ID: nht95-2.11

TYPE: INTERPRETATION-NHTSA

DATE: March 23, 1995

FROM: Mary J. Gazich -- Owner - Clever Kids, inc.

TO: Phillip Recht -- Chief Council, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 5/19/95 LETTER FROM JOHN WOMACK TO MARY J. GAZICH (A43; REDBOOK 2; VSA 102(4))

TEXT: Dear Mr. Recht:

My company will be marketing a new automobile accessory for children.

The "Smart Rider" is a seat back protector that is made of vinyl with two 3/4" elastic bands attached. There is a design screenprinted on the vinyl as well. This product slips over either, or both of the front seats, protects the seat back interior from kid's feet, and entertains children riding in the back seat.

Please inform me if this product meets the standards for the National Highway Traffic Safety Administration. If so, do we need to make a statement regarding this on our packaging?

Thank you.

ID: nht95-2.12

TYPE: INTERPRETATION-NHTSA

DATE: March 27, 1995

FROM: Yvonne Roppel -- Liaison Officer, Title and Registration Services, State of Washington, Department of Licensing

TO: Phillip Reckt -- Chief Council, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 5/19/95 LETTER FROM JOHN WOMACK TO YVONNE ROPPEL (A43; REDBOOK 2; Part 580)

TEXT: Dear Mr. Reckt:

I recently conferred with Dick Morse of NHTSA who asked me to request of you a written reply to my question.

I had asked Mr. Morse as to who should sign an original title application for a leased vehicle, the lessee or the lessor.

As background, I advised Mr. Morse that in Washington State the lessee is shown on the title as a registered owner and is required to sign the original application at the dealership. (This is only concerning a vehicle still under the Manufacturer's Cert ificate of Origin.) Normally the lessee is choosing the vehicle from the dealer inventory. The yearly license renewal notice is mailed to the lessee in most cases. The registered owner or lessee is liable if any legal action is filed against the vehicl e.

Mr. Morse has indicated that when the lessee is shown on the title, they would be considered a registered owner and would therefore acknowledge the odometer disclosure made bythe selling dealer. I asked if he would put this in writing at which time he i ndicated that I would have to write to your office. Therefore, I am asking if I could have a letter sent to me verifying in writing his reply.

Thank you for your assistance in this matter.

ID: nht95-2.13

TYPE: INTERPRETATION-NHTSA

DATE: March 27, 1995

FROM: Ken Calvert -- Member of Congress

TO: Edward D. Harrill

TITLE: NONE

ATTACHMT: ATTACHED TO 6/18/95 LETTER FROM JOHN WOMACK TO KEN CALVERT (A43; VSA 102(4))

TEXT: LETTER 1:

Dear Mr. Harrill:

My office has received an authorization for a Congressional Inquiry on behalf of my constituent Mr. Alexander Patnode, SSN 043-07-7207. We are enclosing a copy for your review along with paperwork Mr. Patnode feels will be pertinent to his request.

Mr. Patnode is requesting our assistance in obtaining information regarding the purchase of an engine stand from Pep Boys Auto parts. This stand is made in China for Rally Accessory Inc. located in Miami, Florida. Failure of the stand caused an engine to fail, injuring his ankle. Mr. Patnode states he can't find an agency in the state that will accept or act on his complaint. After a review of Mr. Patnode's paperwork my office would appreciate a written response to his request.

Thank you for your interest in Mr. Patnode. If we may be of further assistance in this matter you may contact Genelle Stephens of my Riverside District Office. I am looking forward to your reply.

Sincerely,

Ken Calvert

LETTER 2:

03/21/95

Ken Calvert 3400 Central Ave. Suite 200 Riverside, Ca. 925

Your Honor,

I need your assistance. I purchased an engine stand from Pep Boy's auto parts, in Temecula, Ca., Failure of the stand caused an engine to fall, injuring my ankle. The stand is made in China, for Rally accessory Inc. located in Miami, Florida. The s tands are obviously made without quality control. I purchased a second stand to use as evidence in my lawsuit. It did not have the same welds, which failed on the first stand. A third stand, on display at Pep Boy's, is made different from either of th e other two. It has an additional brace, welded on the lower portion, in the same area where the first stand failed. None of the stands are equipped with the large brace that appears in the assembly manual.

Home mechanics often leave engines mounted on these stands for extended periods of time. There is potential for serious injury or death to occur, should a stand fail, especially if there are children in the area. Neither Pep Boy's nor Rally seem to be taking this condition seriously.

I called the U.S. Consumer Products Safety Commission hot line. It took until the next day for them to respond, when they told me that they do not handle this. I find it hard to believe that this type of problem doesn't come under their jurisdiction. I haven't been able to find an agency in the state that can accept or act on my complaint. I also contacted the Consumer Affairs in the Attorney General's office, but they couldn't help me. I am enclosing pictures that I hope will illustrate my problem . Any help that you can give will be greatly appreciated.

Sincerly,

Alexander H. Patno

32840 SHEILA LANE

LAKE ELSINORE, CA 92530

(Brochure omitted.)

LETTER 3:

April 27, 1995

John Womack, Esq. Office of the Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation Room 5219 400 7th Street, SW Washington, DC 20590

Dear Mr. Womack:

As we discussed by telephone, the Consumer Product Safety Commission ("CPSC") received an inquiry from Rep. Ken Calvert concerning what agency would have jurisdiction over an engine stand purchased by Mr. Alexander H. Patnode. The stand broke, causin g an injury to Mr. Patnode's ankle.

The Consumer Product Safety Act excludes "motor vehicle equipment," as that term is used in the National Traffic and Motor Vehicle Safety Act of 1966, from the CPSC's jurisdiction. As we discussed by phone, it appears that this engine stand is motor vehicle equipment. Accordingly, I have enclosed the material we received on this incident.

Please contact me if you need anything further.

Sincerely, Harleigh Ewell

cc: The Hon. Ken Calvert

ID: nht95-2.14

TYPE: INTERPRETATION-NHTSA

DATE: March 29, 1995

FROM: Jeffrey D. Shetler -- Kawa Saki Motors Corp., U.S.A

TO: Taylor Vinson -- NHTSA

TITLE: Projector Beam Headlamp

ATTACHMT: ATTACHED TO 4/24/95 LETTER FROM PHILIP RECHT TO JEFFREY SHETLER (A43; STD. 108); ALSO ATTACHED TO 2/7/94 LETTER FROM JEFFREY D. SHETLER TO NHTSA ASSOCIATE ADMINISTRATOR FOR ENFORCEMENT; ALSO ATTACHED TO 5/6/94 LETTER FROM JOHN WOMACK TO JEFFREY D. SHETLER

TEXT: Attached per my telephone conversation with Mr. John Womack are the following:

1. Two drawings of projector beam headlamps a) original drawing submitted with our February 7, 1994 request for interpretation (Drawing A) b) modified drawing showing the addition of a cowling over the headlamp (Drawing B)

2. February 7, 1994 Kawasaki correspondence to NHTSA

3. May 6, 1994 correspondence from Mr. Womack

Standard 108 requires a motorcycle to have at least one headlamp. Table IV requires the headlamp to be located on the vertical centerline, except that if two are used they shall be symmetrically disposed about the vertical centerline.

The subject Kawasaki motorcycle headlamp in Drawing A and B contains the upper and lower beam in one housing and is a single headlamp. However, the addition of the cowling (Drawing B), which is a permanent part of the motorcycle to which the headlamp wi ll be applied, provides the appearance of two headlamps.

My question to Mr. Womack during our telephone conversation was concerning the addition of the cowling and the interpretation of the requirements in Standard 108.

Will the revised proposed application of the projector beam headlamp to a motorcycle as seen in Drawing B meet the requirements of Standard 108?

Thank you in advance for your quick response to our inquiry.

If you have any questions, please do not hesitate to contact me. I can be reached at (714) 770-0400 ext. 2456.

Regards

DRAWINGS OMITTED.

ID: nht95-2.15

TYPE: INTERPRETATION-NHTSA

DATE: March 30, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Brad Rourke -- Director, Government and Community Affairs, The Electric Bicycle Company

TITLE: NONE

ATTACHMT: ATTACHED TO 2/4/95 LETTER FROM BRAD ROURKE TO PHIL RECHT

TEXT: Dear Mr. Rourke:

Thank you for your letter of February 4, 1995. I am pleased to answer your questions about the applicability of the regulations of the National Highway Traffic Safety Administration (NHTSA) to your electric-assisted bicycle.

We have reviewed Adam Englund's memorandum of January 26, 1995, which you enclosed. In general, it is a complete and accurate statement of the applicability of our regulations to motor driven cycles. We have the following comments which I hope you will find helpful.

Certification label. The appropriate regulation is 49 CFR Part 567. The statutory authority that it implements, 15 U.S.C. 1403, was recodified last summer as 49 U.S.C. 30115 without any substantive change.

Vehicle Identification Number. "15 USC 565" should be 49 CFR Part 565.

Lighting. While the analysis is correct, we note that Tables III (required equipment) and IV (location of required equipment) give a reader an immediate ready reference to motorcycle lighting equipment.

Horn. This section can be included in the one following, on controls and displays. The reference to 49 CFR "571.125 Warning Devices" is incorrect. The warning device covered by that standard is a retroreflective triangle, not a horn.

We note also that if a motorcycle is equipped with a windshield, it must comply with Standard No. 205 Glazing Materials, and that motorcycles with hydraulic brake systems are required to be furnished with brake fluid meeting Standard No 116 Brake Fluids.

You also have asked three specific questions. The first relates to the requirement of Standard No. 123 Motorcycle Controls and Displays that the rear brake be operable by the left hand (or right foot) control and the front brake operable by the right ha nd control. This is the opposite of bicycle brake systems. You believe that most riders will expect the electric bicycle to brake like a conventional one and that accidents may occur as a result of confusion. For this reason, you would like to place th e rear brake control on the right handlebar, and the front brake control on the left.

The purpose of Standard No. 123 is "to minimize accidents caused by operator error . . . . by standardizing certain motorcycle controls and displays" so that a motorcycle operator can instinctively respond to threatening situations no matter what the mac hine. Your question raises the possibility that the purpose of the standard might be defeated with respect to the electric bicycle by strict application of Standard No. 123 when it is operated by those who are familiar with bicycle braking systems (thou gh this would not be the case if the operator is switching from a motorcycle to an electric bicycle). We do have authority to exempt manufacturers for up to two years from a requirement if it would promote the development or field evaluation of a low-em ission vehicle, or if compliance would prevent the manufacturer from selling a vehicle whose overall level of safety equals or exceeds that of a complying vehicle. The exemption procedures are contained in 49 CFR Part 555. Taylor Vinson of this Office will be glad to answer any questions you have (202-366-5263). You also may petition for rulemaking, as provided in 49 CFR Part 552, for an appropriate amendment to Standard No. 123. However, in the absence of an exemption or a change in Standard No. 12 3, the braking system of the electric bicycle must operate as provided in this standard.

Your second question relates to headlighting requirements for motor driven cycles. You believe that the headlamp specified by Standard No. 108 will reduce the ability of the electric bicycle to perform at night, and, for this reason, would like to use " a high-power bicycle-type headlamp." SAE J584, incorporated by reference in Standard No. 108, permits a motor driven cycle to be equipped with a single beam headlamp. If you wish to use a headlamp that does not comply with Standard No. 108's requirement s for motor driven cycle headlamps, you must petition for an exemption, and/or for rulemaking, as discussed in the prior paragraph. In addition to allowance of a single beam headlamp, paragraphs S5.1.1.21 and S5.1.1.22 of Standard No. 108 recognize the limitations of low-powered motorcycles and permit motor driven cycles whose top speed is 30 mph or less to omit turn signal lamps, and to be equipped with a smaller less powerful stop lamp.

Your final question relates to Standard No. 123 and your wish to use a spring-loaded thumb-lever throttle. This is permissible, and no requirements are prescribed for it by Standard No. 123. Your interpretation of Standard No. 123 is correct; a twist-g rip throttle is not required, but if it is provided, it must operate in the manner set forth in the standard.

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

ID: nht95-2.16

TYPE: INTERPRETATION-NHTSA

DATE: March 31, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Truman J. Lothen

TITLE: NONE

ATTACHMT: ATTACHED TO 2/6/95 LETTER FROM TRUMAN J. LOTHEN TO NHTSA (OCC 10754)

TEXT: Dear Mr. Lothen:

This responds to your letter of February 6, 1995, requesting information on requirements applicable to a "van seat/bed for aftermarket installation." Your questions and our response to each follows.

Does your department have safety standards that must (should) be designed into aftermarket vehicles seats?

The National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Federal law prohibits any person from manufacturing, intr oducing into commerce, selling, or importing any new motor vehicle or item of motor vehicle equipment unless the vehicle or equipment item is in conformity with all applicable safety standards. NHTSA, however, does not approve motor vehicles or motor ve hicle equipment, nor do we endorse any commercial products. Instead, each manufacturer is required to "self-certify" that its products meet all applicable safety standards.

There are five safety standards that are relevant to your inquiry: Standard No. 207, Seating Systems, Standard No. 208, Occupant Crash Protection, Standard No. 209, Seat Belt Assemblies, Standard No. 210, Seat Belt Assembly Anchorages, and Standard No. 3 02, Flammability of Interior Materials.

Standard No. 209 sets forth strength, elongation, webbing width, durability, and other requirements for seat belt assemblies. This standard applies to all seat belt assemblies for use in motor vehicles, regardless of whether the belts are installed as o riginal equipment in a motor vehicle or sold as replacements. Hence, any seat belts installed on the aftermarket seat have to be certified as complying with Standard No. 209.

The remaining four standards apply only to new vehicles. If the aftermarket seat were installed before the vehicle's first purchase for purposes other than resale, the vehicle would have to be certified as complying with all applicable standards, includ ing these four, with the aftermarket seat installed. Standard No. 207 establishes strength and other performance requirements for vehicle seats. Standard No. 208 sets forth requirements for occupant protection at the various seating positions in vehicl es. Standard No. 210 establishes strength and location requirements for seat belt anchorages. Finally, Standard No. 302 specifies burn resistance requirements for materials used in motor vehicles, specifically including seat cushions, seat backs, and s eat belts. While aftermarket seats, as items of equipment, are not required to meet these requirements, you may wish to use these standards as design guidelines.

After a vehicle's first purchase for purposes other than resale; i.e., the first retail sale of the vehicle, the only provision in Federal law that affects a vehicle's continuing compliance with an applicable safety standard is set forth in 49 U.S.C. 301 22(b). That section provides that:

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 . . . . in compliance with an applicable motor vehicle safety standard.

Any violation of this "make inoperative" prohibition would subject the violator to a potential civil penalty of up to $ 1,000 for each violation. Please note that the "make inoperative" provision prohibits those entities from performing aftermarket modi fications that they know or should know will degrade the safety of the vehicle as it was before the modification.

Please note also that the "make inoperative" prohibition does not apply to modifications vehicle owners make to their own vehicles. Thus, Federal law would not apply in situations where vehicle owners install your seat in their own vehicles, even if the installation were to result in the vehicle no longer complying with the safety standards. However, individual States have the authority to regulate modifications that individual vehicle owners may make to their own vehicles.

Finally, as a manufacturer, you would be subject to federal requirements concerning the recall and remedy of products with defects related to motor vehicle safety (49 U.S.C. 30118-30121). I have enclosed a sheet for new manufacturers that discusses the basic requirements of our standards and regulations, including the provisions relating to manufacturers' responsibilities to ensure that their products are free of safety-related defects.

This seat would be provided with a lap seat belt and shoulder belt with one end attached to the seat frame and the other to the vehicle structure similar to what's currently used in automobiles. What safety design standards must be incorporated into thi s restraint system?

As explained above, the seat belt would have to comply with Standard No. 209. If you install seat belts manufactured by another company, that company should have certified compliance with that standard.

Would this seat require compliance testing to meet safety requirements?

As noted above, if these seats are installed in a vehicle prior to the vehicle's first sale for purposes other than resale, the vehicle must be certified as complying with all applicable safety standards with the seat installed. NHTSA's position on what steps manufacturers must take before certifying that their vehicles or equipment comply with applicable safety standards has been often stated and applies with equal force in your situation.

Our position is as follows. The compliance test procedures set forth in the safety standards must be followed by this agency during our compliance testing. With respect to your company's seats, this means that NHTSA's compliance testing for the vehicle would be conducted using the test procedures set forth in the relevant safety standard or standards. Manufacturers certifying compliance with the safety standards are not required to follow exactly the compliance test procedures set forth in the applica ble standard. In fact, manufacturers are not required to conduct any actual testing before certifying that their products comply with applicable safety standards. However, to avoid liability for civil penalties if the vehicle were determined not to com ply with a safety standard, the certifying manufacturer is required to exercise "reasonable care" to assure compliance and in making its certification. It may be simplest for the manufacturer to establish that it exercised "reasonable care" if the manuf acturer has conducted testing that strictly followed the compliance test procedures set forth in the standard. However, "reasonable care" might also be shown by using modified test procedures, engineering analyses, computer simulations, and the like. T hus, the entity that installs your seat in a vehicle prior to the vehicle's first sale will have to decide for itself, in the first instance, what information it needs to make its certification in the exercise of "reasonable care."

As noted above, if the seat were installed after the first purchase of the vehicle in good faith for purposes other than resale, any manufacturer, distributor, dealer, or repair shop that performed the installation would have to ensure that the installat ion did not "make inoperative" compliance with any applicable safety standard. Your company should carefully examine your product and the proposed installation instructions and compare those with the requirements of the safety standards, to determine if installing your product in accordance with your instructions would result in the vehicle no longer complying with the standards.

I hope you find this information helpful. I have enclosed information on how to get copies of those standards and regulations. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: nht95-2.17

TYPE: INTERPRETATION-NHTSA

DATE: April 3, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Randal K. Busick -- President, Vehicle Science Corporation

TITLE: NONE

ATTACHMT: ATTACHED TO 2/2/95 LETTER FROM RANDAL K. BUSICK TO MARY VERSAILLES (OCC 10694)

TEXT: Dear Mr. Busick:

This responds to your letter of February 2, 1995, asking three questions regarding the anchorage location requirements in Standard No. 210, Seat Belt Assembly Anchorages.

Your first question concerns S4.3 of Standard No. 210 which states, "(anchorages) for seat belt assemblies that meet the frontal crash protection requirements of S5.1 of Standard No. 208 . . . . are exempt from the location requirements of this section." You asked whether a manual 3-point belt installed at a seating position with an air bag is considered a seat belt assembly that meets the frontal crash protection requirements of S5.1. Assuming that the vehicle is certified to the requirements of Stand ard No. 208 using the air bag, the answer is yes.

Your second question asks what is meant by the phrases "belt bears upon the seat frame" and "does not bear upon the seat frame" in S4.3.1.1 and S4.3.1.2 of Standard No. 210. You stated that examples would be useful. NHTSA has previously said that the p hrase "bears upon the seat frame" "refers to seat belt assemblies in which the seat belt presses or rests directly on the main structural frame of the seat." n1 If a more specific answer is needed in the context of a specific design, please send us infor mation on the design in question.

n1 August 25, 1981, letter to Mr. Roger E. Maugh, Ford Motor Company. This letter, a copy of which is enclosed, discusses one example of a design which did not bear upon the seat frame.

Your third question asked whether the anchorage in a drawing which accompanied your letter complies with the location requirements in S4.3.1.1(a) of Standard No. 210. Section S4.3.1.1(a) states:

If the seat is a nonadjustable seat, then a line from the seating reference point to the nearest contact point of the belt with the anchorage shall extend forward from the anchorage at an angle with the horizontal of not less than 30 degrees and not more than 75 degrees.

As your letter correctly explains, prior to a recent amendment, this section in referring to "anchorage," referred to the "nearest contact point of the belt with the hardware attaching it to the anchorage." That amendment was a result of an amendment of the definition of "seat belt anchorage" to include hardware in the definition. Thus, the amendment was not intended to change the location of the "nearest contact point." In reviewing your drawing, the part labeled "belt and buckle assy." appears to be the belt for purposes of S4.3.1.1(a). While it is somewhat unclear in your drawing, it appears that the "nearest contact point" is either the part labeled "belt and buckle pivot/fixing" or the oval part around that part and adjacent to the part labeled "belt and buckle assy." In either case, the "line from the seating reference point to the nearest contact point" would be within the permissible range of angles.

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

ID: nht95-2.18

TYPE: INTERPRETATION-NHTSA

DATE: April 3, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: David T. Holland -- President, Europa International, Inc.

TITLE: NONE

ATTACHMT: ATTACHED TO 2/24/95 LETTER FROM DAVID T. HOLLAND TO MARY VERSAILLES

TEXT: Dear Mr. Holland:

This responds to your letter of February 24, 1995, regarding the passive restraint phase-in requirements of Federal Motor Vehicle Safety Standard (FMVSS) No. 208, Occupant Crash Protection. You asked whether an importer which "imports Canadian specificat ion MPV's (multipurpose passenger vehicles), such as the Chrysler Minivan, that meets (sic) the MPV passive restraint requirements of FMVSS 208 . . . . can count these vehicles toward the required percentage."

Section S4.2.5.6.1(a) states, "(a) vehicle that is imported shall be attributed to the importer." Thus, to determine compliance with the passive restraint phase-in requirements, Europa International should (1) count all trucks, buses, and mpv's with a gr oss vehicle weight rating of 8,500 pounds or less and an unloaded vehicle weight of 5,500 pounds or less, (2) count all such vehicles which meet the passive restraint requirements of FMVSS 208, and (3) determine if that class of vehicles is a sufficient percentage of the first class of vehicles to satisfy the phase-in requirements. However, as Mary Versailles of my staff cautioned you on the phone, some manufacturers are installing European (face) air bags but are not certifying that vehicles with such air bags meet the passive restraint requirements of FMVSS 208. Therefore, you should verify that any vehicle with an air bag is in fact certified to FMVSS 208's passive restraint requirements.

I hope this information has been helpful. If you have other questions or need some additional information, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: nht95-2.19

TYPE: INTERPRETATION-NHTSA

DATE: April 5, 1995

FROM: C. Rufus Pennington, III -- Margol & Pennington, P.A.

TO: Mary Versailles -- Office of Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 6/6/95 LETTER FROM JOHN WOMACK TO C. RUFUS PENNINGTON, JR. (A43; STD. 108; PART 571.3)

TEXT: Dear Ms. Versailles:

On August 1, 1994, my 13 year-old nephew, Richard L. ("Bo") Wilson, III, was injured while an occupant in a rear seat of a 1979 Porsche 911 SC. The rear seat was not equipped with any type of seat belt. The vehicle was manufactured in July 1979 and was imported by Volkswagen of America, Inc in August 1979.

The approximate size and dimensions of the two rear seats are shown in the enclosed photographs and excerpts from the owner's manual. The maximum load capacity, as stated in the owner's manual, is 529 pounds (240 kg). A label in the engine compartme nt states that there are "two front" designated seating positions (although this information is not included in the owner's manual). The top or back portion of each of the rear seats folds down, in order to allow increased storage area in the rear.

By way of additional information, the 1980 model had an increased total load capacity of 661 pounds, but still had no seat belts in the rear seats. Then, in 1981, with a load capacity of 661 pounds and with no discernible change in the configuration of the seats, seat belts were added in the rear seats.

Based upon the foregoing information and the enclosed materials, I would appreciate NHTSA's answers to the following questions:

1. Did the manufacturer's designation of "two front" passenger seats eliminate any obligation on the part of the manufacturer to provide seat belts in the rear seats under Federal Motor Vehicle Safety Standard 208 (49 C.F.R. @ 471.208)?

2. Did the 1979 Porsche 911 SC comply with, or did it violate the requirements of Federal Motor Vehicle Safety Standard 208 (49 C.F.R. @ 471.208)?

Thank you very much for your assistance in this matter.

Enclosures - photo and specifications omitted.

ID: nht95-2.2

TYPE: INTERPRETATION-NHTSA

DATE: March 14, 1995

FROM: David A. White -- Manager of Reliability, Grumman Olson

TO: Administrator, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 4/14/95 LETTER FROM PHILIP RECHT TO DAVID A. WHITE (A43; PART 567)

TEXT: Dear Sir:

Grumman Olson requests an alternate location for the certification label required in 49 CFR 567.4 be approved for some of our vehicles. The vehicles involved are our Freight Star line which is a van body mounted on either a cut-a-way chassis or a chassi s cab. The Freight Star is installed on a wide variety of chassis with a wide variety of trim levels in the cab. We use a metal tag that is 3.5" X 6.0" which we need in order to put all the information we need in a readable size type. As chassis manuf acturers have made changes to their doors and interiors by downsizing, adding plastic trim and installation of their labels, Grumman Olson has found it increasingly difficult, if not impossible, to locate the certification tag in required locations. The refore Grumman Olson would request approval to locate the certification tag in a similar location specified for trailers, the left side, forward area of the cargo box. This location will allow a uniform location for the tag regardless of chassis model o r trim level. It is our understanding that some manufacturers of similar vehicles place their certification tags in this location and I assume they have already received approval to do so.

I would appreciate a prompt consideration of this request as it would relieve a significant problem we have in completing vehicles.

(PHOTO OMITTED.)