ID: nht75-4.1

DATE: 11/17/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: MOTAC, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to MOTAC's September 18, 1975, question whether rebuilding a platform trailer constitutes the manufacture of a new vehicle subject to applicable motor vehicle safety standards when the running gear (the axles, wheels, suspension, and related components sometimes known as a bogie) and the platform of a wrecked trailer is used (1) in combination with entirely new frame members, (2) in combination with one main frame member of the wrecked vehicle and one new frame member, and (3) in combination with part of one or both main frame members. You also ask whether the addition of a second axle to a single axle trailer, or the deletion of one axle on a tandem axle trailer, qualifies as the manufacture of a new vehicle subject to applicable safety standards.

In response to your first question, the National Highway Traffic Safety Administration (NHTSA) has determined (in the Stainless Tank and Equipment letter to which you refer) that, as a minimum, the running gear and main frame of the existing trailer must be used to qualify the rebuilding operation as a repair where all other materials are new. This position does not apply to the three situations you describe in which only the main frame members, and perhaps several cross members, are replaced. Therefore a repair of this type is not considered the manufacture of a new trailer.

In response to your second question, the NHTSA would not consider the addition of a second axle to a single axle trailer, or the removal of one axle from a tandem axle vehicle, to constitute the manufacture of a new vehicle.

Sincerely,

September 18, 1975

National Highway Traffic Safety Administration

Attention: Frank A. Berndt Acting Chief Counsel

We would appreciate your clarification as to the extent that major repairs and/or modifications may be made to semi-trailers and pull trailers without the inclusion of the FMVSS 121 anti-lock brakes.

We have two items or catagories that we wished resolved and they are brought about thru your letter of 8/28/75, file number N40-30 addressed to Stainless Tank and Equipment, Inc., Cottage Grove, Wisconsin. This letter was transmitted to all members of T.T.M.A.

ITEM NO. 1

Assume that a platform trailer had been in a serious accident and possibly rolled over, thereby bending and twisting the main frame members severely. We will also assume that the damage is to such an extent that the main frame members cannot be straightened, which generally can be done.

The following conditions could then prevail for the required repair:

A. Cut the damaged portion off of one or possibly both main frame rails and repair with a new partial section or sections.

B. Replace one main frame rail completely.

C. Replace both main frame rails completely.

In the above hypothesis, the "Bogie", axles, wheels, tires, supports, etc. would all be used. The trailer would maintain the same model and serial number.

In a major repair of this sort will the standard 121 brakes be required? If so, then the old axles would have to be junked and new S-121 axle assemblies with computor/relay valves must be purchased and installed.

ITEM NO. 2

Six years ago, our company manufactured thirty (30) single axle container semi-trailers and thirty (30) tandem axle container semi-trailers, 25 foot long to haul 20 foot containers. The main frame rails, bolsters, supports, etc., are identical on both trailers.

The customer is now contemplating converting the single axle semi-trailers to tandem axle semi-trailers. This will entail relocating the existing front and rear spring hangers, adding a center equalizer hanger and rocker arm assembly, one set of springs, one axle, brake, tire and wheel assembly. The trailer will be reregistered as a tandem axle semi-trailer for state licensing.

In converting a single axle semi-trailer to a tandem axle semi-trailer will the Standard 121 brakes be required? Also, conversely, if a tandem axle semi-trailer should be converted to a single axle semi-trailer will the Standard 121 brakes be required?

MOTAC, INC.

Jack A. Johnson Chief Engineer

ID: nht75-6.23

DATE: 01/01/75 EST

FROM: RICHARD B. DYSON -- NHTSA ASSISTANT CHIEF COUNSEL

TO: ALLAN B. FREDHOLD -- GENERAL MANAGER K-B AXLE CO., INC.

TITLE: N40-30 (TWH)

ATTACHMT: LETTER DATED 4/16/75 FROM RICHARD B. DYSON -- NHTSA CHIEF COUNSEL TO GEOFFREY R. MYERS OF HALL AND MYERS; UNDATED LETTER FROM RICHARD B. DYSON -- NHTSA CHIEF COUNSEL TO ADDRESSEE UNKNOWN

TEXT: Dear Mr. Fredhold:

This responds to K-B Axle Company's March 4, 1975, request for guidance in assisting K-B's customers in meeting their certification responsibilities under Standard No. 121, Air brake systems.

Standard No. 121 specifies air brake performance requirements (and some equipment requirements) which newly-manufactured trucks, buses, and trailers must be capable of meeting. For example, the standard specifies that if a truck or bus, in the loaded and unloaded condition, is stopped six times from 60 mph on certain test surfaces, it must be capable of stopping at least once in 258 feet without leaving a 12-foot wide lane and without uncontrolled wheel lockup.

Many manufacturers incorrectly assume that this requirement means that, in order to certify that it has this capability, each vehicle produced must actually be tested from 60 mph on a test track. In fact the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1391, et. seq.) specifies the manufacturer's certification responsibility, which is to exercise "due care" that the vehicle or item of equipment is capable of meeting all requirements.

NHTSA has made clear in the past, and has emphasized in its implementation of Standard No. 121, that a manufacturer is free to use whatever method is reasonably calculated to fulfill his responsibility to exercise due care. To cite a simple example, if a safety standard specifies that a certain safety device be no less than 8 inches above the ground, it would not be necessary to measure the height of each safety device on each vehicle produced to assure in the exercise of due care that it complies.

Standard No. 121, of course, establishes more complex performance requirements, and they would be affected by the addition of your "tag" or "pusher" axles. Most final-stage manufacturers and alterers feel confident that they can meet such requirements as minimum air tank volume when they add a third axle. In more complex areas, however, they require some reasonable basis on which to certify, in the exercise of due care, that the vehicle still is capable of stopping within the required distance, and that the brake actuation and release times still meet the minimum performance levels of the standard.

As noted earlier, the standard and our statute do not require road testing as the basis of certification. NHTSA, in a preamble to Standard No. 121 recognized:

What constitutes due care in a particular case depends on all relevant facts, including such things as the time to elapse before a new effective date, the availability of test equipment, the limitations of current technology, and above all the diligence evidenced by the manufacturer.

Road testing would be one method of exercising due care. Your customers, of course, may not have the capability to conduct road testing.

As a supplier of the added component, you are in a good position to develop engineering data on the effect your axle has when added to a 121 vehicle. For example, you could add your axle to a 121 chassis with a representative body and conduct a road test to see that the vehicle with the added axle and gross vehicle weight would still meet the stopping distance requirements. You might also test the actuation and release times on this vehicle to see that the axle addition does not cause non-conformity. This experimentation would permit you to make general statements about the conditions under which your axle could be added to a 121-type chassis without causing non-conformity.

Although retardation force is not a requirement for a vehicle other than a trailer, you suggest use of dynamometer data as a basis of certification. Such information would be a valid basis of certification if it is shown that a reasonable correlation exists between the retardation forces you specify and the actual ability of the modified truck to stop.

Yours truly,

ID: nht92-6.37

DATE: May 26, 1992

FROM: Steven Henderson -- Department of Psychology, McGill University

TO: Howard Smolkin -- Acting Administrator, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6-28-93 from John Womack to Steven Henderson (A41; Std. 108).

TEXT: My name Steven Henderson. I am PhD student in the Department of Psychology a McGill University, where I am studying visual perception. My coinventor David Kernaghan and I have designed, built and filed a patent application for a horn-activated headlight/signallight flasher system that enables motorcyclists to temporarily make themselves more conspicuous to other drivers. I have enclosed the patent application for your information. The U.S. Patent Office has granted claims 1-3 and 7-9 in their first response. Claims 4-6 were contained in a more recently submitted continuation in part (CIP).

The horn flasher is used in the following manner. When a motorcyclist becomes aware that another vehicle is about to encroach on his or her path of travel, a push of the motorcycle's horn button causes the headlight and signal lights to flash 10 times per second. (Ten hz is the frequency to which the human eye is most sensitive.) The flickering light in the car driver's visual periphery will immediately cause him or her to flexively fixate the motorcycle's location. By being made aware of the motorcycle's presence, the car driver is prevented from causing an accident. Our hope is that this invention will help to avert some of the approximately three thousand fatalities suffered annually by motorcyclists in North America.

I have exchanged correspondence with Mr. Paul Jackson Rice, Chief Council, NHTSA, concerning the application of DOT Standard No. 108 to our device. I have found his recommendations to be invaluable to our efforts to modify the device to more closely comply with the standard. However, as the invention was not envisioned when the standard was initially written, our device appears not to be in compliance with S5.5.10(c) and (d), and S5.6 of the standard. In his letter of August 28, 1992, Mr. Rice recommends the following:

The agency shares your concern with improving the detectability of motorcycles and their riders ... You may petition the agency for rulemaking to amend Standard No. 108 in a manner that would allow your device. A petition must set forth facts which it is claimed establish that a change in the standard is necessary, and a brief description of the changes which should be made. This means that you should show how your device is expected to improve safety, or, at a minimum, not decrease the existing level of safety.

Accordingly, I am acting on Mr. Rice's suggestion, and have enclosed a petition requesting that the agency for rulemaking amend Sections S5.5.10 and S5.6 of Standard No. 108 in order to permit the use of our device. I have also enclosed the U.S patent application submitted for the device. (On the advice of Mr. Rice, the circuit has been modified so that if the horn button is pressed while signalling for a turn, the appropriate signal light flickers at 2 hz, as required by SAE J590, rather than emitting 2 hz bursts of 10 hz flicker,

as does the unmodified circuit. Please also note that the tail light is always steady-burning, as required by Section S5.5.10(d).

As I state in the enclosed petition, I feel very strongly that our device furthers the purpose of Standard No. 108 as stated in Section S2, as it will:

reduce traffic accidents and deaths and injuries resulting from traffic accidents ... by enhancing the conspicuity of motor vehicles on the public roads so that their presence is perceived and their signals understood.

Furthermore, Section S5.5.10(b) illustrates an intent to allow a device similar to ours, by stating:

(b) Headlamps and side marker lamps may be wired to flash for signalling purposes.

I therefore request that you grant careful consideration to our petition to amend DOT Standard No. 108 so as to allow the use of our device.

Thank You.

ID: nht90-4.44

TYPE: Interpretation-NHTSA

DATE: October 15, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: W. Marshall Rickert -- Motor Vehicle Administrator, Maryland Department of Transportation

TITLE: None

ATTACHMT: Attached to letter dated 7-31-90 from W.M. Rickert to Chief Counsel, NHTSA (OCC 5076); Also attached to Maryland Vehicle Law, sections 22-103 and 104, page 320 (text omitted); Also attached to Maryland Vehicle Inspections procedures regarding m irrors and vehicle glazing, pages 227 and 228 (text omitted)

TEXT:

Thank you for your letter seeking this agency's opinion as to whether the State of Maryland may amend its motor vehicle regulations to permit the installation of aftermarket tinting on motor vehicle windows, for individuals who may desire this for medica l reasons. I am pleased to have this opportunity to describe the legal principles that relate to your question.

The National Highway Traffic Safety Administration ("NHTSA") is responsible for issuing Federal motor vehicle safety standards that impose requirements for specific levels of safety performance for new motor vehicles and motor vehicle equipment. Federal Motor Vehicle Safety Standard No. 205, Glazing Materials (49 CFR S571.205), which has been in effect since 1968, imposes a minimum level of light transmittance of 70 percent in all areas requisite for driving visibility (which includes all windows on pa ssenger cars). The purpose of this requirement is to ensure adequate visibility through the windows, thereby reducing the risk of a motor vehicle crash.

Although Federal motor vehicle safety standards apply directly only to new vehicles and equipment, Federal law also imposes limits on the addition of tinting materials to motor vehicle glazing after vehicles have been purchased by consumers. Pursuant to section 108(a)(2) of the National Traffic and Motor Vehicle Safety Act, 15 U.S.C. 1397(a)(2), manufacturers, distributors, dealers, or motor vehicle repair businesses may not "render inoperative" any equipment or element of design installed in complianc e with a Federal safety standard. Thus, those businesses may not install tinting that reduces the light transmittance of windows covered by Standard 205 to a level below the Federal requirement of 70 percent, since that would make the windows "inoperati ve" within the meaning of Standard 205.

This Federal prohibition is similar to that imposed by section 22-104 of the Maryland Vehicle Law, which provides:

A person may not willfully or intentionally remove or alter any safety device or equipment that has been placed on any motor vehicle . . . in compliance with any law, rule, regulation, or requirement of . . . the United States or of this State . . . unle ss the removal or alteration is permitted by rule or regulation adopted by the (Maryland Motor Vehicle) Administrator.

The "render inoperative" provision of Federal law does not apply to actions by individual vehicle owners. Therefore, each State may regulate the extent to which aftermarket tinting may be applied by vehicle owners to their own vehicles. Thus, although section 22-104 appears to preclude aftermarket tinting by any person if the result would be to reduce the level of light transmittance below 70 percent, Maryland may amend its rules or regulations to permit such tinting by individuals, for medical or any other reasons deemed valid by the State. However, Maryland has no authority to grant any exemptions, including medical exemptions, from the "render inoperative" prohibition of Federal law that applies to commercial entities. Hence, regardless of any p rovisions of Maryland law, no manufacturer, distributor, dealer, or motor vehicle repair business may legally install window tinting film on a vehicle, unless the vehicle continues to comply with the Federal light transmittance requirements.

In adopting Standard 205, NHTSA determined that a minimum light transmittance of 70 percent is necessary to meet the need for motor vehicle safety. This is the same level of light transmittance contained in the Safety Code of the American National Stand ards Institute. If, as your letter suggests, Maryland is considering permitting vehicle owners to modify their vehicles such that their windows will have a lower level of light transmittance, we would urge you to carefully consider the safety consequenc es of such an exemption.

Please let me know if you need any further information on this subject.

ID: nht92-8.16

DATE: March 26, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Larry J. French -- President and CEO, Magnascreen

TITLE: None

ATTACHMT: Attached to letter dated 1/24/92 from Larry J. French to Office of the Chief Counsel, NHTSA (OCC 6921)

TEXT:

This responds to your letter inquiring about a recent amendment to Safety Standard No. 111, Rearview Mirrors. (49 CFR S571.111) You explained that your company is developing electronically controlled dimmable (day/night) rearview mirrors for motor vehicles and requested that the agency assess your reading of section S11 of the standard. We are pleased to have this opportunity to interpret our standard for you.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approval of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, the manufacturer is responsible for certifying that its vehicles or equipment comply with applicable standards. The following letter represents our opinion based on the facts presented in your letter.

Safety Standard No. 111 specifies requirements for the performance and location of rearview mirrors. Section S11, which was recently amended to better address new mirror designs, specifies requirements for mirror construction. (See 56 FR 58513, November 20, 1991.) The section states in relevant part that:

All single reflectance mirrors shall have an average reflectance of at least 35 percent. If a mirror is capable of multiple reflectance levels, the minimum reflectance level in the day mode shall be at least 35 percent and the minimum reflectance level in the night mode shall be at least 4 percent. A multiple reflectance mirror shall either be equipped with a means for the driver to adjust the mirror to a reflectance level of at least 35 percent in the event of electrical failure or achieve such reflectance level automatically in the event of electrical failure.

You asked whether an alternate power source can be used to achieve the specified fail-safe operation (i.e., adjusting the mirror to a reflectance level of at least 35 percent in the event of electrical failure). While your letter did not specify what you meant by "alternate power source," we assume that it means an electrical power source other than the one intended to normally operate the mirror. Examples of an alternate electrical power source include solar energy or a self-contained battery system.

We interpret the term "electrical failure," as used in section S11 of Standard No. 111, to include any type of electrical failure. This would include electrical failure related to an alternate power source as well as electrical failure related to the primary power source. Therefore, unless adjustment of

the mirror to a reflectance level of at least 35 percent occurred even in situations where there was electrical failure related to the alternate power source, the alternate electrical source could not be used to provide the fail-safe operation required by section S11.

The preamble to the final rule amending Standard No. 111 explained that the agency wanted to assure that multiple reflectance mirrors are capable of providing adequate images at all times during this vehicle's operation, including electrical failure situations where the mirror is unpowered. The agency noted that situations can occur where the mirror would be unpowered even though the vehicle could be operational, citing connector faults and circuit board faults. See 56 FR 58515.

To comply with section S11 in situations where a mirror is unpowered as a result of electrical failure, a mirror would either have to default automatically to the high reflectance mode (as in the case of an opposite polarity fail-safe liquid crystal mirror described in the preamble) or be capable of being manually adjusted to the high reflectance mode. We do not have enough information about your proposed mirror to determine whether it would comply with the amendments in the case of electrical failure related to the alternate power source.

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.

ID: aiam1153

Dear Mr. Ford: This is in reply to your letter of May 21, 1973, forwarding to us you second attempt to compose a letter that will conform to Part 577, Defect Notification, for a defect involving the lighting in boat trailers manufactured by V/M Custom Boat Trailers. We responded to an earlier letter from you on May 16, 1973.; Section 577.6 prohibits the making of any statement in the notificatio that either states or implies that the problem discussed is not a defect, or that it does not relate to motor vehicle safety. As we indicated to you in our letter of May 16, we considered your statement, 'The defect on those trailers . . . does not affect the mechanical operation of said trailer except insofar as the lighting is inefficient as installed according to the U.S. Department of Transportation' to be prohibited by section 577.6. The additional phrase, 'This statement is one of fact only and is not intended to be a disclaimer which is prohibited by section 577.6 of the Act', which you have now inserted, does not remedy that deficiency. The regulation states that such a statement may not be made at all, it does not allow it to be made and denied.; Our objection to the statement is with your description of the defec as an 'inefficiency' according to the Department of Transportation. This safety related defect results, rather, from violations of law which require your client's products to meet minimim (sic) safe levels of performance. We recommend that rather than attempt once again to rewrite your statement, and risk violation of the regulation, you delete it entirely, and send the notification to purchasers forthwith.; In other respects your notification appears to conform to Part 577. Sincerely yours, Lawrence R. Schneider, Chief Counsel

ID: aiam4352

Dear Dr Ernst: This is in reply to your letter of February 5, 1987, to Richard Va Iderstine of this agency's Office of Vehicle Safety Standards. You have asked for an interpretation of Motor Vehicle Safety Standard No. 108 with respect to a new headlamp manufactured by Hella that BMW has installed on a new car which it introduced in the United States around April 1, 1987.; The headlamp is of the replaceable bulb type, and as you describe i consist of two additional parts: 'the housing, to which the cover lens is bonded by means of a two-component adhesive', and 'the optical module, consisting of the reflector and the convex lens, joined by the lens carrier....' In your words, 'The two parts are held together by three screws', and you believe that 'the two parts, firmly screwed together, are as effectively joined as would be the case if bonded'.; Paragraph S3 of Standard No. 108 defines a 'replaceable bulb headlamp in pertinent part as 'a headlamp comprising a bonded lens and reflector assembly....' In the Hella design, the lens and reflector assembly are not bonded, and thus the headlamp is not a 'replaceable bulb headlamp' that is permissible for use on motor vehicle sold and used in the United States. The intent of the definition is to ensure that the headlamp lens and reflector are an integral replaceable unit, since that is the only means to assure a mechanically aimable replaceable bulb headlamp which is capable of using any replacement standardized replaceable light source and meets the necessary photometric performance. The foundation of mechanical amiability is that the beam and aiming pad are manufactured to have a specific relationship. If this relationship is altered by replacement of the lens only, or of the reflector only, there is a high likelihood that the lamp may not meet minimum performance requirements when aimed mechanically.; Sincerely, Erika Z. Jones, Chief Counsel

ID: aiam4526

Dear Mr. Scully: This is in reply to your letter of April 22, l988 asking for a clarification of a letter that this Office sent Wesbar Corporation on March 16, 1988, with respect to the term 'effective projected luminous area.' Wesbar had asked whether it could include the 'illuminated (by the turn signal bulb) reflex reflector portion of the turn signal lens' (Wesbar's language) in its calculation of the l2 square inch minimum effective projected luminous area required by S4.1.1.7 of Safety Standard No. 108. We replied that it could, assuming that the light shines through the reflector. You have pointed out that although a small amount of light escapes through a reflex reflector, the reflector is designed to return light from an outside source, rather than to direct light from a source inside the lamp, and that heretofore agency interpretations (e.g. on October 28, 1970, and October 28, 1979) had expressly excluded reflex reflectors from areas included in the calculation of effective projected luminous area. Reflex reflectors are also excluded from the term by SAE J387 Terminology. We appreciate your calling this matter to our attention. Previous interpretations by this Office clearly indicate that a 'reflex reflector' is not to be included in the calculation of effective projected luminous area. We also note that the SAE definition (paragraph 2, SAE J594f, January l977) is incorporated by reference into Standard No. 108, stating that this item of equipment is one that provides an indication of vehicle presence by reflected light (rather than projected light). We are providing a copy of this letter to Wesbar so that it will be apprised of our reevaluation, and our conclusion that the reflex reflector portion of a lens cannot be included in the calculations of the projected luminous lens area. I hope this clarifies the matter for you. Sincerely, Erika Z. Jones Chief Counsel;

ID: aiam5271

"Dear Mr. McIntyre: This responds to your letter in which you withdre your petition for rulemaking of August 18, 1993, and requested an agency interpretation instead. You referred to the final rule issued by this agency on January 15, 1993 (58 FR 4585), which amended Federal Motor Vehicle Safety Standard (FMVSS) 222. Specifically, paragraph S5.4.2.(a)(1) of the amendment provides that wheelchair securement devices composed of webbing or straps must meet the requirements for Type I safety belt systems specified in S4.2, among others, of FMVSS 209. You stated that there is no need to specify a minimum width for wheelchair securement belts and that the current industry standard for securement belts is a 1-inch polyester belt. Finally, you stated that the 1-inch polyester belts have less stretch than the 1.8-inch nylon belts and that the 1-inch belts are easier and less cumbersome to connect to a wheelchair. Paragraph S4.2(a), FMVSS 209, provides that seat belt webbing cannot be less than 1.8 inches wide, 'except for portions that do not touch a 95th percentile adult male with the seat in any adjustment position and the seat back in the manufacturer's nominal design riding position . . . .' That means that seat belt webbing must be at least 1.8 inches wide whenever it touches the person of the seat occupant. The width of webbed wheel chair securement belts that do not touch the persons of the chair occupants is not specified in any standard. Therefore, wheel chair securement belts can be 1 inch or some other width, so long as they do not touch the persons of the chair occupants and meet the other requirements of applicable standards. I hope this clarifies this matter for you. If you have any further questions or need any further information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, John Womack Acting Chief Counsel";

ID: aiam4876

"Dear Ms. Haudler: This responds to your letter seeking furthe information about a possible determination to be made by the Secretary of Transportation under Federal Motor Vehicle Safety Standard No. 208 (49 CFR 571.208). S4.1.4.1 of Standard No. 208 provides that cars manufactured on or after September 1, 1989 must be equipped with automatic crash protection. Vehicles equipped with automatic crash protection protect their occupants by means that require no action by vehicle occupants. Compliance with the minimum performance 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. 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). As you noted in your letter, S4.1.5 of Standard No. 208 provides that: 'If the Secretary of Transportation determines, by not later than April 1, 1989, that state mandatory safety belt usage laws have been enacted that meet the criteria specified in S4.1.5.2 and that are applicable to not less than two-thirds of the total population . . ., the automatic restraint requirements will not go into effect .' You asked whether the Secretary ever made a determination under S4.1.5 regarding State safety belt use laws. The answer is no. Under S4.1.5, the Secretary was not required to make any determination about any State safety belt laws. In fact, the Secretary never did so. Because no determination was made under S4.1.5, the automatic restraint requirements went into effect as of September 1, 1989 for all passenger cars. I have returned the self-addressed, stamped envelope you enclosed in your letter. Good luck in your legal career. Sincerely, Paul Jackson Rice Chief Counsel";