Interpretation ID: nht79-1.3

DATE: 01/26/79

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Motor Coach Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. T. Szkolnicki Mechanical Engineering Motor Coach Industries, Inc. Pembina, North Dakota 58271

Dear Mr. Szkolnicki:

This responds to your January 2, 1979, request for confirmation that a July 23, 1976, interpretation of S5.3.3 and S5.3.4 of Standard No. 121, Air Brake Systems, has been incorporated into the body of the regulation. I regret that you did not receive a reply to your letter of November 27, 1978, which was addressed to someone who is no longer in this office.

The interpretation in question has not been incorporated into the body of the regulation. During a court review of the standard which only recently concluded, the agency was making a few changes to the standard as possible. Consideration is now being given to revision of the standard in minor respects, but no date has been established for action. Until any such action is taken, you may continue to rely on the July 23, 1976, interpretation as the agency's official view of the meaning of S5.3.3 and S5.3.4.

Sincerely,

Original signed By

Joseph J. Levin, Jr. Chief Counsel

January 2, 1979

U.S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street WASHINGTON, D.C. 20590

Attn: Mr. Frank A. Berndt Acting Chief Counsel

Dear Mr. Berndt:

We refer you to our letter of November 27th, copy enclosed, in which we referred your letter of July 23rd, 1976 to White Motor.

We would appreciate a reply, confirming that an amendment to the FMVS 121 was issued.

MOTOR COACH INDUSTRIES

T. Szkolnicki, Supervisor Mechanical Engineering

TS/cf Enclosure

November 27th, 1978

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

Attention: Frank A. Berndt - Acting Chief Counsel

Dear Mr. Berndt:

We refer you to your letter of July 23rd, 1976, to the White Motor Corporation, copy enclosed. The letter refers to the FMVSS #121. Specifically, it refers to the apply and release times for brake chambers that have a lower max. brake chamber pressure.

The last paragraph notes that "the agency will issue an interpretive amendment to S5.3.3 and S5.3.4 to reflect this interpretation".

Can you advise if this amendment was issued, and if so, please forward a copy of this. If the amendment was not issued, can you comment on when this will be done? Thank you.

Yours very truly,

MOTOR COACH INDUSTRIES, INC.,

T. Szkolnicki, Supervisor, Mechanical Engineering.

TS/jp