Interpretation ID: nht92-3.5

DATE: 10/28/92

FROM: JANET TAYLOR -- MARKETING AND SALES MANAGER, A-PEX INTERNATIONAL CO., LTD.

TO: OFFICE OF THE CHIEF COUNCIL, NHTSA

TITLE: SUB: INQUIRY REGARDING THE STANDARD REQUIREMENTS FOR THE INSTALLATION OF THE TAP ROOT EQUIPMENT STAND INTO A MOTOR VEHICLE (CAR, VAN ETC.).; REF.: OUR PHONE CONVERSATION WITH MR. EDWARD JETTNER, 10/28/92.

ATTACHMT: ATTACHED TO LETTER DATED 12-28-92 FROM PAUL J. RICE TO JANET TAYLOR (A40; STD. 208)

TEXT: This letter serves to follow-up on the referenced phone conversation. We are a consulting firm that represents a manufacturer of a mechanical equipment stand, TAP ROOT EQUIPMENT STAND, that is installed into automobiles. Primarily, the use of the stand is for portable equipment such as laptop computers, facsimile machines, car phones, etc. Please refer to the attached drawing of the unit and installation instructions (with reference drawings, 3 pages).

This unit is intended to be sold to consumers after manufacture of a vehicle as additional equipment -OR- possibly this unit will be sold to fleet manufacturers as an accessory to the vehicle prior to reaching the showroom. At this time, the marketing efforts have been aimed to selling it to the consumer as additional equipment.

As indicated in the installation instructions, this is intended to be installed by "Joe Public" and it involves drilling a 1/2" hole in the floor pan of the vehicle.

Our inquiry to your office is the following: Is this product regulated is the USA? If YES . . . 1) How is it regulated? What are the specific requirements/standard #? 2) How may we obtain these requirements? 3) What type of paperwork, testing/evaluation is needed? 4) What agency would we contact for this matter? 5) What is the estimated cost and time for this type evaluation? 60 Can we evaluate and "self-certify" this product to these regulations? **

** Note: Our firm, A-PEX, is a consulting firm with a testing laboratory (do not have NRTL status) that specializes in assisting manufacturers in meeting product safety requirements (e.g. UL, FCC requirements.)

We would greatly appreciate your written response to the above matter as soon as possible. Our client is eager to meet the appropriate safety regulations and bring his evaluated product to market.

If you have any questions or comments to the enclosed, please do not hesitate to contact the undersigned.

ATTACHMENT TAP ROOT EQUIPMENT STAND INSTALLATION INSTRUCTIONS (TEXT AND PHOTOS OMITTED.)