ID: 86-3.12

TYPE: INTERPRETATION-NHTSA

DATE: 05/02/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Sidney K. Saksenberg -- Manager of Regulatory Affairs, CSA Limited, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Sidney R. Saksenberg Manager of Regulatory Affairs CSA Limited, Inc. P.O. Box 690347 Houston, Texas 77269-0347

This responds to your November 12 1985 letter to NHTSA's Office of Vehicle Safety Compliance concerning the packaging requirements of Federal Motor Vehicle Safety Standard No. 116 Brake Fluid . You asked whether the brake fluid container 'you enclosed would comply with the standard. Your letter has been referred to my office for reply.

By way of background information, I must explain that NHTSA does not pass approval on the compliance of any vehicle or equipment with a safety standard before the actual events that underlie certification. Under the National Traffic and Motor Vehicle Safety Act, it is your responsibility as a manufacturer to determine whether your products comply with all applicable safety standards and regulations, and to certify your products in accordance with that determination. Therefore, the following interpretation only represents the agency's opinion based on your letter and enclosure.

The sample container you enclosed is plastic and has a resealable screw cap. The cap is attached to a plastic band, or ring, encircling the opening of the container, and the attachment is broken when the cap is twisted open. The cap itself is lined with an inner seal which you have indicated is impervious to the packaged brake fluid.

Standard No. 116 specifies performance and labeling requirements for motor vehicle brake fluids and their containers. Paragraph S5.2.1 of the standard sets forth specific requirements for container sealing of brake fluid packages:

Each brake fluid or hydraulic system mineral oil container with a capacity of 6 fluid ounces or more shall be provided with a resealable closure that has an inner seal impervious to the packaged brake fluid. The container closure shall include a tamper-proof feature that will either be destroyed or substantially altered when the container closure is initially opened.

The container you enclosed appears to be provided with a resealable closure, i.e., the twist-off cap, and an impervious inner seal. The cap's tamper-proof feature is the attachment to the plastic ring that would be broken (and thus "destroyed or substantially altered") when the cap is initially opened. Although not required by the standard, you have taken the commendable extra step of including a statement on the cap that warns purchasers not to accept the container if the seal is broken, we would suggest that you ensure that the warning is clearly legible.

Sincerely,

Erika Z. Jones Chief Counsel

November 12, 1985

To: John Messera (NES-32) Nat. Hwy. Safety Adm. 400 7th St., SW Washington, DC 20590

Dear Mr. Messera:

With reference to our recent phone conversation:

Enclosed find several bottles and caps we would like to use to package DOT-3 Brake Fluid.

I would like an opinion as to the acceptability of these bottles and caps for packaging DOT-3 Brake Fluid.

Sincerely yours,

Sidney K. Saksenberg Manager of Regulatory Affairs Enc.

SKS/rdc

ID: 86-1.47

TYPE: INTERPRETATION-NHTSA

DATE: 02/26/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Kevin Rossman

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Kevin Rossman Vice president - Sales & Marketing The Highland Group 9300 Midwest Avenue Garfield Heights, Ohio 44125

Dear Mr. Rossman:

This is in reply to your letter of January 13, 1986, to the former chief counsel of this agency, Jeffrey R. Miller, in which you ask whether a deck-mounted luggage rack loaded with luggage is a noncompliance with Federal Motor Vehicle Safety Standard No. 108.

The answer is no. Compliance with Standard No. 108 is determined independent of whether the luggage rack is loaded. However, if the rack is installed before sale of the vehicle to its first purchaser, or if it is installed after sale by a person other than the vehicle owner, care must be taken to insure that the photometric and visibility requirements of the standard for center high-mounted stop lamps continue to be met with the unloaded rack in place.

I hope that this answers your question.

Sincerely,

Erika Z. Jones Chief Counsel

January 13, 1986

Mr. Jeffrey R. Miller Chief Counsel US Department of Transportation 400 Seventh Street S.W. Washington, Washington D.C. 20590

Dear Mr. Miller:

The Highland Group is a US Manufacturer of Passenger Car Rear Deck Luggage Racks.

It has been rumored in the field that a deck - mounted luggage rack loaded with luggage may cause a violation of the center high-mounted stop lamp provisions of Motor Vehicle Safety Standard Number #108.

To alleviate potential problem in the field, any input you could provide in this matter would be greatly appreciated.

Sincerely,

THE HIGHLAND GROUP, INC.

Kevin Rossman Vice President - Sales & Marketing

KR/nc

ID: nht94-3.66

TYPE: INTERPRETATION-NHTSA

DATE: July 13, 1994

FROM: Dietmar K. Haenchen -- Manager, Vehicle Regulations, Volkswagen Of America, Inc.

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: Request for Interpretation relating to 49 CFR Parts 541 and 543, Theft Prevention Standard (Parts Marking Requirements for Replacement Parts)

ATTACHMT: ATTACHED TO 2/17/95 LETTER FROM PHILIP R. RECHT TO DIETMAR K. HAENCHEN (A43; PART 543; PART 541)

TEXT: Thank you for your quick response to our request for interpretation dated 17 May 1994 relating to the marking requirements for replacement parts. This letter presents a follow-up question to the interpretation you gave us relative to the Volkswagen Corr ado carline.

Your interpretation concluded that because the Corrado will not be offered for sale in the United States as a 1995 model year carline (the model year for which the exemption from parts marking on the basis of an approved anti-theft device was granted), t he replacement parts for the 1994 model year and prior years would continue to have to be marked. This was because "no Corrados sold in the U.S. will be equipped with the approved anti-theft device".

However, the fact is that all 1994 model year Corrados were sold in the U.S. with the standard anti-theft device that was approved for the 1995 model year exemption. (The 1994 model year Corrado was parts marked in addition to being equipped with a stan dard anti-theft device.)

Volkswagen could not apply for an anti-theft system exemption for the 1994 model year Corrado because only two exemptions are allowed per model year. For 1994, Volkswagen chose to exempt the Jetta III and the Volkswagen Cabrio carlines.

Volkswagen believes that marking of replacement parts for the Corrado carline can be terminated because the 1994 model year Corrado carline was equipped with a standard anti-theft device that was approved for exemption so that the requirement that Corrad o vehicles be sold in the United States with the approved anti-theft device was, in fact, met. Your interpretation on this issue is requested.

Thank you for your consideration and we look forward to your early response.

ID: nht93-4.29

DATE: June 9, 1993

FROM: William D. McIntosh -- Quality Assurance Manager, Perstorp Components

TO: Chief Council, NHTSA (via John Messera)

TITLE: None

ATTACHMT: Attached to letter dated 4/1/94 from John Womack to William D. McIntosh (42; STD. 302)

TEXT:

This letter is a request for a clarification on FMVSS 302 on an acoustical application in motor vehicles. Reference to the following typical diagram will be made throughout the text.

GRAPHICS OMITTED - SEE ORIGINAL

The composite assembly is an acoustical abatement product that is installed with layer C against vehicle sheet metal inside passenger vehicles. Layer B is always covering and adhering to layer C. The material is not visible to the occupants of the vehicle. It could be covered with carpet, trim, instrument panel etc. It resembles the B and C layers diagrammed in FMVSS 302.

Typical Flammability Results

Layer B SE Full Composite SE to B50 C Sliced at 1/2" SE/NBR to B200 - very dependant on cut quality.

- burning is restricted to C.

We recognize that FMVSS 302 says that test samples are to be cut to 1/2" thickness in preparation to perform the test. The standard goes on to say that the requirement concerning the transmission of a flame front shall not apply to a surface created by the cutting of a test specimen for the purposes of testing. Throughout the development of this product we have worked closely with our automotive customers to ensure that the installed product meets the 101 mm/min propagation criteria of the standard.

I have had discussions with two independent testing labs as well as Mr. John Messera of NHTSA. They agree that we appear to be meeting the spirit of the standard but we received varying comments on how to certify our material to the standard.

Mr. John Messera suggested that we put this question to the NHTSA legal department in the form of a request for a ruling. This letter is a request for such a ruling.

In subsequent conversation with John Messera, he indicated that our product was not listed in S4.1 of FMVSS 302 and as such was not covered by the standard.

If a previous ruling has been made to that effect I would like a copy of that as well.

ID: nht92-2.12

DATE: 11/20/92 EST

FROM: PAUL JACKSON RICE -- CHIEF COUNSEL, NHTSA

TO: RON NOIRFALISE -- DIRECTOR OF PUPIL TRANSPORTATION, MISSOURI DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION

TEXT: This follows up your telephone conversation of November 10, 1992, with Walter Myers of my staff regarding a newly-effective statute in Missouri which revises state requirements on transportation of school children. You also stated that you were told by your counterpart in the State of Washington that Federal law prohibits transportation of school children in vehicles with a passenger capacity of less than ten people.

As discussed in your telephone conversation with Mr. Myers, I have enclosed four recent letters explaining Federal law and pertinent regulations applicable to school buses and transportation of school children. These four are a November 3, 1992 letter to Mr. G. Thomas Owens, a July 7, 1992 letter to Senator Jim Sasser, a May 27, 1992 letter to Mr. Gerald A. Guertain, and a January 15, 1991 letter to Ms. Carol C. Verenea. These letters cover a variety of issues that, I think, will clarify your understanding of the issues with which you are concerned. Also enclosed is a copy of a pamphlet issued by this agency entitled Federal Motor Vehicle Safety Standards and Regulations, revised June 1989, and an information sheet issued by this agency entitled Where to Obtain NHTSA's Safety Standards and Regulations.

In addition, I am enclosing for your information a copy of Highway Safety Program Guideline No. 17, Pupil Transportation Safety. This publication was issued under the authority of the Highway Safety Act of 1966 which authorizes this agency to issue nonbinding guidelines that states may refer to in developing their highway safety programs. Guideline 17 was jointly issued by this agency and the Federal Highway Administration to provide recommendations to the states on various operational aspects of their school bus and pupil transportation safety programs. Among other things, Guideline 17 recommends that any vehicle designed to carry more than ten persons which is used as a school bus comply with all safety standards applicable to school buses at the time the vehicle was manufactured.

I hope the enclosed information will be of assistance to you. If you have any further questions, feel free to contact Mr. Myers at this address or at (202) 366-1992.

ID: 19844.ztv

Mr. Glenn Panes
921 Todville Road
Seabrook, TX 77586

Dear Mr. Panes:

This is in reply to your e-mail of April 7, 1999.

You are interested in buying an aftermarket combination stop/turn signal lamp which has a clear lens and red and amber bulbs. You ask whether the lamps are legal to use. Apparently your local police do not object, but you are concerned about being stopped somewhere else.

The answer to your question depends on a number of factual issues, as well as the laws of local and state jurisdictions. Therefore, this is not a question we can fully answer for you.

We establish the Federal motor vehicle safety standards that apply to new motor vehicles and vehicle equipment from the time of manufacture until time of first sale. One of these, Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment specifies the lighting equipment a vehicle must have when manufactured, and the performance of this original equipment and the aftermarket equipment intended to replace it. We can tell you how this standard relates to the aftermarket lamp you describe.

Aftermarket replacement equipment is required to comply with Federal new-equipment requirements, and be certified as complying. We are unable to tell whether the combination stop/turn signal lamp you describe complies but would like to make a few comments on it. Under Standard No. 108, a turn signal lamp is permitted to emit amber light. The amber light may be provided by either an amber lens and clear bulb, or an amber bulb and a clear lens. The question, then, is whether the turn signal lamp meets Standard No. 108's photometric specifications.

Standard No. 108 has incorporated by reference the Society of Automotive Engineers (SAE) specifications for amber turn signal lamps.

SAE specifications for stop lamps are also incorporated by reference in Standard No. 108. These specifications require the use of special bulbs for testing purposes. However, SAE has no specifications for red bulbs. Thus, it may not be possible for manufacturers to certify that a lamp meets all applicable Federal motor vehicle safety standards. Nevertheless, if the manufacturer has marked the replacement lamp with a "DOT" symbol (or certified its conformance on its container), you may regard that as its representation that the lamp meets all applicable Federal requirements.

This certification, however, does not mean that the original equipment lamp can be removed and the new, different one substituted without causing a noncompliance with Standard No. 108. The standard requires vehicles to have two red reflex reflectors on their rear, and one on each side at the rear. In many instances, these reflectors are incorporated into red rear combination lamp lenses. Thus, depending on the location of red reflex reflectors on the side and rear of the car, substitution of a white-lensed stop lamp might remove this desirable safety feature.

Even if the lamp were certified as complying, if installation of the lamp you are interested in would result in removal of the only reflex reflectors on the side and/or rear, there would be a violation of Federal law if this work was performed by a manufacturer, distributor, dealer, or motor vehicle repair business, and if the modifier did not add two reflex reflectors to the rear of the car. However, this prohibition does not apply to you, if you, the vehicle's owner, substitutes the lamp. Nevertheless, it is possible that you could be cited somewhere for a violation of local laws if the vehicle lacks rear reflex reflectors. As a general rule, we urge caution in replacing any lighting equipment with novelty items.

Some new motor vehicles may be equipped with original equipment rear combination lamps that have clear lenses, but the red color of the light emanating from these lamps is produced by a clear bulb projecting through a red inner plastic lens. Such lamps do not use red bulbs and are certified as complying.

If you have any further questions, you can contact Taylor Vinson of this Office, either by phone (202-366-5263), or by e-mail (Tvinson@nhtsa.dot.gov).

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:108
d.6/14/99

ID: 22040.drn

Mr. Robert Pitre
Nelson Technologies
200 E. Chestnut St. #1414
Chicago, Il 60611





Dear Mr. Pitre:

This responds to your letter asking about the applicability of Federal requirements to the windshield wiper blades that your company is developing. I am pleased to provide the information you requested.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) is authorized to issue Federal motor vehicle safety standards (FMVSSs) for new motor vehicles and new items of motor vehicle equipment. (The standards are codified at Volume 49 of the Code of Federal Regulations, Part 571.) This agency does not provide approvals of motor vehicles or motor vehicle equipment. Instead, manufacturers are required to certify that their vehicles and equipment meet applicable standards. Also, it is unlawful for dealers to sell motor vehicles or motor vehicle equipment that do not meet applicable standards.

Vehicle manufacturers wishing to install your windshield wiper blades in a new vehicle (before first sale of the vehicle to the customer) would be required to certify that their vehicles meet all applicable safety standards with the device installed. An FMVSS that might be relevant to the blades is Standard No. 104, Windshield Wiping and Washing Systems, which specifies a number of requirements for windshield wiping and washing systems. A vehicle manufacturer would need to ensure that if a vehicle had your windshield wiper blades, the vehicle's windshield wiping and washing system met all the requirements of Standard No.104.

No standards would apply to your windshield wiper blades to the extent they are sold as aftermarket equipment. However, Federal law prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from "making inoperative" a vehicle's compliance with any safety standard (Title 49 of the U.S. Code, section 30122). The blades could not be installed by such businesses if the installation adversely affected a vehicle's compliance with any safety standard.

The "make inoperative" provision does not apply to modifications made by owners to their own vehicles. However, NHTSA encourages vehicle owners not to degrade the safety of their vehicles. Also, individual States have authority to regulate modifications that a vehicle owner may make to his or her vehicle. We are not able to provide you with information on State laws. You should contact the individual States in which you intend to sell your product.

A source of information about State laws is the Automotive Manufacturers Equipment Compliance Agency, Inc. (AMECA), 1101 15^th St., N.W., Suite 607, Washington, DC 20005. Their telephone number is: (202) 898-0145, and their FAX number is: (202) 898-0148. The AMECA is a centralized voluntary agency that notifies government, industry and the public about items of motor vehicle safety equipment that have been tested by various laboratories in accordance with United States industry, state and federal standards.

Finally, the windshield wiper blades are considered to be "motor vehicle equipment" under Federal law. This means that you or whoever manufactures your blades would be subject to 49 U.S.C. sections 30118-30121 concerning the recall and remedy of products with defects related to motor vehicle safety. If the manufacturer or NHTSA determined 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.

I hope this information is helpful. If you have any further questions, please contact Ms. Dorothy Nakama this address or at (202) 366-2992.





Sincerely,

Frank Seales, Jr.
Chief Counsel

ref:104#VSA
d.1/5/00

ID: nht80-3.43

DATE: 08/29/80

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood; NHTSA

TO: Columbia Manufacturing Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 17, 1980, and in confirmation of your several telephone conversations with Mr. Schwartz of my office.

In your letter, you asked whether the vehicle identification number (VIN) required by Federal Motor Vehicle Safety Standard No. 115 (49 CFR 571.115) must reflect each of your 16 moped "models" if the differences between the models are cosmetic. Table 1 of S4.5.2 requires that the following information be encoded in the VIN of motorcycles: Type of motorcycle, line, engine type, and net brake horsepower. The encoding of models is not required. "Line" is defined in S3. Definitions to mean a name which a manufacturer applies to a family of vehicles within a make which have a degree of commonality in construction, such as body, chassis or cab type. Therefore, if the 16 moped "models" are of the same construction, they would not be considered different lines unless Columbia chose to designate them as different lines.

You have also stated that Columbia has changed its moped motor manufacturer and has made minor modifications in its open frame moped. You wish to know if this must be reflected in the VIN. The VIN standard for mopeds does not take effect until September 1, 1980, for vehicles whose model year changeover date occurs prior to September 1, 1980, and subsequent to January 1, 1981, and until the actual model year changeover date for vehicles whose model year changeover date falls between these two dates. Therefore, any changes Columbia has made prior to the effective date of the standard would presumably already be reflected in the VIN.

The National Highway Traffic Safety Administration does not give advance approval of a manufacturer's compliance with motor vehicle safety standards or regulations, as it is the manufacturer's responsibility under the National Traffic and Motor Vehicle Safety Act to ensure that its vehicles comply with the applicable safety standards. However, my office has reviewed your proposed labels as forwarded with your letter. Based on our understanding of the information which you have provided, your labeling system apparently complies with Standard No. 115.

Sincerely,

ATTACH.

June 17, 1980

Fred Schwartz -- Department of Transportation, N.H.T.S.A.

Dear Mr. Schwartz,

We have 16 moped models. Most of these models are different cosmetically. Is it necessary to have these models reflect in our V.I.N. number?

We also changed our motor manufacturer and have minor changes in our open frame moped. Is it also necessary for this to reflect in our V.I.N. number?

I would appreciate your approval on our enclosed sample and your answers to the above questions by June 27, 1980.

Sincerely,

David R. Stevens -- Quality Control Manager

enc.

1CEMT0156AC000001 1CEMT0158AC000002 1CEMT015XAC000003 JULY 1980 JULY 1980 JULY 1980 1CEMT0151AC000004 1CEMT0153AC000005 1CEMT0155AC000006 JULY 1980 JULY 1980 JULY 1980 1CEMT0(Illeg.)0000007 1CEMT0159AC000008 1CEMT0150AC000009 JULY 1980 JULY 1980 JULY 1980 1CEMT0157AC0000010 1CEMT0159AC000011 1CEMT0150AC000012 JULY 1980 JULY 1980 JULY 1980 1CEMT0152AC000013 1CEMT0154AC000014 1CEMT0156AC000015 JULY 1980 JULY 1980 JULY 1980 1CEMT0158AC000016 1CEMT015XAC000017 1CEMT0151AC000018 JULY 1980 JULY 1980 JULY 1980 1CEMT0153AC000019 1CEMT015XAC000020 1CEMT0151AC000021 JULY 1980 JULY 1980 JULY 1980 1CEMT0153AC000022 1CEMT0155AC000023 1CEMT0157AC000024 JULY 1980 JULY 1980 JULY 1980 1CEMT0159AC000025 1CEMT0150AC000026 1CEMT0152AC000027 JULY 1980 JULY 1980 JULY 1980 1CEMT0154AC000028 1CEMT0156AC000029 1CEMT0152AC000030 JULY 1980 JULY 1980 JULY 1980 1CEMT0154AC000031 1CEMT0156AC000032 1CEMT0158AC000033

MANUFACTURED BY COLUMBIA MFG. CO.

MOTOR DRIVEN CYCLE VEHICLE IDENTIFICATION NUMBER:

MANUFACTURED BY COLUMBIA MFG. CO.:

MOTOR DRIVEN CYCLE VEHICLE IDENTIFICATION NUMBER:

MANUFACTURED BY COLUMBIA MFG. CO.:

MOTOR DRIVEN CYCLE VEHICLE IDENTIFICATION NUMBER:

THIS MARGIN CONTROL PUNCHED

PAPER FOR THIS PLY IS

PRINTED IN INK UNLESS INDICATED BY BRACKETS

ID: nht93-5.30

TYPE: Interpretation-NHTSA

DATE: July 21, 1993

FROM: Charles Jennings

TO: Office of Chief Counsel, NHTSA

TITLE: Subject: Alternating Wavelength Lights (AWL)

ATTACHMT: Attached to letter dated 8/2/93 from John Womack to Charles Jennings (A41; Std. 108; VSA 108(a)(2)(A))

TEXT:

I have invented an electronic light conditioning device which connects to the already existing low-beam headlights, by just plugging it between the electrical sockets and the lights. To find out how this simple device works and why I developed it, please take a few minutes of your time to read the following letter.

As you know, there are more motor vehicles on our streets today than ever before, per-capita. Whereas i the past, a family would have one vehicle per household. Now, it is common to see one vehicle per family member, which in many cases is quite a few.

SAFETY MUST BE EMPHASIZED:

We are running out of safe driving space. This is space required between each vehicle for safe braking. Every time another vehicle is squeezed into this space. the potential for accidents increases proportionally.

SAFETY EQUIPMENT:

Since the development of the automatic windshield wiper, there have only been a few safety devices developed for the auto industry. Is it because there have been no incentives? Do people think that such ideas only come from the auto makers?

PEOPLE ARE DYING:

While the bureaucrats play politics and the auto makers morgue-file many such ideas, people are dying on our streets.

A simple idea like the "Rear Window Break Light was finally approved by the Department Of Transportation, and has proven to be very effective in preventing thousands of rear end collisions, not to mention the number of human lives, and tax dollars that have been saved.

A NEW INVENTION:

Another accident preventing invention has been developed and tested outside the auto industry, and that is the "Alternating Wavelength Low-Beam" headlight or Alternating Wavelength Light (AWL).

HOW THEY WORK:

Light modulations of less than 17 per second, alternating from one of the two existing, low-beam headlights to the other, and at the same time, changing wavelengths slightly, from one to the other (not flashing on and off), cause several things to occur. See the following statements.

WHEN AND HOW ARE THEY USED:

Daytime; People do not drive with their lights on in the daytime to help them see, but rather to be seen by other drivers.

Vehicles Equipped With AWL: attract the attention of other drivers to the smooth action of the alternating wavelength light, without distracting them, or drivers even realizing that the lights are alternating.

In Rainy Weather: When it is darker and visibility is low, the AWL seems to have an even greater effect in that it helps you see better, and it appears to arouse other peoples awareness. While coming toward you, on coming drivers usually think to turn on their low-beam headlights.

In Fog: As the AWL shortens the wavelength, (a) the glare decreases, thus increasing the visibility, and (b) You are noticed by other drivers.

At Night: As the AWL alternates the wavelengths from one low-beam to the other, this causes shadows to vibrate, thus making holes, poles, signs, and pedestrians more visible. Consequently, safety for all concerned is greatly increased. With AWL, the chance of not seeing a pedestrian in the darkness is very slim.

For about six months now, I have been driving both my 1992 Buick, and an Oldsmobile equipped with AWL. I have shown it to the Texas Department of Public Safety. They see potential, and they do not think it is illegal.

I have seen the results first hand. The effect that the AWL has on approaching drivers is mild and pleasing. They seem to see it more in their subconscious, possibly because the lights never actually turn off during alternation.

It would be good if vehicles who are in traffic a lot like busses, school busses, taxicabs, police vehicles, postal vehicles and trucks were equipped with AWL. After reading this letter, I would appreciate your opinion as soon as possible.

ID: nht69-1.43

DATE: 06/02/69

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Parsons Mobile Products Inc.

TITLE: FMVSR INTERPRETATION

TEXT: Thank you for your letter dated March 18, 1969, in which you state, "[We] differ from all other motor-home manufcturers in that we use an existing chassis body combination, which has already been certified by General Motors Corporation. Therefore, to the best of our knowledge, all certification and safety requirements are being cut or exceeded at this time."

Your letter and the materials that you enclosed with it indicate that you alter a completed vehicle in a way that affects components necessary for compliance with safety standards, and change the vehicle type from a truck to a multipurpose passenger vehicle within the meaning or regulations issued pursuant to the National Traffic and Motor Vehicle Safety Act (49 CFR @ 371.3). In as doing you the evidently acting as a manufacturer within the(Illegible word) of section 102(5) of the Act, and must comply with the Certification Regulations that apply to motor vehicle manufacturer (49 CFR Part 367. pp. 38-40 of the enclosed pamphlet). Copies of the Act and pertinent regulations are enclosed.

The information requested in our letter to you dated February 14, 1969, is still relevant. Could we please have your response to that inquiry as soon as possible.

We trust this reply will be of assistance to you in your desire to comply with existing Federal Motor Vehicle Safety Standards and regulations.