ID: nht94-5.13

TYPE: INTERPRETATION-NHTSA

DATE: December 19, 1994

FROM: Patricia J. Jackson -- Owner, Patnel Co.; Patt Jackson

TO: Mr. Racht, Chief Council, NHTSA

TITLE: None

ATTACHMT: ATTACHED TO 3/3/95 LETTER FROM PHILIP R. RECHT TO PATRICIA JACKSON (REDBOOK (2); STD, 213; PART 302)

TEXT: I have just received a patent on my cushion. I needed to know if their are any safety standards that I need to pass on my cushion. I am sending a pamphlet to help you under stand my product and how the cushion is used. Should I meet any fire safety st andards since my cushion is used by children of all ages.

If you should have any question regarding this please feel free to call me at (314) 839-5382

ENCLOSURE

December 19, 1994

Deirdre R. Fujita NHTSA Office of the Chief Counsel 400 Seventh Street, S.W. Room 5219 Washington D.C. 20590

RE: Phone call conversation in December 7, 1994

Enclosed is the brochure of my product "BoosterBuddy" a childs car cushion that comforts and protects. The cushion is used under the booster seat that is state regulated. This cushion has rolled pads on each side to provide comfort. The cushion prot ects tha car upholstery from the load bearing friction caused by the state regulated restraint seats. The cushion is used under the restraint seat from 0 to 40 pounds. The cushion can be used by the older child over 40 pounds with a safety belt.

Please send me a letter stating if my product meets all safety regulations required. I am looking forward to hearing from you.

Enclosure (OMITTED)

ID: nht88-2.53

TYPE: INTERPRETATION-NHTSA

DATE: 06/20/88

FROM: LEWIS S. BUCHANAN -- NHTSA DRIVER CONTROL PROGRAMS BRANCH OFFICE OF ALCOHOL & STATE PROGRAMS TRAFFIC SAFETY PROGRAMS

TO: LARRY P. EGLEY

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/09/89 FROM STEPHEN P. WOOD -- NHTSA TO LARRY P. EGLEY; REDBOOK A33 [2]; STANDARD 108; LETTER DATED 01/17/89 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 3028; LETTER DATED 05/23/89 FROM LARRY P. EGLEY TO KAT HLEEN DEMETER -- NHTSA; LETTER DATED 09/10/88 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 2530; REPORT DATED 09/10/88 FROM LARRY P. EGLEY, REQUEST FOR EVALUATION / INTERPRETATION OF PROPOSED INVENTION SUDDEN STOP FLASHER [SSF]; REPORT DATED 09/ 07/88 FROM LARRY P. EGLEY, AN APPEAL FOR VARIANT INTERPRETATION OF NHTSA STANDARDS AS THEY RELATE TO BRAKE LIGHTS AND THE SUDDEN STOP FLASHER [SSF]; LETTER DATED 07/13/88 FROM KATHLEEN DEMETER -- NHTSA TO LARRY P. EGLEY; LETTER DATED 06/23/88 FROM LARRY P. EGLEY TO RALPH HITCHCOCK -- NHTSA; OCC 2256; LETTER DATED 06/09/88 FROM LARRY P. EGLEY TO LEWIS BUCHANAN

TEXT: Dear Mr. Egley:

This is in reply to your letter to me regarding your Sudden Stop Flasher.

I do not work in the section of the National Highway Traffic Safety Administration which could appropriately respond to your question. Therefore, I have forwarded your letter to Mr. Ralph Hitchcock, Director, Office of Vehicle Safety Standards with a re quest that his office respond to you. I am certain you will be hearing from someone about your inquiry in the near future.

Thank you for your interest in preventing motor vehicle crashes.

Sincerely,

ID: aiam5038

"Dear Mr. Sharman: This responds to your letter requesting informatio about whether the National Highway Traffic Safety Administration (NHTSA) has issued any regulations addressing the retention of records regarding compliance testing results. Your question arises in the context of the testing procedures set forth in Standard No. 302, Flammability of Interior Materials. (49 CFR 571.302). As explained below, the agency makes available all of its compliance test results through its Technical Reference Division. However, the agency has no such requirements for manufacturers or other persons to keep records concerning any test results. Nevertheless, a manufacturer would be well advised to retain such records in case its motor vehicle or item of equipment did not comply with an applicable safety standard. By way of background information, the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the 'Safety Act') gives this agency the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. Each of the agency's safety standards specifies the test conditions that this agency will use to assure whether the performance of the vehicle or equipment being tested is in compliance with the safety standard. NHTSA follows the established test procedures and conditions when conducting its compliance testing. The results of NHTSA's compliance tests are always recorded and made available to the public in the agency's Technical Reference Division. However, the Safety Act does not require a manufacturer to test its products only in the manner specified in the relevant safety standard, or even to test the products at all. A manufacturer may choose any means of certifying that its products comply with the requirements of the safety standards. If the manufacturer chooses to conduct testing, there is no requirement that the manufacturer retain those results. However, if the agency testing shows that an apparent noncompliance exists with a vehicle or item of equipment, the manufacturer is asked to show the basis for its certification that the vehicle or equipment complies with the relevant safety standard or standards. If, in fact, there is a noncompliance, the manufacturer is subject to civil penalties under the Safety Act unless it can establish that it exercised 'due care' in the design and manufacture of the product and in the checks (through actual testing, computer simulation, engineering analyses, or other means) to ensure compliance, but nevertheless did not have reason to know that the vehicle or item of equipment did not in fact comply with the safety standards. Given the potential for civil penalties, it is in the manufacturer's best interests to retain its testing records in case it must establish due care. (See 15 U.S.C. 1397(b)). I note that the agency has issued a regulation addressing recordkeeping, 49 CFR Part 576, Record Retention, which establishes requirements for the retention by motor vehicle manufacturers of complaints, reports, and other records concerning motor vehicle malfunctions. However, nothing in this provision requires retention of information generated during compliance testing. I hope this information is helpful. If you have any further questions about NHTSA's regulations, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel";

ID: aiam4993

Dear Mr. Aihara: This responds to your letter of March 16, 1992 requesting an interpretation of the applicability of the moisture prohibition of S7.4(i)(6) of Federal Motor Vehicle Safety Standard No. 108. Initially, we would like to call your attention to the fact that S7.4(i)(6), which you quoted in its entirety, was amended on March 11, 1991, to delete the requirement that a headlamp meet the photometric requirements after a humidity test. S7.4(i)(6) now states in pertinent part that, after a humidity test conducted in accordance with S8.7, 'the inside of the headlamp shall show no evidence of delamination or moisture, fogging or condensation visible without magnification.' You have attached a drawing of a vented headlamp with an onboard aiming system. The headlamp is available with two different types of bubble indicators. Your first question is: 'After the humidity test, both types . . . show the fogging in the location as shown in attached sketches. But, this fogging is gone at normal temperature. * * * Is such fogging acceptable after the humidity test?' Your second question is whether ''the inside of the housing' means the lens and reflector portions' or 'the entire inside portion of headlamps?' The humidity test was adopted for replaceable bulb headlamps in l983. Allowing humidity or water in headlamps causes slow degradation of the reflector over the long term. The presence of humidity results in spots on the reflector and lens, and eventual photometric failure. The humidity test is designed to assure that the vents in vented headlamps eliminate moisture in the headlamp when exposed to air flow with the headlamps off, thus assuring adequate performance in long term use. The provision for onboard headlamp aiming devices was not adopted until 1989, and, with respect to replaceable bulb headlamps, did not specify that they be located within the headlamp. From the foregoing, it is evident that the humidity test for replaceable bulb headlamps was not adopted to address a problem inherent in the exposure of onboard aiming devices to moisture. These devices were not in use at the time the humidity test was added to Standard No. 108, and they do not contribute directly to the photometric performance of the headlamp. From the diagram you enclosed, the aiming device appears located behind the reflector. It is not possible to determine from your letter whether moisture forms on the exterior or the interior of the aiming device. Although S7.4(i)(6) prohibits moisture 'inside the headlamp' and the aiming device is located inside the headlamp, we would not read the prohibition as extending to the aiming device if the moisture occurs inside that device. Even if the moisture occurs on the exterior of the aiming device, it does not affect the photometric properties of the headlamp. The agency does not wish to impose inadvertent design restrictions that are not directed towards safety, and therefore regards any moisture that may occur on the exterior of the aiming device as outside the prohibition of S7.4(i)(6). This interpretation, however, is limited to the specific design that you have presented. Sincerely, Paul Jackson Rice Chief Counsel;

ID: 11909RLX.LAB

Ms. Renee Brunson
Renolux Paris
5553 Ravenswood Rd., Suite 103-104
Ft. Lauderdale, FL 33312

Dear Ms. Brunson:

This responds to your May 13, 1996, letter and May 14 telephone call to Deirdre Fujita of my staff, asking about the labeling requirements of Federal Motor Vehicle Safety Standard No. 213, AChild Restraint Systems.@

Your letter is one of several we recently received concerning your company=s plan to sell imported child seats. In previous correspondence between your company (formerly Baby Comfort Inc.) and this office, it became apparent that certain child seats Baby Comfort wished to sell could not meet the requirements of Standard 213 and thus could not be certified to the standard or sold to the public. (April 16, 1996, letter to David Baret, President of Baby Comfort; April 29 letter to Lawrence Feder, counsel to Mr. Baret.) You told Ms. Fujita that the seats you now ask about are different from the nonconforming seats and that you believe these can meet the standard.

You ask a series of 14 questions about Standard 213. Your questions are restated below, followed by our answers.

Question 1: Can the specified labels in the standards be incorporated together? Are there any requirements or restrictions on which statements can be combined? (As long as the wording and placement of labels is according to standards.)

Answer: The information that S5.5.1 of Standard 213 requires to be permanently labeled on each child restraint can appear on one label. The standard has no restriction on which statements can

be combined. Note, however, that S5.5.3 requires some of the required statements to be visible when the system is installed. All the information on the restraint should be presented clearly.

2. Does the wording on the labels have to [appear] exactly as in the standards? Or can we add something to emphasize a point?

Generally, the wording must be as specified. However, manufacturers may present information in addition to the required information, if the additional information is presented in a manner that is not likely to obscure or confuse the meaning of the required information. See, e.g., April 17, 1989 letter to Robert Craig (labeling child seats with metric units), copy enclosed.

3. Can the instruction booklet be anywhere on the seat, possibly under the base?

You ask about S5.6.1.6 of Standard 213, which requires each add-on (portable) child restraint system to have a location on the restraint for storing the manufacturer=s instructions. The storage location may be under the base.

4. Can labels be sewn onto the seat cover? (Made out of a different material than the stickers, of course, and permanently affixed by sewing.)

The child seat cover (pad) may be labeled with the specified information. Under S5.5.1, the information must be permanent. Also, S5.7 of Standard 213 requires Aeach material used in a child restraint system@ to conform to the flammability resistance requirements of Standard 302. Labels affixed to a child restraint must comply with Standard 302, including sewn labels.

5. The label specified in S5.5(i) [sic] with regards to the use of the vehicle=s belt system does not apply to our seats as written in the standards. Can this be modified to suit our particular seat?

The statement specified in S5.5.2(i) is required only for booster seats, which we understand your seat is not. Thus, your seat need not have this statement.

While you are not required to label your seats with the S5.5.2(i) statement, you asked in a telephone call whether you may voluntarily add a statement similar to that of S5.5.2(i), because your seat can be used with both a vehicle=s lap belt or a lap and shoulder belt system. Your statement would direct users Ato install the seat using the vehicle=s belt system as specified in the manufacturer=s instructions.@ Our answer is the statement may be on the label. It would not obscure or confuse labeling required by Standard 213. In fact, it might help ensure that the seat is properly used.

6. Our seats are not belt positioning and no inversion tests were performed to determine aircraft compatibility. Do they require the label - NOT CERTIFIED FOR AIRCRAFT USE?

If the seat is not a belt-positioning seat (defined in S4 of the standard), it is excluded from the requirement of S5.5.2(n) that it must be labeled AThis Restraint is Not Certified for Use in Aircraft.@ Belt- positioning seats must be so labeled because the Federal Aviation Administration and NHTSA determined they are not suitable for aircraft use. The agencies have also recently determined that harnesses and backless booster seats must also be so labeled. (See enclosed final rule, 61 FR 28423, June 4, 1996.)

7. For instructions - as long as all statements are made according to standards - can we add any other information we wish regarding our seats? Are there any restrictions?

You ask about S5.6, which requires each add-on restraint system to be accompanied by installation instructions that includes certain specified information. You may add other information to the instructions, provided that the information would not cause confusion.

8. Are there Federal Label standards for materials [material content]? For any other states other than California?

There is no Federal requirement that you label the material content of the restraint. As for information on state requirements, we suggest you contact the Department of Motor Vehicles in the states the child seat will be sold or used.

9. Are there any requirements as to whether or not the seat (plastic part) has to have any information stamped into it? Or with raised letters?

Some manufacturers may have chosen to mold (or emboss) the required labeling into a restraint to ensure the permanency of the labeling. While NHTSA does not require molding or embossing the information, in a 1979 final rule upgrading Standard 213 NHTSA urged manufacturers, whenever possible, to mold the label into the surface of the restraint rather than use a paper label. 44 FR 72131, December 13, 1979.

10. I have noticed small numbers on some of the labels affixed to other carseats, do you know if it is some Federal requirement or what these numbers are? Must we show a patent number, etc.?

As discussed on the phone, we do not know what small numbers you refer to. Standard 213 does not require you to show a patent number.

11. Since we distribute the carseats, can our name be on the label for the recall information instead of the manufacturer, stating we are the distributor? We will be handling all inquiries regarding the seats.

Your company=s name may be on the label. We consider a Amanufacturer@ to include a company importing motor vehicle equipment.

12. Can we send labels for NHTSA approval before we print all of them? Is there someplace we could send a complete, labeled seat for approval?

NHTSA does not approve products or labeling on products. The responsibility for compliance with the labeling requirements, as well as all other requirements of the standard, rests with the manufacturer. Although we cannot recommend any testing facility, we are aware that the following facilities conduct tests of child restraints:

Calspan Corporation 4455 Genesee St. Buffalo, NY 14255

Detroit Testing Laboratory, Inc. 7111 E. Eleven Mile Rd. Warren, MI 48092

Child Passenger Protection University of Michigan c/o UMTRI 2901 Baxter Rd. Ann Arbor, MI 48019-2150

13. What does Aoutboard@ seating position mean?

You ask this with regard to S5.5.2(l), which requires child restraints to be labeled with an installation diagram showing the system installed in the Aright front outboard seating position . . . .@ AOutboard designated seating position@ is defined in '571.3 of NHTSA=s regulations. The position you ask about is the front right seating position.

14. Does NHTSA require anything (labels, warnings, etc.) on the box or packaging?

The answer is no, with regard to boxes or packages for child restraint systems.

If you have other questions, please call Ms. Fujita at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure

ref:213 d:6/7/96

ID: 15847.ztv

Mr. Mitch L. Williams
President & CEO
Hella, Inc.
P.O. Box 2665
Peachtree City, GA 30269

Dear Mr. Williams:

This is in reply to your letter of August 12, 1997, to Richard Van Iderstine of this agency. For your future reference, interpretations of the Federal motor vehicle safety standards, including Standard No. 108, are properly addressed to the Office of Chief Counsel.

You write that Hella "is currently working with a vehicle manufacturer to provide a fog lamp kit to be initially offered and installed at the car dealer, or vehicle manufacturer zone level, with a possible introduction later for the assembly line." Some of the vehicles will have daytime running lamps (DRL), and on such vehicles, the manufacturer wants to tie the fog lamps into the DRL circuit so that the fog lamps will illuminate when the vehicle is started and be extinguished when the upper beam of the headlamps are activated (if the fog lamp switch is in the "on" position), or when the ignition is turned off. You ask whether we concur with your conclusion that you see no problem with this arrangement.

I regret to say that we cannot concur with your conclusion. Although Standard No. 108 does not regulate fog lamps, it does regulate DRLs. Paragraph S5.5.11 provides that "Any pair of lamps on the front . . ., whether or not required by this standard, other than parking lamps or fog lamps, may be wired [as DRLs]. . . ." Therefore, wiring fog lamps to operate as DRLs is expressly forbidden by Standard No. 108. This means that the fog lamps cannot be tied into the DRL circuit on those vehicles equipped with DRLs.

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

Sincerely,
John Womack
Acting Chief Counsel
ref:108
d.10/1/97

ID: nht92-2.19

DATE: November 19, 1992

FROM: Daniel Cassese

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 1/5/92 (should be 1/5/93) from Paul Jackson Rice (signed by John Womack) to Daniel Cassese (A40; Std. 201; Std. 202; Std. 208; Std. 302; VSA 108(a)(2)(A))

TEXT:

I recently spoke to Mr. John Womack in regard to my questions concerning an invention I have and also a U.S. Patent #5, 135, 283.

The idea is called Head-rest (Extension) it would be used in Automobiles and allow a person to sit in more comfort when placed in the "existing" automobile seat. I need to find out whether my invention will comply to Safety Standards #201, 202, and #208. If it does comply, I have a Manufacturer Company, named GOSHEN CUSHIONS, INC. that is willing to manufacture it.

I've included the Patent Drawings and descriptions, please review them. Will this item (Head-Rest Ext.) comply with safety-standards #201, #202, #208?

How can I get approval??

I do NOT have a model (prototype) at this time.

Dear Sir,

Please note that figure #5 the #22 can be made to extend over the top of the existing head-rest. The Head-rest will NOT change the shape or design of the existing one at all. All dimensions are covered within the U.S. Patent.

HENCE: #34 is obsolete. There is no need for this vertical slot as shown because the existing headrest are not made this way. Instead #22 can be EXTENDED over the existing headrest and placed upon the existing headrest and seat.

#42 can be attached to Fig. 1, 2, 4, 5, 6, 8, 9, if chosen that way.

Attachment

Information regarding Patent # 5,135,283, Head Rest Extension. (Text and graphics omitted.))

ID: nht93-8.38

DATE: November 30, 1993

FROM: Len R. Thies -- C & C Creations

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached To Letter Dated 5/18/94 From John Womack To Len R. Thies (A42; Std. 111; Std. 205; Std. 302)

TEXT: Dear Mr. Womack:

My partner and I have developed an after-market device for use in commercial and non-commercial vans. The device inhibits the flow of air from the back of the van to the front and vice-versa, in effect reducing the amount of volume to be heated or cooled. The result is a more efficient use of the vehicle's heating/cooling system resulting in more comfort for the driver and passengers especially in cases of extreme temperatures.

The device is composed of a sheet of clear vinyl suspended near the ceiling by a metal bar. The vinyl is also attached to the sides of the vehicle by velcro patches. Visibility is unimpaired, and is easily detached and removed from the vehicle by the owner.

After additional testing we intend to start marketing the device. In order to address all potential regulations, I contacted Ms. Mary Verseilles and Mr. Mark Levine in your office, who have given me their informal opinions. I appreciate their time and commend them for their sincerity in addressing my questions and for guidance through other potential areas of concern.

The only real concern regarding the device is one raised by Mr. Levine and focuses on fire resistence. Vinyl will burn but must have constant ignition in order to do so. Many people might call it a "melt" rather than a burning action.

Basis the foregoing I would request from you a written opinion relative to the acceptability of the device for use in vehicles.

Thank you in advance for your handling of my request.

Sincerely,

ID: nht88-2.69

TYPE: INTERPRETATION-NHTSA

DATE: 07/13/88

FROM: KATHLEEN DEMETER -- NHTSA ASSISTANT CHIEF COUNSEL FOR GENERAL LAW

TO: LARRY P. EGLEY

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/09/89 FROM STEPHEN P. WOOD -- NHTSA TO LARRY P. EGLEY; REDBOOK A33 [2]; STANDARD 108; LETTER DATED 01/17/89 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 3028; LETTER DATED 05/23/89 FROM LARRY P. EGLEY TO KAT HLEEN DEMETER -- NHTSA; LETTER DATED 09/10/88 FROM LARRY P. EGLEY TO KATHLEEN DEMETER -- NHTSA; OCC 2530; REPORT DATED 09/10/88 FROM LARRY P. EGLEY, REQUEST FOR EVALUATION / INTERPRETATION OF PROPOSED INVENTION SUDDEN STOP FLASHER [SSF]; REPORT DATED 09/ 07/88 FROM LARRY P. EGLEY, AN APPEAL FOR VARIANT INTERPRETATION OF NHTSA STANDARDS AS THEY RELATE TO BRAKE LIGHTS AND THE SUDDEN STOP FLASHER [SSF]; LETTER DATED 06/23/88 FROM LARRY P. EGLEY TO RALPH HITCHCOCK -- NHTSA; OCC 2256; LETTER DATED 06/20/88 FR OM LEWIS S. BUCHANAN -- EPA TO LARRY P. EGLEY; OCC 2199; LETTER DATED 06/09/88 FROM LARRY P. EGLEY TO LEWIS BUCHANAN

TEXT: Dear Mr. Egley:

In a letter dated June 9, 1988, you requested our interpretation as to whether a new motor vehicle device would comply with applicable Federal Standards. You also asked that details of the device be afforded confidential treatment.

Please be informed that this agency requires all of its interpretations to be made publicly available. Hence, you must decide if you still desire an interpretation to be issued in this matter, with the result that the confidential status of the informat ion will be compromised. I am prepared to delete any information specifically identifying you or your address from our analysis if you so request, but the substantive information describing the item of motor vehicle equipment will be made part of the pu blicly available analysis.

No further action will be taken in this matter until we have received a response from you.

Sincerely,

ID: aiam4962

"Dear Mr. Harris: This responds to your letter asking about Federa motor vehicle safety standards applicable to your product, which you described as a cloth device containing plastic items useful to a baby, for use in motor vehicles. You explained that your product would be placed in a motor vehicle adjacent to, but not touching, a child in a nearby child safety seat. In particular, you were concerned about flammability resistance standards applicable to your product. I am pleased to have this opportunity to explain our requirements to you. I am also enclosing a copy of a fact sheet entitled 'Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment.' By way of background information, NHTSA is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. Section 102(4) of the Safety Act defines, in relevant part, the term 'motor vehicle equipment' as: any system, part, or component of a motor vehicle as originally manufactured or any similar part or component manufactured or sold for replacement or improvement of such system, part, or component or as any accessory, or addition to the motor vehicle ... In determining whether an item of equipment is considered an accessory, NHTSA applies two criteria. The first criterion is whether a substantial portion of the expected use of the item is related to the operation or maintenance of motor vehicles. We determine the expected use by considering product advertising, product labeling, and the type of store that retails the product, as well as available information about the actual use of the product. The second criterion is whether the product is intended to be used principally by ordinary users of motor vehicles. If the product satisfies both criteria, then the product is considered to be an 'accessory' and thus is subject to the provisions of the Safety Act. Applying these criteria to the cloth device containing baby items, it appears that your product would be an accessory and thus an item of motor vehicle equipment under the Safety Act. Based on our understanding of your device, it appears that a substantial portion of its expected use will be during the operation of a motor vehicle. In a telephone conversation with Ms. Dee Fujita of my staff, you explained that your device is intended to be sold for use in motor vehicles. In addition, it appears that your product would typically be used by ordinary users of motor vehicles. While it appears that your device would be considered an item of motor vehicle equipment, this agency has not issued any standards setting forth performance requirements for such a device. Obviously, your device could not be determined to be in noncompliance with a safety standard if there is no applicable safety standard. As for your concern about flammability resistance requirements, please be advised that our safety standard about this issue, Standard No. 302, Flammability of Interior Materials, (49 CFR 571.302, copy enclosed), would not apply to your device. That standard sets forth such requirements applicable to new motor vehicles and not to motor vehicle equipment. You should be aware that, as a manufacturer of an aftermarket item of motor vehicle equipment, you are subject to the requirements in sections 151-159 of the Safety Act concerning the recall and remedy of products with defects related to motor vehicle safety. In the event that you or NHTSA determines that your product contains a safety related defect, you would be responsible for notifying purchasers of the defective equipment and for remedying the problem free of charge. I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosure";