ID: nht94-3.49

TYPE: INTERPRETATION-NHTSA

DATE: June 29, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: R.H. Goble -- President, Goble Enterprises

TITLE: NONE

ATTACHMT: Attached to letter dated 5/16/94 from R.H. Goble to NHTSA Chief Counsel (OCC-10031)

TEXT: This is in reply to your letter of May 16, 1994, with respect to two motor vehicle lighting systems that you have developed, and your question about the regulations that may apply to each.

As we understand the first system, when the brake pedal is applied, the front turn signal lamps and front side marker lamps are simultaneously activated to indicate to observers from the front and side that the vehicle is braking. It appears that this a ctivation is in a steady burning state which continues unless and until the turn signal lamps are activated in either the flashing turn signal or hazard warning signal more. You have also developed a "Wheel Well lighting system", which "will provide lig ht indicators all around (brake, clearance, turn signal, emergency flashers)" through amber lamps mounted in the well at the top of each front and rear wheel opening. As we understand this system, these supplementary lamps will be activated simultaneous ly when the four named lamp systems are activated.

The regulation governing the lighting on new motor vehicles (i.e., requirements that must be met when a new vehicle is delivered to its first purchaser) is Federal Motor Vehicle Safety Standard No. 108. With respect to optional equipment such as your sy stems, Standard No. 108 allows each, provided that each does not impair the effectiveness of the lighting equipment required by the standard. The law governing the lighting on motor vehicles after their first sale is the National Traffic and Motor Vehic le Safety Act. In essence, it allows installation of each of your systems by a manufacturer, dealer, distributor, or motor vehicle repair business as long as the system does not "knowingly render inoperative, in whole or part, any device or element of d esign installed in accordance with" Standard No. 108.

We regard any supplemental lighting system with the potential of creating confusion in the eye of the beholder as one that impairs the effectiveness of other lamps on the vehicle, and

2

one that renders inoperative, in part at least, other lamps by compromising their effectiveness. This is especially true when existing vehicle lamps are used to convey messages that are different from the purpose of those lamps. We believe it especiall y important to motor vehicle safety that signal lamps convey their message unmistakably and without ambiguity. We see no real problem that might be occasioned by the activation of the front turn signal lamps in a steady burning mode, although this might cause initial puzzlement in the eye of an oncoming driver unfamiliar with the system. While confusion is more likely when the turn signal is operating on one side while the other side remains steady burning, we believe that the flashing of the turn sig nal will continue to be interpreted as an intention to turn. Of course, when the hazard warning system is activated and completely overrides the steady burning front stop lamp, there would be no confusion as to signal message. Therefore, in our opinion , Federal law permits use of your front stop lamp system.

Your second system does not operate through existing vehicle lamps but consists of additional lamps mounted in the wheel wells. These lamps would appear not to have the potential of confusion since they supplement existing lamps and operate in conjuncti on with them to convey the same message. Thus, Federal law, in our view, does not preclude use of your second system either.

However, even if a supplementary lighting system is permissible under Federal law, it is subject to regulation by any State in which it is operated. We are not able to advise you with respect to State law, and suggest that you write for an opinion to th e American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203.

ID: 0031

Mr. R. H. Goble
President, Goble Enterprises
P.O. Box 423
Lake Mary, FL 32795

Dear Mr. Goble:

This is in reply to your letter of May 16, 1994, with respect to two motor vehicle lighting systems that you have developed, and your question about the regulations that may apply to each.

As we understand the first system, when the brake pedal is applied, the front turn signal lamps and front side marker lamps are simultaneously activated to indicate to observers from the front and side that the vehicle is braking. It appears that this activation is in a steady burning state which continues unless and until the turn signal lamps are activated in either the flashing turn signal or hazard warning signal more. You have also developed a "Wheel Well lighting system", which "will provide light indicators all around (brake, clearance, turn signal, emergency flashers)" through amber lamps mounted in the well at the top of each front and rear wheel opening. As we understand this system, these supplementary lamps will be activated simultaneously when the four named lamp systems are activated.

The regulation governing the lighting on new motor vehicles (i.e., requirements that must be met when a new vehicle is delivered to its first purchaser) is Federal Motor Vehicle Safety Standard No. 108. With respect to optional equipment such as your systems, Standard No. 108 allows each, provided that each does not impair the effectiveness of the lighting equipment required by the standard. The law governing the lighting on motor vehicles after their first sale is the National Traffic and Motor Vehicle Safety Act. In essence, it allows installation of each of your systems by a manufacturer, dealer, distributor, or motor vehicle repair business as long as the system does not "knowingly render inoperative, in whole or part, any device or element of design installed in accordance with" Standard No. 108.

We regard any supplemental lighting system with the potential of creating confusion in the eye of the beholder as one that impairs the effectiveness of other lamps on the vehicle, and

one that renders inoperative, in part at least, other lamps by compromising their effectiveness. This is especially true when existing vehicle lamps are used to convey messages that are different from the purpose of those lamps. We believe it especially important to motor vehicle safety that signal lamps convey their message unmistakably and without ambiguity. We see no real problem that might be occasioned by the activation of the front turn signal lamps in a steady burning mode, although this might cause initial puzzlement in the eye of an oncoming driver unfamiliar with the system. While confusion is more likely when the turn signal is operating on one side while the other side remains steady burning, we believe that the flashing of the turn signal will continue to be interpreted as an intention to turn. Of course, when the hazard warning system is activated and completely overrides the steady burning front stop lamp, there would be no confusion as to signal message. Therefore, in our opinion, Federal law permits use of your front stop lamp system.

Your second system does not operate through existing vehicle lamps but consists of additional lamps mounted in the wheel wells. These lamps would appear not to have the potential of confusion since they supplement existing lamps and operate in conjunction with them to convey the same message. Thus, Federal law, in our view, does not preclude use of your second system either.

However, even if a supplementary lighting system is permissible under Federal law, it is subject to regulation by any State in which it is operated. We are not able to advise you with respect to State law, and suggest that you write for an opinion to the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203.

Sincerely,

John Womack Acting Chief Counsel ref:108#VSA d:6/29/94

ID: nht67-1.33

DATE: 03/18/67

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Petroleum Equipment Institute

TITLE: FMVSR INTERPRETATION

TEXT: The General Counsel of the Department of Transportation has asked that(Illegible Word) further to your letter of February 13, 1968 to the Department of Transportation.

Enclosed in a copy of the National Traffic and Motor Vehicle Safety Act of 1966, published Federal Motor Vehicle Safety Standards and a regulation and ruling issued December 29, 1967 pertaining to "chassis-cabs" and persons who combine "chassis-cabs" with motor vehicle bodies or other like structures.

Based on the limited information given in your letter it appears that members of your organization who affix a task to a chassis-cab, as defined in(Illegible Word) 5.3(b), will be responsible for "(1) compliance of the combined assemblage with. . .standards in effect in the date of(Illegible Word) of the chassis-cab. . .not already. . .certified to by the chassis-cab manufacturer, and (2) compliance with all applicable standards in effect on the date of manufacture of the chassis-cab to the extent that the addition of a body or other structure to the chassis-cab affects the chassis-cabs previous conformance with applicable standards."

As to the certification requirement, which is set forth in section 114 of the National Traffic and Motor Vehicle Safety Act of 1966 (copy enclosed) and amplified by a notice issued October 31, 1967, ((Illegible Words) than requirement as it relates to your organization members would be limited to a situation where your members combine a chassis-cab which has not been certified to be in conformance with Standard 108 with a body or other like structure and sells the combined assemblage to a distributor or dealer. In this case certification of compliance with the lighting standard (Standard No. 108) would be mandatory.

The Petroleum Equipment Institute(Illegible Word) will be added to the Federal Highway Administrator's Office of Public Affairs mailing list and it will(Illegible Words) published rulings and regulations relating to traffic safety. Additionally, enclosed is a copy of present regulations and rulings published to date.

I hope this letter adequately answers the question you raise.

ID: 3165yy

Mr. Ken Hanna
Lectric Limited, Inc.
7322 S. Archer Road
Justice, Illinois 60458

Dear Mr. Hanna:

This responds to your letter of July 8, 1991, to Richard Van Iderstine of this agency. You asked whether a proposed manufacturing and marketing scheme would be in violation of any NHTSA regulations.

You intend to petition for rulemaking to amend Standard No. l08 to reinstate SAE Standard J579a as an optional standard for sealed beam headlamps. These lamps would be used on "antique cars." Until SAE J579a is reinstated, you would like to manufacture headlamps to conform to SAE J579c, the current specification for sealed beam headlamps that is incorporated into Standard No. 108. However, you do not wish to mark the lenses with the identification nomenclature that SAE J579c requires (presumably because it was lacking from the J579a headlamps with which the antique cars were originally equipped). You ask if you may market these lamps with identification on the package stating that they are "for display purposes only and not approved for highway use."

Your letter clearly indicates that the purpose of manufacturing the sealed beam headlamps is for their installation on motor vehicles, albeit old ones, and not for "display purposes only." The headlamps are motor vehicle equipment, and must comply with all applicable Federal motor vehicle safety standards, in this instance, SAE J579c. Partial compliance with the requirements is not permissible, and the lenses of headlamps manufactured to conform with SAE J579c must be marked as that standard requires. Thus, your suggested manufacturing and marketing scheme would not conform to Standard No. l08, and, if pursued, it would be a violation of the National Traffic and Motor Vehicle Safety Act.

The manufacture and sale of noncomplying motor vehicle equipment is a violation of the for which a civil penalty of up to $1,000 per violation may be imposed, up to a total of $800,000 for any related series of violations. In addition, as the manufacturer of the equipment, Lectric Limited must certify them as meeting all applicable Federal motor vehicle safety standards, and similar penalties may be imposed for certification that is false and misleading in a material respect. Finally, the manufacturer of nonconforming equipment is required to notify and remedy in accordance with the requirements of the Act.

Because SAE J579a and 579c headlamps are identical in external appearance except for lens marking, we do not believe that authenticity of the appearance of older vehicles will be affected to any discernable degree by requiring that their lenses be marked as the contemporary standard requires.

Sincerely,

Paul Jackson Rice Chief Counsel

Ref.# Std. 108 D. 7/29/91

ID: 3108yy

Mr. Ken Hanna
Lectric Limited, Inc.
7322 S. Archer Road
Justice, Illinois 60458

Dear Mr. Hanna:

This responds to your letter of July 8, 1991, to Richard Van Iderstine of this agency. You asked whether a proposed manufacturing and marketing scheme would be in violation of any NHTSA regulations.

You intend to petition for rulemaking to amend Standard No. l08 to reinstate SAE Standard J579a as an optional standard for sealed beam headlamps. These lamps would be used on "antique cars." Until SAE J579a is reinstated, you would like to manufacture headlamps to conform to SAE J579c, the current specification for sealed beam headlamps that is incorporated into Standard No. 108. However, you do not wish to mark the lenses with the identification nomenclature that SAE J579c requires (presumably because it was lacking from the J579a headlamps with which the antique cars were originally equipped). You ask if you may market these lamps with identification on the package stating that they are "for display purposes only and not approved for highway use."

Your letter clearly indicates that the purpose of manufacturing the sealed beam headlamps is for their installation on motor vehicles, albeit old ones, and not for "display purposes only." The headlamps are motor vehicle equipment, and must comply with all applicable Federal motor vehicle safety standards, in this instance, SAE J579c. Partial compliance with the requirements is not permissible, and the lenses of headlamps manufactured to conform with SAE J579c must be marked as that standard requires. Thus, your suggested manufacturing and marketing scheme would not conform to Standard No. l08, and, if pursued, it would be a violation of the National Traffic and Motor Vehicle Safety Act.

The manufacture and sale of noncomplying motor vehicle equipment is a violation of the for which a civil penalty of up to $1,000 per violation may be imposed, up to a total of $800,000 for any related series of violations. In addition, as the manufacturer of the equipment, Lectric Limited must certify them as meeting all applicable Federal motor vehicle safety standards, and similar penalties may be imposed for certification that is false and misleading in a material respect. Finally, the manufacturer of nonconforming equipment is required to notify and remedy in accordance with the requirements of the Act.

Because SAE J579a and 579c headlamps are identical in external appearance except for lens marking, we do not believe that authenticity of the appearance of older vehicles will be affected to any discernable degree by requiring that their lenses be marked as the contemporary standard requires.

Sincerely,

Paul Jackson Rice Chief Counsel

Ref.# Std. 108 D. 7/29/91

ID: 3111yy

Mr. Ken Hanna
Lectric Limited, Inc.
7322 S. Archer Road
Justice, Illinois 60458

Dear Mr. Hanna:

This responds to your letter of July 8, 1991, to Richard Van Iderstine of this agency. You asked whether a proposed manufacturing and marketing scheme would be in violation of any NHTSA regulations.

You intend to petition for rulemaking to amend Standard No. l08 to reinstate SAE Standard J579a as an optional standard for sealed beam headlamps. These lamps would be used on "antique cars." Until SAE J579a is reinstated, you would like to manufacture headlamps to conform to SAE J579c, the current specification for sealed beam headlamps that is incorporated into Standard No. 108. However, you do not wish to mark the lenses with the identification nomenclature that SAE J579c requires (presumably because it was lacking from the J579a headlamps with which the antique cars were originally equipped). You ask if you may market these lamps with identification on the package stating that they are "for display purposes only and not approved for highway use."

Your letter clearly indicates that the purpose of manufacturing the sealed beam headlamps is for their installation on motor vehicles, albeit old ones, and not for "display purposes only." The headlamps are motor vehicle equipment, and must comply with all applicable Federal motor vehicle safety standards, in this instance, SAE J579c. Partial compliance with the requirements is not permissible, and the lenses of headlamps manufactured to conform with SAE J579c must be marked as that standard requires. Thus, your suggested manufacturing and marketing scheme would not conform to Standard No. l08, and, if pursued, it would be a violation of the National Traffic and Motor Vehicle Safety Act.

The manufacture and sale of noncomplying motor vehicle equipment is a violation of the for which a civil penalty of up to $1,000 per violation may be imposed, up to a total of $800,000 for any related series of violations. In addition, as the manufacturer of the equipment, Lectric Limited must certify them as meeting all applicable Federal motor vehicle safety standards, and similar penalties may be imposed for certification that is false and misleading in a material respect. Finally, the manufacturer of nonconforming equipment is required to notify and remedy in accordance with the requirements of the Act.

Because SAE J579a and 579c headlamps are identical in external appearance except for lens marking, we do not believe that authenticity of the appearance of older vehicles will be affected to any discernable degree by requiring that their lenses be marked as the contemporary standard requires.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:l08 d:7/29/9l

ID: nht91-5.6

DATE: July 29, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Ken Hanna -- Lectric Limited, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7-8-91 from Ken Hanna to Richard Van Iderstine (OCC 6238)

TEXT:

This responds to your letter of July 8, 1991, to Richard Van Iderstine of this agency. You asked whether a proposed manufacturing and marketing scheme would be in violation of any NHTSA regulations.

You intend to petition for rulemaking to amend Standard No. 108 to reinstate SAE Standard J579a as an optional standard for sealed beam headlamps. These lamps would be used on "antique cars." Until SAE J579a is reinstated, you would like to manufacture headlamps to conform to SAE J579c, the current specification for sealed beam headlamps that is incorporated into Standard No. 108. However, you do not wish to mark the lenses with the identification nomenclature that SAE J579c requires (presumably because it was lacking from the J579a headlamps with which the antique cars were originally equipped). You ask if you may market these lamps with identification on the package stating that they are "for display purposes only and not approved for highway use."

Your letter clearly indicates that the purpose of manufacturing the sealed beam headlamps is for their installation on motor vehicles, albeit old ones, and not for "display purposes only." The headlamps are motor vehicle equipment, and must comply with all applicable Federal motor vehicle safety standards, in this instance, SAE J579c. Partial compliance with the requirements is not permissible, and the lenses of headlamps manufactured to conform with SAE J579c must be marked as that standard requires. Thus, your suggested manufacturing and marketing scheme would not conform to Standard No. 108, and, if pursued, it would be a violation of the National Traffic and Motor Vehicle Safety Act.

The manufacture and sale of noncomplying motor vehicle equipment is a violation of the for which a civil penalty of up to $1,000 per violation may be imposed, up to a total of $800,000 for any related series of violations. In addition, as the manufacturer of the equipment, Lectric Limited must certify them as meeting all applicable Federal motor vehicle safety standards, and similar penalties may be imposed for certification tht is false and misleading in a material respect. Finally, the manufacturer of nonconforming equipment is required to notify and remedy in accordance with the requirements of the Act.

Because SAE J579a and 579c headlamps are identical in external appearance except for lens marking, we do not believe that authenticity of the appearance of older vehicles will be affected to any discernable degree by requiring that their lenses be marked as the contemporary standard requires.

ID: nht78-1.31

DATE: 10/19/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Colorado Department of Education

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your September 22, 1978, letter asking whether the Federal government has any school bus safety standards that would prevent the State of Colorado from regulating in two areas.

A State is not permitted to have any regulation concerning an area of safety regulated by the Federal government unless the State regulation is identical to the Federal standard or imposes a higher standard of care than the Federal regulation and applies only to vehicles purchased for use by the State. With respect to the body diagonal strength test proposed in your letter, the agency does not regulate that aspect of performance. Therefore, the State of Colorado is permitted to regulate this aspect as long as its regulation does not conflict with any Federal standard.

Your second proposal would define "activity bus" in a manner that would except it from State requirements for lighting and color but would continue to require it to be constructed in accordance with the Federal school bus safety standards. Highway Safety Program Standard No. 17 formerly granted activity buses the option of meeting all of the color and marking requirements for school buses or none of those requirements. That standard has been changed with respect to this option. All activity buses manufactured after April 1, 1978, must comply with all of the requirements applicable to school buses including the color and lighting requirements. Therefore, it is the opinion of the agency that your proposed definition of activity bus would conflict with Standard No. 17.

SINCERELY,

COLORADO DEPARTMENT OF EDUCATION

September 22, 1978

Roger Tilton National Highway Traffic Safety Administration

Dear Sir:

The State Board of Education in Colorado is considering revision of current standards governing school bus construction.

Two matters have been raised which are connected with current Federal Motor Vehicle Safety Standards. They are:

1. Colorado prescribes a diagonal strength test for school bus bodies (sometimes referred to as a "racking load test"). Are there any federal standards which would preclude such a test being required in Colorado?

2. Current Colorado standards define an "Activity Bus" as a vehicle meeting Type II construction standards except for color, alternating flashing signals and stop-arm. Is such a definition acceptable under current federal standards?

The Board will begin reconsideration of these matters at the November 9 meeting. The information needs to be distributed to them as of October 20. I realize that this time frame is constricted; if you could forward some preliminary information by the October 20 date, it would be most helpful.

Thank you for your consideration.

Neal McCormick Consultant School Transportation

ID: 1985-02.48

TYPE: INTERPRETATION-NHTSA

DATE: 06/24/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Pat Reese -- Mannesmann Pipe and Steel Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

June 24, 1985 Mr. Pat Reese Mannesmann Pipe & Steel Corp. 1900 Post Oak Blvd., 18th Floor Houston, TX 77056

This responds to your letter to Steve Kratzke of my staff, asking for an interpretation of the requirements of Standard No. 120, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars (49 CFR 571.120). Specifically, you indicated you were writing on behalf of Mannesmann Kronprinz, a German branch of your company which manufactures wheels. You noted that section S5.2(d) of Standard No. 120 requires rims for use on motor vehicles other than passenger cars to be marked with the name, trademark or symbol identifying the rim manufacturer, and asked if this requirement meant that the German branch of your company had to register its logo or trademark with this agency. Standard No. 120 does not require manufacturers to register trademarks whose vehicles or items of motor vehicle equipment are imported into the United States to file a designation of agent with NHTSA, and this designation must include a listing of the marks, trade names or other designations of origin used by the manufacturer on its products. A check of our files shows that no such designation has ever been filed by Mannesmann Kronprinz. Section S5.2 of Standard No. 120 sets forth the rim marking requirements applicable to all rims for use on motor vehicles other than passenger cars. One of the items of information required to be marked on such rims is "a designation that identifies tha manufacturer of the rim by name, trademark, or symbol;" S5.2(d). This information allows the agency and the public to identify the manufacturer of the rim if there is some problem with it. The use of a trademark or symbol is allowed, instead of the manufacturer's name, because the agency can easily determine the identity of the manufacturer from the trademark or symbols would be registered with the United States Patent and Trademark Office. In the case of foreign manufacturers, 49 CFR 551.45 requires them to file a designation of agent with this agency. One of the items of information required to be included in the designation agent is a listing of the marks, trade names, or other designations of origin" which appear on any of the manufacturer's products in lieu of its legal name. Both 49 CFR 551.45 and 15 U.S.C. 1399(e) require all foreign manufacturers to file a designation of agent with NHTSA before importing motor vehicles or items of motor vehicle equipment, including wheels, into the United States. I have enclosed copies of the regulation and the statute for your reference. As you will see Part 551 specifies that the designation of agent must contain the following six items of information: 1. A certification that the designation is valid in form and binding on Mannesmann Kronprinz under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made; 2. The full legal name, principal place of business and mailing address for Mannesmann Kronprinz; 3. Marks, trade names, or other designations of origin for any of Mannesmann Kronprinz's products which do not bear its name; 4. A statement that the designation shall remain in effect until withdrawn or replaced by Mannesmann Kronprinz; 5. A declaration of acceptance duly signed by the agent appointed by Mannesmann Kronprinz, and the agent may be an individual, firm, or U.S. corporation; and 6. The full legal name and address of the designated agent. Further, 49 Cfr Part 566, Manufacturer Identification (copy enclosed) requires manufacturers of motor vehicle equipment covered by our standards to provide certain information to NHTSA. The required information is simply the manufacturer's full name, address, and a brief description of the motor vehicle equipment it manufactures. Should you have any further questions in this area, please contact Mr. Kratzke at this address or by telephone at (202) 426-2992. Sincerely, Original Signed By Jeffrey R. Miller Chief Counsel Enclosures

ID: nht74-4.20

DATE: 07/17/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Imperial-Eastman Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your June 24, 1974, questions whether brake hose manufactured before September 1, 1974, to comply with all performance requirements of Standard 106-74, Brake hoses, may be marked with the DOT symbol after that date, and whether the DOT may be used on hose, fittings, and assemblies prior to that date.

The answer to your questions is no. The DOT symbol means that a vehicle or item of motor vehicle equipment was manufactured in compliance with a Federal motor vehicle safety standard and that it complies with the standard. Therefore, the DOT symbol can not be placed on hose, fitting, or assemblies manufactured before the date the standard becomes applicable to them, whether or not the DOT is actually placed on the hose before or after the effective date.

With regard to your supply of pre-106 vacuum hose, it may be used in assemblies as late as February 28, 1975, and in vehicles as late as August 31, 1975, if it is only clamped to the vehicle and not made into assemblies.

Yours Truly,

Imperial-Eastman Corporation

June 24, 1974

Legal Department National Highway Traffic Safety Administration

Attention: T. W. Herlihy

At the present time, Imperial-Eastman has a large quantity (about a two year supply) of 5/8 I. D. SAE J1403 Vacuum Brake Hose in inventory and it is evident this hose will not be sold before the DOT-106 goes into effect on September 1, 1974 or later. Our customers are already changing drawings and all new purchase orders call for brake hose that meets FMVSS 106.

It is impossible for any hose assembly supplier to sell unmarked hose up to the day 106 goes into effect and then switch to hose with the DOT layline without having a lot of old hose left over.

For this reason, it is imperative we get answers to the following questions as soon as possible.

1. Is it permissible for us to return the J1403 brake hose to the manufacturer and have it DOT branded? This hose meets all FMVSS 106 requirements and it would be marked with the original date of manufacture (Jan. 1972).

2. Is it permissible to purchase, couple and sell DOT hose and assemblies prior to the date 106 becomes effective? This is the only way we can balance our hose inventories and use up unbranded hose.

If it would be more convenient and less time consuming to discuss the above, please don't hesitate to call me collect.

M. A. Chermak