ID: nht81-2.23

DATE: 05/12/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Gateway Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 12 1981

NOA-30

Mr. John S. Miskowicz Gateway Industries, Inc. 17512 Carriage Way Drive Hazel Crest, Illinois 60429

Dear Mr. Miskowicz:

This responds to your letter of March 2, 1981, to Vladislav Radovich concerning Standard No. 213, Child Restraint Systems. Your letter was forwarded to this office for reply.

You asked whether a child restraint belt buckle must meet the buckle force release requirements when tested in an unloaded condition. As explained below, the answer is no. The buckle force requirements only apply to buckles tested in a loaded condition. In addition, you asked whether section 4.3(a) and 4.3(b) of Standard No. 209, Seat Belt Assemblies, are the only requirements of that standard which apply to buckles in child restraint systems. The answer is yes.

Section 5.4.3.5 of Standard No. 213 provides that each child restraint belt buckle, when tested in accordance with S6.2, must not release when a force of not more than 12 pounds is applied before the dynamic sled specified in S6.1 is conducted. The buckle must release when a force of 20 pounds is applied after the dynamic sled test. Section 6.2 provides that in conducting the belt buckle release force test, the appropriate test dummy is placed in the restraint and either a pull force of 20 pounds is applied, in the case of 6 month-old-test dummy, or a 45 pound pull force is applied, in the case of the three-year-old test dummy. Thus, the buckle is not tested in an unloaded state.

Section 5.4.2 of the standard provides that each belt buckle has to conform to the "requirements of S4.3(a) and S4.3(b) of FMVSS No. 209." No other provisions of Standard No. 209 apply to belt buckles used in child restraints.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

March 2, 1981

Office of Vehicle Safety Standards National Highway Traffic Safety Administration 400 Seventh Street S.W. Washington D.C. 20590

Attention: Mr. Vladislav Radovich

Dear Mr. Radovich:

Enclosed please find three prototype samples of our child seat buckle we would like to market. Gateway Industries is a major supplier of seat belts to General Motors and Chrysler and we hope to expand our product line by offering this item to child seat manufacturers.

We feel that our buckle meets all of the specifications of Standard 213, however, there is one area we wish you would clarify in regard to the 12 lb. to 20 lb. release force. (You may recall my phone call to you in the first week of January.)

Our buckle meets the letter of the spec as written. That is, as specified in S5.4.3.5 we meet S6.2 before and after the test specified in S6.1. Standard 213 makes no mention of how to test the buckle in an unloaded state. Does the 12 to 20 lbs. apply to the unloaded condition?

The three enclosed buckles do meet the 12 lb. minimum in the unloaded state, however, we are marginal and I doubt we can consistently obtain this on a large volume product basis. I theorize that on cccasion we will have release efforts of 10 lbs. in the unloaded state. Would this mean that we do not comply with Standard 213? With the slightest load applied to the buckle (approximately 5 lbs.), the release efforts increase and we again are in compliance. Also, in the "Summary of Final Rule Provisions", No. 5 states the requirements in 209 apply and S5.4.2 states S4.3(a) and S4.3(b) of 209 apply. Does this mean that only the requirements of S4.3(a) and S4.3(b) apply or do all the requirements of 209 apply?

We thank you for your time in reviewing this matter and would appreciate your written response. Please feel free to include any comments you may have concerning our product.

I would like to add that our buckle has been dynamically tested to Standard 213 on a Strolee Seat System at the University of Michigan in Ann Arbor and proven successful. We can guarantee a tensile load of 750 lbs.

Truly yours,

GATEWAY INDUSTRIES, INC.

John S. Miskowicz Manager, Design Engineering

ID: nht81-2.24

DATE: 05/12/81

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood for F. Berndt; NHTSA

TO: Severy, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

May 12, 1981 NOA-30

Mr. James J. Schultz Severy, Incorporated 2233 El Segundo Boulevard El Segundo, California 90245

Dear Mr. Schultz:

This responds to your recent letter asking whether a 4-wheel drive pickup truck must comply with Safety Standard No. 216, Roof Crush Resistance. You also ask whether the definitions of vehicle classifications under Federal regulations are mutually exclusive.

The application section of Safety Standard No. 216, section 3, specifies that the standard applies to passenger cars. This means that the standard applies only to passenger cars. Therefore, the standard does not apply to a pickup truck.

The definitions of the basic vehicle classifications found in 49 CFR Part 571.3 are mutually exclusive. If a vehicle falls within the definition of a "truck," the vehicle is not also within the definition of a "passenger car." The definition of a passenger car does not specifically exclude trucks because the definition is based on the function of the vehicle. Thus, a passenger car is defined as a motor vehicle designed for carrying persons. A truck, on the other hand, is defined as a vehicle designed primarily for the transportation of property or special purpose equipment. Since a pickup is designed primarily for carrying property and not persons, it is a truck and not a passenger car. Each motor vehicle has a certification label attached to its door which specifies the vehicle's classification.

I hope this has clarified any questions you had concerning vehicle classification under the Federal Motor Vehicle Safety Standards.

Sincerely,

Frank Berndt Chief Counsel

April 15, 1981

Chief Council NHTSA 400 7th St. S.W. Washington, D.C. 20590 ATTENTlON: MR. OATES

Gentlemen:

We have been retained in numerous instances in litigation which involve the Federal Motor Vehicle Safety Standards and in particular their application. The issues usually involve the definitions of various vehicle types ad to what category a given vehicle belongs. Currently we are working on a case that involves a 4-wheel drive pickup truck with bucket seats. The allegations being made are that this vehicle must conform with FMVSS 216 since the definition of passenger car does not exclude this type of pickup. In order to satisfy that question and others, please send me a letter of interpretation that is specific for this instance and also general to cover other such questions. These questions are:

(1) Does federal law require a 4-wheel drive pickup with either bucket seats or a bench seat to conform to FMVSS 216?

(2) Are the definitions of vehicles in the act mutually exclusive and if so, how does one determine which category applies to any given vehicle.

Please have the letter of interpretation made official and certified.

Very truly yours,

James J. Schultz

JJS:ln

ID: nht81-2.25

DATE: 05/12/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Gregory Equipment & Manufacturing Co.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 13, 1981, with respect to placement of identification lamps on the boat trailer you wish to manufacture.

You have informed us that the trailers are not built for transporting boats on the highways and your sales sheet reiterates that point: "These trailers are for in marina use only. Not for over the road use." Under the National Traffic and Motor Vehicle Safety Act, a vehicle that is not manufactured primarily for use on the public roads is not a vehicle subject to our regulations. From your letter and advertising enclosure, it appears that your intent is to build a vehicle that will be used primarily on private property. Therefore, our lighting requirements would not apply to it.

I hope that this answers your question.

SINCERELY,

Gregory Equipment & Manufacturing Co.

April 13, 1981

Chief Consul National Hwy. Traffic Safety Administration

Dear Sir;

I would like a ruling on the 3 cluster light for the rear of trailers. The boat trailer we are starting to manufacture doesn't have a place which such light may be mounted as shown in Picture #1. If lights were placed on the rear they would be jammed into the mud in the bottom of the river as shown in picture #2.

These lights are for the movement of the empty trailers from the plant to the sales designation. These are not built for transporting boats on the highways.

Inclosed is a brouchure. The trailer in this brochure is not equiped with lights because it is our prototype.

If any further information is needed please call me at 319-372-5314.

James E. Gregory

ID: nht81-2.26

DATE: May 12, 1981

FROM: Frank Berndt -- Chief Counsel, NHTSA

TO: Doris Perlmutter -- Betty-June School

TITLE: None

ATTACHMT: Attached to letter dated 6-11-90 from Ron Marion to Paul Jackson Rice (OCC 4915); Attached to letter dated 11-11-77 from James Tydings to Roger Tilton; Also attached to letter dated 12-21-77 from Joseph J. Levin, Jr. to James Tydings; Also attached to letter dated 3-8-91 from Paul Jackson Rice to Ron Marion (A37; VSA 102(14) Part 571.3); Also attached to letter dated 5-10-82 from Frank Berndt (Signature by Stephen P. Wood) to Martin V. Chauvin

TEXT:

This responds to your March 20, 1981, letter asking that we reconsider our interpretation that the school bus safety standards apply to vehicles that transport 10 or more children to or from nursery schools. The National Highway Traffic Safety Administration is unable to alter this interpretation.

The Congress in Public Law 93-492 stated that school bus safety standards shall apply to vehicles that transport more than 10 persons to or from preprimary, primary or secondary schools. A nursery school is considered a preprimary school and thus falls within the ambit of that law. We cannot alter the requirements of the law.

ID: nht81-2.27

DATE: 05/19/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Bridgestone Tire Co., Ltd.

TITLE: FMVSR INTERPRETATION

TEXT:

May 19, 1981

Mr. H. Hayashi Manager for Safety Standards Tire Quality Assurance Dept. Bridgestone Tire Co., Ltd. 2800-1, Ogawa, Higashi-Cho Kodaira-Shi, Tokyo, JAPAN

Dear Mr. Hayashi:

This is in response to your letter of March 26, 1981, requesting, an interpretation of the Uniform Tire Quality Grading (UTQG) Standards (49 CFR S575.104). You ask whether a tire designed for service as a temporary use spare tire, and labeled on its sidewall with the inscription: TEMPORARY USE ONLY FOR SPARE TIRE, INFLATE TO 40 PSI, MAX. SPEED 50 MPH, is exempt from the requirements of the UTQG Standards.

As you note, the "Application" section of the UTQG regulation does not apply to space-saver or temporary use spare tires. Thus, the UTQG Standards would not apply to the tire you describe, which is designed as a temporary use spare tire and is so labeled.

Sincerely,

Frank Berndt Chief Counsel

March 26, 1981

Office of the Chief Counsel, National Highway Traffic Safety Administration, 400 Seventh Street s.w., Washington,D.C.20590 U.S.A. Subject: Request for official advice in respect to the interpretation of Uniform Tire Quality Grading Standards (49CFR 575.104)

Dear Sirs:

Recently we have a plan to manufacture a temporary use type spare tire with 185/70 R14 size designation for U.S.A. market at the request of some automobile manufacturer. This type temporary use spare tire is designed to comply all the requirements of FMVSS No. 109, including labelling requirements.

In addition, this spare tire is to have the following labelling letters molded on both sidewalls:

Letters to be labelled

1) TEMPORARY USE ONLY FOR SPARE TIRE

2) INFLATE TO 40 PSI

3) MAX. SPEED 50 MPH

Note:- Refer to the attached sheet.

In the section 49CFR 575.104(C), it is provided that "However, this section does not apply to deep tread, winter-type snowtires or to space-saver or temporary use spare tires."

We, therefore, understand that Uniform Tire Quality Grading requirements would not apply to our temporary use type spare tire.

We hope to have your official comments and/or advice on our interpretation of the application of UTQG Standards.

Your kind and early reply would be highly appreciated.

Sincerely yours,

H. HAYASHI MANAGER FOR SAFETY STANDARDS TIRE QUALITY ASSURANCE DEPT.

ID: nht81-2.28

DATE: 05/21/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Indiana Mills & Manufacturing, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 21 1981

NOA-30

Mr. William E. Lawler Specifications Manager Indiana Mills & Manufacturing, Inc. 120 West Main Street Carmel, Indiana 46032

Dear Mr. Lawler:

This responds to your recent letter concerning S6.2.4 of Standard No. 213, Child Restraint Systems. You asked whether section 5.2(d)(1) of Standard No. 209 is the relevant section to be used in testing the release force on buckles used on a child restraint system. The answer is yes.

Section 6.2 of Standard No. 213 sets out the test procedure for measuring the release force for buckles used in child restraint systems. Section 6.2.4 states that the buckle is to be operated in the manner described in section 5.2(d) of Standard No. 209, Seat Belt Assemblies. S5.2(d)(1) of Standard No. 209 sets out the procedure for measuring the buckle release force. You are correct that S5.2(d)(2) and (3) set out the procedures for conducting several other requirements of Standard No. 209 which do not apply to child restraints and thus are not relevant to the buckle release force test.

If you have any further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

April 2, 1981

Mr. Frank Berndt, Chief Counsel National Highway Traffic Safety Administration 400 7th Street S.W., Room 5219 Washington, D.C. 20590

Dear Sir:

Indiana Mills and Manufacturing, Inc. is a manufacturer of seat belt assemblies for use in motor vehicles. We make every effort to comply with the requirements of the motor vehicle safety standards set forth by the National Highway Traffic Safety Administration.

Standard No. 213 (49 CFR 571.213), Child Restraint Systems, refers in S6.2.4 to S5.2(d) of Standard No. 209 (49 CFR 571.209), Seat Belt Assemblies. The buckle release mechanism mentioned in S6.2.4 (213) is to be operated in the specific manner described in section 5.2(d) of Standard No. 209. We assume that only the portion of S5.2(d) of Standard No. 209 pertaining to the method of releasing the buckle mechanism is included by reference in Standard No. 213, and we believe that portion consists of paragraph (1) beginning with the words "The buckle release force shall be measured..." through the end of the paragraph. Because S5.2(d)(2) and S5.2(d)(3) deal with subjects other than the proper method of releasing the buckle mechanism, we interpret Standard No. 213 as excluding them while including only the portion of S5.2(d)(1) described above.

We would appreciate receiving from you an official written explanation of the intent of S6.2.4 of Standard No. 213.

Thank you for your assistance.

Yours very truly,

William E. Lawler Specifications Manager

WEL/jr

ID: nht81-2.29

DATE: 05/27/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Thomas Built Buses, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 27 1981

NOA-30

Mr. Jim Tydings Thomas Built Buses, Inc. 1408 Courtesy Road P.O. Box 2450 High Point, North Carolina 27261

Dear Mr. Tydings:

This responds to your April 14, 1981, letter asking whether a fold-up seat that you plan to build in a school bus would comply with the Federal motor vehicle safety standards.

You state in your letter that the seat would comply with all of the requirements of Standard No. 222, School Bus Passenger Seating and Crash Protection. If the seat complies with that standard and if its location in the bus will not interfere with the requirements applicable to emergency exits, then the seat should comply with all of the Federal safety standards.

Sincerely,

Frank Berndt Chief Counsel

April 14, 1981

Office of the Chief Counsel U.S. Department of Transportation 400 S.W. 7th St. Washington, D.C. 20590

Attn: Mr. Roger Tilton

Subject: FMVSS 217-76, Bus Window Retention and Release

Dear Mr. Tilton:

Enclosed is our print #46-009627, Sketch - Fold Up Seat Cushion at Emergency Exit, plus photos.

This print shows a side (left) emergency exit and the location of a seat wherein the cushion is spring loaded to maintain the cushion in an upright position when the seat is unoccupied.

The advantage being that this seat configuration provides greater egress to the side door. This seat naturally would meet all requirements of FMVSS-222 School Bus Passenger Seating and Crash Protection.

It is our opinion that this arrangement meets the applicable Federal Motor Vehicle Standards.

We would appreciate it if you would review this material and advise us of your conclusions.

Thanking you in advance, I remain

Sincerely,

THOMAS BUILT BUSES, INC.

Jim Tydings, Specifications Engineer

JT/jf

Enclosure

ID: nht81-2.30

DATE: 06/01/81

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: British Standards Institution

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letters concerning section 4.2(d) of Standard No. 209, Seat Belt Assemblies. Section 4.2(d) provides that after seat belt webbing has been subjected to an abrasion test, it must have not less than 75 percent of the strength of the unabraded webbing set in section 4.2(b) of the standard. You pointed out that section 5.2(d) is inconsistent with section 4.2(d). As explained below, section 4.2(d) correctly states the requirement intended by the agency and section 5.2(d) needs to be corrected.

The abraded webbing strength test procedure set forth in section 5.2(d) of the standard is incorrect. It specifies that the median value of the breaking strengths of the abraded and unabraded webbing are used to determine the percentage of breaking strength retained. Such a test procedure unfairly penalizes a manufacturer that produces webbing with an unabraded breaking strength far in excess of the requirements specified in section 4.2(b).

For example, section 4.2(b) specifies that Type I webbing is to have a breaking strength of 6,000 pounds. Assume that the unabraded webbing has a median breaking strength of 8,000 pounds and the abraded webbing has a median breaking strength of 5,600 pounds. The median breaking strength of the abraded webbing is substantially more than 75 percent of the 6,000 pound breaking strength specified in section 4.2(b). However, the median abraded breaking strength is only 70 percent of the median unabraded breaking strength.

The agency intends to modify the standard so that the abraded webbing strength test procedure specifies that the median breaking strength of the abraded webbing is compared to the breaking strength specified in section 4.2(b) to determine the percentage of breaking strength retained.

Sincerely,

ATTACH.

British Standards Institution

JANUARY 6, 1981

F. BERNDT -- U.S. Department of Transportation, NHTSA

Dear Sirs

FMVSS

Many thanks for your letter of 12 December 1980 on the above subject.

You say in your letter that Standard Number 209 requires abraded webbing in manual belt systems for use in motor vehicles to have not less than 75% of the strength of unabraded webbing.

Clause @ 4.2(b) at the end states 'the median value shall be used for determining the retention of breaking strength in paragraphs (d), (e) and (f) of this section'.

Clause @@ 4.2(d) states that 'after abrasion, the webbing shall have a breaking strength of not less than 75% of the breaking strength listed in @@ 4.2(b). For clarity surely this should read - not less than 75% of the median value obtained during tests to clause @@ 4.2(b)'.

I would appreciate your comments.

Yours faithfully

J E BINGHAM SENIOR TEST ENGINEER

British Standards Institution

FRANK BERNDT -- CHIEF COUNSEL, U.S. Department of Transportation, NHTSA

Dear Sirs

FMVSS - 209 SEAT BELT ASSEMBLIES

Clause 5.1 (b) reads . . . . the median value shall be used for determining the retention of breaking strength in paragraphs (d) (e) and (f) of the section.

Clause 4.2(d) reads . . . . shall have a breaking strength of not less than 75% of the breaking strength listed in Clause 4.2(b) for that type of belt assembly.

Please clarify the level to which the webbing strength after abrasion is to be compared. Is it:-

1. 75% of median breaking strength found under clause 5.1(b) or

2. 75% of minimum breaking strength listed in clause 4.2(b)

I have written to you on this subject before and would appreciate a speedy reply.

Yours faithfully

J E BINGHAM -- SENIOR TEST ENGINEER, MOTOR VEHICLE SAFETY COMPONENTS SECTION

ID: nht81-2.31

DATE: 06/03/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: North American Classics Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of April 15, 1981, asking two questions with respect to the temporary exemption provisions of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1410) and implementing regulations (49 CFR Part 555).

Your first question is:

(1) Assuming North American Classics designs the total engineering of the Thunderbird reproduction; selects all components to be incorporated therein; retains primary control over quality control, testing, FMVSS compliance in design; and manufacturing assembly sequence; and markets the produced vehicles on its behalf to its customers, does North American Classics remain eligible to apply for exemption from meeting certain FMVSS requirements for this vehicle in the event that the actual responsibility for the assembly of the vehicles is contracted by North American Classics to a manufacturer which produces more than 10,000 motor vehicles per year?

Although you have not said so, I understand from Taylor Vinson that the manufacturer with whom you would contract is a foreign corporation which has never produced motor vehicles for the American market. We also understand that it may be less expensive to have your car built abroad than at home.

Under the circumstances you describe, the foreign corporation appears to be nothing more than your agent in fabricating the vehicles and returning them for sale. This would not affect your eligibility for exemption. You would retain the responsibility for certification, as we understand it, even though the name of the foreign manufacturer would also appear on the certification label, as required by 49 CFR 567.4(g)(1).

Your second question is:

(2) In the event that North American Classics enters into an agreement to have such vehicles produced or assembled by a major automotive manufacturer, who would not be so eligible, and if such agreement provides for the sharing of profits derived from the sales of the finished product between North American Classics and such manufacturer, as a means of providing North American Classics assurance that projected costs of such manufacturer do not increase beyond North American Classics' ability to survive financially, in such event would North American Classics retain its eligibility status, assuming North American Classics retains control of the functions outlined in paragraph?

We do not believe that a profit-sharing agreement per se would affect your eligibility for exemption. Were the foreign company to receive a majority share of the profits or to purchase sufficient stock in your company to give it effective control, however, we would have substantial questions about which party actually exercises primary control.

I hope this answers your questions.

SINCERELY,

North American Classics Corporation

April 15, 1981

Frank Berndt Acting Chief Counsel (NOA-30) National Highway Traffic Safety Administration

Dear Mr. Berndt:

I am writing on behalf of North American Classics Corporation, a Michigan Corporation, formed in July of 1980 for the purpose of initially engineering and designing; assembling; and marketing motor vehicles which resemble the 1957 Ford Thunderbird. In September 1980, as attorney for the Corporation, I met with Mr. Taylor Vinson of your office concerning North American Classics' project.

The purpose of this letter is to request of your office a written opinion concerning the following inquiries:

(1) Assuming North American Classics designs the total engineering of the Thunderbird reproduction; selects all components to be incorporated therein; retains primary control over quality control, testing, FMVSS compliance in design; and manufacturing assembly sequence; and markets the produced vehicles on its behalf of its customers, does North American Classics remain eligible to apply for exemption from meeting certain FMVSS requirements for this vehicle in the event that the actual responsibility for the assembly of the vehicles is contracted by North American Classics to a manufacturer which produces more than 10,000 motor vehicles per year?

(2) In the event that North American Classics enters into an agreement to have such vehicles produced or assembled by a major automotive manufacturer, who would not be so eligible, and if such agreement provides for the sharing of profits derived from the sales of the finished product between North American Classics and such manufacturer, as a means of providing North American Classics assurance that projected costs of such manufacturer do not increase beyond North American Classics' ability to survive financially, in such event would North American Classics retain its eligibility status, assuming North American Classics retains control of the functions outlined in paragraph?

As the inquiries intimate, North American Classics is considering having the actual asembly work of the vehicle completed by an automotive manufacturer that now produces more than 10,000 vehicles per twelve calendar months. It is uncertain at this time what the agreed upon terms of such an agreement might be that satisfies the interest of both parties. My primary concern in requesting an opinion is to assure myself that North American Classics does not inadvertently contract away its rights to apply for certain exemptions from FMVSS should the need to do so arise.

I thank you for your anticipated cooperation in this regard.

Thomas W. Elkins Secretary

ID: nht81-2.32

DATE: 06/09/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Robinson L. P. Gas Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter requesting information regarding the conversion of school bus fuel systems to dual fuel carburetion running on propane gas. Specifically, you ask whether any regulations require that a protective cage be placed around a propane fuel tank, if propane carburetion is installed on a school bus.

The answer to your specific question is no. Federal motor vehicle safety standards and regulations do not require protective cages for propane fuel tanks. In fact, the Federal safety standard regarding fuel system integrity, Standard No. 301, is not directly applicable to propane fuel systems.

I am enclosing a fact sheet for your information which discusses the Federal implications of installing auxiliary fuel tanks and of converting fuel systems to use alternate fuels. From that fact sheet you will see that there may be certain responsibilities which must be met by persons converting school buses to use dual fuel systems. Please feel free to contact Hugh Oates of my staff if you have any further questions after reviewing this information (202-426-2992).

You will have to contact your State department of motor vehicles to determine if there are any local laws or regulations which would require the installation of a protective cage around propane fuel tanks.

SINCERELY

May 12, 1981

National Highway Traffic Safety Administration

Attn: Roger Tilton Legal Counsel

I recently had a conversation with Billie Renyolds, Executive Director of the National School Transportation Association and she directed me to your office for information regarding the conversion of school buses to dual fuel carburetion running on propane fuel.

More specifically, I am interested in finding if the application of a cage around a propane tank is necessary for installation of propane carburetion on school buses. There has been much controversy regarding this subject during the past year. Because Robinson L. P. Gas Company will be converting school buses to propane, we, of course, are very interested in knowing what the proper procedures should be according to state and federal codes.

As of this date, all propane conversions done in the state of Pennsylvania have not had a cage around the fuel tank. The tanks have been installed according to Pamphlet 58 and we are using ASME motot fuel 312 PSI tanks.

Thank you for your consideration. I will be looking forward to your reply in the near future.

Carol Kirk Marketing Representative

CC: RICHARD C. MARTIN -- ROBINSON L. P. GAS CO.