ID: nht70-1.11

DATE: 12/17/70

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Northeast Kentucky Area Development Council, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 28, 1970, to Mr. Lowell K. Bridwall, Administrator, Federal Highway Administration, asking for a definition of "blemished," "second," and "form use only," which has been referred to this office for reply.

Tire manufacturers are required to certify that their product complies with the Federal Motor Vehicle Safety Standard No. 109, and do so by labeling each tire they certify with the symbol "DOT." Tires that are certified by the manufacturer and marked "seconds" are not necessarily unsafe, as the "second" may be due to a cosmetic defect not affecting the tire's performance.

Sometime a tire manufacturer will make a tire that he believes is defective in a way that affects the safety of the tire. Often, that manufacturer will mark the tire "farm use only" or "non-highway use" and then sell it. In such instances, he is required to remove the DOT symbol.

We do not have a definition for "blemished."

We have enclosed a copy of an amendment to the passenger car tire standard (No. 109) that contains the definition for "non-highway use tires" which is applicable to "farm use only," and "tire identification and recordkeeping" which is applicable to "manufacturer's marks on tires."

Thank you for your interest in the Motor Vehicle Safety Program.

ID: nht70-1.12

DATE: 10/29/70

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

TO: Atlas Supply Company

TITLE: FMVSS INTERPRETATION

TEXT: Reference is made to your letter of October 8, 1970, requesting an increase in the maximum permissable overall width of the "78" series belted bias passenger car tires covered by Table I-J, Appendix A, of MVSS 109.

The dimensional requirements specified in MVSS 109 for passenger car tires are the result of a rule making action in which the tire industry and other interested persons participated. Tire section width and overall width were permitted to exceed the specified section width dimensions by 7% to accommodate differences in manufacturing tolerances, design practice, tire growth patterns when inflated, and to provide for sidewall decorations and protective ribs.

The allowance of 7% is considered the maximum desirable for dimensional uniformity and interchangeability among tires of the same size produced by different manufacturers. For this reason, we cannot give favourable consideration to your request at this time.

ID: nht70-1.13

DATE: 04/30/70

FROM: AUTHOR UNAVAILABLE; Frances Armstrong; NHTSA

TO: Clements, McClellan and Hawley

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 3, 1970, to the Director, National Highway Safety Bureau, that has been referred to this office.

The type of information requested under items 1 and 2 of your letter can be extracted, within the limitations of the tests conducted, from the enclosed test result summaries. However, it should be recognized that the scope of the Bureau's testing program is such that valid statistical inferences relating to industry-wide rates or tire defects or failures are not possible with the limited data available.

Prior to the adoption of the labeling requirement in Federal Motor Vehicle Safety Standard No. 109, tires could be identified by manufacturer. This was an industry practice, involving the use of serial number systems and was not required by Government regulation nor was the coding used readily available to the general public.

We trust this and the enclosed publications will answer your questions. We will be pleased to answer any additional questions.

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

ID: nht70-1.14

DATE: 05/18/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Calhoun & Phelan

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter of April 29, 1970, to the National Commission on Products Safety, that has been referred to this office.

In your letter you ask for our advice as to whether or not there are any accepted standards for passenger car automobile tires such as weight and size limits. We do have standards for passenger car tires such as weight limit versus ply rating and there are accepted tests to determine the reliability of tires. Federal Motor Vehicle Safety Standard No. 109 has been established for that purpose. The Standard's requirements are for labeling, which includes maximum inflation pressure and maximum load rating, strength, continuous load-carrying endurance and high speed performance under load.

Federal Motor Vehicle Safety Standard No. 110, Tire Selection and Rims - Passenger Cars, requires, among other things, a placard, permanently affixed to the glove compartment door or an equally accessible location. The placard must contain all of the information spelled out in Part S.4.3 of that Standard, a copy of which is contained in the enclosed booklet on page 19. Tire labeling requirements along with test procedures are listed under Federal Motor Vehicle Safety Standard No. 109, on pages 12 through 19.

The tire to which you refer is a 2-ply 4-ply rated tire. The load ratings for a 855-14 tire can be found on page 15 of the enclosed booklet. The maximum load rating is 1,770 lbs. at the maximum inflation pressure of 32 p.s.i.

It is important for you to note that the test procedures have to do with new tires. We have no procedures for testing tires that have failed.

Although we do not become involved in private litigations, there is a publication for sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402, under the title, "Automobile Accident Litigation - A Report to the Federal Judicial Center to the Department of Transportation," that might be of interest to you. The price for the publication is $ 2.75.

We are also enclosing the following publications:

The National Traffic and Motor Vehicle Safety Act of 1966

Summary of 1968 Compliance Tests Arranged by Standard, that includes a General 855-14 tire and, a form letter explaining the Bureau's position relative to test results and where they might be obtained.

We trust this information will be useful to you.

ID: nht70-1.15

DATE: 10/01/70

FROM: C. A. Baker for R. H. Compton; NHTSA

TO: Barrington Homes of Florida, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of September 14, 1970, to Mr. Rodolfo A. Diaz, Acting Associate Director for Motor Vehicle Programs, National Highway Safety Bureau concerning clearance lights on mobile homes.

A mobile home moved on its own wheels is a "motor vehicle" under the National Traffic and Motor Vehicle Safety Act, and is categorized as a "trailer".

Federal Motor Vehicle Safety Standard No. 108 requires clearance lamps to be installed on trailers 80 or more inches in overall width. In transit a mobile home towed on its own wheels must therefore be equipped with clearance lamps; however, these lamps may be temporarily installed and removed when the mobile home has reached its destination.

We would appreciate your providing us, if possible, with the names of manufacturers of mobile homes whom you believe to be towing these vehicles without equipping them with lighting devices meeting Standard No. 108. This will assist us in our efforts to insure that all manufacturers meet their obligations under the Act.

ID: nht70-1.16

DATE: 08/01/70 EST

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

TO: Transelex Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of August 5 discussing your "new type of warning beacon' for use on emergency vehicles.

The photometric test action of SAE Recommended Practice J845,(Illegible Words) Emergency Warning Lamp refers to both "lamps flashed by rotation or oscillation" and lamps flashed by current interruption". The letter phrase appears to cover the Transelex lamp as you have described it, and we interpret J845 as applicable. Our interpretation would seem to answer your question on AAMVA approval.

Current Federal lighting requirements do not cover warning lamps, and even if they did, no Department of Transportation approval would be required. Under the National Traffic and Motor Vehicle Safety Act of 1966 it is the manufacturer of motor vehicles or equipment to which a standard applies who certifies compliance with that standard.

Sincerely,

ID: nht70-1.17

DATE: 03/17/70

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: The Auto Sun Products Company

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of February 13 indicates that your understanding of the regulatory situation is correct. There is no prohibition in the motor vehicle safety standards against the sale of a non-conforming attachment bolt as a separate item. All that Standard No. 209 requires is that the seat belt assemblies which your firm supplies must be accompanied by conforming attachment bolts.

Before you act on your understanding, however, you should give special consideration to the consequences of any widespread use of attachment bolts which do not conform to the strength and other requirements of the standard. If, for example, we found that vehicle owners were being induced to secure their aftermarket seat belts to anchorages by the use of attachment bolts that do not provide adequate strength in crash situations, we would be compelled to consider whether the public interest would require rulemaking action aimed at preventing the marketing of such understrength bolts. We appreciate your desire not to evade the regulations or take advantage of what may be considered a loophole in them.

Sincerely,

ID: nht70-1.18

DATE: 04/01/70 EST.

FROM: Lawrence R. Schneider; NHTSA

TO: Motion Development

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of June 23 requesting confirmation that vehicles with a curb weight of 1,000 pounds or less are not required to meet Federal motor vehicle safety standards.

As Mr. Vinson of my staff informed you, 49 CFR @@571.7(a) requires conformance to Federal standards of "motorcycles and trailers regardless of weight and...all other motor vehicles over 1,000 pounds curb weight." Thus your dune buggy with a "weight" of 385 pounds appears to be exempt from the Federal standards.

ID: nht70-1.19

DATE: 07/01/70 EST

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Department of California Highway Patrol

TITLE: FMVSR INTERPRETATION

TEXT: In response to your letter of July 9 to Mr. Toms I would like to make clear that the creation of the subcategory "mobile structure trailer" does not remove mobile homes towed on their own wheels from their original categorization under the Federal motor vehicle safety standards as trailers. This means that rule making actions applicable to "trailers" are also applicable to mobile homes unless there is specific language indicating that a Federal standard or portion thereof does not apply to a mobile structure trailer.

Therefore, in answer to your specific questions:

(a) Proposed Standards Nos. 119 and 120 would apply to trailers and therefore to mobile structure trailers.

(b) No proposal has been issued which would extend the Federal hydraulic brake standard, No. 105, to cover trailers. Therefore a State may adopt hydraulic brake requirements for mobile homes. However, we have issued a proposal (Docket No. 70-16; 35 F.R. 10456, June 26, 1970) which would establish requirements for "trailers equipped with air brake systems". If adopted, this new standard would preclude a state from adopting other than identical air brake requirements for mobile homes and other trailers. The point may be academic as it is my understanding that mobile homes, as a rule, are equipped with electric brakes.

ID: nht70-1.2

DATE: 10/06/70

FROM: AUTHOR UNAVAILABLE; G. C. Nield; NHTSA

TO: European Tyre and Rim Technical Organization

TITLE: FMVSS INTERPRETATION

TEXT: (Illegible Text)