ID: 2707y

Mr. M. Iwase
General Manager
Technical Administration Dept.
Shizuoka Works
Koito Manufacturing Co. Ltd.
500, Kitawaki
Shimizu-shi, Shizuoka-ken
Japan

Dear Mr. Iwase:

This is in reply to your letter of August 22, l990, to Erika Z. Jones, formerly the Chief Counsel, requesting an interpretation of Standard No. l08.

You state that section S7.7.5.2(a)(2)(iv) of Standard No. l08 requires that the horizontal indicator of a vehicle headlamp aiming device (VHAD) shall be capable of re-calibration over a movement of +/- 2.5 degrees, and you would like us to confirm our interpretation of the method and procedures of recalibration on the vehicle after repair from accident damage. You say that NHTSA "interprets as follows: If the dimensional specifications of vehicle body and appropriate instruction are described in shop manual, re-calibration could be addressed." (55 FR pages 4425 and 4426, February 8, l990). You stated that Koito did not believe that this method is practicable.

We believe that you have misunderstood the Federal Register notice. The notice was the agency's response to petitions for reconsideration of Section S7.7.5.2(a)(2)(iv). Subsection (iv) states that the horizontal aim indicator of a VHAD "shall be capable of recalibration over a movement of +/- 2.5 degrees . . . to accommodate any adjustment necessary for recalibrating the indicator after vehicle repair from accident damage." Ford Motor Company had commented that this requirement was unduly restrictive. It asked NHTSA to allow the option of a VHAD with only a vertical aim indicator if the headlamps as installed met a suggested horizontal aim specification of 0.0 +0.8/-0.4 degree.

NHTSA, believing in the importance of horizontal aim capablility, found that a principal area of concern was that circumstances could occur during the life of the vehicle that could adversely affect maintenance of correct horizontal aim, and that without horizontal aim capability, it was unclear that the accuracy of horizontal aim could be assured after repair of accident damage. It was at that point that NHTSA observed:

"Manufacturers could address this concern by providing dimensional data for precise structural alignment of the vehicle in shop manuals and appropriate instructions for performing the necessary and potentially extensive parts replacement and vehicle reconstruction requisite for correct horizontal aim."

However, NHTSA went on to say that this concern was already met by subsection (iv) which requires the horizontal aim indicator to be capable of recalibration after crash damage or vehicle repair. NHTSA denied Ford's petition. Thus, it did not propose or adopt a requirement, as Ford wanted, that a manufacturer could provide instructions in place of a VHAD with a horizontal aim indicator. The existing requirement of subsection (iv) remained unchanged. Thus, it is the manufacturer's decision on how to provide for recalibration after crash damage and vehicle repair. Therefore, as long as a VHAD complies with subsection (iv), a manufacturer may provide whatever re-calibration instructions it deems appropriate.

I hope that this answers your question.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:l08 d:l0/3/90

ID: 2708y

Mr. William D. Rogers
President
SportsCar America, Inc.
400 South Elliott Road
Chapel Hill, N.C. 27514

Dear Mr. Rogers:

We have received the (unsigned) petition of SportsCar America, Inc., for a temporary exemption from Motor Vehicle Safety Standard No. 208, on grounds of substantial economic hardship, and are returning all copies to you for the reasons stated below.

SportsCar America wishes to undertake the importation and sale of passenger cars produced in Brazil. Pursuant to an "Exclusive Distribution Agreement" ("the Agreement") with Alfa Metais Veiculos Ltda. of Brazil, which you enclosed, it has imported a prototype vehicle for study, with reference to its status of conformance with the U.S. vehicle safety and emission standards.

The proper petitioner for this exemption is Alfa Metais Veiculos Ltda., identified in the Agreement that you attached as the "Manufacturer." Under Section l of the Agreement, SportsCar America is to return the prototype to the Manufacturer with "those modifications necessary in order to meet the emission and safety standards necessary for the importation" of the cars, and the Manufacturer will then use it as a model for the production of vehicles for sale in the United States. Under 49 CFR Part 567, the Manufacturer must also attach its certification of compliance to the completed vehicle before its shipment to the United States. Part 555 restricts petitions for temporary exemptions to Manufacturers of motor vehicles.

Although you identify SportsCar America as the "distribution agent", we have no record that the Manufacturer has filed the designation of agent pursuant to 49 CFR 551.45 that is required of Manufacturers offering their products for importation and sale in the United States. Presumably Alfa Metais would wish to appoint SportsCar America as its agent. Once it has done so, SportsCar America may submit the petition on behalf of the Manufacturer. The production and financial data (in dollars, please) must be those of the Manufacturer. However, we regard as relevant to conformance arguments the efforts that SportsCar America intends to make during the time a possible exemption is in effect, as outlined in your petition.

Noting your requests for confidential treatment of information, we are returning all copies of your petition, with our comments. Generally, the agency does not like to accord confidential treatment to all financial data submitted. At a minimum, it would like to include in its notice asking comments from the public a dollar amount of the cumulative net profit or loss experienced by the Manufacturer in the three years preceding the filing of the petition. Similarly, it would like to publish a dollar figure in discussing the effects of a denial of the petition on the petitioner. The purpose of this is our policy that if the public is to make an informed comment on the issue of whether compliance would cause a Manufacturer substantial economic hardship, the public should have access to much the same data as is available to the agency in its determination.

If you would like clarification of any of these matters, Taylor Vinson of this Office (202-366-5263) will be happy to provide them.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosures ref:555 d:l0/9/90

ID: 27124.ztv

Mr. Dennis G. Moore
Sierra Products, Inc.
1113 Greenville Road
Livermore, CA 94550

Dear Mr. Moore:

This is in reply to your letter of May 25, 2000, asking for an interpretation of Standard No. 108 as it concerns Light-Emitting Diode (LED) lamps.

You believe that the agency is allowing manufacturers of LED lamps to "violate" the requirements of Federal Motor Vehicle Safety Standard No. 108 with respect to the "effective projected luminous lens area" specifications.

As you know, the agency has been engaged for some time in rulemaking to adapt Standard No. 108 to accommodate LED technology. In the Notice of Proposed Rulemaking that established Docket No. NHTSA-98-3967, we asked for comments on the issue that you raise. This issue will be discussed in the preamble to the final rule presently being prepared. In the meantime, I am sending your letter to this docket as a comment to be considered.

Thank you for your interest in motor vehicle safety.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.7/12/00

ID: 2741y

William F. Canever, Esq.
Staff Attorney
Office of General Counsel
Ford Motor Company
The American Road
Dearborn, MI 48l2l

Dear Mr. Canever:

This responds to your letter concerning the implications under the Corporate Average Fuel Economy ("CAFE") program of the acquisition by Ford Motor Company ("Ford") of Jaguar plc ("Jaguar"). You stated that you believe all Ford and Jaguar vehicles produced and imported for model year ("MY") 1989 should be placed in Ford's fleet.

As discussed below, we have concluded that Ford's acquisition of Jaguar did not take place until MY 1990. Thus, Ford and Jaguar vehicles constituted separate fleets for MY 1989. As a consequence, while the fuel economy credits earned by the combined Ford/Jaguar fleet in MY l990 may be applied to reduce (or eliminate) Jaguar's CAFE shortfall in MY 1987 and later years, the credits earned by Ford in MY 1989 may not be applied to offset any Jaguar shortfall.

According to your letter, Ford publicly announced its tender offer for Jaguar shares on November 2, l989. This occurred after Ford had obtained the agreement of the Board of Directors of Jaguar to recommend the offer. The offer document, which constituted the formal legal offer, was mailed on November 8. After over 50 percent of Jaguar stock had been tendered, Ford declared the tender offer "unconditional" on December l0, l989.

You stated that during the period of negotiation, tender offer, and acceptance, and continuing through the end of calender year l989, Ford was "manufacturing" MY l989 vehicles. Apparently, that statement is based on your statement that a small number of MY l989 Jaguar and Aston Martin vehicles were imported into the United States "through calendar year end l989." You argued that because Ford controlled Jaguar and the importer of Jaguar vehicles prior to the time that the last of these MY l989 vehicles were imported, and because fuel economy standards apply to particular model years as a whole and not to separate parts of a model year, all Ford and Jaguar vehicles produced and imported for MY l989 should be placed in Ford's fleet. You contended that this treatment would be consistent with that accorded Chrysler Corporation ("Chrysler") and American Motors Corporation ("AMC") for model year l987.

We disagree with your analysis comparing your situation to that of Chrysler/AMC, given significant differences in the timing of the respective acquisitions. In a letter to Chrysler dated April 4, l990, NHTSA stated the following:

Another issue raised by Chrysler's memorandum is whether Chrysler and AMC became the same manufacturer for fuel economy purposes for model year l987. According to the memorandum, Chrysler agreed to acquire AMC in the spring of l987, and the transaction closed on August 6, l987. . . . Since Chrysler controlled AMC prior to the end of the l987 model year, and since fuel economy standards apply to particular model years as a whole and not to separate parts of a model year, it is our opinion that all of the vehicles produced by both Chrysler and AMC for model year l987 shall be treated as if manufactured by the same manufacturer, i.e., placed into one fleet. Otherwise, one or both of the manufacturers would have two separate CAFE values, pre-acquisition (or pre-control) and post-acquisition (or post-control), for the same model year.

We continue to adhere to our view that where one manufacturer acquires another during a model year, they should be deemed as the same manufacturer, with a single CAFE value, for that model year. However, in the Chrysler/AMC acquisition, all relevant aspects of the transaction took place during the l987 model year.

As you know, the Motor Vehicle Information and Cost Savings Act ("Act") establishes time limits within which NHTSA must establish and/or amend fuel economy standards for a given model year that are based upon the beginning of the model year. See sections 502(b) and 502(f)(2) of the Act. In interpreting those provisions, both NHTSA and the courts have concluded that the model year is traditionally thought to start approximately October l. See In re Center for Auto Safety, 793 F.2d l346, l349 (D.C. Cir. l986); 49 Fed. Reg. 225l6 (May 30, l984); 49 Fed. Reg. 4l250 (October 22, l984). See also General Motors Corporation v. NHTSA, 898 F.2d l65, l76 (D.C. Cir. l990); Center for Auto Safety v. NHTSA, 7l0 F.2d 842, 847 (D.C. Cir. l983).

In the Chrysler/AMC case, all relevant aspects of the transaction were completed well before the completion of MY 1987, i.e., September 30, l987. Conversely, in the Ford/Jaguar transaction, Ford made its tender offer in early November 1989 and declared the tender offer "unconditional" on December 10, 1989. These dates and any other possible date for the acquisition are clearly within the l990 model year, which began on approximately October l, l989.

We recognize that manufacturers may produce or import vehicles that are designated as belonging to a particular model year after October l of that year. However, for purposes of deciding the model year in which one manufacturer acquires another, we have concluded that the traditional model year is the appropriate frame of reference.

This conclusion is supported by the fact that by early November l989, the earliest date referred to in your letter, when Ford made its tender offer, it had been selling its MY l990 models for over a month. The fact that Ford or Jaguar may have produced or imported a small number of MY 1989 cars after the date of the acquisition is not determinative, since it has always been the case that model years can overlap for a given manufacturer, and some prior model year cars may be produced after the commencement of a given model year. Thus, any MY 1989 Jaguar vehicles that were imported during the last three months of 1989 should be included in Jaguar's MY 1989 fleet, as they would have been had the acquisition not occurred.

I note that your letter indicated that Ford intended to file its Final l989 Model Year Report under the CAFE program with all MY 1989 Jaguar vehicles included in Ford's fleet. You stated, however, that you would not file that Report until you received this agency's views on the propriety of that action. For the reasons set out above, we believe that Ford and Jaguar had separate, distinct fleets in MY 1989, and that therefore separate information should be filed for that model year.

I hope that this letter adequately explains our position on these issues. If you have any questions, please do not hesitate to contact me.

Sincerely,

Paul Jackson Rice Chief Counsel

d:l0/22/90 ref:50l(8)#50l(l2)

ID: 2742y

Mr. Lawrence W. Rusk
Project Engineer, Drum Brakes
Bendix Automotive Systems
Allied-Signal, Inc.
P.O. Box 4001
South Bend, IN 46634-4001

Dear Mr. Rusk:

This responds to your recent inquiry concerning adjustment procedures for hydraulic brakes during testing in accordance with Federal Motor Vehicle Safety Standard No. 105; Hydraulic Brake Systems. You asked whether, following the revisions effective September 1, 1991, the Standard will authorize manual brake adjustment on a vehicle equipped with duo-servo brakes and automatic brake adjusters following the initial burnish and three subsequent reburnishes. Although your letter did not specify that the focus of your inquiry is vehicles with a GVWR of 10,000 pounds or less, based on the context of your letter, I am assuming that this is the case. The answer to your question is yes, if manual adjustment is the published procedure recommended by the vehicle manufacturer.

Standard 105 currently provides that where automatic brake adjusters have been locked out during testing, the brakes may be manually adjusted following the initial burnish and each subsequent reburnish. Where the automatic adjusters have not been locked out, the Standard requires that the brakes be adjusted at these points by making stops in accordance with the manufacturer's recommendations. See, S7.4.1.2, S7.6, S7.12 and S7.14.

On September 29, 1989, NHTSA published a final rule (54 FR 40080) which requires that as of September 1, 1991, for all vehicles equipped with automatic brake adjusters being tested to Standard No. 105, that the automatic adjusters be operational during the test. In addition, the rule revises the provisions in S7.4 governing brake adjustment after burnish to delete language requiring that vehicles equipped with automatic adjusters be adjusted by making stops in accordance with the manufacturer's recommendations. These provisions are revised to state that following each specified burnishing, the brakes are to be adjusted in accordance with the manufacturer's published recommendations (e.g. recommendations set forth in service literature). Thus, if the manufacturer recommends that the brakes be adjusted manually, notwithstanding the automatic adjusters, they are to be manually adjusted. Alternatively, if the manufacturer recommends that the brakes be adjusted by completing a series of specified stops, that procedure must be followed.

In conclusion, under the new provisions in Standard No. 105, brakes on a vehicle with automatic brake adjusters and a GVWR of 10,000 pounds or less should be manually adjusted at the end of the initial and subsequent burnishes if the manufacturer's published recommendations call for manual adjustment.

I hope you find this information helpful. If you have further questions, please do not hesitate to contact David Greenburg of my staff, at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

/ref: 105 d:ll/7/90

ID: 2743y

Mr. W. C. Glasscock
Sun-Cool & Co.
2201 North Fifth Street
Springfield, Illinois 62702

Dear Mr. Glasscock:

This responds to your letter concerning the installation of aftermarket tinting on motor vehicle windows. According to your letter, you have been involved in the window tinting business for many years but only recently became aware of the fact that Federal law prohibits businesses from adding tinting film to motor vehicle windows if it reduces the level of light transmittance below that required by the Federal standard. You expressed concern that there appears to be a conflict between Federal and state law in this area and that there has been a lack of enforcement of the Federal requirement.

We are pleased that you have become aware of the Federal requirement in this area and that you are apparently now complying with it. As you may have heard, we have brought suit against six tint businesses in Florida. Those cases are pending in Federal court. We also plan to take appropriate steps to enforce the Federal requirement in other parts of the nation.

I will now discuss the relationship between Federal and state law in this area. The National Highway Traffic Safety Administration ("NHTSA") is responsible for issuing Federal motor vehicle safety standards that establish 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 571.205), 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 passenger 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 compliance 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 "inoperative" within the meaning of Standard 205.

You stated that state laws differ from the Federal law, citing as an example an Illinois law which, according to your letter, allows tinting on the rear and sides of vehicles as long as the vehicle's owner has a letter from a physician licensed to practice in the state of Illinois that explains the medical basis for the need.

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 after market tinting may be applied by vehicle owners to their own vehicles.

However, no state has the authority to grant any exemptions from the "render inoperative" prohibition of Federal law that applies to commercial entities. Hence, regardless of any provisions of state 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.

I hope this information is helpful.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:205 d:ll/9/90

ID: 2744y

Mr. William Shapiro
Manager, Regulations and Compliance
Volvo Cars of North America
Rockleigh, NJ 07647

Dear Mr. Shapiro:

This responds to your request for an interpretation of Standard No. 210, Seat Belt Assembly Anchorages (49 CFR 571.210). More specifically, you asked about the anchorage location requirements for the upper torso portion of Type 2 safety belts (i.e., lap/shoulder belts), set forth in S4.3.2 of Standard No. 210. I am pleased to have this opportunity to explain those regulatory requirements for you.

Before discussing the substantive issues raised in your letter, I would like to respond to your request that NHTSA not publicly release the design drawings for this proposed new safety belt design. We hereby grant your request. We will make available to the public your incoming letter and this response, but not the design drawings.

Your letter stated that Volvo is designing lap/shoulder belts for the rear seating positions of proposed future vehicles. The retractor for the upper end of the shoulder belt portion of these safety belts would be located in the seat back, and not within the acceptable anchorage location zone shown in Figure 1 of Standard No. 210. However, the shoulder belt webbing would pass through a device on the top of the seat back that you called a "belt anchor" on the way to the retractor. This "belt anchor" would bear most of the loads imposed on the shoulder belts from the forward direction, and would redirect the shoulder belt webbing downward to the retractor. This function is similar to that performed by D-rings for many current designs of manual lap/shoulder safety belts. The "belt anchor" would be within the acceptable anchorage location zone shown in Figure 1 of Standard No. 210. You asked if this design would comply with the requirements of S4.3.2 of Standard No. 210. The answer to your question is yes.

Both the "belt anchor" and the retractor would be "anchorages" within the meaning of S3 of Standard No. 210 for the shoulder belt, because both would transfer belt loads to the vehicle structure. However, S4.3.2 does not require that both these anchorages comply with the anchorage location requirements. Instead, S4.3.2 provides that, "the seat belt anchorage for the upper end of the upper torso restraint shall be located within the acceptable range shown in Figure 1." NHTSA has interpreted this language as follows. If there is a single "anchorage" for the upper end of the shoulder belt, that single "anchorage" must comply with the anchorage location requirements. If there is more than one "anchorage" for the upper end of the shoulder belt, the uppermost of these multiple anchorages must comply with the anchorage location requirements.

I hope this information is helpful. Please let me know if you have any further questions or need some additional information on this subject.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:2l0 d:ll/9/90

ID: 2771y

Mr. Richard Cahalan
Director of Core Services
Commonwealth of Massachusetts
Executive Office of Human Services
Department of Mental Retardation
160 North Washington Street
Boston, MA 02114

Dear Mr. Cahalan:

This responds to Mr. Oscar Harrell's letter requesting information about Federal regulations concerning the modification of vehicles to accommodate mentally retarded individuals. According to that letter, in response to conversations about this issue with Mr. George Shifflett of this agency's Office of Vehicle Safety Compliance, Mr. Harrell received copies of interpretation letters from my office to Mr. Vincent Foster dated September 4, 1986 and to Mr. W.G. Milby dated November 26, 1979. These letters express NHTSA's policy concerning modifications of vehicles to accommodate the special needs of handicapped individuals and the requirement in 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act prohibiting commercial businesses from knowingly rendering inoperative any elements of design installed on a vehicle in compliance with a Federal motor vehicle safety standard. Given the public interest against restricting the mobility of the handicapped, it is the agency's policy, depending on the particular situation, to consider certain violations of that section as technical ones justified by public need.

In a telephone conversation with Marvin Shaw of my staff, you explained that a van conversion company modified new Dodge Maxi-vans for your agency before they were purchased. Among the steps taken by the converter to accommodate handicapped individuals are the removal of the "top," the addition of a new "bottom," and the installation of a wheelchair lift. According to Mr. Harrell's letter, the converter, when contacted last year, stated that the vehicles, after being converted, comply with State and Federal regulations. You indicated, however, that the converter failed to certify that the vans, as altered, comply with Federal motor vehicle safety standards.

I am pleased to have this opportunity to explain our laws and regulations to you. I apologize for the delay in our response.

The National Traffic and Motor Vehicle Safety Act authorizes the National Highway Traffic Safety Administration (NHTSA) to issue safety standards applicable to new motor vehicles and new motor vehicle equipment. Each manufacturer is required to certify that its products meet all applicable safety standards.

Based on your letter and the telephone conversation with my staff, it appears that the van converter would be considered an "alterer" for purposes of of Part 567, Certification (copy enclosed). Section 567.7 defines "alterer" as

A person who alters a vehicle that has previously been certified in accordance with 567.4 or 567.5, other than by the addition, substitution, or removal of readily attachable components such as mirrors or tire and rim assemblies, or minor finishing operations such as painting, or who alters the vehicle in such a manner that its stated weight ratings are no longer valid, before the first purchase of the vehicle in good faith for purposes other than resale...

As an alterer, section 567.7 requires the vehicle converter to do the following:

(1) Supplement the certification label affixed by the original manufacturer by affixing an additional label stating that the vehicle as altered conforms to all applicable Federal motor vehicle safety standards. This supplemental label must state the name of the alterer and the month and the year in which the alterations were completed (see 567.7(a));

(2) Provide the modified values for the gross vehicle weight ratings or any of the gross axle weight ratings of the vehicle as altered if they are different from those shown on the original certification label (see 567.7(b)); and

(3) Provide the type classification, if the vehicle as altered has a different type classification from that shown on the original certification (see 567.7(c).

If the converter did not comply with these requirements, then it did not fulfill its certification responsibilities under Part 567. From what you have written to us, we assume that is the case. However, this does not in itself mean that the vehicles, as altered, do not comply with applicable safety standards or are otherwise unsafe. If you believe that the conversion of these vehicles poses a safety problem, you should contact this agency's Office of Enforcement and explain the specific safety problem.

If you have any further questions or need additional information on this subject, 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 ref:567 d:l/4/91

ID: 2772 cmc cloth label

ID: 2772y

Robert B. Roden, Esq.
Roden & Hayes
2015 First Avenue No.
Suite 400
Birmingham, AL 35203

Dear Mr. Roden:

This responds to your letter that asked whether Section 114 of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1403) requires some form of certification on "every replacement item of motor vehicle equipment." The answer to this question is that manufacturers of replacement items of motor vehicle equipment that are regulated by a Federal motor vehicle safety standard must certify these items. The background for this response is provided below.

Section 114 requires manufacturers or distributors of motor vehicle equipment to furnish dealers and distributors of such equipment with a certification that the items of motor vehicle equipment conform to all applicable Federal motor vehicle safety standards. The first issue to be discussed, therefore, is whether replacement parts are encompassed within the definition of "motor vehicle equipment." "Motor vehicle equipment" is defined at Section 102(4) of the Safety Act (15 U.S.C. 1391(4)). This definition includes systems, parts and components of motor vehicles that are "manufactured or sold for replacement."

The second issue to be discussed is what items of replacement motor vehicle equipment must be certified. In an interpretation letter of June 3, 1977 to Mr. Larry Stroble, this agency stated if there are no safety standards in effect regulating particular items of motor vehicle equipment, manufacturers of the equipment would not be required to certify in accordance with Section 114 and in the regulation promulgated thereunder (49 CFR Part 567). I am, for your information, enclosing a copy of this letter. Examples of items of motor vehicle equipment that have corresponding Federal motor vehicle safety standards are: brake hoses and brake hose assemblies (Standard No. 106); lighting (Standard No. 108); brake fluid (Standard No. 116); tires (Standard No. 109 and 117); glazing (Standard No. 205); seat belt assemblies (Standard No. 209); and wheel covers (Standard No. 211). I hope this responds to your concerns. If you have any further questions or need any additional information about this topic, please feel free to contact Ms. Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

Enclosure ref:VSAll4 d:l2/3/90