FordTHINKNeighbor.CRS

Mr. James P. Vondale

Dear Mr. Vondale:

This responds to your letter of August 17, 2001 to

Dr. Jeffrey W. Runge, requesting the National Highway Traffic Safety Administration (NHTSA) to approve an alternate location for placement of the certification label on the THINK Neighbor low speed vehicle.

NHTSA's regulations at 49 CFR 567.4(c) prescribe specific locations for the installation of vehicle certification labels, and provide that if none of those locations are practicable, the manufacturer may suggest an alternate location for the agency's approval. As stated in your letter and illustrated in accompanying photographs, the THINK Neighbor is not equipped with doors, and consequently lacks hinge pillars and door-latch posts. You further state that the instrument panel and the seat stanchion cover are plastic components that can be easily removed and would therefore not be permanently affixed to the vehicle. In light of these circumstances, you state that "Ford recommends attaching the label to the inside surface of the roof in the left rear corner." You contend that in this location, "[t]he label will be permanently affixed to an integral component of the structure and is easily readable without moving any part of the vehicle." You further note that "other manufacturers have utilized a similar location" for the certification label.

In specifying locations for the placement of vehicle certification labels, NHTSA's objective is to ensure that those labels may be easily read. The location that you have proposed for the THINK Neighbor would meet this objective. NHTSA therefore approves your request.

If you have any further questions regarding vehicle certification requirements, feel free to contact Coleman Sachs of my staff at 202-366-5238.

Sincerely,

John Womack
Acting Chief Counsel

ref:567
d.10/5/01

Interpretation ID: FordTHINKNeighbor.CRS