ID: 20099.ogm

Mr. Mark LaPlante
Vice President, Manufacturing
EnTech Industries, Inc.
2211 Central Avenue, NW
P.O. Box 422
East Grand Forks, MN 56721-0422

Dear Mr. LaPlante:

Please pardon the delay in responding to your letter to this office in which you asked whether the equipment that your company produces for the steel structures recoating industry is excluded from the antilock brake system (ABS) requirement of Federal Motor Vehicle Safety Standard (Standard) No. 121, Air brake systems. The answer is yes.

You stated that the equipment that you manufacture is a trailer-mounted grit collection and cleaning device used to collect sandblasting grit and make it ready for re-use. The equipment in question is permanently mounted on a 40- foot single-drop fifth wheel trailer equipped with air brakes. You describe the equipment as being intended to be transported to a job site and moved only when a job is completed. Your letter further states that the trailer has a gross vehicle weight rating (GVWR) of 48,000 pounds and is not used to transport any other payload.

Chapter 301 of Title 49, U.S. Code (hereinafter Safety Act) authorizes this agency to establish Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. The Safety Act defines "motor vehicle" as:

[A] vehicle driven or drawn by mechanical power and manufactured primarily for use on the public streets, roads, and highways, but does not include a vehicle operated only on a rail line.

49 U.S.Code 30102(a)(6).

In reviewing the information you provided, assuming that the equipment in question remains stationary at job sites for an extended period of time, it is our opinion that the equipment is not a motor vehicle within the statutory definition. It is obviously designed to be used primarily off-road. Although it is portable and therefore capable of being transported on-road from the factory to the customer and by the customer from one job site to another, its on-road use is only incidental and not the primary purpose for which it was manufactured. Because it is not a motor vehicles, therefore, your equipment is not required to comply with the Federal motor vehicle safety standards, including Standard No. 121.

Please note that since State laws may require the mobile equipment your company manufactures to be registered, you may wish to contact State motor vehicle administrators to determine whether there are State requirements that must be met.

I hope this information is helpful to you. Should you have any further questions or need additional information, feel free to contact Otto Matheke of my staff at this address or at (202) 366-2992, fax (202) 366-3820.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:121

ID: 20117.nhf

Mr. Richard Lefebvre
President
Canadian Kingpin Specialists Ltd.
P.O. Box 74, Blezard Valley
Ontario Canada P0M 1E0

Dear Mr. Lefebvre:

This responds to your letter asking whether there are any National Highway Traffic Safety Administration (NHTSA) regulations that apply to the re-manufacture of kingpins or upper couplers. I apologize for the delay in our response. You ask about the male part of the connection that holds a tractor and semitrailer together.

By way of background information, NHTSA has the authority to issue Federal motor vehicle safety standards (FMVSSs) applicable to new motor vehicles and new items of motor vehicle equipment. We have a self-certification system under which motor vehicle and equipment manufacturers certify that their products comply with all applicable standards. For that reason, NHTSA neither approves, disapproves, endorses, nor grants letters of approval of products. We enforce compliance with the standards by purchasing new vehicles and equipment when they have been offered for sale to consumers and testing the products to our standards' requirements. Vehicles and equipment must also be free of safety-related defects. If a vehicle or item of equipment does not comply with our standards or has a safety-related defect, the manufacturer of the product has the responsibility of recalling the product and remedying the problem free of charge.

Turning now to your question about kingpins and upper couplers, NHTSA has not issued any standard applicable to these items of motor vehicle equipment. However, the products are subject to our authority to investigate safety-related defects. If NHTSA or a manufacturer determines that the product contains a safety defect, the manufacturer would have to notify purchasers of the defective equipment and remedy the problem free of charge.

Our statute at 49 U.S.C. 30122 (copy enclosed) provides that a manufacturer, distributor, dealer, or vehicle repair business may not knowingly "make inoperative" any device or element of design installed on or in a motor vehicle in accordance with any FMVSS. Therefore, your product could not be installed by one of the parties listed in 30122 if the installation would adversely affect the compliance of a device or element of design installed pursuant to an FMVSS. This provision does not apply to modifications made to a vehicle by its owner.

I note that the Department's Federal Motor Carrier Safety Administration has jurisdiction over interstate motor carriers operating in the U.S. You should contact that office at (202) 366-4012, for information about any requirements that may apply to your product. In addition, states have the authority to regulate the use and licensing of vehicles operating within their jurisdictions. You should therefore check with the Department of Motor Vehicles in any state in which the equipment will be sold or used.

For your further information, I am enclosing a fact sheet we prepared entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment, and Where to Obtain NHTSA's Safety Standards and Regulations.

I hope this information is helpful. If you have any questions or need additional information, feel free to contact us at (202) 366-2992.

Sincerely,

Frank Seales, Jr.
Chief Counsel
Enclosures
ref:VSA
d.3/7/2000

ID: 20127.ztv

Mr. Tom Shreeve
Manager of Engineering
Trident Automotive Lighting
P.O. Box 821
Kentwood, MI 49518-0821

Dear Mr. Shreeve:

This is in reply to your letter of June 7, 1999, asking for an interpretation of S5.1.1.18 of Federal Motor Vehicle Safety Standard No. 108, as modified by footnote 1 of Figure 2.

Table I and Table III of Standard No. 108 require motor vehicles as specified in these Tables to be equipped with a backup lamp complying with SAE Standard J593c Backup Lamps February 1968. However, under S5.1.1.18, a backup lamp is not required to meet the minimum photometric values at each test point specified in Table 1 of SAE J593c if the sum of the candlepower actually measured at the test points within a group listed in Figure 2 of Standard No. 108 is not less than the sum of the total minimum candlepower specified in Figure 2 for test points in that group.

Figure 2 specifies minimum luminous intensity for backup lamps for five groups of test points, or "zones" as you refer to them. Both J593c and Standard No. 108 permit more than one backup lamp to be used. Footnote 1 of Figure 2 states that:

When 2 lamps of the same or symmetrically opposite design are used, the reading along the vertical axis and the averages of the readings for the same angles left and right of vertical for 1 lamp shall be used to determine compliance with the requirements. If 2 lamps of differing designs are used, they shall be tested individually and the values added to determine that the combined units meet twice the candela requirements.

When only 1 backup lamp is used on the vehicle, it shall be tested to twice the candela requirements.

You interpret this as meaning that,

when using two lamps that are symmetrically opposite in design, the intent of this footnote was to allow the average of the two lamps combined output. That is, the right hand lamp output in zone 2 added with the left hand lamp output in that same zone 2, and that the average of those two lamps for that zone must not be less than the minimum candela requirements.

However, your customer thinks that

the intent is for us to average the zones 2 and 5 of the same lamp. If this is done, it is measuring output of the lamp at angles opposite of each other and that these two zones actually are intended to illuminate a completely different target area. If the averaging is done in this manner, it will also default the third sentence of the footnote [which reads: "When only one backup lamp is used on the vehicle, it shall be tested to twice the candela requirements."].

SAE Standard J593c is straight-forward. If a single backup lamp is used, it shall comply with twice the minimum candela requirements specified in Table 1 of J593c. If two lamps are used (and they are identical or symmetrical), each lamp must meet the minimum candela requirements. Thus, the total light output of a backup lamp system is intended to be roughly the same, whether the system consists of one or two lamps. This is the basic backup lamp requirement incorporated by reference in Standard No. 108.

Unlike SAE J593c and as an alternative to it, S5.1.1.18 does not require a lamp to meet every test point if the sum of the candlepower measured for all test points within a group of test points described in Figure 2 is not less than the sum of the minimum candlepower required for all test points in that group.

The question that you have asked is how Footnote 1 shall be interpreted as to group photometric measurements in a backup lamp system consisting of two symmetrically opposite lamps. This requires an interpretation of the meaning of "the averages of the readings for the same angles left and right of vertical for 1 lamp shall be used to determine compliance with the requirements." We did not intend Footnote 1 to alter the concept of group photometrics. The quoted language simply means that each lamp shall meet the group candlepower minimum specified in Figure 2 for each group. It does not mean, as your customer thinks, that two groups within the same lamp left and right of vertical are combined into a larger group and averaged. The footnote deals solely with individual test points.

Footnote 1 clearly refers to a single lamp and not, as you argue, to the average of the output of the same group in two lamps, one on each side of the vehicle. We interpret it as saying that, if two lamps of the same or symmetrically opposite design are to be installed, the test for a single lamp in a pair shall be as follows. First, measure all test points. Second, take the values of the test points on the vertical axis and use them to calculate their respective group totals. Next, add the measured values of two symmetrically opposite test points, divide by two, and use this average as the value for each of the two test points when calculating the group sum in which each of the two test points is located. Then do the same for the rest of the test points. Finally, calculate the sum of each group and compare with the totals provided in Figure 2 for each group to determine whether the lamp meets the test requirements of Standard No. 108.

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.10/26/99

ID: 20132.ztv

Mr. Shigeyoshi Aihara
Project Manager
Regulation and Compliance
Engineering Administration Department
Ichikoh Industries, Ltd.
80 Itado Ishehara City
Kanagawa Pref.
250-1192 Japan

Dear Mr. Aihara:

This is in reply to your letter of June 10, 1999, presented at a meeting with NHTSA representatives that day, asking for an interpretation of S5.1.2 of Federal Motor Vehicle Safety Standard No. 108. I am sorry that we were unable to provide you a response by July 6 as you requested in your letter of June 28 to Taylor Vinson of this Office.

Your company has developed a new rear turn signal lamp, consisting of an outer plastic lens, an inner cap, and an uncolored filament bulb. The color of the lens is "pale (light) pink color, and, this plastic material complies with the requirements of SAE J576c . . . excluding the color requirement." You tell us that the trichromaticity coordinates of the plastic material used in the outer lens do not fall within either the red or the white areas of the chromaticity chart of SAE J578c. However, when illuminated, the lamp provides an amber color that fall within the coordinates specified in SAE J578c. You have asked whether this design is acceptable under S5.1.2 relating to plastic materials used in optical parts of motor vehicle lighting devices.

Although this does not affect our answer to your question, please note, in Standard No. 108, that SAE Recommended Practice J576c of 1970 has been replaced by SAE J576 JUL91 as the applicable standard for plastic materials used in lighting devices. However, J578c remains the Federal standard for color.

We regret to inform you that this design is not acceptable. Although S1, Scope, of SAE J578c states that "The specification applies to the overall effective color of light emitted by the device," regardless of the color of its lens, both SAE J576 JUL91 and Standard No. 108 apply the color requirement to plastic components of lamps as well. S5.1.2(e) of Standard No. 108 requires the trichromatic coordinates of the plastic samples, tested according to that paragraph, to conform to the requirements of SAE J578c. Paragraphs 4.1 and 4.2.2 of SAE J576 JUL91 also require conformance of plastic samples to the chromaticity coordinate requirements of SAE J578c. This standard specifies color coordinates only for red, white, yellow (amber), green, and blue. Because the lens of your lamp does not meet any of the coordinates of SAE J578c, Standard No. 108 does not permit its use.

At the meeting, we noted that the iner lens was a greenish color. It, too, must comply with the color coordinate requirements of paragraphs 4.1 and 4.2.2 of SAE J576 JUL91.

At that time, you also asked if it were acceptable to use a plastic fabricated from the mix of two resins, each of which complied with the requirements of SAE J576. You cannot assume, when two complying resins are blended, that the resulting plastic will also comply with SAE J576 JUL91, and we recommend that you test the blended plastic to ensure that it meets all the specifications of S5.1.2 and SAE J576 JUL91. This would be the case whether it was the intent to create a new color, or whether the rejected molded parts are reground and plastics of differing compositions are mixed and recycled into newly-molded lamp lenses. As we said in the preamble to the 1995 final rule amending S5.1.2, "it is incumbent upon the vehicle or equipment manufacturer . . . not to change the composition of the plastics materials [obtained from the plastics manufacturer] in a manner that would cause it to be noncomplying." 60 FR 46066, copy enclosed.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:108
d.8/27/99

ID: 20146.drn

Dr. Barbara Goodman
Director, Pupil Transportation
Commonwealth of Virginia
Department of Education
P.O. Box 2120
Richmond, VA 23218-2120

Dear Dr. Goodman:

This responds to your request for an interpretation on the continuing validity of the National Highway Traffic Safety Administration's interpretation letter of August 11,1987, to Mr. Ernest Farmer, Director of Pupil Transportation of the Tennessee Department of Education on refurbishing school buses.

This letter confirms that the August 11, 1987, interpretation letter to Mr. Farmer is still valid. For your information, I am enclosing a copy of a May 2, 1988, interpretation letter to Robert R. Keatinge, Esq. The Keatinge letter clarifies the Farmer letter by explaining that in interpreting 49 CFR 571.7(e), the Farmer letter understood the bus bodies involved to be new. Therefore, the Farmer letter did not purport to address the question of combining an old bus body with new and/or used chassis components.

I hope this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:VSA#571.3
d.7/16/99

ID: 20159.ztv

Ms. Tammy Ruff
Sandrail Mfg. Co.
231 E. Alessandro Blvd 344
Riverside, CA 92508-8963

Dear Ms Ruff:

The Federal Highway Administration has forwarded to us for reply your letter of May 5, 1999. Your letter has been supplemented with information obtained from a telephone call to your office on June 23, 1999, by the agency's Office of Vehicle Safety Compliance, as well as from your website on June 22, 1999.

You ask for a list of "the necessary equipment to enable the street legal construction of dune buggies to be driven in Hawaii" as rental vehicles.

Under the laws that we administer, a vehicle that is "street legal," i.e., which is manufactured primarily for use on the public roads, is required to comply with all applicable Federal motor vehicle safety standards. Your website information describes the Sandrail as "designed to be driven on soft sand, the beach and tall hills." Thus, the Sandrail has not been designed primarily for on road use and, in its present configuration, is not a "motor vehicle" subject to our jurisdiction.

However, your present intent is to construct "street legal" Sandrails. We shall consider those vehicles as manufactured primarily for use on the public roads and therefore "motor vehicles" which must comply with our laws regulating motor vehicles and their manufacturers.

Our Office of Vehicle Safety Compliance learned from your company on June 23, 1999, that the vehicles that Sandrail intends to manufacture will be capable of speeds of more than 25 miles per hour. The on-road Sandrail will be required to meet the same Federal motor vehicle safety standards as "multipurpose passenger vehicles" (assuming that the dune buggies retain their capability for occasional off-road operation). These standards include the requirements to provide air bags for the driver and outboard front seat passenger. Sandrail is also required to submit to this agency certain information relating to its VIN in accordance with 49 CFR Part 565 Vehicle Information Number.

Sandrail is also required, within 30 days after it commences manufacture of motor vehicles, to file with us an information statement in compliance with 49 CFR Part 566 Manufacturer Identification.

I enclose a copy of a "New Manufacturers" information package which will outline our requirements for manufacturers.

If you would like more information on the Federal motor vehicle safety standards, or have any other questions, please contact the agency's Office of Vehicle Safety Compliance.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
ref:500
d.7/22/99

ID: 20161.ztv

Mr. Ron Woodward, P.E.
Section Supervisor Optics & Adv. Eng.
Federal-Mogul Corporation
Lighting Products
2513 58^th Street
Hampton, VA 23661

Dear Mr. Woodward:

This is in reply to your letter of June 7, 1999, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108.

S7.8.2.1(c) of Standard No. 108 states that:

A visually/optically aimable headlamp that has a lower beam shall not have a horizontal adjustment mechanism unless such mechanism meets the requirement of paragraph S7.8.5.2 of this standard.

Paragraph S7.8.5.2 requires each headlamp system that is capable of being aimed by equipment installed on the vehicle to include a Vehicle Headlamp Aiming Device (VHAD) that conforms to the remainder of the paragraph. Paragraph S7.8.5.2(a)(2)(iv)requires that the horizontal indicator of a horizontal adjustment mechanism of a VHAD

shall be capable of recalibration over a movement of +/- 2.5 degrees relative to the longitudinal axis of the vehicle to accommodate any adjustment necessary for recalibrating the indicator after vehicle repair from accident damage.

You ask for

a ruling on the acceptability of a horizontal adjustment system which purposely does not meet the +/- 2.5 degrees horizontal adjustment requirement and does not incorporate the VHAD indicator, on the assertion that since they purposely do not meet the requirements for the permitted horizontal adjuster system that the system qualifies as not having a horizontal adjuster system.

You give as an example a lamp that has a +/- 1 degree of horizontal travel.

You are asking for an interpretation that a system that adjusts a headlamp horizontally but which differs from the specifications of S7.8.5.2 is not a "horizontal adjustment system" within the meaning of S7.8.2.1(c). We cannot provide the interpretation you seek. You admit that the headlamp is not fixed but is adjustable horizontally up to +/- 1 degree. As you note, "[t]he standard

. . . states that the only acceptable type of horizontal adjuster is a horizontal adjuster which conforms to the horizontal VHAD requirements contained in the standard."

Standard No. 108 is quite clear on this point: a manufacturer need not provide a horizontal adjustment mechanism on a headlamp that is visually/optically aimable and has a lower beam. But if the manufacturer chooses to provide a mechanism that adjusts the headlamp, it must meet all requirements of S7.8.5.2 including the +/-2.5 degree specification, even if the headlamp itself is designed for only +/- 1 degree of horizontal travel.

Because we cannot concur with your desired interpretation, we are treating this matter as a petition for rulemaking in accordance with your request. We have forwarded your letter to the Associate Administrator for Safety Performance Standards who will respond to your petition.

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.8/20/99

ID: 20174.ztv

Mr. Bart W. Hill
JMH Trailers
233 Far View Road
Hamburg, PA 19526

Dear Mr. Hill:

This is in reply to your letter of June 9, 1999, with respect to the operation of side turn signal lamps on dump bodies that your company manufactures. Thank you for including photos to help us advise you.

You install side turn signal lamps on your products. The wiring on trucks with dump bodies is such that "the side turn also lights when the brakes are applied" (we understand that the side turn signal is steady burning when activated by the brakes). A Pennsylvania state police officer has told your customer that this is illegal. However, the Pennsylvania Department of Transportation ("PennDot")has informed you that it is legal "if it does not violate the Federal standard." Therefore, you have asked whether this configuration does violate the Federal standard.

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, does not require a vehicle to have side turn signal lamps. S5.1.3 of Standard No. 108 prohibits the installation of supplemental lighting equipment if the lamps would impair the effectiveness of lighting equipment that the standard requires. As we see it, the question here is whether the operation of both amber-colored side turn signal lamps in a steady burning mode when the red stop lamps are activated in a steady burning mode can be said to impair the effectiveness of the stop lamps.

The activation of both side turn signal lamps in a steady burning mode is the functional equivalent of an amber supplementary stop lamp that is mounted on the vehicle's side. In our opinion, auxiliary lighting equipment must perform in the same manner, and perform the same function, as the original equipment it is intended to supplement. Standardization of signals is important so that following drivers will not hesitate to respond when the brakes of a vehicle are applied and its stop lamps are activated. The combination of amber side lamps and red rear ones have the potential to create confusion in adjacent and following drivers. I am sorry, therefore, to tell you that we have concluded that your system of amber stop lamps would impair the effectiveness of the stop lamps required by Standard No. 108, and, hence is impermissible under S5.1.3.

If you have any questions you may phone Taylor Vinson of this Office (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.8/27/99

ID: 20176.ztv

Ms. Debra Taylor
Vice President - Finance
Mercury GSE
135 Sheldon Street
El Segundo, CA 90245

Re: Classification of Airfield Bus as "Off Road" Vehicle

Dear Ms. Taylor:

We are replying to your letter of June 19, 1999. You have asked for confirmation that the Cobus 3000 is an "off road" vehicle, and "as such with which Federal and State specifications and regulations, if any we must comply with to legally sell our bus to Covington Airport in northern Kentucky."

The National Highway Traffic Safety Administration is authorized to regulate "motor vehicles." A "motor vehicle" is defined in pertinent part as a vehicle "manufactured primarily for use on the public streets, roads, and highways" (49 U.S.C. 30103(a)(6)).

You have enclosed a brochure on the Cobus 3000 and tell us that it is "built specifically for airfield use, to transport passengers between a remotely parked aircraft and the terminal or from terminal to terminal." The brochure identifies the Cobus 3000 as "the airport star" and depicts it in various applications around airfields.

We do not consider airfields to be "public roads," nor such service roads as may lead from terminal to terminal or from parking lots to terminals. Therefore, we do not consider the Cobus 3000 to be "manufactured primarily for use on the public roads," and a "motor vehicle" subject to our jurisdiction (we have no definition of an "off road" vehicle as such).

This means that there are no regulations or specifications of this agency that apply to the Cobus 3000. The Consumer Product Safety Commission (CPSC) has jurisdiction over vehicles that are not motor vehicles. We are unable to advise you whether the CPSChas issued regulations covering airport buses. I am sorry that we are also unable to advise you whether either Kentucky or the Covington airport authority has issued rules or regulations on airport buses.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:571
d.9/9/99

ID: 20178.ztv

ECIE
Via Comune Antico, 43
20125 Milano
Italy
Attn: Mara Migliazza

Dear Ms. Migliazza:

We are replying to your emails of June 18, 1999, to Kenneth Weinstein of this agency, and of July 8, 1999, to Taylor Vinson of this Office. We apologize for the delay in responding to you.

In your first email, you have told us that your company manufactures lighting equipment for motorcycles and that you "have the certificate of compliance and test report of our device with tests according to your FMVSS 108." You have asked whether the certificate of compliance is "always acceptable for you or have we to remake all the test to obtain another certificate after some year?" You reference a headlamp that meets the 1992 version of Standard No. 108 and is molded with a "92DOT" symbol, which is supported by "the test report and the certificate of compliance of 1992."

First, a clarification. We believe that you are using the term "certificate of compliance" to mean the statement by a test laboratory that the lighting device that it has tested meets the specifications of Standard No. 108, as indicated by the accompanying test report. However, under our laws, a "certificate of compliance" is the indication by a manufacturer that its lighting product meets Standard No. 108, such as the DOT symbol on a headlamp lens.

Each item of motorcycle lighting equipment covered by Standard No. 108 must comply with the standard, and be certified by its manufacturer as conforming to the standard. A test report based on proper testing can verify that the particular lamp tested conforms to Standard No. 108, and can afford a reasonable basis for the manufacturer to certify compliance, by concluding that identical lamps, if tested, would also conform to Standard No. 108. However, human and mechanical errors in production (such as failure to account for variations in tolerances) can result in the production of non-complying products. Therefore, we believe that a manufacturer of lighting equipment should test its product pursuant to a quality control program after the lighting item is produced to assure itself that the product as manufactured conforms to Standard No. 108.

In your email of July 8, 1999, you ask if we can write "what is the US right procedure for lighting device certification." We are pleased to provide you with this information. The lens of each headlamp (other than a motorcycle headlamp) must be certified by marking it with the DOT symbol (S7.2(a) of Standard No. 108), whether the headlamp is original or replacement equipment. Other items of replacement lighting equipment, including motorcycle headlamps, may be certified either by marking with the DOT symbol (S5.8.10), or "by a label or tag on the equipment or on the outside of the container in which the equipment is delivered" (49 U.S.C. 30115). Other than headlamps, no certification is required for lighting items installed on a motor vehicle as original equipment; the manufacturer of the vehicle attaches a label to the vehicle certifying that it complies with all applicable Federal motor vehicle safety standards, and this includes certification to the requirements of Standard No. 108. Of course, the vehicle manufacturer should obtain test reports and other quality-related assurances from the lighting equipment manufacturer that the equipment complies before it affixes its vehicle certification label.

There is no need to "register" a certificate of compliance with NHTSA or any other entity. However, a manufacturer located outside the United States is required to designate an agent in the United States who can receive official correspondence (49 CFR 551.45). Further, all manufacturers of equipment covered by Standard No. 108 are required to file an identification statement with us (49 CFR 566).

I hope that this answers your questions.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.10/28/99