ID: 11618.MLV

Philip E. Brown, General Manager Europe
First Technology Safety Systems
European Office
2, Columbus Drive
Summit Ave., Southwood
Farnborough, Hants GU14 ONZ
England

Dear Mr. Brown:

This responds to your letter of February 23, 1996, concerning the pants for the Hybrid III dummy. You asked whether the pants should be below- or above-the- knee.

Section S8.1.9.2 of Standard No. 208, Occupant Crash Protection, states that the Hybrid III dummy shall be Aclothed in formfitting cotton stretch garments with . . . midcalf length pants.@ However, it has come to our attention that it is common practice for manufacturers and for the National Highway Traffic Safety Administration (NHTSA) contractors performing compliance tests to either cut off the pants above the dummy knees or to roll the pants up above the knees. Therefore, to update Standard No. 208 to reflect current practices, NHTSA will be publishing a notice of proposed rulemaking to amend Standard No. 208 to specify that the pants on the test dummies are to be above the knee. NHTSA will continue using above-the-knee pants in the interim, and we assume manufacturers will do so also.

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

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:208 d:6/14/96

ID: 11621MLV

Mr. Powell M. Smith II
President
Alamo Mobility, Inc.
8666 Huebner Road, Suite 104
San Antonio, TX 78240

Dear Mr. Powell:

This responds to your letter of March 1, 1996, requesting:

permission to disable an airbag in a vehicle being modified for a driver who has a physical disability. Her condition requires that the OEM steering wheel be replaced with a smaller 13" wheel. In addition, in order to drive from her wheelchair, she must be positioned so close to the wheel that it appears that deployment of the airbag will cause bodily injury.

In summary, our answer is that the vehicle may be modified. NHTSA will not institute enforcement proceedings against a repair business that modifies the seat on a vehicle to accommodate a condition such as you describe. A more detailed answer to your letter is provided below.

I would like to begin by noting that repair businesses are permitted to modify vehicles without obtaining permission from NHTSA to do so, but are subject to certain regulatory limits on the type of modifications they may make. In certain limited situations, we have exercised our discretion in enforcing our requirements to provide some allowances to a repair business which cannot conform to our requirements when making modifications to accommodate the special needs of persons with disabilities. Since the situation you describe is among those given special consideration by NHTSA, this letter should provide you with the relief you seek.

Our agency is authorized to issue Federal Motor Vehicle Safety Standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. Manufacturers are required to certify that their products conform to our safety standards before they can be offered for sale. Manufacturers, distributors, dealers, and repair businesses are prohibited from "knowingly making inoperative" any device or element of design installed on or in a motor vehicle in compliance with an applicable standard. In general, the "make inoperative" prohibition would require repair businesses which modify motor vehicles to ensure that they do not remove, disconnect, or degrade the performance of safety equipment installed in compliance with an applicable standard. Violations of this prohibition are punishable by civil fines up to $1,000 per violation.

In situations such as yours where a vehicle must be modified to accommodate the needs of a particular disability, we have been willing to consider any violations of the "make inoperative" prohibition a purely technical one justified by public need. As I have already noted above, NHTSA will not institute enforcement proceedings against a repair business that modifies the steering wheel and air bag on the vehicle to accommodate the condition you describe.

We caution, however, that only necessary modifications should be made to the vehicle. In addition, the modifier should take care in making the modifications. The modification may cause the air bag to deploy, and the manufacturer should be able to provide information on how the modification can be safely performed. Finally, if the vehicle is resold, we urge the owner to advise the purchaser of the modifications and consider reinstalling the removed safety equipment, if appropriate.

Finally, I note that an air bag may not be required for this vehicle. NHTSA has amended Standard No. 208 to allow an exclusion from the automatic protection requirements for trucks and multipurpose passenger vehicles "manufactured for operation by persons with disabilities." That term is defined to include:

vehicles that incorporate a level change device (e.g., a wheelchair lift or a ramp) for onloading or offloading an occupant in a wheelchair, an interior element of design intended to provide the vertical clearance necessary to permit a person in a wheelchair to move between the lift or ramp and the driver's position or to occupy that position, and either an adaptive control or special driver seating accommodation to enable persons who have limited use of their arms or legs to operate a vehicle. For purposes of this definition, special driver seating accommodations include a driver's seat easily removable with means installed for that purpose or with simple tools, or a driver's seat with extended adjustment capability to allow a person to easily transfer from a wheelchair to the driver's seat.

This exclusion will not be available under the new regulation that requires the installation of air bags to meet the automatic protection requirements. That regulation will be phased in beginning with vehicles manufactured on or after September 1, 1997 (1998 model year). All vehicles must comply the following year. NHTSA is, however, examining issues concerning the undesired side effects from air bags, including interactions with special adaptive equipment for persons with disabilities. I have enclosed a previously published request for comments, related to this issue, for your information.

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

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure ref:VSA#208 d:4/2/96

ID: 11625DRN

The Honorable Byron L. Dorgan
United States Senate
312 Federal Building
Third and Rosser Avenue
P. O. Box 2579
Bismarck, N.D. 58502

Dear Senator Dorgan:

Thank you for your letter on behalf of your constituent, Officer Rick Koropatnicki of Bowbells, asking how Federal regulations apply to a product ("The Plate") Officer Koropatnicki designed. Your letter was referred to the National Highway Traffic Safety Administration (NHTSA) for reply, as NHTSA regulates the manufacture and sale of new motor vehicles and items of motor vehicle equipment.

According to the product literature and other material you enclosed, The Plate is a type of signal that a motorist could use to alert other motorists of his or her need for help in an emergency. The Plate is made of highly reflective material and attaches to a license plate. When activated from a wireless key chain transmitter, The Plate displays a message: "I need help. Call Police." The Plate apparently is sold separately from the motor vehicle, but it is unclear whether The Plate is attached to the vehicle by the individual user or a business.

The Plate is an item of "motor vehicle equipment," and thus subject to this agency=s rulemaking and enforcement authority under Title 49, United States Code (U.S.C.). NHTSA has not issued any Federal motor vehicle safety standard that directly regulates the performance of products such as The Plate.

Nevertheless, as a manufacturer of motor vehicle equipment, the manufacturer of The Plate is subject to the requirements in Title 49 U.S.C. sections 30118 - 30121 concerning the recall and remedy of products with defects related to motor vehicle safety. In the event that the manufacturer or NHTSA determines that the product contains a safety-related defect, the manufacturer would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge.

Further, a commercial business that installs The Plate is subject to provisions of Title 49 U.S.C. that affect modifications of new or used vehicles. 49 U.S.C. section 30122(b) provides that:

A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard prescribed under this chapter . . . .

This means that a manufacturer, distributor, dealer, or motor vehicle repair business must not install The Plate if such installation should make inoperative the vehicle's compliance with the agency=s safety standards. The following example illustrates the applicability of this provision: Standard No. 108, ALamps, Reflective Devices, and Associated Equipment,@ specifies that motor vehicles must have a rear license plate lamp, to illuminate the plate from the top or sides. If any of the above named businesses should install The Plate, that business must ensure that the installation does not "make inoperative" the compliance of the motor vehicle with Standard No. 108. Any violation of the "make inoperative" prohibition would subject the violator to a potential civil penalty of up to $1,000 for each violation.

Please note that the Amake inoperative@ prohibition does not apply to modifications that vehicle owners make to their own vehicles. Thus, Federal law would not apply when individual vehicle owners install The Plate in their own vehicles, even if the installation were to result in the vehicle no longer complying with the standards.

Individual States do have the authority to regulate modifications that individual vehicle owners make to their vehicles. Your constituent may wish to consult State requirements to see whether The Plate would be permitted under State law.

I hope this information is helpful. I have enclosed a fact sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment." If you have any further questions, please feel free to contact me at this address or by telephone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure ref:VSA102(4) d:3/13/96

ID: 11640ZTV

Mr. Robert E. Hunter
President
Automotive Repair Corporation
P.O. Box 1542
Airway Heights, WA. 99041

Dear Mr. Hunter:

We have received your FAX of March 4 , 1996, to John Womack of this Office asking for advice "as to the procedure for initiating the approval process for [ a multi-functional turn signal device] this device for the OEM and after markets."

There are no laws that require Federal approval of motor vehicle lighting equipment before it is offered to the public. A manufacturer of replacement lighting equipment must ensure that its product complies with any applicable requirement of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment , and certify such compliance, before offering the item for sale. The manufacturer may certify, either by a DOT symbol on the item itself, or by a statement of compliance attached to the item or to the carton in which it is shipped. If the item is offered as original equipment, the manufacturer of the vehicle on which it is installed is responsible for certification that the vehicle as equipped with all lighting devices is in conformance with Standard No. 108.

Standard No. 108 requires motor vehicles to be equipped with turn signal lamps meeting the requirements of SAE Standard J588 NOV84, a turn signal operating unit in conformance with SAE Standard J589, April 1964, and a turn signal flasher complying with SAE J590b October 1965. However, if the vehicle's overall width is 80 or more inches, the turn signal lamps must meet the requirements of SAE Standard J1385 APR85.

If you review these SAE materials and have specific questions about how they relate to your device, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel ref:108 d:3/28/96

ID: 11641ZTV

Mr. Nathan L.M. McCarthy
The Syndicate, LLC
Drawer 250793
West Bloomfield, MI 48325-0793

Dear Mr. McCarthy:

This is in reply to your letter of February 22, 1996, to Barry Felrice of this agency with respect to your "intermittent daytime running lights" invention.

The invention "is intended primarily for the aftermarket" where "vehicles are without the OEM installed DRL." You wish to know whether it is regulated by Motor Vehicle Safety Standard No. 108, whether " a waiver from NHTSA could be obtained to permit on the road testing" if not under Standard No. 108, "or if there is any other direction to take to achieve the desired end result to support the patent." The system consists of front and rear mounted strobe lamps which flash 45 times a minute.

Your system would not be allowed as original motor vehicle equipment under Standard No. 108 because this standard does not permit supplementary lighting equipment such as your invention to flash. Aftermarket equipment is regulated by Standard No. 108 only if it is equipment intended to replace the lighting equipment with which a vehicle was originally equipped pursuant to the requirements of Standard No. 108. This is not the intended purpose of your invention. Consequently, Standard No. 108 does not regulate your invention. However, it is subject to the prohibitions of Title 49 United States Code Section 30122 Making safety devices and elements inoperative. Under this section, a manufacturer, distributor, dealer, or motor vehicle repair business "may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle" pursuant to an applicable Federal motor vehicle safety standard.

The question, then, is whether the operation of a flashing strobe lamp would affect the purpose of the required lighting equipment, which is to convey signals and to mark the vehicle. It is our considered opinion that a flashing strobe lamp, surely a novelty, would distract other drivers, at least momentarily, from stop signals and turn signals, and, in that sense, make them "inoperative." Section 30122 then would prohibit manufacturers, dealers, distributors, and motor vehicle repair businesses from installing your invention.

The prohibition does not extend to the vehicle owner, and there may be some purchasers with the expertise necessary to install your system on their vehicles. In this event, operation of the system is regulated by the individual states. It is our impression that many states restrict the use of strobe lights to emergency vehicles. If you wish to know more about state laws, we recommend that you contact the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22303.

Although we have authority to establish regulations under Section 30122, we have not done so, and, in the absence of this, have no general authority to waive its prohibitions. We have no other suggestions for you. If you have further questions, you may contact Taylor Vinson of this Office (202-366-5263).

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:108:SEC.30122 d:4/2/96

ID: 11643MLS

Mr. J. Brian Powers
NGV Sales and Service Manager
BC Gas Utility Ltd.
207-4190 Lougheed Highway
Burnaby, British Columbia
Canada V5C 6A8

Dear Mr. Powers:

This responds to your letter asking whether Compressed Natural Gas (CNG) containers used as fuel tanks for motor vehicles in the United States require periodic hydrostatic testing. You stated that these containers had been purchased by BC gas and stored in a warehouse, but did not state the date of their manufacture. The answer is no. This agency, the National Highway Traffic Safety Administration (NHTSA), has no authority to require the periodic testing of motor vehicles or items of motor vehicle equipment, after the first consumer purchase.

Congress has authorized NHTSA to issue Federal motor vehicle safety standards (FMVSSs) for new motor vehicles and new items of motor vehicle equipment. The agency has exercised this authority to issue FMVSS No. 304, Compressed natural gas fuel container integrity, (49 CFR 571.304) which specifies requirements for the integrity of new CNG containers used to fuel motor vehicles. One such requirement is that each new CNG container comply with a hydrostatic burst test. Each new CNG container manufactured on or after March 27, 1995 (the date the standard took effect) must comply with the hydrostatic burst test and the other requirements in FMVSS No. 304 and be certified as complying with that standard when it is sold. However, after the first consumer purchase of a motor vehicle or an item of motor vehicle equipment, NHTSA's authority is much more limited and does not extend to periodic hydrostatic testing (or any other periodic testing) of motor vehicles or such equipment.

I wish to note that another agency of the U.S. Department of Transportation, the Research and Special Programs Administration (RSPA), is authorized by Congress to issue standards for containers used to transport hazardous materials, including CNG containers. RSPA, however, does not have the statutory authority to regulate CNG containers that are used to fuel a motor vehicle. In other words, there are no Federal requirements applicable to the periodic retesting of CNG containers designed to fuel a motor vehicle.

Even though there are no Federal requirements about the periodic hydrostatic testing of CNG containers used to fuel motor vehicles, each state has the authority to regulate motor vehicles while they are in use. Accordingly, a state could regulate the testing of CNG containers in the aftermarket.

I hope you find this information helpful. If you have any other questions, please contact Marvin Shaw at this address or by phone at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

ref: 304 d:4/19/96

ID: 11644WKM

Mr. Dennis L. O'Connor
Manager, Government & Customer Compliance
The Goodyear Tire & Rubber Company
Akron, OH 44316-0001

Dear Mr. O'Connor:

This responds to your letter addressed to Walter Myers of my staff, in which you requested this agency's interpretation of what constitutes a "new" tire for purposes of applying the provisions of Federal Motor Vehicle Safety Standard (FMVSS) No. 109, New pneumatic tires and No. 119, New pneumatic tires for vehicles other than passenger cars.

Your question relates to section 30112 of Title 49, United States Code, which provides, in paragraph (a), that no person may manufacture for sale, sell, offer for sale, introduce into interstate commerce, or import for sale any motor vehicle or item of motor vehicle equipment on or after the effective date of any FMVSS that does not comply with that standard and is so certified. Section 30112(b) provides that this requirement does not apply, however, to a vehicle or item of equipment after the first purchase of that product in good faith other than for resale. Section 30112(a) applies, therefore, to the sale of Anew@ motor vehicles and Anew@ items of motor vehicle equipment, as opposed to used vehicles and equipment items.

FMVSS Nos. 109 and 119 specify performance and labeling requirements applicable to new pneumatic tires for use on passenger cars and motor vehicles other than passenger cars, respectively. Standard Nos. 110 and 120 require that new motor vehicles be equipped with tires that meet either FMVSS No. 109 or FMVSS No. 119.

Turning now to the question of what is meant by a "new" tire as opposed to a "used" tire, a vehicle or item of equipment is new from the time of its manufacture until its first retail sale. The agency considers the point at which the vehicle or item of equipment is delivered to the customer to be a critical factor in determining whether and when an item has been purchased. Thus, it is at the point of delivery of the item to the retail purchaser that a vehicle or item of equipment ceases to be "new" and therefore subject to Federal law and the FMVSSs, and becomes "used" and subject to state law and regulations.

The agency considers a motor vehicle to be the sum of its parts, including the tires mounted on the vehicle and its spare tire, if any. Accordingly, after a vehicle is delivered to its first retail purchaser, every component on and in that vehicle, including all its tires, becomes "used" for the purposes of the FMVSSs.

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

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:109#119 d:4/18/96

ID: 11645DF

Mr. David T. Holland
President
Europa International, Inc.
1570A Pacheco Street
Santa Fe, NM 87605

Dear Mr. Holland:

This responds to your letter addressed to Walter Myers of my staff and your telephone conversations with Mr. Myers. You asked whether tires for vehicles other than passenger cars that are not labeled with the DOT symbol must be branded "FOR OFF ROAD USE ONLY" before you can sell them, or whether you can test such tires and if they pass the test, brand the DOT symbol on them.

You explained to Mr. Myers that your company imports Mercedes sport utility vehicles whose tires are not labeled with the DOT symbol. You stated that you remove the noncertified tires from the vehicles and substitute certified tires therefor so the vehicles can be sold in the United States. However, since neither Bridgestone, the manufacturer of the tires, nor Mercedes will accept return of the tires, you are seeking ways in which these tires can legally be sold in the United States. Based on the information you provided to Mr. Myers, the tires in question must meet the performance and labeling requirements of Federal motor vehicle safety standard (FMVSS) No. 119, New pneumatic tires for vehicles other than passenger cars, and the labeling and recordkeeping requirements of 49 CFR Part 574, Tire Identification and Recordkeeping. Paragraph S6.5 of FMVSS No. 119 requires that each tire be marked with:

(a) The symbol DOT, which shall constitute a certification that the tire conforms to applicable Federal motor vehicle safety standards. This symbol may be marked on only one sidewall.

The DOT symbol is normally molded into or onto the sidewalls of tires during the manufacturing process to indicate the manufacturer's certification that the tire complies with applicable FMVSSs. In addition, the original manufacturer of the tires must mold a tire identification number into or onto the sidewall of each tire it produces in accordance with Part 574.5. Thus, whether or not tires comply with FMVSS No. 119 and are marked with the DOT symbol, if they do not contain the required tire identification number, they cannot be sold in the United States.

Although tires for vehicles other than passenger cars that do not contain the DOT symbol may not be sold for use on the streets, roads, or highways of this country, they may be sold for off-road use only. There is no requirement that tires be branded or otherwise marked "FOR OFF ROAD USE ONLY" before selling them in this way. However, it is advisable that the seller of such tires make a statement to that effect on the sales voucher or other written document as proof that the seller sold the tires with the understanding that they would only be used off-road.

The FMVSSs are not applicable to tires intended solely for export, provided the tires and their shipping containers are labeled for export only. Thus, you are free to export the tires in question, whether or not they comply with FMVSSs. In that respect, see attached letter to Oxytire, Inc., dated May 24, 1995.

I hope this information is helpful to you. Should you have any further questions or need additional information, please feel free to contact this office at this address or at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosures ref:119 d:4/23/96

ID: 11646RENLUX

Mr. David Baret
President
Baby Comfort Inc.
5553 Ravenswood Rd., Suite 103-104
Ft. Lauderdale, FL 33312

Dear Mr. Baret:

This responds to your March 6, 1996, letter asking about our requirements for child restraint systems.

You explain that your company would like to sell child restraints manufactured abroad in the United States. During a dynamic test you had conducted on one of the restraints, the seat failed to meet the performance requirements of Standard 213, AChild Restraint Systems,@ when secured to the test seat assembly with only a lap belt. You ask if Standard 213 would permit the child seat to meet performance requirements when secured with a lap and shoulder belt, rather than just a lap belt.

The answer is no. Under S6.1.2 of Standard 213, child restraint systems such as yours must meet performance requirements when secured with only a lap belt. Certain types of child restraints are excepted from the lap belt only requirement, but your restraint is not among these. Among the excluded restraints are Abelt- positioning@ child seats, which are defined in S4 of the standard as:

[A] child restraint system that positions a child on a vehicle seat to improve the fit of a vehicle Type II [lap and shoulder] belt system on the child and that lacks any component, such as a belt system or a structural element, designed to restrain forward movement of the child=s torso in a forward impact. (Emphasis added.)

As Ms. Fujita of my staff discussed with you in a March 25, 1996, telephone conversation, your child seat has an internal belt system harness and thus is not a belt- positioning seat. Accordingly, your child restraint system would be tested secured with only a lap belt. The National Highway Traffic Safety Administration (NHTSA) tests most child restraint systems with only a lap belt because lap belts are provided in the rear seats of many older model vehicles still on the road, and in the center seating position in the rear seat of many newer model vehicles as well. If your seat cannot meet Standard 213's requirements with only a lap belt, you could not in good faith certify your product as complying with Standard 213.

I have enclosed an information sheet for your information, which briefly outlines NHTSA=s standards for new manufacturers. If you have any further questions, please do not hesitate to contact Ms. Fujita at (202) 366-2992.

Sincerely,

Samuel J. Dubbin Chief Counsel

Enclosure

ref:213 d:4/16/96

ID: 11647MLV

Mr. Michael Love
Manager, Compliance
Porsche Cars North America, Inc.
100 West Liberty Street
P.O. Box 30911
Reno, Nevada 89520-3911

Dear Mr. Love:

This responds to your letter of December 19, 1995, requesting information concerning the readiness indicator requirement in S4.5.2 of Standard No. 208, Occupant Crash Protection. I apologize for the delay in responding.

S4.5.2 of Standard No. 208 states:

An occupant protection system that deploys in the event of a crash shall have a monitoring system with a readiness indicator. The indicator shall monitor its own readiness and shall be clearly visible from the driver's designated seating position.

You ask whether this requirement applies (1) to a voluntarily-installed inflatable restraint (not needed to comply with Standard No. 208), or (2) to an inflatable restraint installed to meet the requirements of another standard (such as Standard No. 214, Side Impact Protection). You state that Porsche believed that in both of these situations the manufacturer could install:

- no readiness indicator, or - a separate readiness indicator from that required by Standard No. 208, or - a readiness indicator combined with that required by Standard No. 208.

As explained below, for both types of inflatable restraints, we agree with the first two of these statements, but not necessarily with the third.

Voluntarily-Installed Inflatable Restraints

A crash-deployed occupant protection system installed in addition to required safety systems would not be required to

comply with the provisions of the safety standards. Thus, a readiness indicator would not be required. However, in the interest of safety, we would urge you to consider voluntarily providing a readiness indicator for the system.

As explained below, if you voluntarily provide a readiness indicator, and decide to combine it with the required readiness indicator, the information provided by the former must not confuse or obscure the information provided by the latter about the required air bag. The indicator must distinguish between the different air bag systems, such as by having dissimilar signals for the different systems.

While systems or components installed in addition to required safety systems are not required to comply with the standards, they must not make inoperative the compliance of the required systems (49 U.S.C. '30122). We urge you to make sure that by combining a voluntarily-installed readiness indicator with the required indicator, you do not prevent the latter from complying with Standard No. 208. If the messages of the two indicators were not distinguishable, a driver would not know if the illuminated telltale showed a problem with the occupant protection system installed to comply with Standard No. 208, or a problem with another system being monitored.

NHTSA addressed a related issue in a rulemaking that allowed manufacturers to install a manual cut-off device for a passenger-side air bag in certain situations (60 FR 27233; May 23, 1995). The agency stated there that the readiness indicator must monitor only the driver's air bag when the passenger-side air bag was deactivated. In other words, the indicator must not be affected by the deactivated state of the passenger-side air bag.

Systems Installed for a Standard Other than Standard 208

The requirement for a readiness indicator (S4.5.2) applies only to systems that are installed to comply with the requirements of Standard No. 208, and not to systems installed to comply with another standard. Air bag systems installed pursuant to Standard No. 208 are generally installed to meet the frontal protection requirements of that standard. While a readiness indicator is not required for systems installed for other purposes, we would urge the manufacturer to provide a means of monitoring the readiness of the system, consistent with the cautions above.

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

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:208#214 d:4/25/96