Interpretation ID: aiam0200
Product Equipment Coordinator
U.S. Suzuki Motor Corporation
13767 Freeway Drive
Santa Fe Springs
CA 90607;
>>>Re: Request for Interpretations by Suzuki<<< Dear Mr. Petler: This is in reply to your letter of October 13, 1969, requestin confirmation of your interpretation of certain Federal Motor Vehicle Safety Standards and regulations, and further asking whether or not certain other areas of (motor) vehicle performance are presently regulated under the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1391 *et seq*.).; In your letter you state that your request results from the fact tha Suzuki is considering the production of a multipurpose passenger vehicle for export into the United States sometime in 1970, and attach a sketch of this vehicle. The vehicle represented by the sketch, however, appears to be a truck, and not a multipurpose passenger vehicle. 'Multipurpose passenger vehicle' is defined in the regulations (49 CFR 371.3(b)) as 'a motor vehicle with motive power, except a trailer, designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off-road operation.' 'Truck' is defined to mean (49 CFR 371.3(b)) 'a motor vehicle with motive power, except a trailer, designed primarily for the transportation of property or special equipment.' The distinction between a truck and multipurpose passenger vehicle, therefore, is whether the vehicle is designed primarily to carry persons or property. The sketch you enclose is of a vehicle designed to carry property, and for this reason I have answered your questions with reference only to trucks. Your questions are repeated below, with our replies following them:; *Subject No. 1* - Glazing Requirements - Rear Windows 1.>>>'We understand it would be permissible to use a fabric soft to with no rear window if an outside mirror was installed on the right side of the vehicle.'<<<; You are correct in saying you may use a fabric soft top with no rea window. Federal Motor Vehicle Safety Standard No. 205 specifies glazing materials for use in passenger cars, multipurpose passenger vehicles, motorcycles, trucks and buses. It does not require a rear window or the use of glazing material therein. If a rear window is installed, however, the referenced United States of America Standards Institute 'American Standard Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways,' ASA Standard Z26.1-1966, July 15, 1966, specifies the types of material which must be used.; There are no National Highway Safety Bureau requirements for mirrors o trucks.; 2.>>>'We understand it would be permissible to use a fabric soft top with an open section in the back, utilizing no installation of glazing material, but just an open area which would permit viewing to the rear using the inside rear view mirror.'<<<; Your understanding is correct. As stated before, Standard No. 205 doe not require the use of glazing material.; 3.>>>'We understand it would be permissible to use a fabric soft top using a rear window such as found in the tops of convertible automobiles, in which the rear window's composition has utilized a ASA plastic material conforming to Z26.1-1966 regulations.(sic); 'If this is correct we would appreciate being informed which plasti materials can be utilized.'<<<; That is incorrect. The criterion for 'a rear window such as found i convertible automobiles' is inappropriate for trucks. The only plastics which may be used in trucks are AS4 and AS5, rigid plastics, and then only 'where other means to afford visibility of the highway' are provided.; 4.>>>'We understand it would be permissible to use a fabric soft top using a rear window such as found in the tops of convertible automobiles, in which the rear window's composition has utilized a ASA safety glass material conforming to Z26.1- 1966 regulations.(sic); 'If this is correct we would appreciate being informed which safet glass materials can be utilized.'<<<; As indicated in our comment to number 3 above, the criterion for rea window glizing (sic) used in convertible automobiles is inappropriate for trucks. ASA Standard Z26.1-1966 allows the use of Items 1, 2, 3, 8, 9, 10, and 11 glass in the rear window of trucks. Item 3 or 9 glass may only be used, however, 'where other means to afford visibility of the highway' are provided.; *Subject No. 2* - Gross Vehicle Weight >>>'It is our understanding that, at present, there is no requiremen that a manufacturer attach a label to the vehicle stating the gross vehicle weight of . . . [trucks] in the weight category of 2,000 lbs. or less.'<<<; Your understanding is correct. The National Highway Safety Bureau doe not presently have a requirement for gross vehicle weight labeling.; *Subject No. 3* - Fuel Tank Requirements >>>'It is our understanding again that there is no present Federa Motor Vehicle Safety Standard pertaining to gas tanks on . . . [trucks]. I understand that there may be future standards implemented in the near future regarding this subject.'<<<; Your understanding is correct. Federal Motor Vehicle Safety Standar No. 301, 'Fuel Tanks, Fuel Tank Filler Pipes, and Fuel Tank Connections - Passenger Cars', applies to only passenger cars at this time. Docket No. 3-2 (F.R. 14282), currently under consideration, contemplates extending the requirements of Standard No. 301 to multipurpose passenger vehicles, trucks, buses and motorcycles.; *Subject No. 4* - Vehicle Noise Level >>>'It is our understanding that, at the present time, there is n special noise level requirements pertaining to . . . (sic)trucks]. We would appreciate your comments as to any future standard presently under discussion regarding this subject.'<<<; Your understanding is correct. There are no Federal requirements o proposals at present concerning vehicle noise level, (sic) There are states and municipalities, however, that have requirements concerning this subject.; *Subject No. 5* - Speedometer Error >>>'There are several questions we have regarding this subject. 1. Is there a stipulation regarding allowance of percentage o speedometer error.; 2. Would it be considered the manufacturer's responsibility fo speedometer error in case the user or person was to change the tire size.'<<<; There are presently no Federal requirements concerning speedometers. substantial speedometer error resulting from a reasonable tire size change might be considered a safety related defect for which the manufacturer would be responsible.; *Subject No. 6* - Special Label for Non-Conforming Vehicle Entry Int The United States; >>>'I would like to confirm the following information regarding th placement of a special label to be placed on the inside of the vehicle's windshield so that it is readable from the outside of a vehicle being imported into the United States. This would be placed on a vehicle that does not have the required Federal Motor Vehicle Safety Standard items readily attached in their respective place on the vehicle.(sic); 'It is my understanding, for instance, that if the outside rear vie mirror was not attached to the vehicle, but packaged in a box to prevent damage or pilferage while in transit to the United States, that in such a case a label would be required to be attached to the vehicle stating essentially the following message.; THIS VEHICLE DOES NOT CONFORM TO FEDERAL MOTOR VEHICLE SAFETY STANDAR NO. 111 BECAUSE THE OUTSIDE REAR VIEW MIRROR HAS NOT BEEN ATTACHED FOR THE CONVENIENCE OF SHIPMENT. THIS VEHICLE WILL BE BROUGHT INTO CONFORMITY BY ATTACHMENT OF THE OUTSIDE REAR VIEW MIRROR BEFORE IT IS OFFERED FOR SALE TO THE FIRST PURCHASER FOR THE PURPOSE OF RESALE.(sic); 'If we have interpreted this requirement correctly would you pleas advise us of the full requirements for this label. It is also our understanding that at the time of importation of these vehicles the importer would be required to submit in duplicate the Federal Highway Administration Form Number HS-7.'<<<; Your interpretation of the above is correct. A label such as you hav described, used in conjunction with the certification label required in 49 CFR 367, would meet the requirements. Your understanding regarding the HS-7 form is also correct.; We trust this will clarify the situation for you. Sincerely, Francis Armstrong, Director, Office of Performance Analysis Motor Vehicle Safety Performance Service;