ID: nht93-2.29

DATE: March 26, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jay Lee -- President, Pacific Agritrade Inc.

TITLE: None

ATTACHMT: Attached to letter dated 1-14-93 from Jay Lee to Jackson Rice (OCC 8262)

TEXT: This responds to your January 14, 1993, letter asking for information on how to have an air bag you wish to import from Korea tested by the National Highway Traffic Safety Administration (NHTSA).

I am pleased to have this opportunity to explain our laws and regulations to you. NHTSA is authorized under the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 ET SEQ.; Safety Act) to issue motor vehicle safety standards that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products or conduct pre-sale testing of any commercial products. Instead, the Safety Act establishes a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. I note that the term "manufacturer" is defined by section 102(5) of the Safety Act to mean "any person engaged in the manufacturing or assembling of motor vehicles or motor vehicle equipment, INCLUDING ANY PERSON IMPORTING MOTOR VEHICLES OR MOTOR VEHICLE EQUIPMENT FOR RESALE." (Emphasis added.)

NHTSA has exercised its authority under the Safety Act to establish Standard No. 208, OCCUPANT CRASH PROTECTION (49 CFR S571.208). Standard No. 208 requires, among other things, that passenger cars provide automatic crash protection. Light trucks will also be required to provide automatic crash protection beginning with the 1995 model year. Vehicles equipped with automatic crash protection protect their occupants by means that require no action by vehicle occupants. Compliance with the automatic crash protection requirements of Standard No. 208 is determined in a dynamic crash test. That is, a vehicle must comply with specified injury criteria, as measured on a test dummy, when tested by this agency in a 30 mph barrier crash test.

At this time, manufacturers are not required to use a specific method of automatic crash protection to meet the requirements of Standard No. 208. Instead, each automobile manufacturer is allowed to select the particular method for the automatic crash protection installed in its vehicles. The two types of automatic crash protection currently offered on new passenger cars are automatic safety belts (which help to assure belt use) and air bags (which supplement safety belts and offer some protection even when safety belts are not used).

Please note that the automatic crash protection requirement applies to the performance of the vehicle as a whole, instead of setting requirements for the air bag as an individual item of equipment. This approach permits vehicle manufacturers to "tune" the performance of the air bag to the crash pulse and other specific attributes of each of their vehicle models. However, this approach also means that the Federal standards do not specify specific performance attributes for air bags such as inflated dimensions, actuation time, and the like.

It is unclear from your letter if the air bags you wish to import will be sold to manufacturers for installation in new vehicles or if the air bags will be sold as replacement air bags or retrofit air bags for vehicles which do not have air bags as original equipment. If the air bags are sold to manufacturers for installation in new vehicles, the vehicle manufacturer is required to certify that the vehicle complies with all applicable safety standards, including Standard No. 208. If the air bag is added to a previously certified new motor vehicle prior to its first sale, the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the installation of the air bag. (See 49 CFR Part 567.7.)

While most of Standard No. 208's requirements are expressed in terms of the performance of the vehicle as a whole and apply only to new vehicles and not to aftermarket equipment, there is one exception to this. Pressure vessels and explosive devices for use in air bag systems must comply with section S9 of Standard No. 208 whether they are part of a new motor vehicle or are aftermarket equipment. Therefore, the manufacturer of these items must certify that they comply with the requirements of S9 of Standard No. 208.

Another Federal requirement that would affect the device if it were installed in a used vehicle, either as a replacement or retrofit air bag, is the "render inoperative" prohibition in section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)) would apply. That section provides that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard.

The "render inoperative" provision would prohibit a commercial business from installing an aftermarket air bag in a manner that would negatively affect the vehicle's compliance with Standard No. 208.

You should also note that a replacement or retrofit air bag would be considered "motor vehicle equipment" within the meaning of the Safety Act. Therefore, if the air bag contained a defect (either in manufacture, design, or performance) that relates to motor vehicle safety, the manufacturer would be required to conduct a recall campaign to notify owners and to remedy the defect free of charge. You should be aware that recently the manufacturer of an aftermarket air bag that did not provide crash protection benefits to vehicle occupants ceased offering its air bags following a NHTSA investigation. In addition, NHTSA provided information to the Federal Trade Commission concerning the claims made by the manufacturer in its advertising. We suggest you carefully review the manufacturer's test data on the devices you are considering importing to assure yourself that the air bag would afford adequate protection to vehicle occupants in crashes and that the claims made in the company's advertising are true.

I have enclosed an information sheet that identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers, and explains how to obtain copies of these materials.

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: nht93-2.3

DATE: March 2, 1993

FROM: Berkley C. Sweet -- Executive Vice President, School Bus Manufacturers Institute (SBMI)

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

TITLE: None

ATTACHMT: Attached to letter dated 6-3-93 from John Womack to Berkley C. Sweet (A41; Part 571.3; VSA 102(14)); Also attached to letter dated 3-20-90 from Stephen P. Wood to Cadwallader Jones (A35; VSA 102(14); Part 571.3).

TEXT: On July 28, 1992, Mr. Paul Rice responded to our letter of May 29, 1992 concerning MVSS 222 regarding under-aged children transported in school buses.

In this correspondence, he referred to primary, pre-primary, and secondary school students. We would like to have your definition for each class of the students mentioned in Mr. Rice's letter.

Your cooperation in assisting us in this matter will be greatly appreciated.

ID: nht93-2.30

DATE: March 26, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Steven C. Friedman -- Director of New Product Development, Saddleman, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 1-19-93 from Steven C. Friedman to Office of the Chief Counsel, NHTSA (OCC 8263)

TEXT: This responds to your January 19, 1993, letter asking for information on any Federal motor vehicle safety standards applicable to retrofit air bags. Your letter states that these devices are intended for vehicles which do not have factory-installed air bags.

I am pleased to have this opportunity to explain our laws and regulations to you. The National Traffic and Motor Vehicle Safety Act (the Safety Act; 15 U.S.C. 1381 ET SEQ.) authorizes this agency to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. NHTSA has exercised this authority to establish Standard No. 208, OCCUPANT CRASH PROTECTION (49 CFR S571.208). Standard No. 208 requires, among other things that passenger cars provide automatic crash protection. Light trucks will also be required to provide automatic crash protection beginning with the 1995 model year. Vehicles equipped with automatic crash protection protect their occupants by means that require no action by vehicle occupants. Compliance with the automatic crash protection requirements of Standard No. 208 is determined in a dynamic crash test. That is, a vehicle must comply with specified injury criteria, as measured on a test dummy, when tested by this agency in a 30 mph barrier crash test.

At this time, manufacturers are not required to use a specific method of automatic crash protection to meet the requirements of Standard No. 208. Instead, each automobile manufacturer is allowed to select the particular method for the automatic crash protection installed in its vehicles. The two types of automatic crash protection currently offered on new passenger cars are automatic safety belts (which help to assure belt use) and air bags (which supplement safety belts and offer some protection even when safety belts are not used).

Please note that the automatic crash protection requirement applies to the performance of the vehicle as a whole, instead of setting requirements for the air bag as an individual item of equipment. This approach permits vehicle manufacturers to "tune" the performance of the air bag to the crash pulse and other specific attributes of each of their vehicle models. However, this approach also means that the Federal standards do not specify specific performance attributes for air bags such as inflated dimensions, actuation time, and the like.

While most of Standard No. 208's requirements are expressed in terms of the performance of the vehicle as a whole and apply only to new vehicles and not to aftermarket equipment, there is one exception to this. Pressure vessels and explosive devices for use in air bag systems must comply with section S9 of Standard No. 208 whether they are part of a new motor vehicle or are aftermarket equipment. Therefore, the manufacturer of these items must certify that they comply with the requirements of S9 of Standard No. 208.

Another Federal requirement that would affect a retrofit air bag is the "render inoperative" prohibition in section 108(a)(2)(A) of the Safety Act (15 U.S.C. 1397(a)(2)(A)). That section provides that:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle ... in compliance with an applicable Federal motor vehicle safety standard.

The "render inoperative" provision would prohibit a commercial business from installing an aftermarket air bag in a manner that would negatively affect the vehicle's compliance with Standard No. 208 or any other safety standard.

You should also note that a replacement or retrofit air bag would be considered "motor vehicle equipment" within the meaning of the Safety Act. Therefore, if the air bag contained a defect (either in manufacture, design, or performance) that relates to motor vehicle safety, the manufacturer would be required to conduct a recall campaign to notify owners and to remedy the defect free of charge. Please note that recently a manufacturer of an aftermarket air bag that did not provide any crash protection benefits to vehicle occupants recalled its air bags following a NHTSA investigation. In addition, NHTSA provided information to the Federal Trade Commission concerning the claims made by the manufacturer in its advertising. We suggest you carefully review the test data on the devices you are considering importing to assure yourself that the air bag would afford adequate protection to vehicle occupants in crashes and that the claims made in the company's advertising are true.

I also note that, based on the product information you provided with your letter, NHTSA technical staff raised possible concerns about the air bag you are considering importing. The design differs from other air bags in two significant ways. First, while the crash sensor for air bag systems is normally located in the vehicle structure, yours is not. Second, while air bags generally are released toward the driver's chest from the steering wheel, your air bag would be released from above toward the driver's face and chest. For driver crash protection, the crash sensor of an air bag system must initiate deployment of the air bag early enough in a crash to position the inflated air bag between the driver and the steering wheel in time to cushion the impact. At the same time, it must not be so sensitive that it deploys the air bag in non-crash situations. Given the ways in which the crash sensor of your system differs from other air bag systems, our technical staff questions whether it is possible for it to initiate deployment early enough in a crash to provide occupant protection yet not be so sensitive that it deploys the air bag in non-crash situations. In addition, while the inadvertent deployment of any air bag system would raise safety concerns, the location of your air bag would increase those concerns, since it would appear to interfere with the driver's forward vision even after deflation.

I have enclosed an information sheet that identifies relevant Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers, and explains how to get copies of these materials.

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: nht93-2.31

DATE: March 27, 1993

FROM: Carl W. Ruegg -- President, Carlo International, Inc.

TO: Niel Eisner -- Assistant General Council, U.S. Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5-18-93 from John Womack to Carl W. Ruegg (A41; Part 568; Part 592; VSA 102(3))

TEXT: We intend to ship car parts from the Philippines to the U.S. We need to know the legal definition of a vehicle that comes within the scope of D.O.T. regulations. We assume a part such as fender or other body parts do not.

For instance we may wish to ship some parts partially assembled such as chassis and body assembly or perhaps chassis and body plus front & rear axle transmissions. These parts and partial assembly's would be sold as kits for conversion to electric vehicle.

ID: nht93-2.32

DATE: March 27, 1993

FROM: Carl W. Ruegg -- President, Carlo International, Inc.

TO: Niel Eisner -- Assistant General Council, U.S. Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5-18-93 from John Womack to Carl W. Ruegg (A41; Part 568; Part 591; VSA 102(3))

TEXT: We intend to ship car parts from the Philippines to the U.S. We need to know the legal definition of a vehicle that comes within the scope of D.O.T. regulations. We assume a part such as fender or other body parts do not.

For instance we may wish to ship some parts partially assembled such as chassis and body assembly or perhaps chassis and body plus front & rear axle transmissions. These parts and partial assembly's would be sold as kits for conversion to electric vehicle.

ID: nht93-2.33

DATE: March 29, 1993

FROM: Carl W. Ruegg -- President, Carlo International Inc.

TO: Taylor Vinson -- Chief Council, U.S. Department of Transporation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-13-93 from John Womack to Carl W. Ruegg (A41; Part 591)

TEXT: Kindly send us information and regulations regarding the importation of non-conforming vehicles for research, investigation studies, demonstrations.

ID: nht93-2.34

DATE: March 30, 1993

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Marty D. Pope -- President, Wheels "R" Rollin, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 2-18-93 from Marty D. Pope to Walter Myers (OCC 8326)

TEXT: This responds to your February 18, 1993 letter to Walter Myers of this office. You stated in your letter and in telephone conversations with Mr. Myers that your firm obtains used wheels from salvage yards, mostly passenger car wheels, refurbishes them by sandblasting and refinishing them, then sells them to manufacturers of utility trailers. You asked how to "bring the wheels manufactured before 1977 up to standards" (referring to Federal Motor Vehicle Safety Standard No. 120, TIRE SELECTION AND RIMS FOR MOTOR VEHICLES OTHER THAN PASSENGER CARS), and whether it is possible to "stamp the wheels previous to 1977 with a regulation code to approve their usability." "Wheels" refers to the wheel rim and the hub to which the rim is attached.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized by the National Traffic and Motor Vehicle Safety Act (15 U.S.C. S1381 ET SEQ.) (Safety Act) to issue Federal motor vehicle safety standards (FMVSS's) for new motor vehicles (including trailers) and new items of motor vehicle equipment (including tires and wheels). The purpose of Standard 120 is to provide safe operational performance by ensuring that vehicles to which it applies are equipped with tires of adequate size and load rating and with rims of appropriate size and type designation. The standard applies to new trailers, and to rims manufactured on or after August 1, 1977. Violations of any of the standards are punishable by civil fines of up to $1,000 per violation, with a maximum fine of up to $800,000 for a related series of violations.

You ask about our requirements for the rims of the wheels you refurbish. The answer depends on whether the rim is intended to be installed on a new trailer or intended as a replacement rim for a used trailer.

If the rim is intended for a new trailer, the new trailer manufacturer must certify that the vehicle complies with Standard 120. Standard 120 establishes two requirements for the vehicle. First, S5.1.1 requires that the rims on a new trailer be listed by the manufacturer of the tires mounted on the trailer as suitable for use with those tires. Second, the rims on a new trailer must meet the rim marking requirements of S5.2 of Standard 120. Since the rims you refurbish were originally passenger car rims, they will not have the required markings, regardless of date of manufacture because Standard 120 does not apply to passenger car rims. Therefore, trailer manufacturers may not install passenger car rims on new trailers unless those rims are marked in accordance with Standard 120.

If the rim is intended as a replacement rim on a used trailer, different requirements apply. The rim marking requirements of S5.2 of Standard 120 apply only to NEW rims manufactured on or after August 1, 1977. Refurbished wheels sold for used trailers are considered used wheels instead of new wheels for purposes of Standard 120, and are thus not subject to the rim marking

requirements of the standard. As pointed out above, however, a new or refurbished rim installed on a new trailer must meet the rim selection and marking requirements of Standard 120 (S5.1.1 and S5.2).

Relatedly, you ask about marking a used rim with the information required by Standard 120 for new rims. Any rim, new or used, that is installed on a new vehicle must be marked with the "regulation code" (i.e., the "DOT" symbol constituting the manufacturer's certification of compliance with Standard 120) and the other information required by the standard. However, a rim manufactured prior to August 1, 1977, that is sold as a replacement rim must not be marked with the DOT symbol. NHTSA has long held that manufacturers may not show the DOT certification on items of motor vehicle equipment to which no Federal motor vehicle safety standard applies. The reason for that decision is that such a certification would be false and misleading to NHTSA and to consumers who might assume that the item was subject to and met a Federal safety standard. Thus, since Standard 120 does not apply to rims manufactured prior to August 1, 1977, such rims cannot now be marked with the DOT symbol.

You should also be aware of two other provisions of the Safety Act. The first provision is S108(a)(2)(A), which provides that no manufacturer, distributor, dealer, or motor vehicle repair business may knowingly render inoperative, in whole or in part, any device or element of design installed on or in a new or used motor vehicle or item of motor vehicle equipment in compliance with an applicable FMVSS. This means that a person in these categories cannot remove the label information required by Standard 120 during the refurbishing process.

Second, under S151-157 of the Safety Act, manufacturers of motor vehicles and items of motor vehicle equipment (e.g., wheel rims) are responsible for safety-related defects in their products. If a manufacturer or NHTSA determines that a safety-related defect exists, the manufacturer must notify purchasers of the product and remedy the problem free of charge. (This responsibility is borne by the vehicle manufacturer in cases in which a defective wheel rim is installed on a new vehicle by or with the express authorization of that vehicle manufacturer.) A refurbished rim that had been previously damaged (e.g., cracked, bent, or pitted) might not be capable of performing safely while in service.

For your further information, I am enclosing a pamphlet issued by this agency entitled FEDERAL MOTOR VEHICLE SAFETY STANDARDS AND REGULATIONS and a fact sheet entitled WHERE TO OBTAIN NHTSA'S SAFETY STANDARDS AND REGULATIONS. The pamphlet briefly summarizes each of our Federal motor vehicle safety standards and the fact sheet advises where to obtain the full text of those standards and our other regulations. You may also find helpful the attached fact sheet entitled INFORMATION FOR NEW MANUFACTURERS OF MOTOR VEHICLES AND MOTOR VEHICLE EQUIPMENT.

We also note that the Occupational Safety and Health Administration (OSHA) has a regulation on the refurbishing of damaged rim components. You can contact OSHA at (PHONE NUMBER) for information about that regulation.

I hope this information is will be of assistance to you. Should you have any further questions, please feel free to contact Mr. Myers at this address or at (202) 366-2992.

ID: nht93-2.35

DATE: March 30, 1993

FROM: Dann T. Deaver -- President, Origins International Corporation

TO: Taylor Vinson -- Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-23-93 from John Womack to Dann T. Deaver (A41; VSA 102(3)); Also attached to letter dated 12-3-91 from Paul Jackson Rice to Matthew J. Plache; Also attached to letter dated 10-31-88 from Erika Z. Jones (Signature by Stephen P. Wood) to Hiroshi Kato; Also attached to letter dated 4-16-85 from Jeffrey R. Miller to Alexander E. Nagy

TEXT: At your request during our telephone conversation today, the following is a description of the physical characteristics and intended use of an electric vehicle which my company has been commissioned to develop.

GENERAL DATA

LENGTH - 107" HEIGHT - 61" BODY WIDTH - 58" WIDTH WITH MIRRORS - 71"

WEIGHT - 1050 LBS.

POWER - 48V SERIES DC, ELECTRIC SPEED RANGE: 1 25 MPH MAX.

MARKET USE

This vehicle will be marketed as a closed community vehicle for retirement communities, closed club grounds, on site/off road/construction vehicles, theme parks, resorts, etc. The vehicle is not to be marketed as useable on public thoroughfares and/or highways. The tires are of a high profile design capable of being used on golf courses, and golf bag wells and golf accessories are designed into the vehicle.

Where many golf cars today are used in the above applications, our vehicle provides better handling, greater load carrying capability, higher speed, longer range, better weather protection, and a very unique appearance and package.

As we discussed today, it is important that we are made aware of any federal safety regulations which may apply to vehicles of the above description and use. Concurrently we are exploring similar state vehicle safety/equipment requirements.

We would appreciate a letter, addressed to me at the address below, stating your Department's position on this matter.

I appreciate your attention and consideration.

ID: nht93-2.36

DATE: March 30, 1993

FROM: Arvind V. Rajan -- Vice President, Marketing and Planning, Solectria Corporation

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-26-93 from John Womack to Arvind V. Rajan (A41; Part 591)

TEXT: The Solectria Corporation is a manufacturer of electric vehicles and advanced EV components, based in Massachusetts. We currently produce the Solectria Force, which is a Geo Metro that has been converted to electric drive. In order to serve the needs of vehicle customers in Southeast Asia and the Caribbean, we need to use a vehicle chassis with right-hand steering. Since the Geo Metro is only available in left-hand steering we will need to import an equivalent vehicle, the Suzuki Swift, from Japan. After we receive the vehicle, we will convert it to electric, and immediately export it.

The Suzuki Swift with right-hand drive may not be certified for use in the United States by NHTSA. However, as the vehicles will never be used on public roads in the United States and will not be sold to U.S. customers, we believe that we will be allowed to import them into the U.S. Mr. Frank Turpin of NHTSA has confirmed this view. However, the U.S. Customs Office has informed us that it will need written confirmation from the Department of Transportation before releasing such vehicles to us.

We would appreciate written confirmation from the D.O.T. that we are indeed permitted to import such vehicles for the purposes mentioned above. If you have any questions, please call me at (508) 658-2231 or fax me at (508) 658-3224. Thank you for your time and attention, and we look forward to hearing from you.

ID: nht93-2.37

DATE: March 30, 1993

FROM: David L. Boren -- United States Senator, United States Senate

TO: Howard Smolkin -- Acting Administrator, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-15-93 from Howard M. Smolkin to David L. Boren (A41; Redbook (2); Std. 121)

TEXT: Enclosed are copies of correspondence I have recently received from ABAS Marketing, Inc., of Norman, Oklahoma, concerning an invention they have for a noncomputerized antilock braking system.

This company has been trying to get the NHTSA to investigate their product through some research that is currently being conducted by your agency. In an effort to be helpful to my constituents, I would appreciate your review of this correspondence and a response that I can share with them.

Thank you for allowing me this opportunity to write in behalf of this Oklahoma Company. I will look forward to hearing from you at your earliest convenience. Please send your response to my Oklahoma City office to the attention of Jim Hopper. Best wishes.

February 11, 1993

Senator David Boren U.S. Senate Washington, D.C. 20510

Dear Senator Boren:

Due to the adamant position of President Clinton, regarding the encouragement of small business enterprise as a means to stimulate our economy, we are heartened to rebel against apparent discrimination we have encountered in the Department of Transportation. I am enclosing a letter sent to Jim Britell of the Research and Development section of the National Highway Traffic Safety Administration explaining the problem. In order for you to better understand the scope and implication thereof, I am providing some background information below.

We have invented and applied for patent on a noncomputerized antilock braking system applicable to trucks and trailers equipped with air, brakes, air over hydraulic brakes, vacuum hydraulic brakes and electric brakes. We have the only products in the world, so far as we know, in the last three categories. In the air brake ABS competition, currently being waged in the U.S., we are pitted against Bendix Corporation, Midland-Grau, Wabco/Rockwell and Bosch, all of whom have a computerized system. Most of the technology they rely upon is

adapted from European products and imported from Germany by Grau, Wabco and Bosch.

We have products that were created in Oklahoma by Oklahomans. They are manufactured in Oklahoma and we are respectfully asking that the leaders of our State assist us in overcoming the barriers. This can easily become a major industry for Oklahoma if we are not stomped on by the giants or forced to sell out to out of state interests.

Will you please give us the benefit of your expertise in the political arena? We have a great contribution to enhance affordable highway safety, but our government regulators are ignoring it.

Very truly yours, STRAIT-STOP MANUFACTURING CO., INC.

Thomas D. Price President

TDP/dlg Encl.

P.S. I sincerely appreciate the help you have given us in the past. There is no question but that you do stimulate the regulators to action.

Attachment: Letter dated 2-10-93 from Thomas D. Price, President, Strait-Stop Manufacturing Co., Inc., to Jim Britell, Research and Development, NHTSA.

(Text omitted.)