Mr. Freeman Chen
Associate Counsel
US JVC Corp.
41 Slater Drive
Elmwood Park, NJ 07407

Dear Mr. Chen:

This responds to your letter regarding your company's intention to produce a small flat screen LCD television receiver which would be suitable for use in passenger cars. Specifically, you ask if there are any guidelines or regulations regarding the size of the television, special feature requirements, or any restrictions on where these televisions may be installed in a vehicle.

The National Highway Traffic Safety Administration (NHTSA) does not have any safety standards specifically covering television receivers. However, it is possible that the installation of a television receiver could affect the compliance of a vehicle with some safety standards.

All new vehicles manufactured for sale in the United States must be certified by their manufacturer as complying with the Federal motor vehicle safety standards. If your television receivers are installed in a new vehicle prior to its first sale to a consumer, the manufacturer or dealer would be required to certify that the vehicle as altered continues to comply with all applicable Federal motor vehicle safety standards.

After a vehicle is sold at retail, Federal law limits the modifications made to it by manufacturers, distributors, dealers, and repair businesses. These entities are prohibited under 49 U.S.C. section 30122 from "knowingly making inoperative" any device or element of design installed on or in a motor vehicle in compliance with an applicable safety standard. In general, the "make inoperative" prohibition would require a business which modifies motor vehicles to ensure that they do not remove, disconnect, or degrade the performance of safety equipment installed in compliance with an applicable safety standard. Violations of this prohibition are punishable by civil fines up to $1,100 per violation.

Depending on where and how the device is mounted, the installation of a television receiver could affect the compliance of a vehicle with some safety standards. For example, standard No. 201, Occupant protection in interior impact, establishes requirements for the performance of certain interior areas of a vehicle in protecting occupants from injury if they contact these areas in a crash. The requirements of standard 201 apply to dashboards, seat backs, visors, and other interior sections where a flat panel TV screen might be mounted. Beginning September 1, 1998, new head impact protection requirements will apply to pillars, side rails, roof headers and the roof itself.

Standard No. l0l, Controls and Displays, contains requirements relating to the location, illumination, and labeling of controls and displays. One section of this standard, section S5.3.5, imposes certain requirements on illuminated devices in the vicinity of the driver. This section provides:

Any source of illumination within the passenger compartment which is forward of a transverse vertical plane 4.35 inch (ll0.6 mm) rearward of the manikin 'H' point with the driver's seat in its rearmost driving position, which is not used for the controls and displays regulated by this standard, which is not a telltale, and which is capable of being illuminated while the vehicle is in motion, shall have either (l) light intensity which is manually or automatically adjustable to provide at least two levels of brightness, (2) a single intensity that is barely discernible to a driver who has adapted to dark ambient roadway conditions, or (3) a means of being turned off.

The purpose of this requirement is to prevent glare visible to the driver. If a television receiver installed in view of the driver is capable of operation while the vehicle is in motion, it would be subject to this requirement.

While NHTSA does not have any safety standards specifically covering television receivers, the installation of a television receiver in view of the driver which is capable of operation while the vehicle is in motion would raise obvious safety concerns related to possible driver distraction.

Finally, I note that state laws may cover the installation of television receivers in motor vehicles. You should contact the Department of Motor Vehicles in any state in which the equipment will be sold or used for information on state laws.

I hope that this is information is helpful. If you have any questions, please contact Otto Matheke of my staff at (202) 366-5253.

Sincerely,
John Womack
Acting Chief Counsel
d.1/8/98
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