ID: nht71-1.15

DATE: 12/30/71

FROM: Richard B. Dyson; NHTSA

TO: Gurley Refining Company

TITLE: FMVSS INTERPRETATION

TEXT: We have examined the proposed label for "GRC" brake fluid you have submitted to us for comment.

Generally, the label appears to meet the requirements of paragraph S5.2.2 of [Illegible Word] Vehicle Safety Standard No. 116 (36 f.r. 11987, June 24, 1971, as amended, 36 F.R. 21594, November 11, [Illegible Date]. The words "or [Illegible Word]" in your conformity statement are redundant; since the standard is a minimum requirement, "conforming to" and "exceeding" it mean exactly the same thing. If the fluid packager is an entity other than Curley, the packager's name or code identification must appear either below Gurley's name or on the bottom of the can. We assume that the required serial number identifying the packaged lot and date of packaging will be stamped either below Curley's name or on the bottom of the can.

ID: nht71-1.16

DATE: 07/02/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Drake America Corporation

TITLE: FMVSS INTERPRETATION

TEXT: In your letter of June 18 you ask for confirmation "that automotive brake fluids SAS 7OR1 Heavy Duty and SAE 7OR3 Super Heavy Duty currently meet U.S. standards."

Federal Motor Vehicle Safety Standard No. 116, Motor Vehicle Hydraulic Brake Fluids, specifies performance requirements for SAE Type 7OR1, Type 7031 Arctic, and Type 70R3 brake fluids. Thus if those Types of brake fluids conform to the performance requirements of Standard No. 116 they will meet current Federal requirements.

You also ask for confirmation "that it is illegal for SAE 70R2 Moderate Duty to be sold in the U.S. . . . ." Paragraph S4 of Standard No. 116 does allow the manufacture and sale of types other than 70R1, 70R1 Arctic and 70R3, however, "when the type indicated is not the of these three types, the hydraulic brake fluid shall comply with [Standard No. 116's performance] requirements for SAE Type 70R1 ...." Since SAE Type 70R2 does not meet these requirements, its manufacturer, sale, and importation into the United States is precluded.

For your information I enclose a copy of a new amendment to Standard No. 116, a revised version of the Standard effective March 1, 1972, and an advance notice of proposed amendment which would allow fluids other than petroleum base, all of which appeared in the Federal Register for June 24.

Sincerely,

June 18, 1971

National Highway Traffic Administration Department of Transportation

Att:Lawrence R. Schneider

Acting Chief Counsel

Gentlemen:

As requested during our telephone conversation of this afternoon, we would appreciate your confirming to us the fact that automotive brake fluids SAE70RI Heavy Duty and SAE70R3 Super Heavy Duty currently meet U.S. standards.

If you can likewise indicate that it is illegal for SAE70R2 Moderate Duty to be sold in the U.S., it will be of assistance to us in establishing for a foreign government the standards followed by our government in the use of automotive brake fluids.

Many thanks for your assistance.

Yours very truly

Automotive Export Division

DRAKE AMERICA CORPORATION --

Paul M. Pancirer, Manager

ID: nht71-1.17

DATE: 09/20/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Phillips Petroleum Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to a request made on behalf of Phillips Petroleum Company by Veigh J. Nielson for an assigned identification mark for two of Phillips' plants which manufacture tires for research purposes.

As I informed you in my letter of September 20, 1971, if Phillips purchases a new tire, removes the trend material and then applies its own experimental trend containing various rubber compounds, Phillips is considered to be a new tire manufacturer. If Phillips applies its experimental tread to a used tire, it is considered a retreader of tires.

As a new tire manufacturer you are required to certify the tire as conforming to the new passenger car tire standard (No. 109) and comply with Part 574 - Tire Identification and Record Keeping (49 CFR 574). Accordingly, you are assigned the identification mark of "J1" for tires made in your (Illegible Word), Oklahoma plant and "K1" for tires manufactured in your Stow, Ohio plant.

If you act as a retreader then Part 574 would not be applicable for the tires you retread because they are retreaded for your own use. (Enclosed is a copy of Docket No. 70-12, Notice No. 8 which makes the regulation inapplicable to retreaders who retread for their own use). As explained in my letter of September 20, you are, of course, required to certify that your new tires and your retreaded tires comply with the respective standards for new and retreaded tires if they are to be used on the public highways, by placing the symbol DOT on the tires in the prescribed location.

ID: nht71-1.18

DATE: 09/14/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Roger Levin, Esq.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 23, 1971, concerning certain aspects of Motor Vehicle Safety Standard No. 205, "Glazing Materials."

You are correct in your statement that Standard No. 205, which has been in effect since January 1, 1968, and was amended on September 19, 1968 (33 F.R. 14163) and March 1, 1969 (34 F.R. 3688), applies to a manufacturer of automobile sunroofs, "either in kits for installation by others, or for direct installation by the sunroof manufacturer, in either case after the car has been completed." To comply with the standard the sunroof material must meet the requirements for either AS1, AS2, AS3, AS5, AS10, or AS11 glazing material, as specified in ANSI Standard (formerly ASA Standard) Z26.1-1966, July 15, 1966. The 1969 amendment to this standard has not, as you state, been incorporated into Standard No. 205. However, a notice of proposed rulemaking published January 9, 1971 (36 F.R. 326), proposed to include that amendment. This matter is presently under consideration.

You are also correct in stating that a sunroof is an item of motor vehicle equipment, and not a motor vehicle. Certification may be made, pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403), by the statement you submit, "Material Certified to Comply with U.S. Motor Vehicle Safety Standard No. 205", followed by the name of the manufacturer.

We are pleased to be of assistance.

July 23, 1971

Office of the Chief Counsel National Highway Safety Administration

Dear Sir:

This is an inquiry about certain aspects of Motor Vehicle Safety Standard No. 205. I would appreciate your advising me if your interpretation of the statute and regulation is different from mine.

In the manufacture of automobile sunroofs, either in kits for installation by others, or for direct installation by the sunroof manufacturer, in either case after the car has been completed, Standard No. 205 applies and requires the manufacturer to comply with ASA Standard Z26.1-1966, specifically with the requirements of Item 5 glazing materials. Standard No. 205, as amended in 1968 and 1969, is now in effect.

The manufacturer of the sunroof is required by sec. 114 of the National Traffic and Motor Vehicle Safety Act of 1966 to certify to its customer that the sunroof complies with Motor Vehicle Safety Standard No. 205; since the sunroof is a piece of equipment, not a motor vehicle, that certification may be made by a tag or sticker attached to the sunroof, in language equivalent to the following:

"Material Certified to Comply with U.S. Motor Vehicle Safety Standard No. 205",

followed by the name of the manufacturer.

The 1969 amendment to ASA Standard Z26.1-1966 has not yet been incorporated into Standard No. 205.

Thank you in advance for your help in this matter.

Sincerely yours,

Roger Levin

ID: nht71-1.19

DATE: 04/01/71 EST

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Leasor & Leasor

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 26, 1971, concerning regulations pertaining to automobile windshields.

Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses, a copy of which is enclosed, specifies the requirements of automotive glazing materials manufactured on or after January 1, 1963. ANSI Standard Z26.1-1966, incorporated by reference, can be obtained from the American National Standards Institute, 1430 Broadway, New York, New York 10013, at a cost of $ 4.00.

The marking of the windshield that you depict in your letter of March 26 is not sufficient to identify its manufacturer. However, based on the "63" in the marking and the fact that the windshield shape fit the 1969 Plymouth, it can be hypothesized that the material in question is a laminated windshield of the improved design that has been used in 1966 and later models of U.S. automobiles.

There is not a requirement that windshields of this type completely shatter leaving no jagged fragments upon collison.

Sincerely,

ID: nht71-1.2

DATE: 07/12/71

FROM: AUTHOR UNAVAILABLE; D. Schneider; NHTSA

TO: Toyota Motor Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 9, 1971, regarding the definition of "curb weight" in Motor Vehicle Safety Standard No. 110.

The air conditioner and the additional weight optional engine are to be included in "curb weight" if the motor vehicle is equipped with these items. If the motor vehicle is not so equipped, then the items are not to be included in the "curb weight" or the "accessory weight".

ID: nht71-1.20

DATE: 06/26/71

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: D.C. Transit System, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of June 15, 1971, to Mr. Roy J. Dennison, concerning the use of Abcite coated acrylics in side windows of D.C. Transit buses.

Standard No. 205, Glazing Materials-Passenger Cars, Multipurpose Passenger Vehicles, Motorcycles, Trucks and Buses presently allows the use of AS-4 or AS-5 rigid plastics in the side wiodows of buses when the side windows are readily removable. Readily removable windows are defined in ANSX Standards ZZ6.1-1966 as "windows that can be quickly and completely removed from the motor vehicle without tools."

If this provision of the Standard is not adequate to satisfy your needs, we will be pleased to meet with you to discuss the matter further.

Office of the General Counsel D.C. Transit System. Inc.

June 15, 1971

Roy A. Dennison,

Safety Standards Engineer

Code 41-42

National Highway Traffic Safety Administration

Dear Mr. Dennison:

Pursuant to our conversations regarding the use of acrylic coated with Aboite, I enclose herewith for your consideration two letters from the Dupont Company relative to certain tests made.

I wish to request that you give this matter your prompt consideration for the reason that this organization would like to be able to use this material in certain new buses that it intends to order as part of its fleet together with the use of same in windows on our used buses. I am arranging for a sample of the material to be sent to you under separate cover.

What we hope to obtain from you is a statement to the effect that the material does meet the safety standards of your department and in turn this would allow us to take this matter up with the District of Columbia authorities in order to be able to use this material as windows in our fleet.

I will await your reply after your investigation of this matter.

Very truly yours,

May 28, 1971

R. Dennison, Office of Crash Injury Reduction, U.S. Department of Transportation, Federal Highway Administration, National Highway Safety Bureau,

Dear Mr. Dennison,

I have been having difficulty trying to contact you over the last two weeks, probably because of your vacation, but hope that you can give me a very quick answer to two questions arising out of the proposed modifications to Standard 205.

The first question concerns the date when the marking modifications become effective. My own reading of the Standard is that, since it is a Standard for glazing materials, then the effective date applies to the manufacture of the glazing material and not to the fitting of the glazing material into the automobile. If I am wrong in my assumption, then we have to bring our whole modification process very much more forward, because a glass to be, fitted in January must have been made by September, because of the large number of glasses already in the pipe line.

The second problem concerns the actual form in which the DOT certification appears. Triplex has been allocated symbol DOT 17 and that is the symbol which we put on the glass. The proposed modification to 205 calls for a hyphen to be placed between DOT and the number (17 in our case). Will you accept the marking DOT 17 without the hyphen, because all our stencils and master plates have been made in this form and we should be put to both considerable expense and delay in getting all the master plates modified.

I am sending a copy of this letter to Mr. Clue to Mr. D. Ferguson in case you are still on vacation, as I am urgently needing advice.

With kind regards,

Yours sincerely,

A. J. HOLLAND--TRIPLEX SAFETY GLASS CO. LTD.

E. I. Du Pont De Nemours & Company

PLASTICS DEPARTMENT

May 7, 1971

H. T. Smyth

Vice President Purchasing - Contracts

D. C. Transit System, Inc.

Dear Mr. Smyth:

In your letter of March 25, 1971, you asked me to certify to the following:

Du Pont Abcite abrasion resistant sheet - acrylic satisfies the requirements of Items 4, 5, 6 and 7 of the ASA Safety Code for Safety Glazing Materials for glazing motor vehicles operating on land highways - Z26.1 - 1966.

I am pleased to advise that our tests and investigations are now completed to an extent where we certify our material (Abcite abrasion resistant sheet - acrylic) does meet all of the ASA Z26.1 - 1966 requirements for the above items.

I hope this certification is in time for you to specify Abcite for your new coaches, and you will now proceed with additional usage on your current fleet.

If you have questions or need additional information, please contact me.

Sincerely,

Russell H. Berry, Jr.--

Development Specialist

Abcite Venture

E. I. Du Pont De Nemours & Company

PLASTICS DEPARTMENT

March 29, 1971

H. T. Smyth

Vice President, Purchasing - Contracts

D. C. Transit System, Inc.

Dear Mr. Smyth:

Thank you for your letter of March 25, and we are pleased to hear of the satisfactory results of your tests with windows of acrylic coated with Abcite (Registered). Your decision to convert your fleet to Abcite (Registered) pending governmental approval is also exciting news.

You asked for a letter "stating that this material satisfies the requirements of: Items 4, 5, 6 & 7 of the ASA Safety Code for Safety Glazing Materials for glazing motor vehicles operating on land highways - Z26.1 - 1966".

All our data indicate that acrylic coated with Abcite (Registered) abrasion resistant coating satisfies all of the requirements in the above items of the ASA Code. We are submitting sample material to an outside testing laboratory for certification to verify our data. Tests run by an independent testing laboratory at the request of the Department of Transportation show a non-compliance in the weathering tests with which we seriously disagree. All our weathering data, both in lab tests and outside weathering tests, show essentially no change in optical quality, light transmission and haze levels. (See Page 3 of attached product bulletin.) However, as I stated, we are having these tests run at our request for certification.

I hope the above satisfies your requirements but if there are any questions or if you need additional information, please contact me. My telephone number is 302//4-4639.

Sincerely,

Russell H. Berry, Jr. --

Development Specialist

Abcite (Registered) Venture

Enclosure

ID: nht71-1.21

DATE: 09/13/71

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Sierracin Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 4, 1971, in which you enclosed a copy of the manufacturer's symbol that would be used to identify windshields manufactured by the Sierracin Corporation, and ask whether the symbol is acceptable as illustrated. You also request our comments on requirements for the label location on the product.

The symbol you have enclosed complies with Motor Vehicle Safety Standard No. 205, "Glazing Materials" and, except for the omission of a hyphen between the "DOT" symbol and the manufacturer's code mark, also with the marking requirements proposed in the notice of January 9, 1971 (36 F.R. 326), which would amend certain provisions of the standard. We would consider this deviation to be inconsequential.

With reference to location requirements, the present standard does not specify a location for the windshield marking. The proposed amendment, which is still under consideration, would require the mark to be placed in the lower left hand corner of the windshield.

Sincerely,

August 4, 1971 Ref: SD7108-5

Lawrence R. Schneider Acting Chief Counsel NATIONAL HIGHWAY TRAFFIC Safety Administration

Dear Mr. Schneider:

Enclosed is a copy (SK-2137) of the Sierracin Corporation's manufacturing symbol to be used to identify automotive windshields of our manufacture.

May we please have your comments regarding its acceptance as shown and an expression of the label location requirement on the product.

Very truly yours,

SIERRACIN CORPORATION

William H. Lawson, Jr., Manager, Market Development

Enclosure

ID: nht71-1.22

DATE: 05/01/71 EST

FROM: AUTHOR UNAVAILABLE; Clue D. Ferguson; NHTSA

TO: Mr. Harvey R. Rosen, Attorney at Law

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 2, 1971, to Mr. Douglas Toms, in which you inquired about Federal requirements governing the interaction of passenger car door locking mechanisms and door opening capability.

I am enclosing a copy of Federal Motor Vehicle Safety Standard No. 206, entitled Door Locks and Door Retention Components, which applies to the area you have discussed. Please further note that paragraph 54.1.3.1 is applicable to the point in question, and requires that only the outside latch release control become inoperative on front doors when the locking mechanism is engaged. In the case of rear doors, addressed by paragraph 54.1.3.2, both inside and outside release mechanisms are affected. For your clarification, this standard was issued pursuant to the National Traffic and Motor Vehicle Safety Act of 1966 (Public Law 89-563).

As you point out, certain manufacturers have included the inside and outside feature on front as well as rear doors; however, the inside application to front doors was not required by the standard.

Thank you for your interest in motor vehicle safety.

ID: nht71-1.23

DATE: 12/20/71

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Mechanism Division

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of November 4, 1971, concerning the compliance of two dual rear door locking systems with Standard 206, has been forwarded to this office for reply.

Both systems consist of

. . . a primary locking system which when engaged renders the outside rear door handle and the inside rear door handle inoperative and a special locking device accessible from the door shut face, which when engaged renders the inside door handle imperative but does not affect the outside door handle.

The systems differ is that engagement of the special locking device in the first system prevents the engagement of the primary locking system, while engagement of the special device in the second system does not have this effect.

As stated in the preamble to the April 27, 1968 amendment (33 F.R. 6465) to the standard, S4.1.3 does not preclude the installation of a special locking mechanism in addition to the required locking mechanism. However, the required locking mechanism must be engageable or disengageable regardless of whether any additional locking mechanism is engaged or disengaged. If the special locking mechanism does not interfere with the operation of the required locking mechanism, it will not constitute a failure to comply with the standard.

Under these criteria, the first dual system would not comply with the standard since engagement of the special locking mechanism would interfere with the operation of the primary locking mechanism.

The second dual system would comply if engagement of the special locking mechanism would prevent neither the engagement nor the disengagement of the primary locking mechanism.

Please write if I can be of any further assistance.