ID: nht92-5.46

DATE: June 24, 1992

FROM: Kenneth Lenz -- HME Incorporated

TO: Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated July 1, 1992 (est.) from Paul J. Rice to Kenneth Lenz (A39; Std. 206)

TEXT:

I have been reviewing Federal Motor Vehicle Safety Standards (FMVSS) for applicability to fire trucks, specifically certain provisions of FMVSS 206.

There have been requests from fire departments to eliminate the interior and exterior door locks required by FMVSS 206, S4.1.3. The fire company's reasons for eliminating all door locks is that "the vehicle is used in emergency situations and a door that has been locked accidently may hinder the ability of the apparatus to respond".

I would appreciate and interpretation of FMVSS 206 on whether or not fire trucks are required to comply with this regulation or if an exemption from compliance with S4.1.3 can be obtained for fire trucks.

Thank you.

ID: 008062.rbm

Mr. Dietmar K. Haenchen
Volkswagen
Safety Affairs and Vehicle Testing
Mail Code 3C02
3800 Hamlin Road
Auburn Hills, MI 48326

Dear Mr. Haenchen:

This responds to your letter requesting clarification of Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door locks and door retention components. Specifically, you have asked whether the back door requirements apply to latch systems on a hinged window that is integrated into the back door. For the system described in your letter, the answer is no. This system is not subject to FMVSS No. 206s back door requirements because the standard is designed to address latch systems on doors rather than windows.

As you are aware, the National Highway Traffic Safety Administration (NHTSA) administers a statute requiring that motor vehicles manufactured for sale in the United States or imported into the United States be manufactured so as to reduce the likelihood of motor vehicle crashes and of deaths and injuries when crashes do occur. We refer to that statute as the Vehicle Safety Act. It is codified at 49 U.S.C. 30101, et seq.

One of the agencys functions under the Vehicle Safety Act is to issue and enforce FMVSSs. These standards specify safety performance requirements for motor vehicles and/or items of motor vehicle equipment. Manufacturers of motor vehicles must certify compliance with all applicable safety standards and permanently apply a label to each vehicle stating that the vehicle complies with all applicable FMVSSs.

FMVSS No. 206 specifies certain performance requirements for door retention components, including those on back doors. The definition of a back door, contained in S3 of the standard, states:

Back door means a door or door system on the back end of a motor vehicle through which passengers can enter or depart the vehicle, or cargo can be loaded or unloaded; but does not include:


(a) a trunk lid; or
(b) a door or window that is composed entirely of glazing material and whose latches and/or hinges are attached directly to the glazing material.

Your question relates specifically to a system consisting of a back door that would fully comply with the requirements of FMVSS No. 206, but which has a window integrated into the door that rotates away from the vehicle when opened. The window would be supported by a thin metal or plastic frame and have hinges or latches that are attached to either the thin frame or directly to the piece of glazing.

You are concerned that because the window would incorporate a latch/hinge design, it would be considered a back door under the standard, and the latch would be regulated by FMVSS No. 206 unless exempt under subpart (b) of the back door definition. As explained more fully below, based on the information you have provided, it appears that the window would not be considered a back door.

In excluding doors and windows "composed entirely of glazing material" NHTSA was referring to large pieces of glazing that act as a back door, not window glazing that is mounted in and framed by a metal door (see letter of interpretation to General Motors Corporation, dated May 6, 1996). NHTSA decided to exempt windows composed entirely of glazing because many back doors incorporate a design whereby the back door system consists of a lower, metal tailgate and an upper piece of glazing that is not surrounded by a metal frame sufficiently strong to retain a door latch or hinge component in a crash. The piece of glazing is joined directly to the vehicle structure via a set of hinges and the latch is married to a striker positioned in the tailgate or the frame of the vehicle. As originally proposed, such a design would have required each piece of attachment hardware to meet the newly proposed back door requirements (59 FR 44691, August 30, 1994). In response to industry comments, NHTSA acknowledged that it was unreasonable to expect retention hardware to meet the requirements of the standard when the glazing surrounding such hardware could not reasonably be expected to restrain an occupant in a crash. Thus, the exemption for doors or windows consisting entirely of glazing was crafted.

As discussed in the May 1996 letter of interpretation to General Motors referenced above, the relevant criterion in determining whether the latches or hinges are directly attached to glazing is if the glazing constitutes the principal structural component of the door or window. Based on the information provided in your letter, we believe the design you have presented is entirely glazing material with a small frame added solely for structural support fro the glazing. Because the thin metal or plastic frame described in your letter would not be the principal structural component of the door or window, the latches and/or hinges would be considered directly attached to the glazing structure. Thus, the latch of this design is not subject to the standard.

Because the window system discussed in your letter would not qualify as a type of glazing considered by NHTSA to constitute a door, there is no need to further evaluate whether the window could be used to load or unload cargo, or whether the attachment hardware is attached directly to the piece of glazing. However, I caution you that the standard does not speak to doors that are typically used to load cargo, as indicated in your letter, but rather to doors through which cargo "can be loaded or unloaded".

Should you require any additional information or assistance, please contact Rebecca MacPherson, of my staff, (202) 366-2992 or at the address given above.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:206
d.2/12/04

ID: Costa.1

Mr. Larry J. Costa
Costa Technologies
54201 Ash Road
Osceola, IN 46561

Dear Mr. Costa:

This responds to your letters of May 6, 2003, and May 7, 2003, in which you request interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials (49 CFR 571.205). Specifically, you asked whether the weight of a conductor is included along with attached glass fragments under Test No. 7 ("fracture test") when determining compliance with the requirement that no individual glass fragment may weigh more than 4.25 g (0.15 oz.), and if so, whether attachment of such conductors would result in a violation of 49 U.S.C. 30122. In a subsequent phone conversation with Eric Stas of this office, you stated that a subsequent soldering process or application of conductive adhesive may result in changes in the structure of the glass, such that when the glass breaks, certain glass fragments (either attached to a conductor or free-standing) may exceed 4.25 g.

FMVSS No. 205 specifies performance requirements for various types of glazing (called "items"). FMVSS No. 205 incorporates by reference American National Standard Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways Standard ANSI Z26.1-1977, as supplemented by Z26.1a-1980 (hereinafter collectively referred to as "ANSI Z26-1980").

ANSI Z26.1-1980, Section 5.7, "Fracture, Test No. 7," limits the size of individual glass fragments that form as a result of impact to a glazing surface and requires that no individual fragment weigh more than 4.25 g (0.15 oz.). That test is conducted using twelve 12 x 12-inch (305 x 305 mm) flat specimens, without any attached conductors or other enhancements.

At present, FMVSS No. 205 does not specify requirements applicable to glazing to which conductors have been attached. However, as noted in our previous letter to you on this subject, NHTSA has been in the process of updating FMVSS No. 205 to incorporate a more recent version of ANSI-Z26, under which the glazing would need to be tested with conductors attached, if that condition represents the most difficult part or pattern designation within a given model number. On July 25, 2003, we published a final rule adopting the updated ANSI standard (68 FR 43964). Accordingly, this requirement will apply to all glazing certified on or after September 23, 2003, the effective date of the rule.

I hope this information is helpful. 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:205
d.7/25/03

ID: Costa_1

Mr. Larry J. Costa
Costa Technologies
54201 Ash Road
Osceola, IN 46561

Dear Mr. Costa:

This responds to your letters of May 6, 2003, and May 7, 2003, in which you request interpretation of Federal Motor Vehicle Safety Standard (FMVSS) No. 205, Glazing Materials (49 CFR 571.205). Specifically, you asked whether the weight of a conductor is included along with attached glass fragments under Test No. 7 ("fracture test") when determining compliance with the requirement that no individual glass fragment may weigh more than 4.25 g (0.15 oz.), and if so, whether attachment of such conductors would result in a violation of 49 U.S.C. 30122. In a subsequent phone conversation with Eric Stas of this office, you stated that a subsequent soldering process or application of conductive adhesive may result in changes in the structure of the glass, such that when the glass breaks, certain glass fragments (either attached to a conductor or free-standing) may exceed 4.25 g.

FMVSS No. 205 specifies performance requirements for various types of glazing (called "items"). FMVSS No. 205 incorporates by reference American National Standard Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways Standard ANSI Z26.1-1977, as supplemented by Z26.1a-1980 (hereinafter collectively referred to as "ANSI Z26-1980").

ANSI Z26.1-1980, Section 5.7, "Fracture, Test No. 7," limits the size of individual glass fragments that form as a result of impact to a glazing surface and requires that no individual fragment weigh more than 4.25 g (0.15 oz.). That test is conducted using twelve 12 x 12-inch (305 x 305 mm) flat specimens, without any attached conductors or other enhancements.

At present, FMVSS No. 205 does not specify requirements applicable to glazing to which conductors have been attached. However, as noted in our previous letter to you on this subject, NHTSA has been in the process of updating FMVSS No. 205 to incorporate a more recent version of ANSI-Z26, under which the glazing would need to be tested with conductors attached, if that condition represents the most difficult part or pattern designation within a given model number. On July 25, 2003, we published a final rule adopting the updated ANSI standard (68 FR 43964). Accordingly, this requirement will apply to all glazing certified on or after September 23, 2003, the effective date of the rule.

I hope this information is helpful. 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:205
d.7/25/03

ID: nht93-4.38

DATE: June 18, 1993

FROM: John Womack -- Acting Chief Counsel, U.S. Department of Transportation, NHTSA; Signature by Ken Weinstein

TO: Bob Jones -- Director of Engineering, Independent Mobility Systems, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 4-29-93 from Bob Jones to Mary Versailles.

TEXT: This responds to your letter of April 29 1993, addressed to Mary Versailles of this office, requesting information on the proper testing of your raised-roof minivan for compliance with Federal Motor Vehicle Safety Standard (FMVSS) 220, SCHOOL BUS ROLLOVER PROTECTION.

You correctly stated in your letter that the school bus rollover protection requirements of FMVSS 220 do not apply to minivans. You explained, however, that many states and/or localities require compliance with FMVSS 220 for vehicles equipped to transport the handicapped, and you asked how properly to test your raised-roof minivan for compliance with FMVSS 220.

Since the requirements you referred to are state or local requirements, this agency cannot comment on them. You should contact the states or localities concerned to find out what their expectations are in that regard.

I hope this information will be of assistance to you.

ID: 11846.ZTV

Mr. John Misumi
Operations Officer
Vision Industries
2338 Walgrove Avenue
Mar Vista, CA 90066

Dear Mr. Misumi:

This replies to your letter of April 22, 1996, to Enid Rubenstein of this Office asking for information on the applicability of the Federal motor vehicle safety standards to a limited-production vehicle you intend to manufacture in the near future. You have the following specific questions:

1. "Which FMVSS tests are applicable to us as an automobile manufacturer?"

Every manufacturer must meet all Federal motor vehicle safety standards, regardless of the size of its production, unless otherwise exempted by this agency pursuant to the procedures of 49 CFR Part 555. I enclose a copy of this regulation for your information.

2. "What are the estimated fees and costs of applicable FMVSS tests?"

I am sorry, but we have no information of the fees and costs that the various test laboratories charge private concerns.

3. "What is the time frame pertaining to the administration and completion of applicable FMVSS tests, relative to the vehicle production and sales cycle, (i.e., are tests to be administered and completed before any production vehicles "roll off" the production line, or can certification be completed after vehicles roll off the production line?)?"

Title 49 United States Code Chapter 301 - Motor Vehicle Safety does not require a manufacturer to conduct "tests", but it does require the manufacturer to produce motor vehicles that comply, and are certified as complying, with all applicable Federal motor vehicle safety standards. We advise manufacturers that, although the soundest way to assure compliance and the veracity of its associated certification is to test according to the procedures set forth in the standards, it may certify on the basis of computer simulations, engineering studies, mathematical calculations and

other reasonable substitutes for physical testing. Furthermore, it should retain the data in its files upon which its certification was based, in the event NHTSA ever asks the manufacturer to substantiate its certification.

Under 49 U.S.C. 30115 Certification of compliance, a manufacturer is required to "certify [compliance] to the distributor or dealer at delivery", and it "may not issue the certificate if, in exercising reasonable care, the [manufacturer] has reason to know the certificate is false or misleading in a material respect." Thus, a manufacturer should assure itself before applying the certification label that its vehicle fully conforms. This suggests that all test or other substantiating data be at hand at the time the first vehicle is certified. However, if a test laboratory has informed the manufacturer on an informal basis that it has tested a vehicle and found it to meet the performance requirements of a standard, the manufacturer could reasonably certify compliance before receiving the official test report.

The question you have asked is really best answered by the individual manufacturer based upon its best judgment and the legal considerations discussed above.

4. "What agencies or business entities administer FMVSS tests in the Los Angeles area?"

I enclose a list of test laboratories in the United States that NHTSA used in fiscal year 1995 to conduct its compliance testing. There may be additional testing labs that perform these services, and you may wish to consult other sources.

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

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosures ref:567#VSA d:5/24/96

ID: 1985-01.1

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Masaki Ogura -- Manager, Truck Engineering, MMC Services Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Masaki Ogura Manager, Truck Engineering MMC Services Inc. 3000 Town Center, Suite 501 Southfield, Michigan 48075

This responds to your letter concerning Federal Motor Vehicle Safety Standard No. 101, Controls and Displays. According to your letter, your trucks, which have a GVWR of more than 10,000 pounds, have a coolant temperature sensor for overheat warning and also a coolant level sensor for lack of engine coolant to prevent engine overheating. Both sensors are connected to the same telltale lamp, so that either excessive coolant temperature or lack of coolant will illuminate the telltale. Your letter noted that Standard No. 101 specifies an identifying symbol for coolant temperature but not a symbol for coolant level. You asked whether a system displaying the symbol specified by Standard No. 101 for coolant temperature meets the requirements of the standard. As discussed below, while some of Standard No. 101's requirements are applicable to your trucks, the standard's telltale requirements do not apply to trucks with a GVWR of 10,000 pounds or more.

Section 5, Reguirements, states:

Each passenger car, multipurpose passenger vehicle, truck and bus manufactured with any control listed in S5.1 or in column 1 of Table 1, and each passenger car, multipurpose passenger vehicle and truck or bus less than 10,000 pounds GVWR with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display. (Emphasis added.)

Thus, Standard No. 101's requirements for identification of controls are applicable to trucks with a GVWR of 10,000 pounds or more, but the standard's requirements for identification of internal displays are not applicable to such vehicles. Since telltales for coolant temperature are a type of internal display, that requirement of Standard No. 101 is not applicable to the vehicles (more than 10,000 pounds) described by your letter.

Sincerely, Jeffrey R. Miller Chief Counsel

December 24,1984

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Subject: Telltale Identifying Symbol for Coolant; FMVSS No. 101 Controls and Displays

Dear Sir:

This is to inquire about the identifying symbol for engine coolant.

1. Our interpretation is as follows:

In Standard No. 101 the telltale identifying symbol for coolant temperature is specified, but a symbol for coolant level is not specified.

2. Telltale for coolant

Our trucks (more than 10,000 pounds GVWR) have a coolant temperature sensor for overheat warning, and also a coolant level sensor for lack of engine coolant to prevent engine overheat.

Both sensors are connected to the same telltale lamp, so that either excessive coolant temperature or lack of coolant will illuminate the telltale for coolant temperature described in FMVSS No. 101 (column 4).

3. Question

Does our system described above conforms to FMVSS No. 101?

Very truly yours,

Masaki Ogura Manager Truck Engineering

MMC SERVICES INC.

ID: nht87-1.64

TYPE: INTERPRETATION-NHTSA

DATE: 04/13/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: George Ziolo

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. George Ziolo 16182 Arena Drive Ramona, CA 92005

Dear Mr. Ziolo:

This letter responds to your inquiry concerning Federal Motor Vehicle Safety Standard No. 111. I apologize for the delay. As I understand your question, you are concerned with a passenger car whose inside rearview mirror apparently does not meet the fiel d-of-view specifications in S5.1 of FMVSS 111 and therefore that must have an outside passenger side mirror in order to comply with the standard. You wish to know whether the need to inscribe the convex mirror in accordance with S5.4.2 is eliminated when the passenger side of the car has both a complying mirror of unit magnification and a convex mirror.

Please understand that the National Highway Traffic Safety Administration (NHTSA) does not approve motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the manufacturer's responsibility to ensure that its vehicle or equipment complies with applicable standards. Therefore, this letter is an opinion based on the facts you provide in your letter.

The answer to your question is "yes." The passenger side of a new car would need an outside convex mirror inscribed in accordance with S5.4.2 only if its inside rearview mirror failed to meet the S5.1.1 field of view specifications, and the manufacturer chose to comply with the requirement of S5.3 for an outside passenger side mirror by installing a convex passenger-side mirror rather than a unit magnification passenger-side mirror. S5.4 provides that the requirements in S5.4.1 - S5.4.3 are applicable t o a convex mirror only if that mirror is used to comply with S5.3. In your example, a mirror of unit magnification is used to comply with S5.3. I should add that the manufacturer would have to ensure that installing the convex mirror does not take the mi rror of unit magnification out of compliance with FMVSS 111.

Please let me know if you have any further questions.

Sincerely, Erika Z. Jones Chief Counsel

GEORGE ZIOLO 16182 ARENA DRIVE RAMONA, CA 92065 619-789-9792

Office of the Chief Counsel US DOT/NHTSA 400 7th St SW Washington, DC 20590

Subj: FMVSS 111

A convex mirror installed in accordance with (IAW) S5.3 must meet S5.4.2 (inscription)

Mirrors installed IAW S6 must meet S6.1(a) or (b); the latter makes no mention of a convex mirror.

I have observed that vehicles falling into the category specified in S6 are sold with mirrors meeting S6.1.(b). However, in addition to mirrors of unit maginification, convex mirrors are also installed but they do not bear the inscription mentioned in S5 .4.2 (bear no inscription).

It therefore appears to me that when a mirror of unit magnification is supplemented by a convex mirror, the latter need not meet the inscription requirement of S5.4.2.

The question therefore arises whether the above would as well apply to vehicles falling into the category of S5 - passenger cars. That is to say, is the need for the inscription (S5.4.2) eliminated when there is installed a mirror of unit magnification in addition to a convex mirror.

Please advise me of your opinion in this matter.

Sincerely,

GEORGE ZIOLO DOT Paperwork Processor

ID: 86-1.4

TYPE: INTERPRETATION-NHTSA

DATE: 01/03/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. R. C. Attwood

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. R. C. Attwood ASE (UK) Ltd. Norfolk Street Carlisle, Cumbria ENGLAND CA2 5HX

Dear Mr. Attwood:

Thank you for your letter of October 8, 1985, concerning the safety belt: anchorage requirements of Standard No. 210, Seat Belt Assembly Anchorages. You asked a question about the anchorage requirements that would apply to a two point automatic safety belt, which has a separate manual lap belt. You asked if it is permissible for the two anchorages of the automatic belt and the two anchorages of the manual lap belt to be located outside of the zones specified in Standard No. 210, if three additional anchorages are located within Standard No. 210's zones. As explained below, the design you described would be permissible, assuming that you are voluntarily providing the manual lap belt.

Section S4.1.1 of the standard requires anchorages for a Type 2 safety belt to be provided at each front outboard seating position. Sections S4.3.1 and S4.3.2 set out the location requirements for Type 2 belts. However, S4.3 provides that the anchorages for automatic restraints which meet the frontal crash protection requirements of Standard No. 208, Occupant Crash Protection, do not have to meet the location requirements of the standard.

In interpreting the location requirement, the agency has said that all of the anchorages for an automatic belt may be located outside of the zones specified in Standard No. 210, as long as there are the three anchorages for a Type 2 safety belt located within the zone. Since your design for the automatic belt would provide three anchorages within the required zone, it would be permissible as long as the anchorages meet the strength requirements of the standard.

If you are voluntarily providing the manual lap belt, then its anchorages would not have to comply with Standard No. 210 as long as the use of the lap belt would not degrade the ability of the automatic lap belt to comply with Standard No. 208. However, if you are providing the lap belt to comply with the requirements of S4.1.2.1(c) of Standard No. 208, then the lap belt would have to have anchorages complying with Standard No. 210.

I hope this information is of assistance. If you need further information please let me know.

Sincerely, Erika Z. Jones Chief Counsel

Our Ref: RCA/EC 8th October, 1985

The Chief Counsel U.S. Dept. of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington D.C. 20590 U.S.A.

Dear Sir,

FMVSS 208 a Seat Belt Anchorages

We seek your assistance in resolving a query about the location and number of anchorages in a passenger vehicle fitted with a two point automatic seat belt (passive restraint), and an active lap belt.

We wish to know if it is permissible for both anchorages of the two point automatic belt and both anchorages of the active lap belt to be situated outside the zones stipulated in FMVSS 210 on condition that three additional anchorages are provided in the zones specified in FMVSS 210.

Your early response to our questions will be very much appreciated.

Yours faithfully, R. C. Attwood Quality Assurance Director

ID: 86-2.16

TYPE: INTERPRETATION-NHTSA

DATE: 04/09/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Carl R. Walker

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Carl R. Walker Manager, Technical Sales and Service P.T. Brake Lining Company, Inc. P.O. Box 329 Lawrence, Ma 01842

Dear Mr. Walker:

This responds to your letter addressed to Mr. Richard Radlinski, concerning a statement by International Transquip alleging that the National Highway Traffic Safety Administration (NHTSA) and the Bureau of Motor Carrier Safety (BMCS) "agree" that the Mini-Max brake system produced by that company complies with Federal standards. You noted that International Transquip has referenced a June 6, 1984 letter from BMCS.

NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment complies with applicable safety standards. I would emphasize that NHTSA has not issued any statement that could be read as "agreement" that the Mini-Max brake complies with FMVSS No. 121.

We are enclosing a copy of a letter addressed to Navistar which discusses NHTSA's position concerning the June 6, 1984 letter from BMCS. The letter also notes that the California Highway Patrol (CHP) has raised a number of issues relating to the compliance and overall safety of Mini-Max brakes in connection with a petition for rulemaking, and that International Transquip has submitted comments on CHP's analysis. We have enclosed for your information a notice granting the CHP petition and two related interpretation letters, to International Transquip and the New Jersey Division of Motor Vehicles. The CHP and Mini-Max submissions have been placed in the Petitions for Rulemaking (PRM) Docket for FMVSS No. 121. If you desire copies of those submissions, please contact: Docket Section, National Highway Traffic Safety Administration, Room 5109, 400 Seventh Street, S.W., Washington, D.C. 20590 (202-426-2768).

Sincerely,

Erika Z. Jones Chief Counsel

Enclosures

January 24, 1985

Mr. Richard Radlinski Manager, Brake Research NHSTA P. O. BOX 37 East Liberty, OH 43319

Subject: Mini-Max Brake

Dear Dick:

As per our discussion, please find a complete folder and cover letter from International Transquip Industries, Inc., manufacturers of the subject brake. Of particular concern to me is their reference to "compliance to the brake standards", by NHSTA and BMCS. "All agree that it complies to the standards."

In their literature, they make reference to a letter from BMCS (on US DOT stationary), dated June 6, 1984, which seemingly meets the parking requirements of NHSTA. All is attached for your information and reference. Even though this response from BMCS is related to a change notice, it is being interpreted as "full compliance" to FMVSS 121.

Your written clarification of this matter would be most helpful.

Very truly yours,

P.T. BRAKE LINING COMPANY, INC.

Carl R. Walker Manager, Technical Sales & Service

CRW/mdp

Enclosure

cc: Steven Doyle Jim Rabith