ID: nht81-3.6

DATE: 08/07/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Volkswagen of America, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking which of the specific requirements of Safety Standard No. 209, Seat Belt Assemblies, must be met by an automatic seat belt assembly that is installed in a vehicle in accordance with the automatic restraint requirements of Safety Standard No. 208, Occupant Crash Protection.

The agency has stated in the past that automatic seat belt assemblies must meet the adjustment requirements of paragraph S7.1 of Safety Standard No. 208, and those parts of Safety Standard No. 209 that are incorporated by reference in S7.1, whether or not the automatic belts are installed to meet the frontal crash protection requirements of paragraph S5.1 of Safety Standard No. 208. Automatic belts that are installed to comply with the frontal crash protection requirements are excepted from the other requirements of Safety Standard No. 209 by paragraph S4.5.3.4 of Safety Standard No. 208. As noted in your letter, paragraph S7.1 of Safety Standard No. 208 requires the automatic belt assembly to have a retractor that complies with Safety Standard No. 209. However, the requirements for retractor performance in Safety Standard No. 209 are based on other tests in the standard which are used for preconditioning or as prerequisites. Therefore, you state that it is not clear which requirements must be met by a retractor on an automatic belt assembly.

Paragraph S7.1 of Safety Standard No. 208 is only intended to incorporate by reference those provisions in Safety Standard No. 209 that are directly related to retractor performance. Therefore, all automatic belt retractors are required to comply with the following provisions of Safety Standard No. 209: S4.3(j); S4.3(k); and S5.2(a), (b), (j), and (k). Please note, however, that the retractors do not have to comply with paragraph S4.4 which is incorporated by reference in S4.3(k), since S4.4 relates to the performance of entire belt assemblies.

I hope this has been responsive to your inquiry. We apologize for the delay.

Sincerely,

ATTACH.

VOLKSWAGEN OF AMERICA, INC.

APRIL 29, 1981

Frank Berndt -- Chief Counsel, National Highway Traffic Safety Administration SUBJECT: Request for Interpretation - FMVSS 208 and 209 Requirements for Automatic Belts

Dear Mr. Berndt:

Federal Motor Vehicle Safety Standard (FMVSS) 208, which specifies restraint system requirements for passenger cars, includes a paragraph (S 4.5.3.4) which modifies the applicability of FMVSS 209 to automatic belts. The paragraph actually states that an automatic belt which is not subject to perpendicular frontal crash protection requirements of FMVSS 208 shall meet the webbing, attachment hardware, and assembly performance requirements of FMVSS 209. We believe that the converse is then also true, i.e., that automatic belts which are subject to the perpendicular frontal crash protection requirements do not have to meet the webbing, attachment hardware, and assembly performance requirements of FMVSS 209. On the face of it, and after examination of FMVSS 209, it would seem that these crash-tested automatic belts are then exempt from the entire FMVSS 209. The agency reinforced this belief in a letter of interpretation to Mr. Nield (Attachments 1 & 2).

However, this situation is confounded by a requirement, also in FMVSS 208 (ref. S 4.5.3.3(a)), that automatic belts comply with S 7.1 of the standard. This section, in addition to specifying belt fit requirements, requires a retractor which conforms to FMVSS 209. This conflict with the agency's letter of interpretation to Mr. Nield was brought up by Mr. Pepe (Attachment 3), and the agency responded with a further letter of interpretation to Mr. Pepe (Attachment 4). This letter stated that the automatic belts must meet the fit requirements of S 7.1, "and those parts of Safety Standard No. 209 incorporated by reference". To the best of our knowledge, this response to Mr. Pepe represents the agency's latest pronouncement on the topic.

This now brings us to our question: Exactly what specific parts of FMVSS 209 are applicable to automatic belts? The language of S 7.1 of FMVSS 208, and the letter of interpretation to Mr. Pepe would imply that the paragraphs which apply would be those relating to retractor performance. Mr. John Smreker of my staff suggested this to Mr. Hugh Oates, and he tentatively concurred. However, the interrelationship of the test sequences in FMVSS 209 and the requirements that one test serve as a prerequisite or precondition for another, would seem to bring in sections of FMVSS 209 which are specifically enumerated as excluded in S 4.5.3.4 of FMVSS 208. n1 We therefore need the agency to clarify exactly which paragraphs and which sections of FMVSS 209 do and do not apply to automatic belts.

n1 FMVSS 209 S 4.3(k) Performance of Retractor specifies that the retractor must meet the requirements of S 4.4 (after the tests in S 5.2(k)). However, S 4.4 is entitled "Requirements for Assembly Performance", a topic which is specifically excluded in FMVSS 208 S 4.5.3.4.

We will appreciate your prompt consideration of this matter.

Very truly yours,

Dietmar K. Haenchen -- Vehicle Regulations

Encl.

ATTACHMENT 1

Joseph Levin -- Chief Counsel, National Highway Traffic Safety Administration

Subject: Request for an Interpretation FMVSS 208/209

Dear Mr. Levin:

In reviewing the requirements presented in FMVSS 209, Seat Belt Assemblies in connection with the design of passive belt systems, there appears to be no distinction between the applicability of the standard as to active and passive belt systems. In reviewing FMVSS 208, Occupant Crash Protection However, paragraph 4.5.3.4 appears to exempt passive belt systems from compliance in any manner with the requirements of FMVSS 209. Since such an exemption would provide the design latitude necessary in the development of an optimum passive belt system, I would appreciate your confirmation that this exemption is intended.

In view of the extensive development efforts now underway in the engineering departments of many manufacturers, an expeditious response to this request would be appreciated.

Sincerely,

ATTACHMENT 2

George C. Nield

George C. Nield -- President, Automobile Importers of America

July 17, 1978

Dear Mr. Nield:

This responds to your recent letter asking whether passive safety belts are exempt from the requirements of Safety Standard No. 209, Seat Belt Assemblies.

The answer to your question is yes, with one exception, (Illegible Words) of Safety Standard No. 208, Occupant Crash Protection, specifies that passive safety belts that are not required for the vehicle to meet the perpendicular frontal crash protection requirements of the standard must meet the requirements of Standard No. 209. Therefore, only passive belts that are installed to meet the frontal crash protection requirements of Standard No. 208 are exempted from the requirements of Standard No. 209.

Sincerely,

Joseph J. Levin -- Chief Counsel, NHTSA

ATTACHMENT 3 Joseph J. Levin, -- Chief Counsel, National Highway Traffic Safety Administration

July 23, 1979

Reference: Your letter dated July 17, 1978 to Mr. George C. Nield, President, Automobile Importers of America - NOA-30.

Dear Mr. Levin:

I have this date, received a copy of your letter, referenced above, concerning the testing of passive seat belt assemblies to FMVSS No. 208 or 209 requirements. I feel that your letter may need some clarification or I need some further interpretation.

The question posed was pertaining to para. S4.5.3.4 of FMVSS No. 208. Your answer to that question was yes, that seat belt passive systems are exempt from FMVSS No. 209 testing with the exception of those that are not required to meet the perpendicular frontal crash protection requirements.

My interpretation of the Standard is that the aforementioned paragraph replaces only the assembly performance requirements of FMVSS No. 209, which is a Static Test, with the Dynamic test requirements of FMVSS No. 208.

Paragraph S4.5.3.3 of FMVSS No. 208 states that the passive belt assembly must meet the requirements of FMVSS No. 209 for retractor performance (para. S7.1 Adjustment). Therefore, all passive belt systems whether or not they are installed to meet the frontal crash protection requirements must conform to paragraph S7.1 (S4.5.3.3) of FMVSS No. 208. If my interpretation is not correct, then a retractor which will encounter more usage in a passive belt system, does not have to be tested for endurance per FMVSS No. 209 (i.e. resistence to environments, cycling and retraction force); but an active belt system which sees far less use, must meet those same 209 tests.

In view of testing programs presently in progress for several manufacturers an early reply would be greatly appreciated.

Very truly yours,

Frank Pepe -- Assistant Vice President, Engineering Division

Frank Pepe -- Assistant Vice President, United States Testing Co., Inc.

ATTACHMENT 4

SEPTEMBER 12, 1979

Dear Mr. Pepe:

This responds to your recent letter concerning the requirements applicable to automatic seat belts under Safety Standard No. 208, Occupant Crash Protection. Specifically, you ask for confirmation that all automatic belts must comply with the adjustment specifications of paragraph S7.1 of the standard.

Your understanding is correct. Automatic seat belts must meet the adjustment requirements of paragraph S7.1, and those parts of Safety Standard No. 209 incorporated by reference, whether or not they are required to meet the frontal crash protection requirements of paragraph S5.1 of the standard. Automatic belts that are installed to meet the frontal crash protection requirements are excepted from the other parts of Safety Standard No. 209 by paragraph S4.5.3.4 of Safety Standard No. 208. Please contact Hugh Oates of my office if you have any further questions (202-426-2992).

Sincerely, STEPHEN P WOOD -- NHTSA

ID: nht81-3.7

DATE: 08/12/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bajaj Auto Limited

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 7, 1981 asking for an "exemption" from the requirement of paragraph S4.5.6 of Motor Vehicle Safety Standard No. 108 that an illuminated pilot indicator be provided in each vehicle equipped with a turn signal operating unit.

In your opinion, the front turn signal lamps mounted on the handlebars of certain motor scooters that you manufacture can serve as pilot indicators; if a front turn signal lamp fails to operate, the failure is readily apparent to the operator; if a left turn signal lamp fails, there is an "appreciable change in the flashing rate" of the front lamp.

We concur in your interpretation. Although S4.5.6 does require the indicator, SAE Standard J588e Turn Signal Lamps, September 1970, incorporated by reference, requires it only if turn signal lamps are not readily visible to the driver. Because the operability of both front and rear turn signal lamps on the vehicles you describe may be confirmed by the front turn signal alone, the front lamp is the functional equivalent of a turn signal indicator, and a separate indicator need not be provided.

As this is a matter of long-standing interpretation of Standard No. 108 we have no plans to amend S4.5.6 to incorporate it.

SINCERELY,

Date: 7th July 1981.

To

The Administrator, National Highway Traffic Safety Administration,

Subject: Petition for exemption from the requirements for illuminated pilot indicator (Illegible Word) to 49 CFR PARTS 571 S 108 Lamps - Reflective devices and (Illegible Word) equipment.

Dear Sir,

We are herewith making a petition in connection with the above stated reference for exemption from fitting illuminated pilot indicator. The facts concerning this are placed below for your kind consideration.

PETITION:

Federal Motor Vehicle Safety Standard No. 108, S 4.5.6 states "Each vehicle equipped with a turn signal operating unit shall also have an illuminated pilot indicator. Failure of one or more lamps to operate shall be indicated in accordance with SAE Standard J 588 (e) Turn Signal Lamps" (September 1970) except where a variable lead turn signal flasher is used on a bus, truck, multipurpose passenger vehicle etc.

According to SAE J 568 (e) "Failure of one or more lamps to operate should be indicated by a "Steady On" or "Steady Off" or by a significant change in the flashing rate of the illuminated pilot indicator". Also it states "If any signal lamp is not readily visible to the driver, ther shall be as illuminated pilot indicator to give him a clear and (Illegible Word) indication that the turn signal system is turned "ON".

Also SAE J 568 (f) (Reference SAE Hand Book 1981) states "If one right and one left turn signal is not readily visible to the driver there shall be an illuminated indicator provided to give clear and unmistakable indication that the turn signal system is (Illegible Word)."

The Motor Scooters, we are manufacturing fall under the (Illegible Word) of Class I motorcycles. The scooters are provided with turn signal lamps both at the front and the rear. The front signal lamps, one left and one right are positioned on the handle bar and are directly in front of the rider and are fully visible to the rider. In our opinion those from signal lamps themselves can serve as pilot indicators based on the following analysis:

CASE (a): When both the signal lamps on one side, say right side are working, the front right lamp is visible to the rider.

CASE (b): If any of front signal lamp is not operating, the failure of it is directly observed by the rider.

CASE (c): The failure of rear lamp to operate is indicated by a appreciable change in the flashing rate of the front lamp.

In view of this, in our opinion, the vehicle conforms to the provisions of SAE J (e) and J 568 (f) without providing an illuminated pilot indicator.

BRIEF DESCRIPTION OF THE SUBSTANCE OF ORDER

In view of the above points made we would like exemption from the requirement of illuminated pilot indicator and also an ammendment in 49 CFR PART 108 S 4.5.6 saying "If visible to the rider, (Illegible Word) front signal lamp can serve as the pilot indicator".

We are enclosing herewith photographs illustrating the location of the front signal lamps on our vehicle for your observation and kind consideration.

NAME AND ADDRESS OF THE PETITIONER:

M. S. (Illegible Word) MANAGER (RESEARCH & DEVELOPMENT)

BAJAJ AUTO LIMITED (Illegible Word)

(Illegible Word) - 411 055 INDIAN.

Thanking you, For BAJAJ AUTO LIMITED

(M. S. (Illegible Word) MANAGER ((Illegible Word))

Enclosures Omitted.

ID: nht81-3.8

DATE: 08/17/81

FROM: AUTHOR UNAVAILABLE; S. P. Wood for F. Berndt; NHTSA

TO: Antonio Cano - Sales Representative

COPYEE: F. BRENDT -- NHTSA; SIGNATURE BY STEVE WOOD

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your question, raised during a meeting with Carl Clark, Vernon Bloom, Harry Thompson and Edward Glancy, whether any Federal motor vehicle safety standard precludes the importation or sale of your anti-theft device called "Hyperblock." The device works by preventing release of the brakes. Installation of the device requires cutting into a vehicle's braking system.

By way of background information, the agency does not give approvals of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to ensure that its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with all applicable standards. We note that the term "manufacturer" is defined by section 102(5) of the Act to mean "any person engaged in the manufacturing or assembling of motor vehicles or motor vehicle equipment, including any person importing motor vehicles or motor vehicle equipment for resale." [Emphasis added.]

The agency does not have any regulations covering anti-theft devices that work by preventing release of the brakes. However, since installation of Hyperblock requires cutting into a vehicle's braking system, it may affect a vehicle's compliance with other safety standards.

If your device is added to a new motor vehicle prior to its first sale, the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. In the case of Hyperblock, this would include Safety Standard No. 105, Hydraulic Brake Systems (49 CFR 571.105). You will find the specific certification requirements for alterers at 49 CFR Part 567.7, Certification. On the other hand, you as the manufacturer of Hyperblock would have no certification requirements, because we have no safety standards applicable to your equipment. However, an alterer would probably require information from you in order to make the necessary certification.

If your device is installed on a used vehicle by a business such as a garage, the installer would not be required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative the compliance of the vehicle with any safety standard. This is required by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, which states in relevant part:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . .

You indicated at the aforementioned meeting that installation of Hyperblock does not affect a vehicle's braking performance. You also indicated that Hyperblock maintains the integrity of a vehicle's split system. In addition to requirements in those areas, Standard No. 105 establishes brake system integrity requirements, requiring that a braking system be able to withstand a series of spike stops. You may wish to consider testing Hyperblock as to whether it affects a vehicle's compliance with the spike stop test requirements, if you have not done so already. We suggest that you carefully examine all of Standard No. 105's requirements to determine the degree to which installation of your device affects compliance with the standard.

While we do not have any opinion as to the safety of your particular device, we do have a general concern about the safety of anti-theft devices which work by preventing release of the brakes. We note that some manufacturers state in their service manuals that hydraulic brake locking devices should not be used on their vehicles.

Should a safety-related defect be discovered in your device, whether by the agency or yourself, you as the manufacturer would be required under sections 151 et seq. of the Act to notify vehicle owners, purchasers, and dealers and provide a remedy for the defect.

Finally, in addition to the provisions of Federal law discussed above, there is a possibility of liability in tort should your device prove to be unsafe in operation. You may wish to consult a local lawyer concerning liability in tort.

ID: nht81-3.9

DATE: 08/20/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company -- Thomas D. Turner

TITLE: FMVSS INTERPRETATION

ATTACHMT: 4/26/76 letter from Frank Berndt to W G. Milby

TEXT:

This responds to your July 13, 1981, letter asking whether the joints in your school buses that fall within the rear cargo compartment or rear engine compartment must comply with Standard No. 221, School Bus Body Joint Strength.

Standard No. 221 applies to joints that connect body panels to body components. Body panels are defined to include those components that enclose the bus' occupant space. The agency has stated in the past that those portions of a bus falling below the floor level would not be considered as having a function in enclosing occupant space, and accordingly, joints in those area would not be required to comply with the standard's requirements.

Applying the standard to the joints that you question, appears that they would not be required to comply with the standard. The agency would consider the walls separating the cargo area or the engine from the remainder of the occupant compartment to be a continuation of the bus floor. Accordingly, joints falling behind and below those walls would not be required to comply with the standard. We do note, however, that the joints along the walls themselves must comply with the standard, since the wall panels enclose the occupant space and provide the separation of the engine or cargo area from the occupant space.

Sincerely,

Frank Berndt Chief Counsel

July 13, 1981

SUBJECT: FMVSS 221: 41 F.R. 3872, 1-27-76

REFERENCE: 1. Letter Frank Bernett to W.G. Milby dated 4-26-76; N40-30

Dear Mr. Berndt, Federal Motor Vehicle Safety Standard No. 221 School Bus Body Joint Strength covers body panel joints for body panels that enclose the bus occupant space. NHTSA has issued interpretations, see reference, that state components that are not considered to have a function in enclosing the occupant space (Example "...located entirely below the level of floor line...") are not considered a body component and are not subject to the standard.

The enclosed drawing 1034917 illustrates the configurations of a rear center luggage compartment and a rear engine "Pusher" bus. The cross-hatched areas of these cross-sectional views are the occupant space and body panels enclosing this occupant space are covered by the standard.

It is our interpretation that components located entirely within the shaded areas of the drawing, below the floor and below and/or to the rear of the walls between the occupant space and the compartments shown, do not enclose the occupant space, are not considered body components, and are not subject to the standard. Using this interpretation components such as trim panels inside the luggage compartment and panels forming the inner and outer skin of the body that are "located entirely" in the shaded area would not have to meet the joint strength requirements of FMVSS 221.

We feel that this interpretation conforms to the letter of the standard and subsequent interpretations and further conforms to the intent of the standard. We therefore request your early consideration of this matter and confirmation that our interpretation is correct.

Very truly yours,

Thomas D. Turner Manager, Engineering Services

slt

Enclosure

[April 26, 1976 letter from Frank Berndt to W. G. Milby omitted here]

ID: nht87-1.1

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/87 EST

FROM: S.L. LEPOSKY -- EQUIPMENT SUPPLY CO

TO: ALL DISTRIBUTORS AND SALESMEN.

TITLE: NON USE OF DUCK BILLED STEEL TIRE HAMMERS

ATTACHMT: ATTACHED TO LETTER DATED 02/11/88 FROM ERIKA Z JONES TO BETH WHITMAN; REDBOOK A31, STANDARD 110, 120; SA 19 AR STEELHAMMERS 2J; SA 29 STEELHAMMERS 2J; LETTER DATED 01/21/87 FROM S. L. LEPOSKY TO DISTRIBUTORS; LETTER DATED 07/09/87 FROM LEO CARE Y TO BETH WHITMAN

TEXT: We have just returned from the annual National Wheel & Rim Meeting in Phoenix, Arizona. The tone of the meeting from Wheel & Rim Manufacturers was one of concern and rightly so. They have all reprinted and issued their new Rim & Tire Service Manuals ou t-lining and telling tire dealers, fleets, mining and construction users that they MUST NOT USE steel hammers to disassemble or assemble truck rim components. The practice still goes on and probably will until more people are injured and more lawsuits f iled.

For your convenience we have enclosed two pieces of instruction material produced by Rubber Manufacturers Association (RMA) and National Highway, Traffic Safety & Health Administration (NHTSHA). Have your salesmen carry this with them and discuss it wit h your customers.

The logical alternative to the steel duck bill hammer is the "COMBI" Truck & Farm Tire Bead Breaker. If your people will talk about the regulations, your customers will soon start to buy the proper equipment to replace the hammer.

One of the best places to start is with local City, County, State and Federal service operations. They are very cognizant of the OSHA regulations.

ID: nht87-1.10

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Fred E. Maynard

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Fred E. Maynard 13208 Creek Park Lane Poway, CA 92064

Dear Mr. Maynard:

This is in reply to your letter of November 14, 1986, to Taylor Vinson of this Office with respect to an automotive lighting product that you have developed.

According to your letter the VISICOM is an electronic message sending unit which incorporates a center high-mounted stoplamp "which will meet all of the standards required by Regulation 108 as to size, light intensity, angle of visibility, etc.." You hav e asked for an opinion "on any potential current or future legal problems that might arise when this product is marketed."

I will be pleased to discuss the relationship of your device to Federal Motor Vehicle Safety Standard No. 108 and the National Traffic and Motor Vehicle Safety Act, but we cannot advise you of problems you might encounter under State or common law. Stand ard No. 108 covers original vehicle equipment and items manufactured to replace original equipment. Paragraph 54.4 of Standard No. 108 states, in pertinent part, that "...no high-mounted stoplamp shall be combined with any other lamp or reflective device ." In our view, this precludes you from offering the VISICOM as either an original center high-mounted stoplamp, or as one intended to replace such a stoplamp on any passenger car manufactured on or after September 1, 1985.

However, you are not precluded by Standard No. 108 or the Act from offering this device as aftermarket equipment on passenger cars manufactured before September 1, 1985. Whether VISICOM is acceptable on these vehicles must be determined by the laws of ea ch State in which the device will be sold or used.

Thank you for your interest in safety. If you have further questions we would be pleased to answer them.

Sincerely, Erika Z. Jones Chief Counsel

November 14, 1986

Mr. Taylor Vinson, Legal Council NHTSA, Dept. of Transportation 400 7th Street SW

Dear Sir:

I was referred to your office by the people at the D.O.T. 1-800 number as the source for an NHTSA legal opinion concerning an automotive accessory product I have developed. Since one of its functions is somewhat related to the third brakelight now requir ed in 1986 or newer automobiles, but no reference to its total concept is made in Regulation 108, I feel its necessary we have an official opinion on any potential current or future legal problems that might arise when this product is marketed.

I have included a complete functional description of the product as we now intend to manufacture It and I Hill certainly appreciate any suggestions or comments you might have and any reference to other NHTSA regulations that define a product concept like VISICOM if any exist at all.

Thanking you in advance I remain:

Sincerely

Fred E. Maynard 13208 Creek Park Lane Poway, Ca. 92064 (619) 748 5883

VISICOM-Product Description

The VISICOM concept can best be described as an electronic sign or message sending unit. It has a number of potential applications with the most attractive market being that of an automotive accessory. In this configuration It will be sold with a number of preprogrammed words and messages the primary purpose of which will be to enhance the safety aspects of automobile operation and promote a higher degree of courtesy on the road.

Physically the unit comes in two sections. the control panel which mounts on the dashboard of the vehicle, and the display section which is to be positioned in the center of the rear window. According to NHTSA (National Highway Traffic Safety Administrat ion) guidelines, a third brakelight would be located in this area of the vehicle in 1986 or newer cars so in order to avoid any conflict with these regulations, the VISICOM automotive model will be supplied with an integrated third brake light which will meet all of the standards required by NHTSA regulation 108 as to size, light intensity, angle of visibility, etc.. This third brakelight will also serve as the base for the display section of the VISICOM which measures approximately 4"H x 17"L x 3"D. Th is enclosure contains virtually all of the electronic control and programming circuits as well as the display itself which consists of six 14 segment alpha-numeric characters 2.5"W x 3.9 "H. Each segment contains a 1.2 watt incandescent bulb which is ene rgized when that segment is required to form a specific number or letter. The words formed by the segmented characters are displayed one at a time for a duration of the seconds with a half second pause in between until the message is complete. Some of th e messages are automatically activated and some of the others continue repeating until the operator ceases the transmission. The messages contained in the system are as follows:

Automatic Messages One Time Display Messages

1. STOP 1. HELLO 2. TURN ------ 2. THANK YOU 3. TURN ------ 3. HAVE A NICE DAY 4. BACKUP 4. SORRY 5. BYEBYE Driver Activated Repeating 6. OK TO PASS Messages 7. NOT OK TO PASS 8. PLEASE DIM YOUR LIGHTS 1. PLEASE CALL POLICE 9. YOU ARE TOO CLOSE 2. NEED HELP 10. CHILD IN CAR 3. HAZARD AHEAD 11. CHECK YOUR DOORS 4. OUT OF GAS 12. CHECK YOUR TIRES

ID: nht87-1.100

TYPE: INTERPRETATION-NHTSA

DATE: 06/04/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Barry Bartlett

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Barry Bartlett President Canadian Automotive Radiator Air Industrial Park P.O. Box 189 Debert, Nova Scotia, BOM 1GO CANADA

Dear Mr. Bartlett:

Thank you for your letter of May 5, 1987, concerning Standard No. 301, Fuel System Integrity. You asked the agency to confirm that the requirements set out in the standard apply only to fuel systems installed as items of original equipment in new vehicles and do not apply to aftermarket fuel systems. Several of the Federal Motor Vehicle Safety Standards apply both to original any aftermarket equipment. Standard No. 301, however, applies only to fuel system; installed as items of original equipment in new vehicles.

Although the agency does not have any standards that directly apply to aftermarket fuel systems, manufacturers of motor vehicle equipment, which includes aftermarket fuel systems, are subject to the requirements in sections 151-159 of the Vehicle Safety Act concerning the recall any remedy of products with defects related to motor vehicle safety. I have enclosed an information sheet which briefly describes those responsibilities.

In addition, installation of your product can be affected by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act. This section prohibits commercial businesses from knowingly rendering inoperative devices or elements of design installed in a vehicle in compliance with the Federal motor vehicle Safety Standards. Thus, a manufacturer, dealer, distributor or motor vehicle repair shop that installs replacement fuel tanks most ensure that it does not knowingly render inoperative the vehicle's compliance with Standard No. 301.

The prohibition of section 108(a)(2)(a) does not apply to individual vehicle owners who alter their own vehicles. Thus, under Federal law, they may install or remove any items of motor vehicle equipment regardless of its effect on compliance with Federal Motor Vehicle Safety Standards. However, the agency encourages vehicle owners not to remove or otherwise tamper with the vehicle safety equipment.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel

May 5, 1987 Ms. Erika Z. Jones, Chief Counsel National Highway Traffic Safety, 400 7th St. S.W., Washington, D.C. 20590

Dear Ms. Jones:

Recent discussions with Mr. Steven Wood, representative of the Legal Regulations Office of the National Highway Safety Transportation, regards gas tank production for the automotive market, has prompted my writing this letter to you for clarification and confirmation. It is Mr. Wood's opinion that regulation standard number 301 as outlined in your Federal Motor Standards Act governs gas tank specifications aimed at original equipment production and does not cover products produced solely for aftermarket consumption. We would appreciate it greatly if you would confirm Mr. Wood's observations.

Thanking you in advance for your assistance in this matter, I remain,

Yours very truly,

CANADIAN AUTOMOTIVE RADIATOR EXCHANGE AND MANUFACTURING LIMITED

Barry Bartlett, President

ID: nht87-1.11

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: A.L. Bragg

TITLE: FMVSS INTERPRETATION

TEXT:

Ms. Erika Jones Chief Counsel UNITED STATES DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 7th Street Southwest Washington, D.C. 20590

Subject: INTERPRETATION OF PARAGRAPH S4.1.1.3 WHICH STATES: "INTERMEDIATE SIDEMARKER DEVICES ARE NOT REQUIRED ON VEHICLES LESS THAN 30 FEET IN OVERALL LENGTH"

Dear Ms. Jones:

We would appreciate it if you could clarify the above referenced section of 108 as it pertains to both tables 2 and 3 which state that trailers, both under 80 and over 80 inches, require intermediate side marker lamps. However, a footnote in both of thes e tables points out paragraph S4.1.1.3 which does not require intermediate sidemarkers on vehicles less than 30 feet in overall length. Our question is in regard to the proper interpretation of vehicles less than 30 feet in overall length. In the case of trailers, does this mean just the trailer as it sits by itself or does it include the power unit that may be pulling the trailer? In the case of straight trucks, that is, trucks in which the power unit and the trailer are not separable, our understanding is that the overall length refers to everything between the front and the rear bumpers.

Thank you for your comments. Please feel free to contact us if there are any questions.

Sincerely,

TRUCK-LITE CO., INC. A.L. Bragg Laboratory Manager

ALB/bme

cc: B. Yorks J. Swanson J. Latona B. Maternowski

Mr. A. L. Bragg Laboratory Manager Truck-Lite Co., Inc 310 East Elmwood Ave. Falconer, NY 14733

Dear Mr. Bragg:

This is in reply to your letter of October 14, 1986, in which you ask how the overall length of vehicles is calculated in determining whether they are to be equipped with intermediate side marker lamps.

With respect to trailers, you ask whether overall length includes the towing unit. No, the overall length to be calculated is only that of the trailer.

As for trucks, you assume that overall length "refers to everything between the front and rear bumpers." I assume that you are including the bumpers in the quoted phase, and that would be correct.

If you have any further questions we would be pleased to answer them.

Sincerely,

Erika Z. Jones Chief counsel

ID: nht87-1.12

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: T. Chikada

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Chikada Manager, Automotive Lighting Engineering Control Dept. Stanley Electric Co., Ltd. 2-9-13, Nakameguro, Meguro-ku Tokyo 153, Japan

Dear Mr. Chikada:

This is in reply to your letter of November 21, 1986, with reference to the distance between a front turn signal lamp and a lower beam headlamp.

In brief, SAE Standard J588e, incorporated by reference in Standard No. 108 requires a minimum separation distance of 4 inches between the optical axis (filament center) of the front turn signal lamp to the inside diameter of the retaining ring of the lo wer bean headlamp. You have pointed out that a replaceable bulb headlamp does not have a retaining ring, and you have presented two possible substitutes as a measuring point. The first (your Item A) is the outer edge of the headlamp, and the second (your Item B) is the end of the effective area of the reflector. You believe that Item B is the more appropriate.

We concur with your interpretation. Of the two options, the distance to the edge of the effective area of the reflector is the one most similar to the inside diameter of the retaining ring of the lower beam headlamp. The basis for this interpretation is the assumption that the headlamp lens between the outer edge of the headlamp and the edge of the effective area of the reflector is not used for production of the lamp's bean, has mo significant luminance, and therefore will not mask the turn signal.

Sincerely,

Erika Z. Jones Chief Counsel

November 21, 1986

Erika Z. Jones Chief Counsel Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590 U.S.A.

Dear Ms. Jones,

Re : Distance between a front turn signal lamp and a low beam headlamp)

In Motor Vehicle Safety Standard N0.108, Paragraph 4.3.1.7, the following is prescribed:

S4.3.1.7 The requirement that there be not less than 4 inches between a front turn signal lamp and a low beam headlamp, specified in SAE Standard J588e, "Turn Signal Lamps," September 1970, shall not apply if the sum of the candlepower values of the turn signal lamps Measured at the test point within each group listed in Figure 1c is not less than two and one-half times the sum specified for each group for yellow turn signal lamps.

According to the SAE Standard J588e, the distance is defined as from the optical axis (filament center) of the front turn signal lamp to the inside diameter of the retaining ring of the headlamp unit providing the lower beam. This definition applies only to a standardized headlamp. What definition is appropriate for a replaceable bulb headlamp, in other words, an unstandardized headlamp? We think B in the following definition is appropriate.

A : From the filament center of the front turn signal lamp to the outer edge of a low beam headlamp

B : From the filament center of the front turn signal lamp to the end of the effective area of the reflector of a low beam headlamp

SEE HARD COPY FOR GRAPHIC ILLUSTRATION

ID: nht87-1.13

TYPE: INTERPRETATION-NHTSA

DATE: 01/12/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Jean-Paul Turgeon -- Security and Legality Manager, Prevost Car Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Jean-Paul Turgeon Security and Legality Manager Prevost Car Inc Sainte-Claire, Quebec Canada

In your letter of November 7, 1986, to the Administrator, you have asked whether Federal Motor Vehicle Safety Standard No. 108 requires intermediate Bide marker lamps to be mounted at approximately the same level as the front and rear marker lamps.

No. The requirement that they be located at or near the midpoint between front and rear side marker lamp refers to the horizontal distance between the front and rear lamps, and the intermediate lamps are subject only to the requirement that they not be m ounted less than 15 inches above the road surface.

Sincerely,

Erika Z. Jones Chief Counsel

U.S. Department of Transportation N.H.T.S. 400, 7th Street S.W. Washington, D.C.

Attention: Diane K. Steed, Administrator

Re: F.M.V.S.S. 571.S.108 Intermediate Side Markers (Table 2)

Dear Mrs. Steed:

We are looking for an interpretation of 5.108 regulation as follows:

It is specified on 5.108.20, Table 2, that the intermediate side marker be located at or near the mid point between the front and rear side marker lamps.

Our question is: Does that mean that the intermediate side marker must be approximately , the same level as the front and rear marker lamps, i.e. on the same level line?

Yours truly,

Jean-Paul Turgeon Security and Legality Manager