ID: 1984-4.13

TYPE: INTERPRETATION-NHTSA

DATE: 12/21/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Western Star Trucks Inc. -- Stan R. Gornick, MVSS Compliance Specialist

TITLE: FMVSS INTERPRETATION

ATTACHMT: 7/20/84 letter from Frank Berndt to Hino Motors (U.S.A.) Inc.

TEXT:

Stan R. Gornick, P. Eng. MVSS Compliance Specialist Western Star Trucks Inc. 2076 Enterprise Way Kelowna, British Columbia V1Y 6HB Canada

This is in reply to your letter of December 10, 1984, informing us of compliance difficulties with respect to braking systems on two concrete mixer trucks which "are scheduled to be shipped the last week of December." You have asked for an "exemption to the certification requirements of FMVSS 105 and FMVSS 121."

Although you have stated that the mixer is being installed elsewhere, your letter implies that Western Star will nevertheless be the certifier of the assembled vehicle and not must its initial stage manufacturer. That you are the certified as the assumption on which this letter is based. We have reviewed your letter and have determined that it is the air brake standard, No. 121, with which these vehicles must comply. I enclosed a copy of a recent interpretation covering air-over-hydraulic systems similar to yours which reiterate earlier interpretations. I would like to point out that there is no legal requirement in the United States that a manufacturer conduct the tests specified in the safety standards before he certifies compliance. Your certification may be based on a good faith conclusion that were the vehicles to be tested in the manner specified they would conform to the stopping distance requirement. This conclusion can be based, for example, on computer analyses (such as that provided you by Rockwell International with respect to requirements other than stopping distances), engineering studies or mathematical analyses.

We have no authority to provide exemptions within a time frame that is responsive to your problem. There are detailed requirements for petitions and the public must be offered an opportunity to comment on them. The entire process requires three to four months.

Having filed two inconsequentiality petitions in 1984, Western Star is familiar with that procedure, but the agency has no wish to encourage manufacture of nonconforming vehicles with the implied promise that such petitions would be granted. We therefore advise you to reconsider the compliance status of the two concrete mixers in light of our comment that certification need not be based upon actual vehicle testing, with the thought that you may conclude that the trucks can be certified as meeting Standard No. 121.

Sincerely,

Frank Berndt Chief Counsel

Enclosure (7/20/84 Letter from Frank Berndt to Hino Motors (U.S.A.) Inc. omitted here.)

December 10, 1984

Office of Chief Counsel, NHTSA

Dear Sir:

Western Star Trucks Inc. has been awarded the contract to manufacture two only concrete mixer trucks. These vehicles are 6X6's with LRockwell SSHD 44,000 lb. tandem rear axles arid Fabco SDA23 -23,000 lb. front axles. The load distribution is 21,780 lbs. on the front axles and 44,000 lbs. on the rear.

The problem I am facing is that the Fabco front driving axle cannot accomodate air chambers, therefore it is manufactured with hydraulic brakes.

Now I have a vehicle with air brakes on the rear wheels and hydraulic brakes on the front wheels with an air over hydraulic actuator.

FMVSS 121 and FMVSS 105 do not indicate how to deal with vehicles equipped with both air and hydraulic systems.

We have had Rockwell International do a computer analysis of our braking system and they agree with the sizes of brakes, linings, air chamber sizes, etc. and have issued a certificate stating "THE BRAKES APPROVED ARE CERTIFIED TO MEET APPLICABLE DYNAMETER REQUIREMENT OF FMVSS 121 PARAGRAPH 55.4 WHEN APPLIED WITHIN THE LIMITING CONDITIONS OF VEHICULAR BRAKE RECOMMENDATION APPROVAL NO. C-04817 - CERTIFICATION NOT APPLICABLE TO VEHICLE STOPPING REQUIREMENTS".

The test data we have on file does not cover this brake configuration, therefore, we would have to perform a complete set of brake test; to verify FMVSS compliance.

The problems I have with this are: 1) We are not installing the mixer on the vehicle. It is being installed elsewhere.

2) To do a proper brake test the vehicle should be equipped as it will be used in the field.

3) A mixer contains an unstable load as it will shift as the brakes are applied. Therefore, to conduct a test in the laden condition it should contain concrete so that the weight transfer effects will be taken into account.

As the truck manufacturer we cannot certify compliance to FMVSS 105 and 121 for the reasons stated above and the mixer installer will not have the facilities or experience to conduct the required tests.

From our experience with 6X4 mixer vehicles with air brakes on all wheels we are confident the vehicle will pass all required braking tests.

In view of the above circumstances we are applying for an exemption to the certification requirements of FMVSS 105 and FMVSS 121.

These vehicles are scheduled to be shipped the last week of December. If an answer to my request can be made prior to this date it would be greatly appreciated. I may be contacted via a collect call to 604-860-3319, ext. 526.

If you require any additional information please contact me by telephone as letters from the United States generally take two weeks to arrive here.

Sincerely,

WESTERN STAR TRUCKS INC.

PER:

Stan R. Gornick, P. Eng. MVSS Compliance Specialist

SRG/az

c.c. Glen Ashdown Bruce Mabbett

ID: 08-000207--04 Jun 08--sa--revised

ID: 10316

Mr. Ken Daining
Supervisor, Vehicle Test and Development
ITT Automotive
3000 University Drive
Auburn Hills, MI 48326

Dear Mr. Daining:

This responds to your letter about Federal requirements applicable to an "on/off switch" for antilock brake systems (ABS). I apologize for the delay in our response. You stated that Chrysler Jeep owners disengage their ABS in response to the "perceived degraded performance it offers on off-road situations." You mentioned the possibility of designing a vehicle's gear system so that the ABS function is automatically disengaged when the vehicle is shifted into the four wheel drive-LO configuration. As explained below, while both manual and automatic ABS on/off switches are permitted under the current requirements, neither is required.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized under Title 49, Chapter 301 of the U.S. Code to issue FMVSSs that set performance requirements for new motor vehicles and new items of motor vehicle equipment. NHTSA does not approve or certify any vehicles or items of equipment, as is the practice in Europe. Instead, Chapter 301 establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards.

The agency has used this authority to issue FMVSS No. 105, Hydraulic Brake Systems, which specifies requirements for hydraulic service brake and associated parking brake systems. This Standard does not contain any provision requiring or prohibiting ABS. Likewise, it does not contain any provision requiring or prohibiting either a manual or automatic ABS on/off switch. Accordingly, either type of switch is permitted under the standard, provided the vehicle complies with the standard both when the device is "on" and when the device is "off."

FMVSS No. 105 will continue to apply to multipurpose passenger vehicles (MPVs), notwithstanding the agency's recent adoption of FMVSS No. 135 Hydraulic Brake Systems; Passenger Car Brake Systems, which applies only to passenger car brake systems (60 FR 6411, February 2, 1995). Even though FMVSS No. 135 does not apply to MPVs, you should be aware that FMVSS No. 135 prohibits passenger cars from being equipped with ABS disabling switches. The agency stated in a July 1991 notice that "such a switch could be left off when the ABS is needed, and that therefore, it would be more likely to be harmful than beneficial." Please note that this prohibition does not become immediately effective, even for passenger cars, since manufacturers can continue to certify compliance to FMVSS No. 105 for five years after FMVSS No. 135 takes effect.

If an automatic or manual ABS on/off switch were installed in a used vehicle, such a device must not "make inoperative" the vehicle's compliance with FMVSS No. 105. Specifically, 49 U.S.C. 30122 prohibits a motor vehicle manufacturer, distributor, dealer or repair business from installing such a device if the installation "makes inoperative" compliance with any safety standard. For instance, if a vehicle could only comply with the stopping distance or other service brake requirements in Standard No. 105 when the ABS is activated, then installation of the switch would serve to make inoperative compliance with the safety standard.

I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw of my staff at this address or by phone at (202) 366-2992.

Sincerely,

Philip R. Recht Chief Counsel

ref:105 d:3/8/95

ID: 07-0040004

ID: LCDDVD.1

Mr. Harold R. Burke, Esq.
Philip Russell, P.C.
71 Lewis Street
P.O. Box 1437
Greenwich, CT06836

Dear Mr. Burke:

This responds to your letter of January 23, 2003, in which you describe an automobile crash in which your client, a rear seat passenger, suffered serious facial trauma resulting from impact with an LCD screen that was part of a DVD television system incorporated into the rear of the headrest of the front passenger seat. You state that this television system was an aftermarket installation. Your letter then asks five questions seeking clarification of 49 U.S.C. 30122 and Federal Motor Vehicle Safety Standard (FMVSS) No. 201, Occupant Protection in Interior Impact, in the context of this factual scenario.

Preliminarily, we note that it is the policy of the National Highway Traffic Safety Administration (NHTSA) not to express any views or advice on the ultimate questions raised in litigation of private incidents or controversies. However, a pending lawsuit will not affect our ability to interpret our statutes and regulations. Accordingly, the following restates each question presented in your letter and provides our response. Please note that we have reordered your questions so as to simplify our response.

1. Is an entity which installs aftermarket electronic components such as DVD television screens in automobiles considered "a motor vehicle repair business" under 49 U.S.C. Sec. 30122?

Although NHTSA does not have any safety standards specifically covering television receivers, it is possible that the installation of a television receiver could affect the compliance of a vehicle with some safety standards. 49 U.S.C. 30122 expresses a general prohibition on making safety devices and elements inoperative. Specifically, subsection (b) provides:

A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard prescribed under this chapter [49 USC 30101 et seq.] unless the manufacturer, distributor, dealer, or repair business reasonably believes the vehicle or equipment will not be used (except for testing or a similar purpose during maintenance or repair) when the device or element is inoperative.

The statute defines "motor vehicle repair business" as "a person holding itself out to the public to repair for compensation a motor vehicle or motor vehicle equipment." 49 U.S.C. 30122(a). The term is further defined in NHTSAs regulations at 49 CFR 595.4 as including "businesses that receive compensation for servicing vehicles without malfunctioning or broken parts or systems by adding or removing features or components to or from those vehicles or otherwise customizing those vehicles." Status as a "motor vehicle repair business" is not dependent upon whether the vehicle or component was previously "broken" or needed to be "repaired," but, rather, it is based upon the commercial relationship between the vehicle owner and the individual or company performing the work on the vehicle or component. Any person who will accept compensation to repair a vehicle is a motor vehicle repair business.

To the extent that a commercial entity installs aftermarket electronic components in motor vehicles, that entity would be a motor vehicle repair business that would be prohibited from knowingly making inoperative features covered by any FMVSS under 49 U.S.C. 30122. This prohibition applies even if the modifications are to be made pursuant to the vehicle owners instructions. However, because we have not examined the vehicle in the present case, we express no opinion as to whether installation of the television system in question has precipitated a violation of section 30122.

2. Is the rear portion of a vehicles front headrest considered a "head impact area" pursuant to 49 C.F.R. Sec. 571.201S5?

The purpose of FMVSS No. 201 is to specify requirements designed to afford interior impact protection to vehicle occupants. Within that standard, paragraph S5.2 specifically deals with requirements for seat backs, providing:

Except as provided in S5.2.1 [provision applicable to school buses, not at issue here], when that area of the seat back that is within the head impact area is impacted in accordance with S5.2.2 by a 6.8 kilogram, 165 mm diameter head form at a relative velocity of 24 kilometers per hour, the deceleration of the head form shall not exceed 80g continuously for more than 3 milliseconds.

Paragraph S5.2.2 goes on to provide a demonstration procedure for seat backs. In conducting this test procedure, S5.2.2(d) provides, "For seats having head restraints installed, each test shall be conducted with the head restraints in place at its lowest adjusted position, at a point on the head restraint centerline." However, the requirements of this paragraph are only triggered once it has been determined that a portion of the seat back is within the "head impact area," as defined in the following section.

Under 49 CFR 571.3, Definitions, NHTSA defines the term "head impact area" as follows:

Head impact area means all nonglazed surfaces of the interior of a vehicle that are statically contactable by a 6.5-inch diameter spherical head form of a measuring device having a pivot point to "top-of-head" dimension infinitely adjustable from 29 to 33 inches in accordance with the following procedure, or its graphic equivalent:

(a)At each designated seating position, place the pivot point of the measuring device

(1)For seats that are adjustable fore and aft, at

(i)The seating reference point; and

(ii)A point 5 inches horizontally forward of the seating reference point and vertically above the seating reference point an amount equal to the rise which results from a 5-inch forward adjustment of the seat or 0.75 inch; and

(2)For seats that are not adjustable fore and aft, at the seating reference point.

(b)With the pivot point to "top-of-head" dimension at each value allowed by the device and the interior dimensions of the vehicle, determine all contact points above the lower windshield glass line and forward of the seating reference point.

(c)With the head form at each contact point, and with the device in a vertical position if no contact points exists [sic] for a particular adjusted length, pivot the measuring device forward and downward through all arcs in vertical planes to 90 each side of the vertical longitudinal plane through the seating reference point, until the head form contacts an interior surface or until it is tangent to a horizontal plane 1 inch above the seating reference point, whichever occurs first.

It is possible that the rear portion of a front headrest could fall within the "head impact area" as defined within NHTSAs regulations. Such determination would be made by undertaking the necessary calculations under paragraph S5.2.2 of FMVSS No. 201. However, because we have not examined the vehicle in question, we do not express any opinion as to whether the rear of the headrest in the present case is within the "head impact area" under the standard.

3. Is the rear portion of a vehicles front headrest considered to be a seat back pursuant to 49 C.F.R. Sec. 571.201S5?

NHTSAs regulations do not define the term "seat back." However, as noted above, under paragraph S5.2.2(d) of FMVSS No. 201, the test procedures clearly contemplate the presence of a headrest when conducting the necessary calculations related to seat backs. Additionally, FMVSS No. 202, Head Restraints, requires motor vehicle manufacturers to install head restraints at each front outboard seating position of light passenger vehicles. In light of the purpose of FMVSS No. 201, it is appropriate to include headrests within the scope of the standards protection, to the extent that they fall within the zone covered under the standard. Consequently, in conducting its enforcement activities, NHTSA has considered head restraints to be part of the seat back when calculating the "head impact area" under FMVSS No. 201.

4. Is the padded rear portion of a vehicles front headrest considered a "part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard?"

In order for a vehicle component to be considered a "part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard," thereby triggering the "make inoperative" provision of 49 U.S.C. 30122, it must be covered by an existing FMVSS. As discussed in the responses to questions #2 and #3 above, our review of existing FMVSSs suggests that FMVSS No. 201 may be applicable to the rear portion of a headrest, depending upon vehicle design.

However, because we have not examined the specific vehicle in question and have not conducted the necessary calculations under FMVSS No. 201, we cannot express any opinion as to whether the padded rear portion of a vehicles headrest is a plan view location covered under any FMVSS, and thereby subject to the "make inoperative" provision of 49 U.S.C. 30122.

5. Would a manufacturer of aftermarket equipment which is installed in accordance with the manufacturers instructions subject the manufacturer to liability under 49 U.S.C. 30122 if 49 C.F.R. Sec. 571.201S5 is violated in the process?

If NHTSA determines that a business has violated the "make inoperative" provision, it may assess a civil penalty in the amount of $5,000 per violation (not to exceed $15,000,000 in the aggregate). 49 U.S.C. 30165(a)(1). However, the applicability of 49 U.S.C. 30122 to a particular business is dependent upon the product or services that the business provides. As noted above, manufacturers, distributors, dealers, and motor vehicle repair businesses that install a product in a motor vehicle would be subject to 49 U.S.C. 30122.

In contrast, we have consistently held that producers of equipment, whether or not that equipment is used in a system designed to comply with a particular FMVSS, are component suppliers; as such, they are neither directly subject to the requirements of the standard, nor accountable under the "make inoperative" prohibition of 49 U.S.C. 30122. Consequently, a manufacturer of aftermarket electronic components would not be liable under 49 U.S.C. 30122, if it did not install the equipment alleged to have violated any FMVSS. However, manufacturers of motor vehicle replacement equipment are subject to the notification and remedy requirements for products with defects related to motor vehicle safety (49 U.S.C. 30118-30121). (See 49 U.S.C. 30102(a)(7) for the definition of "motor vehicle equipment," and 49 U.S.C. 30102(b)(1)(D) for the definition of "replacement equipment.")

In the present case, we have neither examined the television system in question nor have we investigated the incorporation of that system into this specific motor vehicle. In addition, we do not have any information on the manufacturers intended use for the television system (i.e., whether it is recommended for installation in motor vehicles). Consequently, we do not express any opinion as to whether the system is motor vehicle equipment.

If you have any further questions, please feel free to contact Eric Stas of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:201
d.4/18/03

ID: GF002147

ID: nht75-5.47

DATE: 05/05/75

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Oshkosh Truck Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This will acknowledge receipt of your request for reconsideration of the NHTSA determination of February 18, 1975, to Oshkosh Truck Corporation that Standard No. 121, Air brake systems, permits the installation of a handoperated service brake control that meets the requirements of the standard.

We will advise you of our determination as soon as possible.

YOURS TRULY,

OSHKOSH TRUCK CORPORATION

April 10, 1975

Richard Dyson Chief Council Office NHTSA

This responds to NHTSA approval of a hand-operated service brake control. Previous correspondence on this subject is attached for your reference.

Oshkosh trucks are equipped with service, emergency and parking brake systems which meet the requirements of FMVSS 121. As an additional parking brake, to be used in lieu of the standard parking brake supplied, a customer has requested a hand-operated control to activate the service brake system. Oshkosh Truck is concerned that installation of this control will circumvent certain FMVSS 121 parking brake and service brake requirements.

Parking brakes must be applied by an energy source not affected by an air pressure loss in the service brake system, as stated in FMVSS 121, Section 5.6.3. The parking brake control must be separate from the service brake control as stated in FMVSS 121, Section 5.6.4. If a truck is equipped with a hand-operated control which activates the service brake system and if this system, rather than the parking brake system, is used to park the truck, then Sections 5.6.3 and 5.6.4 are circumvented.

The service brake system must stop the truck in distances specified by FMVSS 121, Section 5.3.1. The hand-operated service brake control only applies air pressure to the front brakes. If a truck is equipped with a hand-operated control which applies only the front service brakes and if this system, rather than the normal dual service braking system (operating on front and rear brakes) is used to stop the truck, then stopping distances will be exceeded and Section 5.3.1 will be circumvented.

The NHTSA with the advent of FMVSS 121 specifies performance requirements for air brake systems. Oshkosh Truck has taken extraordinary measures to comply with these requirements and we are reluctant to add a component which circumvents any of those requirements, or by-passes any of our carefully engineered systems.

The NHTSA has determined that installation of a hand-operated control lever is acceptable. We are concerned that if this system is used to park a truck or stop a moving truck that it will not meet the requirements of FMVSS 121. Therefore, please reconsider the previous NHTSA determination and reply as soon as possible.

Thank you.

Danny J. Lanzdorf

Supervising Engineer

ID: powerliftgate

Mr. Paolo Ivaldi
Fiat Auto R&D U.S.A.
39300 Country Club Drive
Farmington Hills, MI 48331-3473





Dear Mr. Ivaldi:

This responds to your letter of March 20, 2001, and to your telephone conversations with Katherine McDonough of my staff. I am pleased to have this opportunity to answer your question about Federal Motor Vehicle Safety Standard No. 118, "Power-Operated Window, Partition, and Roof-Panel Systems" (49 CFR section 571.118).

You explain that you are designing a power-operated liftgate. By liftgate, you mean the type of vertically-opening back door that is typically found on a sport utility vehicle or van. Your system would allow the user to open and close the liftgate either remotely or by pushing a button on the vehicle console.

With regard to the power-operated liftgate you are designing, you ask three questions. First, you ask whether Standard No. 118 applies to the operation of such power-operated liftgates. Next, assuming that FMVSS No. 118 applies, you ask whether a liftgate, which will operate only when the vehicle's ignition key is in the on position, will satisfy the requirements of FMVSS No.118. Finally, again assuming that FMVSS No. 118 applies, you ask whether the standard requires that you put "pinch sensors along the liftgate openings."

The answer to all of your questions is that FMVSS No. 118 does not apply to power-operated liftgates. Paragraph S2 of FMVSS No. 118 reads, in pertinent part, "this standard specifies requirements for power-operated window, partition, and roof-panel systems." The term partition refers to the type of interior retractable window that might be found in a limousine, and the term roof-panel refers to the type of retractable panels that are commonly known as sunroofs. Accordingly, since a liftgate is not a window, partition, or roof-panel, FMVSS No. 118 does not apply to its operation.

During your conversation with Ms. McDonough, you mentioned that you are voluntarily equipping the liftgate with obstacle sensors. These sensors are capable of detecting the presence of an obstacle in both directions, e.g., both opening and closing, and will stop the motion of the liftgate until the obstacle is removed. We appreciate your effort to reduce the likelihood of injuries caused by the inadvertent closing of a liftgate on an occupant.

Please note that your liftgate must comply with FMVSS No. 206 "Door Locks and Door Retention Components." There are no special exemptions for power doors. Accordingly, your liftgate must meet all of FMVSS No. 206's requirements for back doors. In addition, all other applicable safety standards must be met.

I hope this letter answers your questions. Should you have any further questions, please feel free to call Katherine McDonough at 202-366-2992.

Sincerely,

John Womack
Acting Chief Counsel

ref:118#206
d.5/23/01

ID: aiam5544

Dear Mr. Mack: This is in reply to your letter of April 24, 1995 requesting a confirmation of your interpretation that 'Philips Color Clear (TM) Halogen Headlights . . . are in compliance with FMVSS-108.' The product in questions 'appears to be colored when not in use' but 'when lighted it produces white light as defined by J579C.' You have provided a report from ETL Testing Laboratories which 'indicates that the color of the light is identical to that of a standard halogen headlight.' There is no definition of white light in SAE J579c Sealed Beam Headlamp Units for Motor Vehicles, December 1978. We believe you mean SAE J578d Color Specification for Lighting Devices, September 1978 which does contain a definition expressed in chromaticity coordinates. The report you supplied indicates that the Philips lamp provides a light within the color coordinates for white when equipped with a red, black, blue, or white insert. As Standard No. 108 contains no requirements for the color of glass lamp lenses or bulbs, only the light emitted from the lamp, we confirm your conclusion that the Philips Color Clear (TM) headlamp has been designed to conform to the color requirements of Standard No. 108. We appreciated your visit to NHTSA on April 26 to demonstrate the lamp with its various inserts. I understand that the light produced by the lamp, and by a standard headlamp, appeared identical to the naked eye in a side by side comparison. If you have any further questions, you may refer them to Taylor Vinson of this Office (202-366-5263). Sincerely, John Womack Acting Chief Counsel;

ID: aiam5569

"Dear Mr. Wright: This responds to your request for information abou responsibilities of motorcycle manufacturers. As you discussed with Dorothy Nakama, the National Highway Traffic Safety Administration (NHTSA) does not 'regulate' how an enterprise becomes a 'recognized manufacturer.' Enclosed is NHTSA's information sheet for new manufacturers of motor vehicles and motor vehicle equipment, which discusses the main requirements of 49 U.S.C. section 30101 et seq. (formerly the Vehicle Safety Act). A copy of the Act is enclosed. Under section 30112(a) of the Act, a motorcycle manufacturer may not manufacture a motorcycle for sale unless the vehicle complies with all applicable Federal Motor Vehicle Safety Standards (FMVSS) and is covered by a certification issued under 49 U.S.C. section 30115. One safety standard is Standard No. 115 Vehicle Identification Number - Basic Requirements. (See 49 CFR 571.115.) In our regulations, at 49 CFR part 567 Certification, NHTSA has promulgated the requirement that a manufacturer certify compliance of its motorcycle with all applicable safety standards. Under part 566, NHTSA requires manufacturers to submit certain identifying information and a description of the items they produce. Also enclosed is a copy of a July 13, 1992 interpretation letter to Mr. Jeffrey Puentes, discussing serial numbers on motorcycle frames versus motorcycle VINs. As you may be aware, 'certificates of origin' are matters relating to vehicle titling, which the State regulates, rather than NHTSA. I hope this information is helpful. If you have any further questions, please contact Ms. Nakama at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel Enclosures";