ID: nht70-2.46

DATE: 12/18/70

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

TO: Electrical Testing Laboratories, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your request for clarification of S4.4.2 of Federal Motor Vehicle Safety Standard No. 108 (Lamps, Reflective Devices, and Associated Equipment), as published in the Federal Register on October 31, 1970 (35 F.R. 16843).

You have asked the following questions:

"1. How many flashers constitute a sample for test?"

"2. How many failures, and of what types, are allowed for compliance?"

The safety standards do not specify sampling provisions or failure rates. The reference to test samples in the SAE materials referenced in Standard No. 108 were deleted in the above notice, to bring the standard into conformity with the requirements of the National Traffic and Motor Vehicle Safety Act, which requires that all items conform to the standards. It is the manufacturer's responsibility to institute a test program that will ensure that his products meet the standards.

"3. Which sentences or paragraphs in SAE J590b and SAE J345 are specifically referenced for omission?"

I attach copies of the two SAE Standards marked to show omissions.

"4. Does the statement 'tested consecutively' refer to the combination turn signal and hazard warning signal flasher or the SAE standards?"

This statement means that the combination unit is tested first to determine compliance with SAE J590b and then tested in accordance with SAE J945.

"5. * * What statement of test results is available to the testing organization?"

How you state your test results is a question to be decided between you and your clients. If you find that an item fails the standard in a particular respect, I presume that you will so state.

"6. * * Can or should all current tests on these devices be made according to the above modified procedures during this interim period prior to [the effective date of the amendment]?"

As stated above, the method and timing of a manufacturer's tests is not regulated by the Bureau. The test program should be sufficient to legally constitute are care, on a continuing basis, to ensure that all products manufactured after the effective date of a standard meet the applicable requirements.

I hope this answers your questions.

ID: nht70-2.47

DATE: 10/19/70

FROM: L. R. Schneider, NHTSA

TO: American Honda Motor Company, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Douglas W. Toms has asked me to reply to your letter of September 8 which requests confirmation "that a transmission gear ratio other than the highest ratio is not required to be available at all speeds below 25 miles per hour".

We cannot confirm this interpretation of S3.1.2 of Motor Vehicle Safety Standard No. 102 (Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect). The phrase "at vehicle speeds below 25 miles per hour" in that section is inclusive; it means at all speeds below 25 miles per hour, and not at a speed.

Douglas W. Toms Director National Highway Safety Bureau

We would appreciate receiving an interpretation to clarify the meaning of Paragraph S3.1.2 of Federal Motor Vehicle Safety Standard 102.

It is our understanding that a transmission gear ratio other than the highest ratio is not required to be available at all speeds below 25 miles per hour. For example, in the case of a vehicle equipped with a three speed automatic transmission, if second gear became available only when selected at speeds below 15 miles per hour, the vehicle would conform to the requirements of Paragraph S3.1.2 provided that within the speed range when second gear was available, the vehicle deceleration was greater than if the highest gear ratio were engaged.

We believe that rewording Paragraph S3.1.2 of M.V.S.S. 102 as follows would clarify this matter:

"S3.1.2 Transmission Braking Effect. In vehicles having more than one forward transmission gear ratio, one forward drive position shall provide a greater degree of vehicle deceleration than the highest speed transmission ratio when tested below 25 miles per hour and within the speed range at which the lower gear ratio is available."

We would greatly appreciate an early reply.

C. L. Hale Staff Engineer

ID: nht70-2.48

DATE: 03/11/70

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Kurt Meier

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 13, 1970, to Mr. John. M. Will of this offices, partaining to the identification of shift lever position of customatic transmissions as required by Federal Motor Vehicle Safety Standard (FMVSS) No. 102.

FMVSS No. 102 specifies that each shift lever position of automation transmission shall be identified and shall be permanently displayed in view of the driver. Your proposed shift lever position identification for future automatic tranmissions, as can be determined from your diagrammatical sketch, does not provide identification for the "neutral" position. Appropriate identification, whether it be the letter "N" or some other suitable designation, must be provided to satisfy the requirements of the safety standard.

It was noticed, from your setch, that the tranmission shift lever seque for the forward drive positions progresses from low to high gear from the neutral position. As background information for the National Highway Bureau's Compliance Test Program, we are interested in low you plan to certify a vehicle incorporating the proposed shift lever sequence for FMVSS 105 (Rydraulic Service Brake, Emergency Brake and Parking Brake Systems) during the 30, 60, and 80 m.p.h. Effectiveness Tests. Your response citing the above reference will be greatly appreciated.

Thank you for your interest in the safety program of the National Highway Safety Bureau.

ID: nht70-2.49

DATE: 01/02/70

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

TO: Alba Tire Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 24, 1969 to the National Highway Safety Bureau, concerning our proposed retreated tire standard.

I appreciate your sending your thoughts on tire safety to our attention since we make a point of being as familiar as possible with the present state-of-the-art of all aspects to tire safety.

The Federal Motor Vehicle Safety Standard do not apply to tires manufactured exclusively for off-road competitive use or to tires retreaded exclusively for off-road competitive use. You are cautioned, however, that if the tires are sold for "street use", then these racing tires wil be covered by the proposed standards and would be subject to the requirements.

ID: nht70-2.5

DATE: 04/29/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: David Hemenway

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter of March 9, 1970, addressed to the National Highway Safety Bureau, concerning data provided pursuant to the Consumer Information regulations, 49 CFR @ 575.101, Vehicle Stopping Distance. A copy of the consumer information date for 1970 vehicles is enclosed.

You asked whether stopping distances greater than 194 feet for vehicles traveling 60 mph indicate the likelihood that such vehicles are(Illegible Word) to meet Federal Motor Vehicle Safety Standard No. 105. As you have noted, the stopping distance for a constant(Illegible Words) deceleration from 60 mph would be 194 feet. However, Standard No. 109 does not require an average deceleration rate. ((Illegible Words) up" time) of 24(Illegible Word) during the entire period of deceleration. The Standard requires only that a vehicle attain a deceleration rate of 20(Illegible Word) with a pedal force of between 15 and(Illegible Word) lbs., in a(Illegible Word) 60 mph. Consequently, the standard does not require that the stopping distance not exceed 194 feet, and consumer information data showing a stopping distance in excess of 194 feet for the 60 mph test does not indicate non-compliance with Standard No. 105.

The attached Discussion Paper indicates none of the revisions in Standard No. 105 that are under consideration. Should amendments be found desirable, a notice of proposed rule making containing the proposed revisions will be issued.

Thank you for your interest in motor vehicle safety.

ID: nht70-2.50

DATE: 05/28/70

FROM: AUTHOR UNAVAILABLE; R.A. Diaz; NHTSA

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of May 11,(Illegible Word), in which you asked four questions concerning the application of Standard 206 to your products, with reference to several illustrations and drawings that you enclosed.

1. "It is our opinion that hinge, latch and inside door lock on(Illegible Word) compartment must comply with requirements of FMVSS No. 206. Is this correct?"

Answer: Yes.

2. "Is inside door lock required in this type utility(Illegible Word) compartment?"

Answer: Yes, since it is a "hinged door", and not a "cargo-type door", within the meaning of the standard, on that the requirement of(Illegible Word) applies.

3. "It is our opinion that FMVSS No. 206 does not apply to material compartment door latches illustrated in Exhibit 1. Is this correct?"

Answer: Yes. Material compartment doors are not(Illegible Word)

4. "It is our opinion that hinge, latch and inside door(Illegible Words) illustrated in Exhibit 4 and not done under FMVSS No. 206. Is this correct?"

Answer: Yes. The requirements of the standard apply only to side doors.

We are pleased to be of assistance.

ID: nht70-2.51

DATE: 01/02/70

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

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge your letter of November 25, 1969, to the National Highway Safety Bureau requesting the addition of the 4-J and 4 1/2-J rims for use with the 5.60x15 tire size designation and the 4 1/2-J rim for use with the 6.00x15L tire size designation to Table I, Appendix A of Federal Motor Vehicle Safety Standard No. 110.

The addition of these rims to Standard No. 110 is not necessary, as these combinations are listed within the references cited in S.J of Standard No. 109. The fact that you have changed the hump configuration on these rims requires no action on our part as we do not list variations from the basic Tire and Rim Association's contours. We consider only the rim width and flange coutour designation at this time when listing rims in the standard.

Manufacturers who modify rims are, of course, responsible to see that their product will perform satisfactorily to the requirements of Standard No. 109 and No. 110.

ALBA TIRE COMPANY

NOV. 24, 1969

NATIONAL HIGHWAY SAFETY BUREAU

We unfortunatley were unable to attend the Convention in Atlanta, and to hear your address, delivered to those interested, at the convention. However I have reviewed your address carefully, as reported in the November issue of Modern Tire Dealer, and have some questions.

Will Off the Read New Tires, and Retreads(say Racing Tires) come under the Regulations which are proposed for New Tires- and Retreads? If they are going to be included we wonder why-sincethis Deal is a different Ball game from the other phases of the Tire Business. The reason I say this is because of the difference in the original construction of the Tires (new at the factory). There is also a vast difference in the performance of the Tires-as regards heat buildup-and heat dissipation factors,. For ourselves we have been retreading Racing Tires for some 6 years now, and I have my First complaint-with one of my Retreads coming loose. My 45 years experience in Retreading may not make me an expert- but(Illegible Word) have learned a few things about the performance of Retreaded Tires on the Tracks-as opposed to New Tires. I cannot find any difference in the performance-or the satisfaction of the Users of a new Tire-as opposed to Retreads.

I ship my retreaded Race Tires all over Texas, Oklahoma, Kansas, and Nebrasks, as well as New Mexico. These Tires are run on both Paved, and Dirt Tracks, and by(Illegible Word) slow cars to sprint cars which turn up to 145 mph on the Straightway- NO PROBLEMS.

I buy my Retrenching Rubber Tax Free-since it is not going to be used on Hiway Type Tires- and of course should be Tax free.

I am 100% for a Fine quality Retread-and have for many years been critical of the Marginal Retreader-who had nothing but price- and POOR Quality to recommend his product-but as I say-I am wondering WHY The Race Tire deal should be included in any Guidelines that apply to Highway type Tires?

We will appreciate greatly your consideration of our concern-and thank you for an early response.

ID: nht70-2.52

DATE: 02/03/70

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Bloom and Drobner

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of December 22, 1969, to the National Commission on Product Safety, which was referred to this Bureau for further reply. We have noted the Commission's response to you of December 29, 1969.

A review of our files has failed to produce any specific data relevant to the exact nature of the case you have cited. This is attributable to the fact that the accident investigation methodology on which we depend does not break out data in that particular category.

We would like to advise, however, that Federal rule making sections do address door latch releases, or handles, in a different aspect. We are particularly concerned over configurations of door handles which incorporate sharp features or which tend to protrade excessively, as those types of handles increases the likelihood of the door opening as a result of contact by the body of an occupant during a crash situation. Moreover, if they contain sharp features, they can contribute to increased injury levels resulting from occupant impact when the door remains closed.

I regret we are unable to be more responsive to your inquiry. Thank you for writing.

BLOOM AND DROBNER

DECEMBER 22, 1969

NATIONAL COMMISSION ON PRODUCTS SAFETY

I represent Mrs. Sarah Glover who was a passenger in a 1966 Pontiac. As she lifted up her purse, preparatory to disembark, the purse handle caught on the door handle and the door flew open.

I would appreciate learning if there have been any other cases similar to this in which design negligence concerning the operation of the door handle was the issue.

Thank you in advance for this courtesy.

December 29, 1969

SHERWIN DROBNER

We are in receipt of your letter of December 22, 1969.

As you may know, Congress created this Commission to develop the means to protect the consumer from unreasonably hazardous products used in and around the American household. The scope of inquiry is limited, however, to those products not now the subject of regulations prescribed under existing Federal statutes. These laws are enumerated in Section 6 of Public Law 90-146 (81 Stat. 466).

As your correspondence concerns motor vehicles, it would best be considered by the Department of Transportation. That agency is responsible for the administration of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381 et seq.). Accordingly, I am directing your correspondence to the Department of Transportation and have asked that they reply directly to you with a copy to this Commission.

Thank you for your interest in the Commission and its work.

LARRY A. SCHOTT CHIEF, INVESTIGATION UNIT

cc: DR. ROBERT BRENNER -- DOT

NATIONAL COMMISSION ON PRODUCT SAFETY

DECEMBER 29, 1969

TO: DR. ROBERT BRENNER -- DOT

We would appreciate your handling the attached correspondence as indicated below:

COMMENT

FOR DIRECT REPLY

FOR BACKGROUND BRIEFING ON WHICH TO BASE REPLY FROM THIS OFFICE

FOR SUITABLE ACKNOWLEDGEMENT OR OTHER APPROPRIATE HANDLING

FOR YOUR INFORMATION

Please furnish this office with a copy of your reply. YES

Your cooperation is very much appreciated.

ID: nht70-2.53

DATE: 07/10/70

FROM: AUTHOR UNAVAILABLE; R. A. Diaz; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 26, 1970, to Mr. Douglas W. Toms, Director, National Highway Safety Bureau, concerning plastic materials for reflex reflectors.

The contents of your letter, including the technical data and information enclosed therewith, have been carefully reviewed by interested members of this Bureau. As a result of this review and evaluation, and also considering the nature and intent of the requirements in question, we concur, basically, with your interpretation of the requirements of SAE J576b, as subreferenced in Federal Motor Vehicle Safety Standard No. 108. Your interpretation of the requirements of paragraphs 3.4 and 4.2 of SAE J576b, as quoted from your letter, is as follows:

"A plastic material used in a lamp or reflector assembly so that it is covered by other material and is not directly exposed to sunlight meets the requirements of SAE J576b if, when so covered, it satisfies the requirements of paragraphs 3.4 and 4.2."

We would fully concur with this interpretation if it is rephrased to read as follows:

"A plastic material used in a lamp or reflector assembly so that it is covered by other material and is not directly exposed to sunlight meets the requirements of paragraphs 3.4 and 4.2 of SAE J576b if, when so covered, it satisfies the requirements of those paragraphs."

To test for compliance, using this interpretation, the test sample discs, as specified in SAE 576b, would be exposed to the outdoor exposure test (paragraph 3.4) while covered with the actual lens material used in production lamp assemblies. In your particular case, the discs would be the polycarbonate ("Loxan") material and the "covering material" would be the red taillamp lens molded for production use.

ID: nht70-2.54

DATE: 10/28/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: TVR Engineering Ltd.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of October 14, 1970, to the Director of the National Highway Safety Bureau forwarding information sheets on the TVR Vixen. I am enclosing copies of the Bureau's Consumer Information Regulations (49 CFR Part 575). The substantive provisions, @ 575.101 on vehicle stopping distance, @ 575.102 on tire reserve load, and @ 575.106 on acceleration and passing ability, require the furnishing of specific information in a format which is in the form set out in the regulations. The information sheets which you have provided fall short of these requirements in both form and substance. For example, @ 575.101 requires furnishing information on the minimum stopping distance, expressed in feet, for the particular vehicle, from a particular speed, at specified loads, with the braking system in a specified condition. The information provided by you in this regard is incomplete, and is not in the form specified. In addition, the regulations require the information to describe and be valid for each of the vehicles with which it is provided.

Please study the enclosed regulations carefully and forward to us complying consumer information within the near future. Let us know if you need further assistance.

ENCLOSURES