Interpretation ID: nht68-1.27

DATE: 06/21/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: ATECO Equipment Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your letter to Mr. Slagle dated March 8, 1968, in which you ask for information as to your company's responsibility under the National Traffic and Motor Vehicle Safety Act and regulations issued pursuant to the Act.

As I understand the description of the modification your company makes to trucks the only standard now in effect that is applicable is Standard No. 205, the glazing standard. Therefore, the glass that you install in place of the original glass in the truck cab would have to comply with this standard.

Your company might also be affected by the enclosed Advanced Notice of Proposed Rulemaking. Your particular attention is directed to Docket No. 2-12 which would, if finalized, make the standard concerning anchorage of seats (No. 207) applicable to trucks.

Sincerely,

Enclosure

March 8, 1968

National Highway Safety Bureau Edwin Slagle, Director Motor Vehicle Safety Performance Service

Dear Mr. Slagle:

I talked to David Schmeltzer who I understand is in the Office of the Chief Council of the Federal Highway Administration. Mr. Schmeltzer advised me to approach you for information concerning matter mentioned in the above subject.

This company is a manufacturer and a distributor of motor truck mounted equipment. We are generally to date and are currently practicing the requirements set forth in Federal Regulation #108 and #111 effective January 1, 1968.

Or to January 1, 1968, we had modified Ford, Model C-600 tilt-cabs by handing the original configuration approximately 15-1/4" longer than standard. We incorporate within this change two (2) one-man seats behind the driver-passenger compartment. One of these seats is located on a right angle behind the driver's seat and faces the street side of the vehicle. Another seat is installed behind the passenger's seat in reverse position to the one mentioned. We did not furnish any escape hatch, yet the glazed opening to which the passengers faced was made larger than the original factory furnished glazing. This glazing was set in rubber and locked in place through the use of standard rubber key locks that are used for this purpose in the motor truck industry. This glazing principle did not offer a push-out convenience, yet we at this time could leave the key lock strip out, thereby offering a convenience of a push-out window. We did not change or modify the factory furnished rear window glass.

We now wish to make similar changes to the equipment that we have described. We have researched all printed material and instructions that have been made available to us, to determine a correct and legal path to follow, but we have not found any information by which we should proceed, therefore we have taken the liberty to approach you for help and advice on this matter.

Attached please find the copy of a sketch of the equipment that we are concerned about, on which we have shown a dotted line vertically on the rear portion of the truck cab to indicate the approximate length that we extended the cabs done prior to January 1, 1968.

We need correct information and printed material or a written testimonial from a proper Federal agency telling us if we can or cannot make these changes to fulfill our obligation to Federal requirements.

We wish to take this opportunity to thank you in advance.

Very truly yours,

ATECO EQUIPMENT COMPANY--

R. A. Moynihan

Sales Manager - Truck Equipment

JWT FILE JWT S.O. David Schmeltzer RAM(Illegible Words)

(Graphics omitted)