting the requirements of SAE J579".

Therefore, unsealed motorcycle and motor-driven cycle headlamps must conform to the vibration, moisture, dust and corrosion test requirements of SAE J584. Glass sealed beau motocycle and motor-driven cycle headlamps, which are designed specifically to conform to the requirements of SAE J584 (including photometric values), and which are not intended for use on other vehicles, must conform to the vibration, moisture and corrosion test requirement of SAE J584. Such test requirements would not, however, be applicable if a manufacturer elected to provide optional headlamps meeting the requirements of SAE J579a.

ID: nht70-2.36

DATE: 11/24/70

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Mercedes-Benz of North America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 29, 1970, concerning the application of Federal Motor Vehicle Safety Standard No. 206 to the door locks and door retention components on the C-111's gull-wing doors. I appreciate also the design drawings you submitted earlier this month.

As Standard 206 presently exists, the door locks and door retention components on the C-111 doors must conform to it. As Rocks and retention components on passenger car side doors that meet the description in the first sentence of S4, they are clearly within the ambit of the standard. The Bureau recognizes that some of the requirements and test procedures in the standard may not be entirely appropriate for side doors of all designs, and is accordingly considering amendments to the standard.

If we can be of further assistance, please write.