ID: nht88-1.13

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Harris W. Fawell

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Harris W. Fawell House of Representatives Washington DC 20515

Dear Mr. Fawell:

I have been asked to respond to your recent letter asking the Department of Transportation to provide you with information concerning the use of safety belts on school buses. You ask for this information on behalf of your constituent, Mr. Wayne Mann, in the Illinois Palos Community Consolidated Schools. Mr. Mann specifically seeks "factual information relative to seat (lap) belts on school buses," and information on funding for traffic safety programs involving hazardous conditions outside the school bu s.

I would like to begin with some background information on our school bus regulations. The National Highway Traffic Safety Administration (NHTSA) is responsible for developing safety standards applicable to all new motor vehicles, including school buses. In 1977, we issued a set of motor vehicle safety standards regulating various aspects of school bus performance. Among those standards is Standard 222, School Bus Passenger Seating and Crash Protection. Standard 222 requires large school buses (those wit h a gross vehicle weight' rating over 10,000 pounds) to have passenger crash protection through a concept called "compartmentalization."

Compartmentalization requires large school buses to incorporate certain protective elements into the vehicles' interior construction, thereby reducing the risk of injury to school bus passengers without the need for safety belts. These elements include h igh seats with heavily padded backs and improved seat spacing and performance. (Our regulations require a safety belt for the school bus driver because the driver's 'position is not compartmentalized. Further; because small school buses experience greate r force levels in a crash, passengers on these vehicles need the added safety benefits of the belts.)

School buses continue to have one of the lowest fatality rates for any class of motor vehicle. Large school buses are among the safest motor vehicles because of their size and weight (which generally reduce an occupant's exposure to injury-threatening 'c rash forces'); the drivers' training and experience: and the extra care other motorists take when they are near a school bus. For these reasons, NHTSA has not required safety belts in large school buses.

I enclose a copy of a June 1985 NHTSA publication titled "Safety Belts in School Buses," which discusses many of the issues relative to this subject. I think your constituent may find this information helpful.

With respect to hazardous conditions outside the school bus, the agency realizes that there are special problems of driver visibility associated with transporting students. NHTSA has addressed these problems in Federal Motor Vehicle Safety Standard 111, Rearview mirrors, paragraph S9. In 1975, NHTSA established special mirror requirements for school buses "to reduce the danger of death or injury to school children (by giving) the school bus driver the fullest possible view of all sides of the vehicle... " (The proposed rule, including this preamble quotation, appears at 40 FR 33828, 33829, August 12, 1975. The final rule was published originally at 41 FR 36023, August 26, 1976.) One of these special requirements is that manufacturers equip a school bus with a crossview mirror that permits the driver to see the area in front of the bus. These special school bus mirror requirements help contribute to the low number of fatalities associated with school bus travel.

Your constituent also mentions funding to implement a program to address hazardous conditions outside the school bus. The agency believes that its school bus regulations effectively address the safety of school bus design and performance, and contribute to occupant safety.

We note, however, that 5402 of the Highway Safety Act, provides funds to each State for its use in conducting a highway safety program. Some of these funds are distributed by the State to local governments or organizations within the State. To get inform ation on Illinois' S402 funds, I suggest that your constituent contact the Illinois Governor's Representative for Highway Safety, Mr. Melvin E. Smith, Director, Division of Traffic Safety, 319 Administration Bldg., 2300 South Dirksen Pkwy., Springfield, IL 62764.

If you or Mr. Mann have further questions, I encourage you to contact our agency.

Sincerely, Erika Z. Jones Chief Counsel Enclosure

ID: nht88-1.14

TYPE: INTERPRETATION-NHTSA

DATE: JANUARY 12, 1988

FROM: ROBIN C. GELBURD -- MORRISON & FOERSTER

TO: ERIKA C. JONES -- CHIEF COUNSEL-NHTSA

TITLE: COMPLIANCE WITH 49 C.F.R. @ 571.213 "CHILD RESTRAINT SYSTEMS"

ATTACHMT: ATTACHED TO MAY 31, 1988 LETTER FROM JONES TO GELBURD

TEXT: We represent Hasbro, Inc. and seek an opinion from the National Highway Traffic Safety Administration ("the Agency") about whether a proposed Hasbro product would, in any way, contravene or compromise regulations promulgated by the Agency pursuant to the National Traffic and Motor Vehicle Safety Act -- specifically 49 C.F.R. @ 571.213, the regulation pertaining to Child Restraint Systems.

The product, which we have enclosed for your convenience and evaluation, is intended, inter alia, to be used in conjunction with a car seat restraint; it would be inserted inside the seat to cushion and insulate the child. It should be noted that the product, as finally marketed, will have two additional features:

1. A pocket will be added below the word "Playskool" which will contain a squeaking teddy bear made of 100% spun polyester; and

2. A set of plastic keys on a key ring, detachable with velcro, will be added on the end of the yellow tether. Each key will be 2-1/8 inches long and will have rounded edges.

Please advise me if any further information is necessary to determine whether the product complies with relevant statutes and regulations within your jurisdiction.

We appreciate your prompt consideration of this matter.

Enclosure

ID: nht88-1.15

TYPE: INTERPRETATION-NHTSA

DATE: 01/13/88

FROM: L.F. ROLLIN -- COMMANDER COMMERCIAL AND TECHNICAL SERVICES SECTION DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

TO: THOMAS A. COZ -- LAW DEPARTMENT NORTH AMERICAN VAN LINES

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/24/89 FROM STEPHEN P. WOOD -- NHTSA TO THOMAS A. COZ -- NORTH AMERICAN VAN LINES; REDBOOK A34; STANDARD 108; LETTER DATED 04/28/89 FROM THOMAS A. COZ -- NORTH AMERICAN VAN LINES TO NHTSA, RE HIGH MOUNTED TRAILER STOP LAMPS/TURN SIGNALS; OCC 3469

TEXT: Dear Mr. Coz:

This is in response to your December 30, 1987, letter requesting an "Experimental Devices Permit" for high mounted stop lamp/turn signals which are installed on some North American Van Lines trailers.

No experimental device permit is necessary since these supplemental lamps are currently permitted by the California Vehicle Code. However, these lamps are in violation of Federal Motor Vehicle Safety Standard 108 (FMVSS 108). FMVSS 108 specifies mounti ng heights for brake lights (not less than 15 inches nor more than 72 inches) and turn signals (not less than 15 inches nor more than 83 inches) above the level roadway surface. Both the trailer specifications and the trailer picture you provided show t he lamps to be mounted above the mounting heights specified in FMVSS 108.

The National Highway Traffic Safety Administration (NHTSA) confirmed that all brake lights and turn signals installed by a manufacturer of vehicles must conform to the FMVSS 108 mounting requirements. NHTSA does not differentiate between required or "su pplemental" lights on trailers. The FMVSS 108 restrictions on mounting do not apply to equipment installed by the owner.

If you have any questions, please contact Mr. Ellis Hirst our staff engineer for clarification.

Very truly yours,

ID: nht88-1.16

TYPE: INTERPRETATION-NHTSA

DATE: 01/14/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Nissan Research & Development, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Toshio Maeda Executive Vice President & Chief Operating Officer Nissan Research & Development, Inc. P.O. Box 8650 Ann Arbor, Michigan 48104

Dear Mr. Maeda:

This is in reply to your letter of June 30, 1987, asking for an interpretation of paragraph 54.1.1.36(b)(3) of Motor Vehicle Safety Standard No. 108.

That paragraph specifies in pertinent part that a replaceable bulb headlamp shall be designed to conform to Section 6.1-Aiming Adjustment Test, of SAE Standard J580 AUG79 Sealed Beam Headlamp Assembly. Section 6.1.1 states that "when the headlamp assembl y is tested in the laboratory, a minimum aiming adjustment of +/-4 deg. shall be provided in both the vertical and horizontal planes." You have asked whether the aiming adjustment is to be achieved by the headlamp assembly, or by both the headlamp assemb ly "and by the headlamp when it is mounted on the vehicle."

SAE J580 applies to the design of headlamp assemblies, including the functional parts other than the headlamps, such as aiming and mounting mechanisms and hardware. The assembly may include one or more headlamps. Although the headlamp assembly is tested in the laboratory, its design must be identical to the headlamp assembly used on the vehicle. Thus, if the aiming adjustment requirement is met by the headlamp assembly in the laboratory, it should also be met when the assembly is installed on the vehicl e. An individual headlamp installed on the vehicle need not meet the aiming adjustment test unless that headlamp is part of a headlamp assembly comprising only one headlamp.

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

June 30, 1987 Ref: W-253-H

Ms. Erika Jones Chief Counsel National Highway Traffic Safety Administration 400 7th St., S.W. Room 5219 Washington, D.C. 20590

Dear Ms. Jones:

Nissan Research & Development, Inc., on behalf of Nissan Motor Company, Ltd. of Tokyo, Japan, hereby submits this request for an interpretation relating to the replaceable bulb headlamp aiming provisions in Federal Motor Vehicle Safety Standard 108, "Lam ps, Reflective Devices and Associated Equipment."

Among its requirements, S4.1.1.36(b) (3) of Standard 108 stipulates that the replaceable bulb headlamp shall be designed to conform to Section 6.1 - "Aiming Adjustment Test" of SAE J580 AUG79, "Sealed Beam Headlamp Assembly.

Item 6.1.1 of the above-referenced "Aiming Adjustment Test" states that, "when the headlamp assembly is tested in the laboratory, a minimum aiming adjustment of + 4 deg. shall be provided in both the vertical and horizontal planes."

Nissan's question is whether this minimum aiming adjustment requirement is to be achieved:

1. by the headlamp assembly (by the component unit) itself, or

2. by both the headlamp assembly (as a component unit)

and by the headlamp when it is mounted on the

vehicle?

Erika Jones June 30, 1987 Page Two

Thank you very much for your assistance. Please contact Mr. Tomoyo Hayashi of my Washington staff at (202) 466-5284, if you have any questions or require further details. I would appreciate it if you would please also notify Mr. Hayashi when your respons e has been issued.

Sincerely,

Toshio Maeda Executive Vice President & Chief Operating Officer

ID: nht88-1.17

TYPE: INTERPRETATION-NHTSA

DATE: 01/15/88

FROM: ALICE COLLINS

TO: ERIKA Z JONES -- CHIEF COUNSEL NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/01/88 TO ALICE COLLINS, FROM ERIKA Z. JONES, REDBOOK A32, PART 571.3

TEXT: Dear Ms Jones,

I am behind, to say the least, in writing you.

I am a parent of three children. Two of school age. Plus I do a lot of volunteer work for two school. Part of my volunteer work is driving for field Trips.

I checked out my new vehicle for over 1 year before buying. I chose a 1986 (new) Ply. Voyger mini-van and then in the 1986-87 school year your dept. decided they were unsafe. But in your letter to Mr. Larry H McEntire Administrator, School Transport ation - Fl. Dept. of Education, Dated Aug 7, 1986.

2 I noted that Ply. Voyger was not listed. And the classification of M.P.C. was used on all mini vans, are not these classification made for several reason - and $ having one big reason for foreign vehicle.

Anyway, I am sure you have had many letter, phone calls etc in the past year over parent using vans to transport children for school trips So please review the papers enclose, I feel you see that the Ply. Voyger meet more requirements of a passenger c ar than a truck.

Please review this Mini Van. I feel my children and family are safe in my voyger than a car. No one wants to have an accident. And even the school buses that have been in accident lately have had had injurys - crush tops & sides. Where are the seat Belts?

3

I feel your Department is closing the doors to a better answers to transport our children on short field trips.

You know the driver counts for more than just the kind of vehicle. The driver should be $99[Illegible Word]

Our children are missing out on alot of short educational trips. The schools can not afford to use schools buses for the short trips.

Will Amy Ukey please read enclosed papers and let me know if there is any way to change the Department decision on the Ply. Voyger Mini-Van.

Thank you

Do you have a toll free Phone Number?

(Attachments omitted.)

ID: nht88-1.18

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable William Broomfield

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable William Broomfield United States House of Representatives Washington, DC 20515

Dear Mr. Broomfield:

Thank you for your letter, cosigned by Congressmen Bob Carr and Carl Pursell, urging favorable consideration of a petition for reconsideration of Standard No. 208, Occupant Crash Protection. This petition was filed by C and C, Incorporated, and asked us to reconsider our decision to treat convertibles just like all other passenger cars for the purposes of Standard No. 208, as of September 1, 1989. Further, the petition asked us to change our long-standing interpretation that T-top vehicles are not conve rtibles.

We have not yet completed our analysis and response to this petition. We will consider your views, as well as the arguments presented in the petition, in reaching our final decision. I will see that you are informed of our response to this petition as so on as the analysis is completed.

I have placed a copy of your letter and this response in the public docket for this petition. If you have any further comments or need additional information on this subject, please let me know.

Sincerely,

Diane K. Steed

cc: The Honorable John D. Dingell The Honorable William Lehman

Congress of the United States House of Representatives Washington, DC 20515

January 11, 1988 The Honorable Diane K. Steed Administrator National Highway Traffic Safety Administration Department of Transportation 400 Seventh St., S.W. Washington, DC 20590

Dear Ms. Steed:

We understand that on April 29 and October 19, 1987, C and C, Incorporated of Michigan filed a petition for reconsideration (Docket No. 74-14, Notice 51) of a Notice published in the March 30 Federal Register (52 F.R. 10122). We am also aware of your age ncy's notice of October 17, 1986 (51 F. R. 37028, 37029) wherein you concluded that a "vehicle with a T-bar roof would not be considered a convertible." In the March Notice, we understand NHTSA declined reconsideration of a Toyota petition "to exclude T- bar roof vehicles from the automatic restraint requirement." Your Notice explains:

Toyota said that "due to the lack of a door frame or a roof side rail structure, it is impossible to install an automatic belt that is acceptable to customers to the T-bar roof vehicles in view of current technology." Toyota said it will have to disconti nue T-bar roof vehicles after September 1, 1989, unless those vehicles are excluded from the automatic restraint requirement.

NHTSA has decided to retain its current interpretation of the term convertible and thus, is not adopting the proposed revision requested by Toyota. As discussed earlier in this notice, driver-side air bags and automatic safety belt systems will be availa ble for use in convertibles. Since those systems are available for convertibles, Toyota and other manufacturers of cars with T-bar roofs can use those same systems to comply with the performance requirements of the standard.

We observe that C and C's April 29 letter takes issue with the basis for this conclusion, such as your reference to an Alfa Romeo device.

We understand that you have not acted on the C and C petition which raises factual and economic issues unique to this firm and not to Toyota. Those issues, particularly the potential job loss, are not addressed in your March 30 Notice. They would probabl y not be significant in the case of Toyota. They are very significant for this firm. We understand that one manufacturer, Ford Motor Company', has canceled a T-roof contract. That may or may not be related to this matter, but it bodes badly for this firm and its workers.

We point out also that C and C is not seeking a permanent exemption from the 208 rule.

We urge favorable consideration of this petition for reconsideration and development of a proposal that will not cause a job loss at this firm.

Sincerely,

WILLIAM BROOMFIELD BOD CARR CARL PURSELL Member of Congress Member of Congress Member of Congress

cc: The Honorable John D. Dingell, Chairman Committee on Energy and Commerce

The Honorable William Lehman, Chairman Subcommittee on Transportation and related Agencies Committee on Appropriations

ID: nht88-1.19

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: The Honorable Bob Carr

TITLE: FMVSS INTERPRETATION

TEXT:

The Honorable Bob Carr United States House of Representatives Washington, DC 20515

Dear Mr. Carr:

Thank you for your letter, cosigned by Congressmen William Broomfield and Carl Pursell, urging favorable consideration of a petition for reconsideration of Standard No. 208, Occupant Crash Protection. This petition was filed by C&C, Incorporated, and ask ed us to reconsider our decision to treat convertibles just like all other passenger cars for the purposes of Standard No. 208, as of September 1, 1989. Further, the petition asked us to change our long-standing interpretation that T-top vehicles are not convertibles.

We have not yet completed our analysis and response to this petition. We will consider your views, as well as the arguments presented in the petition, in reaching our final decision. I will see that you are informed of our response to this petition as so on as the analysis is completed.

I have placed a copy of your letter and this response in the public docked for this petition. If you have any further comments or need additional information on this subject, please let me know.

Sincerely,

Diane K. Steed

cc: The Honorable John D. Dingell The Honorable William Lehman

Congress of the United States House of Representatives Washington, DC 20515

January 11, 1988

The Honorable Diane K. Steed Administrator National Highway Traffic Safety Administration Department of Transportation 40O Seventh St., S.W. Washington, DC 20590

Dear Ms. Steed:

We understand that on April 29 and October 19, 1987, C and C, Incorporated of Michigan filed a petition for reconsideration (Docket No. 74-14, Notice 51) of a Notice published in the March 30 Federal Register (52 F.R. 10122). We am also aware of your age ncy's notice of October 17, 1986 (51 F. R. 37028, 37029) wherein you concluded that a "vehicle with a T-bar roof would not be considered a convertible." In the March Notice, we understand NHTSA declined reconsideration of a Toyota petition "to exclude T- bar roof vehicles from the automatic restraint requirement." Your Notice explains:

Toyota said that "due to the lack of a door frame or a roof side rail structure, it is impossible to install an automatic belt that is acceptable to customers to the T-bar roof vehicles in view of current technology." Toyota said it will have to disconti nue T-bar roof vehicles after September 1, 1989, unless those vehicles are excluded from the automatic restraint requirement.

NHTSA has decided to retain its current interpretation of the term convertible and thus, is not adopting the proposed revision requested by Toyota. As discussed earlier in this notice, driver-side air bags and automatic safety belt systems will be availa ble for use in convertibles. Since those systems are available for convertibles, Toyota and other manufacturers of cars with T-bar roofs can use those same systems to comply with the performance requirements of the standard.

We observe that C and C's April 29 letter takes issue with the basis for this conclusion, such as your reference to an device.

We understand that you have not acted on the C and C petition which raises factual and economic issues unique to this firm and not to Toyota. Those issues, particularly the potential job loss, are not addressed in your March 30 Notice. They would probabl y not be significant in the case of Toyota. They are very significant for this firm. We understand that one manufacturer, Ford Motor Company, has canceled a T-roof contract. That may or may not be related to this matter, but it bodes badly for this firm and its workers.

We point out also that C and C is not seeking a permanent exemption from the 208 rule.

We urge favorable consideration of this petition for reconsideration and development of a proposal that will not cause a job loss at this firm.

Sincerely,

WILLIAM BROOMFIELD BOB CARR CARL PURSELL Member of Congress Member of Congress Member of Congress

cc: The Honorable Jon D. Dingell, Chairman Committee on Energy and Commerce

The Honorable William Lehman, Chairman Subcommittee on Transportation and related Agencies Committee on Appropriations

ID: nht88-1.2

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/88 EST

FROM: SAF-TEE SIPING & GROOVING INC.

TITLE: NONE

ATTACHMT: ATTACHED TO DECEMBER 30, 1988 LETTER FROM JONES TO SPRUNK, OCTOBER 8, 1987 LETTER FROM SPRUNK TO JONES, 1978 NSC WINTER TEST REPORT, AUGUST 19, 1986 LETTER FROM KEIL TO SPRUNK, ARTICLE FROM AUGUST 1986 ISSUE OF "SCHOOL BUSINESS AFFAIRS," ARTICL E ENTITLED "SLASHING TIRES FOR SAFETY AND SAVINGS" FROM DECEMBER 1984 "NATIONAL SCHOOL BUS REPORT," MARCH 20, 1985 LETTER FROM GIFFORD TO SPRUNK, OCTOBER 15, 1982 LETTER FROM PALMER TO MARCY MANUFACTURING, AND APRIL 1983 AND APRIL 1984 ARTICLES FROM "GW SAFETY TALK"

TEXT: For SIPING mounted passenger car tires & light duty truck tires

Our model SP Saf-Tee siper is designed specifically for passenger and light duty tires which are mounted on wheels. The machine comes equipped with 12 blades along with the 4 lead screws for siping depths of 5/32", 7/32", 9/32" and 11/32", a wrench for changing the lead screws and a file for sharpening the blades. The machine also comes standard with the Universal Passenger Adapter that will accommodate any wheels that have an opening of 1.75" up to 5 1/2" center hole. This machine has recently been redesigned and the lifting height of the tire has been lowered. It is fast, easy to operate and takes less than 3 minutes to mount, sipe and dismount the tire. The machine requires very little room and operates with 110 power and air.

This machine is an excellent profit builder for a tire operation or anyone who services automobiles and light duty vehicles. With the advent of high performance tires siping is becoming increasingly popular as a way to offer these tires traction and sta bility on wet and slippery surfaces, in addition to extending the tire life.

FEATURES:

* Fast . . . entire siping process takes less than three minutes.

* Exclusive spiral cut creates "tie bars" that strengthen tread components to reduce chunking.

* 90 degrees angle cut across tire gives most traction opposite to the line of travel and desired braking vector.

* Sipes remain sharp and gripping -- can be accomplished only by siping after tire is manufactured.

* Profitable. You get repeat business from satisfied customers. You give them increased safety, reduced operating costs and better tire performance.

SPECIFICATIONS: Height 38"

Width 27"

Side Width 34"

Weight 200lbs.

Motor 1 HP, 110 (standard)

The concept of siping was first patented in the 1920s by John Sipe, who made a series of small cuts in his shoes to give him better traction. The idea is not new, but modern technology has developed siping machines to a high level of sophistication. Siping cannot be duplicated during manufacturing because it leaves a small void of rubber between the sipes. After a short period of time it becomes round and ineffective. Saf-Tee sipes cut into the tire, remove no rubber and the edges remain sharp an d gripping.

Saf-Tee siping machines cut slits at a 90 degrees angle across the tire tread, from 5/32" to 11/32" deep. These slits create thousands of sharp, gripping edges to provide extra traction, safer braking and actually extend the life of the tire as a res ult of dissipation of heat on highway travel. Siping across the tire gives the most traction opposite to the line of travel and desired braking vector.

RUNNING

Under normal road conditions: The ribs flex, responding to bumps and pits in the road, reducing shock to carcass and sidewalls. The tire runs cooler. Under wet, icy snow conditions: The ribs flex, the sharp, exposed edges cut through the hazard squeege eing the water out of the way.

ACCELERATION

Positive traction starts and acceleration in all weather conditions . . . spin on snow and ice is drastically reduced: The ribs separate and expose the sharp squeegee edges to cut to the road surface and channel the hazard out of the way. And . . . sipin g reduces tread wear, extending tire life.

BRAKING

Straight line braking: Without jacknifing, fishtailing or skids. The ribs separate, squeegeeing the hazard or road film away, giving the tire a sure-footed grip on the road surface. Siped tires greatly reduce heat buildup in braking and reduces tire we ar. Siped tires greatly reduce the distance needed to stop.

TESTS

Tests conducted by the National Safety Council on the performance of siped vs. unsiped tires on ice resulted in a 64% increase in breakaway traction and an increase of 28% spinning traction. In stopping distance tests, the reduction was from 200 feet to 155.6 feet -- a 22% improvement.

Major airline engineers tested the use of siping on ground equipment vehicles at O'Hare Field. They recorded a 25.72% increase in drawbar pull on a wet ramp flooded with glycol from deicer. They also show a 33.96% increase in braking under the same conditions. Tests were made before and after siping. As a result of these tests, they have saved thousands of dollars by reducing the need for chains on all vehicles.

The winning car in the Uniroyal One Lap of America auto rally was equipped with siped B. F. Goodrich tires. The 8,800 mile, eight-day endurance race began in Detroit, traveled through 28 states, and ended back at Detroit. Even though the driver enco untered near-blizzard conditions with snow and ice in the mountains, he had no trouble with traction. After the rally the siped tires were just like new.

Saf-Tee sipers employ a circular knife to make slits around the circumference of the tire. This causes the bottom of the sipe to form a scallop pattern, providing a varied depth and strength tie between adjoining sipes. Unlike the uniform depth cut of other siping processes, these scalloped "tie bars" reinforce tread components.

WHAT THEY SAID:

"At the present time we operate three retail stores all dealing in passenger and light duty vehicles. We have a siping machine in each of these stores and in the last twelve months our income has been $ 28,000 from siping."

-- Earl Springer, VP

Roemers Tire Centers, Missoula, MT

"On three sets of our logging tires siped at 11/32 deep the results were 40% less useage of chains, less abrasive damage to tread area and 7%-10% more mileage."

-- Larry Gifford, Service Rep.

Yokohama Tire Corporation

"Increased safety and reduced operating cost don't always go together but with Saf-Tee siped tires, they do. There is no way that I would go back to running without them."

-- Bob Beach

Beach Bus Service, Missoula, MT

"We experienced severe handling problems on snow and ice with police vehicles. In an effort to improve this performance we siped tires on several of these vehicles and ran tests. We found we could negotiate 90% comers safely on ice at 25-30 miles per ho ur after siping where previously we could control the car only at 10 miles per hour. Braking was increased in all cases by 30%."

-- Lynn L. Keil City of Billings, Billings, MT

"The improved safety record of our 44 trucks has earned lower insurance rates."

-- Jim Palmer Trucking, Missoula, MT

"Our truck and trailer tires have 20% better wear after siping."

-- Holland Trans. Co., Fargo, ND

"The traction on ice/snow covered surfaces was much improved."

-- Wayne County Sheriff, Wooster, OH

"Since the tires were siped on our tank truck, we find that braking is better. Tires last longer too."

-- Terreberry Septic Service Ltd.

Port Colborne, Ontario

Call for more information, test results, testimonials, specifications and prices.

For SIPING mounted tires from 12" to 24.5"

The Model ST is our most popular siping machine because it is a multi-purpose unit -- it can sipe any tire from 12" to 24.5". with the adapters available. It's easy to run: operators can be trained in 15 minutes. It's fast: the process takes only 3 to 4 minutes per tire to perform. Any type of tire can be siped -- new, re-cap, or used -- as long as it has 5/32" of tread left. Twelve cutting blades are furnished with the ST, along with four lead screws for siping depths of 5/32", 7/32", 9/32" and 11/3 2", a file, and a wrench for switching lead screws.

FEATURES:

* Fast . . . three to four minutes per tire.

* Versatile. Depth and width of sipe can be changed in seconds. Five depths: 5/32", 7/32", 9/32", 11/32" and 13/32". Two widths: 4 to the inch, 5 to the inch. Five angles: 90 degrees standard, and optional 45 degrees right or left, 60 degrees right o r left.

* Reliable. Machines have been in operation for over 15 years, trouble free. Siping does not affect the tire warranty of major tire manufacturers.

* Profitable. Permits servicing wide range of customers. Truckers buy their tires from dealers who offer siping services.

* Exclusive spiral cut creates "tie bars" at bottom of scalloped sipe to strengthen tread components.

* Marketing assistance. A factory-trained rep will set up the machine, instruct operators, and provide a complete promotional package to help sell siping services to your customers.

SPECIFICATIONS:

Height 42"

Width 34"

Side Width 36"

Weight 250 lbs.

Motor 1 HP,110(standard)

For HIGH VOLUME SIPING before mounting on wheels

The Model STE Siper is designed for use by a retreader, large retailer or wholesaler of tires for volume siping before tires are mounted on wheels. The STE is fast. The rim inflates in about five seconds after the operator positions the tire. The whol e process, including the siping, takes less than three minutes.

The Model STE is equipped with an expandable hub to handle rims to fit tire sizes from 13" to 24.5". Four different size rims are needed to accomodate these sizes -- one from 13" to 16", 17" to 20", 20" to 22.5" and 22.5" to 24.5". Rims are optional equ ipment to be selected depending on the tire sizes you most frequently sipe.

Twelve cutting blades are furnished with the STE, along with four lead screws for siping depths of 5/32", 7/32", 9/32" and 11/32" and a wrench for changing the lead screws.

FEATURES:

* Fast . . . entire siping process takes less than three minutes.

* Exclusive spiral cut creates "tie bars" that strengthen tread components to reduce chunking.

* 90 degrees angle cut across tire gives most traction opposite to the line of travel and desired baking vector.

* Sipes remain sharp and gripping -- can be accomplished only by siping after tire is manufactured.

* Profitable. You get repeat business from satisfied customers. You give them increased safety, reduced operating costs and better tire performance.

SPECIFICATIONS:

Height 45"

Width 42" Side Width 40"

Weight 450 lbs.

Motor 1 HP, 110 (standard)

Blades Available from Saf-Tee Siping & distributors

AVIATION GROUND EQUIPMENT SHOWS NEARLY 34% INCREASE IN PERFORMANCE AFTER SAF-TEE (registered) SIPING

This chart shows documented proof of the dramatic increase in draw bar pull that can be expected with the use of "Siped" tires. Siping can reduce the need for tire chains on all your vehicles. Chains are costly and dangerous especially on airport surfa ces. The outlawing of sludded tires made our need even greater. At United where I managed the ground equipment maintenance, we Siped all drive wheel tires, and also some front tires depending on application.

Thousands of dollars were saved by United at O'Hare by reducing the need for chains on all vehicles. They have been using Siped tires for 6 years. For economy and safety I see Siping as a must in all Airport operations.

C.N. HOSTERT

Equipment Maintenance Manager-Retired

O'Hare Field

United Airlines

TIRE SIPING TEST

GATOR TRACTOR 30500# AT 55

TEST ACCOMPLISHED USING DIGAL READOUT DYNAMOMETER ATTACHED TO REAR HITCH OF GATOR AND FRONT HITCH OF T800 WHICH WAS USED FOR LOAD. A. DRAWBAR PULL BEFORE DRY CONCRETE RAMP SIPING AFTER SIPING % INCREASE TEST 1: 14250 15000 5.26% TEST 2: 14200 15300 7.75% TEST 3: 14350 15800 10.10% AVG. 7.70% WET RAMP (FLOODED WITH RUNNING WATER) TEST 1: 11800 13200 11.86% TEST 2: 11900 12800 7.56% TEST 3: 11650 12500 7.30% AVG. 8.91% WET RAMP GLYCOL (FLOODED WITH GLYCOL FROM DEICER) TEST 1: 9750 12400 27.18% TEST 2: 9700 12160 25.36% TEST 3: 9550 11900 24.61% AVG. 25.72%B. BRAKING TEST ACCOMPLISHED STATIC BY LOCKING BRAKES ON GATOR AND DRAGGING WITH T800 BEFORE DRY CONCRETE RAMP SIPING AFTER SIPING % INCREASE TEST 1: 13000 13800 6.15% TEST 2: 13100 14000 6.87% TEST 3: 13200 13950 5.68% AVG. 6.23% WET RAMP (FLOODED WITH RUNNING WATER) TEST 1: 10700 13450 25.70% TEST 2: ? 13600 ? TEST 3: 11200 13900 24.11% AVG. 24.90% WET RAMP . GLYCOL (FLOODED WITH GLYCOL FROM DEICER) TEST 1: 8700 12270 41.03% TEST 2: 9500 12380 30.32% TEST 3: 9500 12400 30.53% AVG. 33.96%

Test conducted by United Airlines Engineers

ID: nht88-1.20

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Frank S. Perkin -- Assistant General Counsel, The Budd Company

TITLE: FMVSS INTERPRETATION

ATTACHMT: 9/22/86 letter from Erika Z. Jones to Steven R. Taylor; 2/7/83 letter from Frank Berndt to H.J. Lindekugel

TEXT:

Frank. S. Perkin, Esq. Assistant General Counsel The Budd Company Law Department 3155 West Big Beaver Road Box 2601 Troy, Michigan 48084

This responds to your letter expressing concern about a statement in one of our interpretation letters, which you believe could be read as condoning the practice of rebuilding wheels by processes which include heading and welding. As discussed below, our letter's reference to remanufacturing wheels was made only to serve as an illustrative example. and was not intended to address either the safety of such processes or the relevant regulations of other Federal agencies.

The interpretation letter in question is one that we sent on September 22, 1986, to Steven R. Taylor, responding to a request concerning regulations that apply to manufacturers of reconditioned brake drums. The letter included the following paragraph:

NHTSA has in the past considered the issue of what types of operation; bake a person a manufacturer with respect to retreaded tire; and remanufactured wheels. A person who retreads tires is considered to be a manufacturer under the Vehicle Safety Act. Th e retreading process involves significant manufacturing operations, which do not differ substantially from those of manufacturing new tires. By contrast, a person who remanufactures wheels is not considered to be a manufacturer under the Vehicle Safety A ct. The process of remanufacturing wheels consists of such things as straightening, re-welding parts, and repairing cracks by welding. These types of actions are not significant manufacturing operations, but instead are the type of operations commonly pe rformed in repair shops.

You stated that all of the things mentioned in our letter, i.e., straightening, re-welding parts and repairing cracks by welding, are specifically prohibited by the OSHA standard applicable to truck wheels, both multi and single piece. You also stated th at the "out of service" criteria adopted by the Bureau of Motor Carrier Safety mandate that a vehicle be placed out of service if welded repairs are found on certain disc wheels. According to your letter, any significant changes made after the manufactur e of a steel truck wheel, especially involving bending, heating or welding, carry a significant risk of rendering the wheel unsafe.

As is indicated from the context of our September 22, 1986 interpretation letter, the reference to remanufacturing wheels was made solely for the purpose of providing an illustrative example and was not intended to address either the safety of such proce sses or their permissibility or impermissibility under the relevant regulations of other Federal agencies. I would note that NHTSA has long taken the position that remanufactured wheels are considered to be used wheels instead of new wheels for purposes of Federal motor vehicle safety standards. See, for example, our November 28, 1973 letter addressed to Mr. L. Clinton Rich and February 7, 1983 letter to Mr. H. J. Lindekugel (copies enclosed). Again, however, these letters do not purport to address the safety of remanufacturing wheels or the relevant regulations of other Federal agencies.

We appreciate your bringing to our attention your concern about the safety of remanufactured wheels. Copies of this correspondence are being placed in the public docket.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

Erika Z. Jones Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation Washington. D.C.

Dear Ms Jones:

Reference is made to a letter you wrote to Steven Taylor dated Sept. 22, 1986, which was distributed by the TTMA to its members. A copy is enclosed for your convenience.

The Budd Company, as a wheel manufacturer. is seriously concerned by a comment in the next to last paragraph of your letter which could be read as condoning the practice of rebuilding wheels by processes which include heating and welding same.

While I am sure that this was not your intent, I believe it is appropriate to note that all of the things mentioned in your letter, i.e. straightening, re-welding parts and repairing cracks by welding, are specifically prohibited by the OSHA standard app licable to truck wheels, both multi and single piece. See 29 CFR 1910. I further note that the "out of service" criteria adopted by the Bureau of Motor Carrier Safety of the DOT mandate that a vehicle be placed out of service if welded repairs are found on certain disc wheels.

The basis for all of this is that the manufacture of a steel truck wheel is a complex process involving carefully calculated cold forming of its components to produce the required strength, followed by controlled welding or other joining processes, I fol lowed again by elaborate testing to verify the integrity and efficacy of the final product. Any significant changes made later, especially involving bending, heating or welding carry a significant risk of rendering the wheel unsafe.

For the above reasons I hope you will consider advising anyone who may have received the referenced or any similar letter from your agency that such practices are not condoned and may be unlawful. Very truly yours

Frank S. Perkin Asst. General Counsel

cc: Truck Trailer Mfgrs Assn 1020 Princess St Alexandria Va 22314

ID: nht88-1.21

TYPE: INTERPRETATION-NHTSA

DATE: 01/28/88

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Automotive Safety Testing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Billy S. Peterson President Automotive Safety Testing, Inc. Product Liability-Testing-Certification at TRC of Ohio East Liberty, OH 43319

Dear Mr. Peterson:

This is in reply to your letter of September 23, 1987, with respect to positioning of rear mounted lamps and reflectors in accordance with Federal Motor Vehicle Safety Standard No. 108. Your client has designed a vehicle in which the backup lamps and rea r reflex reflectors would be mounted on the deck lid, and you have asked whether there are any current or contemplated prohibitions that would preclude this design.

The lamps in question will be mounted on a rigid part of the vehicle as required by paragraph @4.3.1 of Standard No. 108, and the deck lid will be closed and the lamps and reflectors in full view under normal operating conditions. The visibility requirem ents of lamps and reflectors in Standard No. 108 are predicated on the normal driving or closed deck lid position. Since the use of motor vehicles, including driving with deck lids open or otherwise having the lamps and reflectors obscured by a particula r load on the vehicle is under the jurisdiction of the individual States, we do not anticipate rulemaking on this subject. Thus, this design is not prohibited by Standard No. 108.

Sincerely, Erika Z. Jones Chief Counsel

September 23, 1987 Administration National Highway Traffic Safety U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Ms. Steed:

Our client, Hyundai Motor Company, has asked us to inquire regarding the positioning of rear mounted lamps and reflectors in accordance with FMVSS 108 for a new model currently in the final design stages. The rear lighting design for the new model provides for mounting some of the lighting on the bottom edge of the trunk lid, similar to a design currently used on the Audi 5000.

Although FMVSS 108 Table IV only calls for paired lamps and reflectors that are required on the rear to be at the same height on each side of the vertical centerline and "...as far apart as practicable," Hyundai would like to know if there are any curren t specific prohibitions or future anticipated changes that would preclude or limit the mounting of rear lamps or reflectors on the trunk lid. A schematic of the rear lighting configuration for the new model is enclosed.

Sincerely,

Billy S. Peterson President

BSP/PLS/plm

Enclosure