ID: nht72-1.1

DATE: 12/11/72

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Chrysler United Kingdom Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of November 7, 1972, about Federal Motor Vehicle Safety Standard No. 102 as applied to a four speed automatic gear box.

As described, gear transmission functions as follows:

"When the gear selector is in any forward position and the vehicle speed falls the automatic Mechanism will cause the drive ratio to eventually fall to the lowest gear and thereafter to disengage at about 6 mph leaving the vehicle in a state of 'free-wheel'."

Paragraph S3.1.2, Transmission Braking Effect, requires that:

"In vehicles having more than one forward transmission gear ratio, one forward drive position shall provide a greater degree of engine braking than the highest speed transmission ratio at vehicle speeds below 25 miles per hour."

Your transmission, as described, does not meet this requirement, since, in downshifting, the drive ratio would disengage at about 6 miles per hour leaving the vehicle in a state of "free-wheel" with no engine braking at all.

Sincerely,

CHRYSLER UNITED KINGDOM LTD

The Office of Standards Motor Vehicle Safety Performance Service, U.S. Department of Transportation, Federal Highway Administration, National Highway Safety Bureau,

NOVEMBER 7, 1972

Dear Sirs,

Interpretation of F.M.V.S.S. 102.

We are considering the use of a four speed Automatic Gear Box which has the following characteristic:

When the gear selector is in any forward position and the vehicle speed falls the automatic mechanism will cause the drive ratio to eventually fall to the lowest gear and thereafter to disengage at about 6 mph leaving the vehicle in a state of "free-wheel".

We notice F.M.V.S.S. requires an automatic gear box to be such that: "One forward drive position shall provide a greater degree of engine braking than the highest speed transmission ratio".

Whilst this clause would be met with the characteristic described at speeds above 6 mph it could not be considered to be met at speed below 6 mph.

I would be grateful if you would let me know whether or not you consider such a gear box would meet the requirements of F.M.V.S.S. 102.

P.J.P Horris. Manager, Vehicle Legislation.

ID: nht72-1.10

DATE: 10/06/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Minnesota Automotive, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 19, 1972, asking whether the new hydraulic brake safety standard precludes the provision of a device using the service brake pressure to supplement normal parking brake performance.

Standard No. 105a does not prohibit the inclusion of such a device as original equipment in a motor vehicle, provided that the vehicle can meet the parking brake system requirements of the standard using the mechanical system alone.

ID: nht72-1.11

DATE: 05/04/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: British Leyland Motors, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 19 calling our attention to Mr. Whitehead's letter of February 8 addressed to Docket No. 70-27. We regret the delay in answering Mr. Whitehead's question. Communications addressed to the docket, which arrive in large volume, are normally filed without reply. We request that letters requesting a reply be addressed to the Administrator, not the docket, so that they will be promptly assigned for action.

Mr. Whitehead asked whether a display of "red letters" when the lamp is lit would satisfy the proposed revision of Standard No. 105, and recommended that the words "red lens" be deleted from paragraphs S4.3.2c and S4.7.2d of the proposed amendment to Standard No. 105. The red letters described appear to satisfy the intent of the proposal, and the suggestion for rewording will be considered when the final rule is issued.

ID: nht72-1.12

DATE: 04/25/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Nissan Motor Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 5 to Mr. Schneider asking for an interpretation of Standard No. 106.

You ask whether it is permissible to use a rubber protector on a brake nose which masks in part the identification marking required by Standard No. 106. SAE Standard J40b, Automotive brake Hoses, incorporated by reference in Standard No. 106, requires hose working to be permanent in nature. Therefore, use of this protector is permissible, provided that its rubbing effect, if any, does not oblitorate in time the required marking.

You have also asked whether you may conduct the whip test with the rubber protector removed. We have no objection to this method of conducting the whip test. Standard No. 106 is silent as to how the test may be conducted. Paragraph 57.1.4 of our proposal to amend Standard No. 106 (Docket No. 1-5; Notice 7, 36 F.R. 5855, March 30, 1971) represents our view that "protective armor" should be removed for the fatigue test, and you may interpret this as including the rubber protectors also.

YOURS TRULY,

NISSAN MOTOR CO., LTD.

April 5, 1972

Lawrence Schneider National Highway Traffic Safety Administration

SUBJECT: Interpretation of MVSS 106.

We would like to have your interpretation regarding MVSS 106-Hydraulic Brake Hoses, (1) whether or not we may use the rubber protector which would hide the marking on brake hose in part. (Protector itself is not glued, but envelopes the hose tightly so it could be movable when relatively strong force is applied.) (2) whether or not we may conduct the whip test with the rubber protector removed.

Your assistance in this matter would be greatly appreciated.

Satoshi Nishibori Engineering Representative Liaison Office in U. S. A.

ID: nht72-1.13

DATE: 09/22/72

FROM: AUTHOR UNAVAILABLE; E. T. Driver; NHTSA

TO: Mr. Darrell L. Lindemann

TITLE: FMVSS INTERPRETATION

TEXT: This is in reference to your letter of September 8, 1972, concerning glare from chrome trim on the hood of your 1971 Ford Torino, which was forwarded to our attention by the National Transportation Safety Board.

Federal Motor Vehicle Safety Standard No. 107, "Reflecting Surfaces . . .", regulates the specular gloss of four types of bright metal components in the driver's field of view but does not include chrome trim on the hood of a vehicle. In an effort to extend the scope of this standard to make it more effective in reducing daylight glare, the National Highway Traffic Safety Administration has sponsored four contract investigations dealing with glare. The final report on the last entry will be completed soon. After studying the results of this research. We intend to revise Standard No. 107 to cover other glare-producing areas of the vehicle.

ID: nht72-1.14

DATE: 06/15/72

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

TO: Frank and Frank

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your most recent inquiry regarding hood latch systems, dated May 26, 1972.

Examination of the 1964 Chevrolet hood latch system reveals that this system does meet the requirements of Federal Motor Vehicle Safety Standard No. 113, which was effective on January 1, 1969. While, as stated in our correspondence of February 16, 1972, we favor a system in which two complete operations are necessary, a system which employs two latches having a single operation will meet the requirements of the standard.

A current review of our Office of Defects Investigation files reveals that no information relative to 1964 Chevrolet hood latching systems has been added since our last communication.

Thank you for your inquiry.

Sincerely,

ATTACH.

U.S. DEPARTMENT OF TRANSPORATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

01/01/72 EST.

Irving Frank -- Frank and Frank

Dear Mr. Frank:

Thank you for your letter of December 22, 1971, in which you requested safety information pertaining to 1964 Chevrolet hood latching mechansims.

Our Offices of Defects Investigation and Accident Investigation and Data Analysis have made a search of their files, and have found no specific information relating to defects in 1964 Chevrolet hood latching. I should like to point out that, inasmuch as Federal motor vehicle safety standards first became effective on January 1, 1968, we have not in all cases received information pertaining to defects which may have affected earlier vehicles. We have, however, monitored a recall campaign affecting potentially defective hood latch mechanisms on 1969 Mercury Cougars, wherein the possibility of binding components could cause the hood to open while the vehicle is in motion. In this connection, we are enclosing a copy of a report, Motor Vehicle Safety Defect Recall Campaigns, covering calendar year 1969. Your attention is invited to page 13 of the report for a brief summary of the action, and to page 1 for instructions for obtaining further detailed information relative to this campaign. We are, of course, continuing to be alert for further problems in this area.

Regarding designs of hood latch systems, we favor the type system you describe in which two complete operations are necessary before the hood can be opened completely. I am enclosing a copy of Federal

Motor Vehicle Safety Standard No. 113, entitled Hood Latch Systems, which has required secondary latch positions or secondary hood latch systems on most vehicles since January 1, 1969.

Thank you for your inquiry. Do not hesitate to contact me if I can be of further assistance.

Sincerely, J. E. FORESTER FOR Robert L. Carter -- Acting Associate Administrator Motor Vehicle Programs

Enclosures

ATTACH.

FRANK AND FRANK

December 22, 1971

Office of Compliance, National Safety Bureau

Re: Pettiford v. Hassell and Rhodes Our File No. 70-45

Gentlemen:

We represent a Mr. Dennle Pettiford of Brooklyn, New York who was seriously injured in an automobile accident in October, 1970.

On his behalf we are writing to you to determine whether or not there is any information available concerning the design, construction and maintenance of a hood or hood mechanism used in the 1964 Chevrolet station wagon. We would also be interested in knowing whether there are any statistics or other reports available concerning prior accidents arising in the same manner as the one in which our client was involved.

In September 1970, my client was driving a 1964 Chevrolet station wagon. While the car was in motion, after it had been traveling for some time, with no sign of any impending danger, the hood suddenly opened. Because his vision was completely obstructed, the driver immediately applied his brakes. At this time, there was traveling behind him a large trailer truck. Apparently, it was unable to stop. The truck collided with the rear of the station wagon ramming the station wagon against the side of the bridge and dragging it for a considerable distance. A serious fire ensued. Four people were killed and two others severely burned.

We understand that both vehicles were traveling on a very narrow bridge. A fast-moving vehicle traveling in the opposite direction may have created a vacumm-like effect as it passed our driver's vehicle. The vacuum-like effect in some fashion created pressure on

the hood causing it to fly upward and open.

We understand that at this time other vehicles had not only a latch to control the hood but also an additional safety catch. Thus the 1964 Ford automobile was equipped with a hood-release mechanism and also a secondary safety catch. Two complete operations were necessary before the hood could be opened completely.

The first device was released by compressing a lever located below the grillwork. This allowed for a partial opening of the hood; then a second device above the grillwork and below the hood was compressed to release a "hook" or "safety catch". Thus, assuming that a Ford vehicle was involved and mechanism was operating properly, the passing truck creating a vacuum-like effect, might have allowed the hood-release mechanism to become disengaged. However, the safety hook or catch would still have caught the hood before it could obstruct the driver's vision.

Any information that you may have concerning the hood release mechanism and/or safety catch on vehicles manufactured by General Motors in 1964, or for any other manufacturers that might have a bearing on this particular kind of accident would be greatly appreciated. If there's any additional information you require from us, please do not hesitate to ask.

Thank you for your courtesy and cooperation.

Very truly yours, IRVING FRANK

FRANK AND FRANK

May 26, 1972

Robert L. Carter -- Acting Associate Administrator, Motor Vehicle Programs, U.S. Dept. of Transportation

Re: Pettiford vs. Hassell and Rhodes Our File No. 70-45

Your reference: 41-42

Dear Mr. Carter:

You were good enough to write to us on February 16, 1972. This was in reply to our inquiry concerning the hood-latch systems on the 1964 Chevrolet.

We have recently been able to obtain a diagram from a publication known as "Gleen Mitchell Collision Estimator Inc." which is prepared for automotive mechanics. I am enclosing a copy of the same. You will notice that in the lower right-hand corner of this page 2-7, there is a small diagram of the hood and the locking mechanism.

As near as I can make out, it would appear that there is but one latch, consisting of an upper and lower assembly.

Would you be good enough to have your office indicate to us whether or not this assembly for the hood-latch system complies with the regulations which came into effect through your office on January 1, 1969.

We would also like to know whether or not since our last inquiry, there has been any further information obtained by your office with respect to the 1964 Chevrolet hood-latching mechanism.

Thank you for your courtesy and cooperation.

Very truly yours, IRVING FRANK

Enclosure

ID: nht72-1.15

DATE: 08/22/72

FROM: AUTHOR UNAVAILABLE; L. R. Schneider for R.B. Dyson; NHTSA

TO: Rubber Manufacturers Association

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 24, 1972, to Mike Peskoe, and your letter of July 25, 1972, to Lawrence Schneider. Your letter of July 24 discusses your dissatisfaction with the present method of amending the Appendices of Standards 109 and 110 and suggests that we meet to discuss with you possible methods of changing this procedure. We will be happy to meet with you to discuss possible other methods of amending the Tables, and if you will contact either Ed Wallace or Mike they will arrange a meeting with you.

In your letter of July 25 you request the legal status of a petition dated July 4, 1972, from E.T.R.T.O., to amend the Tables of Standards 109 and 110 to include a tire size designation and alternative rim sizes which have not been standardized by E.T.R.T.O. The guidelines for amending the Tables, which you cite in your letter, do not require tire size designations and alternative rims to be standardized by the respective associations before inclusion in the Tables. Rather, they require only that the petition indicate whether the tire size designation and rim sizes have been standardized. As a consequence, the size in question (240-15 Radial) and the alternative rim sizes were included in the amendment to the Table published August 2, 1972 (37 F.R. 15430). If you object to the inclusion of this size designation in the Tables, as you have been informed by phone, your objection with supporting statements should be submitted to NHTSA in writing, within 30 days from publication of the amendment to the Tables.

ID: nht72-1.16

DATE: 05/31/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: The General Tire & Rubber Company

TITLE: FMVSS INTERPRETATION

TEXT: In response to your letter of May 1, 1972, we would consider a tire with a cord carcass angle of 85 degrees to be within the definition of "radial ply tire" as that term is defined in Motor Vehicle Safety Standard No. 109.

ID: nht72-1.17

DATE: 01/26/72

FROM: AUTHOR UNAVAILABLE; David Schmeltzer; NHTSA

TO: National Farmers Union Property and Casualty Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of January 4, 1972, in which you inquired into the possibility of selling tires that sustained (Illegible Words) damage in a service station fire. In 1969, you were faced with a similar situation and we advised you of the way in which these tires could be sold. In 1970, Safety Standard No. 109 was amended to deal with the problem of tires that had to be reclassified and thus you cannot (Illegible Word) rely upon our comments of three years ago.

I have enclosed a copy of the (Illegible Word) on point. The Amendment indicates a policy of (Illegible Word) control over the sale of "farm use only" tires. Since you are reclassifying the tires, you will have to meet the requirements of (Illegible Words) the same manner as a manufacturer. You will also be interested in the Notice of Proposed Rule Making I have enclosed. This proposal would prohibit the sale of tires which can now be sold as reclassified.

ID: nht72-1.18

DATE: 09/18/72

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Demman Rubber Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 14, 1972, requesting information as to whether you may sell tires to a Mr. Harvey Livingston, who is in the business of repairing tires with correctable defects. You ask what assurance you should obtain that the tires are actually repaired and rebranded by Mr. Livingston before their sale by him.

The sale of passenger car tires is subject to the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) and Motor Vehicle Safety Standard No. 109. "New (Illegible Word) Tires" (49 CFR 571.109). Under these provisions tire manufacturers may sell passenger car tires only in the following circumstances: They may sell tires which perform to the performance and labeling requirements of Standard No. 109, and which have been certified as specified in the standard and the Tire Identification and Recordkeeping regulations (49 CFR Part 574); or, they may sell, until October 1, 1972, (See our notice of August 17, 1972, 37 F.R. 16694) tires which have been reclassified pursuant to paragraph S6 of Standard No. 109. This requires the removal original labeling and the affixing of new labels which were against the was of such tires on public highways. These restrictions apply to the sale of passenger car tires so any purchasers including persons such as Mr. Livingston, who wish to repair the tires and resell them.

If you sell conforming tires to Mr. Livingston, he would not be required by Federal regulations to remove Demmas labeling and to affix his own. Whether or not he did this would depend upon whatever agreement you reach with him. A satisfactory assurance, should you agree with him to follow this procedures, would be a written agreement to that affect; but you should also record the serial numbers of tires which you sell to him. Demman, however, is not permitted to remove its own labeling before sale.

Even if Mr. Livingston affixes the DOT symbol and his own identification number to the tires, the NHTSA would not necessarily find him responsible should the tire fail to conform to Standard No. 109. Mr. Livingston would be entitled to a show that the reason for the nonconformity is not attributable to the work he performed. If he could demonstrate this, Demmas could then be found responsible for the nonconformity.

If you sell Mr. Livingston "reclassified tires", Mr. Livingston would be required to label the tires as required by Standard No. 109, and to certify their conformity to the Standard before he could sell them as passenger car tires. In this situation, Mr. Livingston would be responsible if the tires failed to conform to Standard No. 109.

We have send Mr. Livingston a copy of our response.