ID: 10927pil

Ms. Denise Jones
NiMi Manufacturing, Inc.
1044 Main St.
Mosheim, TN 37818

Dear Ms. Jones:

This responds to your letter to Ms. Deirdre Fujita of my staff asking about safety regulations, particularly for flammability resistance, for a device you call a "Toddler Traveler pillow." According to promotional literature you sent with your letter, the Toddler Traveler pillow is used with a child booster seat to provide "padded comfort and support" to a child sleeping in the booster. The pillow provides a surface the child could lean on while sleeping.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) has the authority to issue Federal motor vehicle safety standards (FMVSSs) for new motor vehicles and new items of motor vehicle equipment. NHTSA does not, however, approve or certify any vehicles or items of equipment. Instead, Congress has established a "self-certification" process under which each manufacturer is responsible for certifying that its products meet all applicable safety standards. The following represents our opinion based on the information set forth in your letter and promotional literature.

Currently there are no Federal motor vehicle safety standards (FMVSSs) that directly apply to the Toddler Traveler pillow. Our standard for "child restraint systems," FMVSS 213, applies to "any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less." The standard does not apply to accessory items, such as a pillow that is used with a child booster seat. Our standard for flammability resistance, FMVSS 302, applies to new motor vehicles and to new child restraint systems. It does not apply to child restraint accessory items.

While no FMVSS applies to the Toddler Traveler pillow, your product is considered to be an item of motor vehicle equipment. As a manufacturer of motor vehicle equipment, you

are subject to the requirements of 49 U.S.C. ''30118- 30121 concerning the recall and remedy of products with safety related defects. I have enclosed a copy of those defect provisions, as well as an information sheet that briefly describes those and other manufacturer responsibilities. In the event you or NHTSA determines that your product contains a safety- related defect, you would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge.

In addition, while it is unlikely that the Toddler Traveler pillow would be installed by a motor vehicle manufacturer, distributor, dealer or repair business, 49 U.S.C. '30122 prohibits those businesses from installing the device if the installation "makes inoperative" compliance with any safety standard. No commercial business listed in '30122 can install a Toddler Traveler pillow if the product undermines the vehicle's compliance with a safety standard, including Standard 302 for flammability resistance.

The prohibition of '30122 does not apply to individual owners who install equipment in their own vehicles. Thus, individual owners may install any item of motor vehicle equipment regardless of its effect on compliance with Federal motor vehicle safety standards. However, NHTSA encourages vehicle owners not to degrade the safety of their vehicles.

Before closing, we would like to comment on a further issue, one that you and Ms. Fujita discussed on the telephone. The advertising literature you enclosed with your letter described the Toddler Traveler pillow as being suitable for use with children ages "18 months to 4 years." We believe this description is potentially confusing concerning the use of booster seats by young children. Booster seats are intended to be used as a transition to safety belts by older children who have outgrown convertible seats (ideally, over 40 pounds and 4 years). A booster seat is not designed to restrain young children, and under a requirement we recently adopted, cannot now be recommended for children under 30 pounds. Stating "18 months to 4 years" may be mistaken to imply that, with your pillow, a booster seat could be used to restrain a child as young as 18 months. To avoid any possible misunderstanding, we suggest that the phrase on recommended use of the pillow should refer to older children, such as those "over 4 years."

One further note in closing. You said that a year ago, Ms. Fujita told you "there are no codes to govern" your product. Ms. Fujita is concerned that you might believe you were given an oral interpretation of how our requirements apply to your product. Please note that we cannot give oral interpretations. Ms. Fujita provided you a copy of an interpretation we'd issued in the past on a child seat pillow accessory, while indicating that an interpretation of which requirements apply to your product must be from us in writing. (This letter comprises that interpretation.) We regret any confusion on this issue.

I hope this information is helpful. If you have any other questions, please feel free to contact Ms. Fujita at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

Enclosures ref:213 d:6/30/95

ID: 8126

Mr. Eugene Berk
Food and Drug Administration
Center for Devices and
Radiological Health
Office of Compliance and Surveillance
1390 Piccard Dr.
Rockville, MD 20850

Dear Mr. Berk:

This follows up on telephone conversations between you and Deirdre Fujita of my staff about a letter you received from the Medical Device Inspection Company (MDI) concerning the "Tumble Forms LifeSeat." While much of the information in the letter is subject to a claim of confidentiality, Ms. Carolann Kotula-Cook of MDI told us that we can provide, for purposes of a letter that will be placed in the public docket, the following description of the LifeSeat. The LifeSeat is described by MDI as "a safety seat designed to protect children who are riding in emergency medical vehicles. The seat is designed to be secured to the ambulance stretcher or cot... [and] may also be secured to the vehicle's captain's chair." You ask whether the LifeSeat is a "child restraint system" regulated by Federal Motor Vehicle Safety Standard No. 213, "Child Restraint Systems." As discussed below, the answer is yes.

Standard No. 213 specifies requirements for child restraint systems used in motor vehicles and aircraft, to reduce the number of children killed or injured in motor vehicle crashes and in aircraft. The term "child restraint system" is defined in S4 of the standard as "any device except Type I or Type II seat belts, designed for use in a motor vehicle or aircraft to restrain, seat, or position children who weigh 50 pounds or less." As described in MDI's letter, the LifeSeat meets the child restraint system definition, since it is designed to restrain or seat a child in a motor vehicle. Under the National Traffic and Motor Vehicle Safety Act, each child restraint system that is sold in or imported into the United States must be certified as complying with Standard No. 213. Since the LifeSeat is a child restraint system, it must be certified as complying with Standard No. 213.

We informed Ms. Kotula-Cook that it appears the LifeSeat would not comply with some of Standard No. 213's requirements. We have sent her a copy of the standard, and an information sheet for manufacturers of motor vehicles and motor vehicle equipment. The information sheet describes manufacturers' responsibilities under Federal law for manufacturing vehicles and items of equipment, such as the responsibility to ensure these products do not have any safety-related defects. Ms. Kotula-Cook said that MDI will be contacting us directly for more information about Standard No. 213 and these responsibilities.

We are returning the copy of MDI's letter you provided us. If you have any questions, please call Ms. Fujita at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel

ref:213 d.1/8/93

ID: nht80-3.40

DATE: 08/28/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Cosco

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of July 30, 1980, asking whether various parts of your Peterson 78 Child Restraint must comply with section 4.3(a) of Standard No. 209, Seat Belt Assemblies. As explained below, the buckle slides located behind the seat and below the unit and the buckle release button must comply with section 4.3(a) and (b) of the standard. The adjustment lever plate does not have to comply with those sections.

Section S5.4.2 of Standard No. 213, Child Restraint Systems, provides that "Each belt buckle and item of belt adjustment hardware used in a child restraint shall conform to the requirements of S4.3(a) and S4.3(b) of FMVSS 209(S571.209)." As shown in the illustration accompanying your letter, the purpose of the slides located below the unit and behind the seat is to adjust the harness system within the child restraint. Thus they are items of belt adjustment hardware and must comply with S4.3(a) and (b) of Standard No. 209. Likewise, section S4.5.2 of Standard No. 213 specifically identifies the belt buckle as an item which must comply with S4.3(a) and (b) of Standard No. 209. The adjustment lever plate on your restraint adjusts the position of the child restraint from fully upright to fully reclining. It does not adjust the child restraint harness system, however. Thus, the lever plate is not an item of belt adjustment hardware covered by section 5.4.2 of Standard No. 213.

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

SINCERELY,

COSCO

Frank Berndt Chief Counsel U.S. Dept. of Transportation National Highway Traffic Safety Administration

July 30, 1980

Dear Mr. Berndt:

Because of some interpretation differences in our own ranks concerning the Standard No. 213, Child Restraint Systems Requirements for Belt Buckles and Belt Adjustment Hardware, we need an official interpretation of some specific parts of our Peterson 78 Child Restraint.

Please refer to the attached illustration showing the child restraint parts. The slides behind the seat and below the unit, the adjustment lever plate, and the buckle release button are the parts in question.

Do these specific parts have to be in compliance with Standard No. 209 S4.3A or will nickle chrome or a zinc finish be adequate as the parts do not come into contact with the occupant.

Your attention to this matter will be greatly appreciated.

Don Gerken Product Engineer

ENCL.

(Graphics omitted)

ID: nht67-1.29

DATE: 05/25/67

FROM: AUTHOR UNAVAILABLE; George C. Nield; NHTSA

TO: Busby and Rivkin, Counsellors at Law

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of April 26, 1967, concerning the interpretation of Safety Standard Number 210.

Paragraph (Illegible Word) of Standard Number 208, specificas that the Type 2 seat belt anchorage shall be installed in each outboard passanger seat position that includes the windshield header within the head impact area. Therefore, the rear seat is not included in this area and no Type 2 belt assembly is required. A copy of the Federal Register published February 3, 1967, is enclosed for your information.

With regard to your comments on Standard Number 209 and on the provision of Section 108(b)(3) of the Act, please be advised that we anticipate the promulgation of joint regulations with the Secretary of the Treasury, permitting the incorporation of vehicles upon appropriate assurance that they will be brought into conformity with all applicable Federal standards prior to sale. These regulations or related regulations will prescribe the proper means of certifying such nonconforming vehicles in order to insure their admission through United States Customs.

ID: nht92-7.25

DATE: April 28, 1992

FROM: Dave Durenberger -- United States Senator

TO: Jerry R. Curry -- Administrator, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5/28/92 from Jerry R. Curry to Dave Durenberger (A39; Std. 209)

TEXT:

I am writing on behalf of my constituent, McNaughton Incorporated of Minneapolis, Minnesota to request your input concerning a safety belt product they have developed to encourage safety belt compliance for children.

As you know, all 50 states have child restraint laws and 41 states have mandatory seat belt laws with varying levels of compliance. Part of the problem, in general, is compliance. Another part of the problem is that although an adult may secure a child in a seat belt restraint, that doesn't mean the child will keep the belt on.

McNaughton Inc. has developed a product that will inhibit a child from unbuckling a seat belt until assisted by an adult. McNaughton would like to be advised of any regulations that may pertain to their product and how they can abide by any legislation that may effect the feasibility of such a product.

I have enclosed photos of the prototype for your inspection. The buckle part of the seat belt fits into the little "box". There is a slot through which you plug in the tongue of the belt. The release button is covered by a removable, FDA-approved "pull and turn" child safety cap. To undo the belt lock, one simply pulls and turns the cap and inserts a finger in the round opening to the release button.

This is an item that the individual consumer would purchase and personally position on their existing safety belts. It would not need commercial installation. Although an adhesive tape will be included to keep the device in place, the product is fully removable, temporary and does not alter the function of the buckle in any way other than its intended design.

In addition to ensuring that it remains in compliance with all regulations and legislation, McNaughton Incorporated would like to become involved in the Department's safety belt campaign. I would greatly appreciate receiving any pertinent information, input, comments and suggestions on ways that my constituent could participate in this endeavor.

I appreciate your serious consideration of this request and look forward to your response.

ID: nht88-4.21

TYPE: INTERPRETATION-NHTSA

DATE: 11/30/88

FROM: R. H. MUNSON -- FORD MOTOR CO

TO: ERIKA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 03/28/89 FROM ERIKA Z. JONES -- NHTSA TO ROBERT H. MUNSON, REDBOOK A33(4), STANDARD 208, STANDARD 209

TEXT: Dear Ms. Jones:

Request for Interpretation

Standards Nos. 208 and 209 contain apparently inconsistent provisions. For the reasons discussed below, Ford believes that the agency intended the later-promulgated provisions to limit the application of the earlier-promulgated ones, and therefore no co nflict actually exists between them. Ford respectfully asks you to confirm that its belief is correct.

In brief, S4.6.3 of Standard No. 208 exempts from the Standard No. 209 restrictions on elongation of seat belt webbing those Type 2 seat belt assemblies that are installed to comply with the manual restraint requirements (S4.1.2.3) of Standard No. 208 and are required by S4.6.1 or S4.6.2 of the standard to meet its frontal crash test requirements. S4.6(a) of Standard No. 209 repeats that exemption. In contrast, S4.5(b) of Standard No. 209 provides that a Type 2 seat belt assembly that "includes a l oad limiter n1 and that does not comply with the elongation requirements of this standard may be installed in a motor vehicle only in conjunction with an automatic restraint system as

part of a total occupant restraint system." (emphasis added). Despite this apparently inconsistent provision, the rulemaking history discussed below suggests strongly that the agency intended to permit such Type 2 seat belts to be used in manual restrai nt systems if such belts also have to meet the frontal crash test requirements of Standard No. 208.

n1 The agency defined "load-limiter" in the preamble to Docket No. 80-12, Notice 2 as a "seat belt assembly component or feature that controls tension on the seat belt and modulates or limits the force loads that are imparted to a restrained vehicle o ccupant by the belt assembly during a crash." (46 Fed. Reg. 2618, January 12, 1981). Notice 2 also added a similar definition to S3 of Standard No. 209.

Discussion

In a final rule n2 modifying Standards Nos. 208 and 209, the agency amended S4.6.2 of Standard No. 208 to require certain trucks and multipurpose passenger vehicles built on or after September 1, 1991, and equipped with a Type 2 seat belt assembly at a f ront outboard designated seating position pursuant to S4.1.2.3 of that standard to meet the frontal crash test requirements of S5.1. The agency also added S4.6.3, a provision that exempts Type 2 seat belt assemblies subject to the requirements of S4.6.1 or S4.6.2 from the webbing width, strength, and elongation requirements of Standard No. 209 [S4.2(a)-(c)] and from the requirements for assembly performance of that standard (S4.4). In addition, the agency amended S4.6 of Standard No. 209 to reiterate t hat exemption and require that such seat belt assemblies be specially labeled.

n2 Docket No. 74-14, Notice 53; 52 Fed. Reg. 44898, November 23, 1987.

In exempting dynamically-tested belts subject to S4.6.2 of Standard No. 208 from certain Standard No. 209 requirements, the agency stated in the preamble to Notice 53, under the heading "Revisions to Standard No. 209":

The agency noted that the webbing of automatic belts is currently excluded from the elongation and other belt webbing and attachment hardware requirements of Standard No. 209, since those belts have to meet the injury protection criteria of Standard N o. 208 during a crash. For dynamically-tested manual belts in passenger cars, NHTSA believed that an exclusion from the webbing width, strength and elongation requirements (sections 4.2(a)-(c) is also appropriate since these belts will also have to meet the injury protection requirements of Standard No. 208. The agency believes that for those same reasons, dynamically-tested safety belts in light trucks and multipurpose passenger vehicles should also be excluded from those requirements of Standard No. 20. (52 Fed. Reg. at 44906). n3

n3 The agency reiterated this reasoning in Docket No. 74-14, Notice 54 (53 Fed. Reg. 5579, February 25, 1988). This Notice denied petitions for reconsideration of the agency's decision to exempt dynamically-tested manual lap/shoulder belts from the a ssembly and elongation requirements (among others) of Standard No. 209. The Notice also denied a petition to delete the provision of Standard No. 208 which exempts automatic safety belts from the Standard No. 209 webbing requirements.

S4.5(b) of Standard No. 209, provides, however, that a Type 2 seat belt assembly that includes a load-limiter and that does not comply with the elongation requirements of Standard No. 209 may be installed in motor vehicles only in conjunction with an aut omatic restraint system as part of a total occupant restraint system. S4.5(c) of that standard also requires that any Type 2 seat belt assembly that includes a load-limiter and does not comply with these elongation requirements be marked or labeled with the following words:

This seat belt assembly may only be installed in vehicles in combination with an automatic restraint system such as an air cushion or an automatic belt. (emphasis added). n4

n4 S4.5 was promulgated in response to a Mercedes-Benz petition to allow use, in conjunction with air bag systems, of belts that did not meet the S4.2(c) elongation requirements. In the preamble to Docket No. 80-12, Notice 2, the agency explained tha t it had proposed restricting the use of load-limiting belts to vehicles equipped with automatic restraints because there are currently no dynamic performance requirements or injury criteria for manual belt systems used alone. There are no requirements to ensure that a load-limiting belt system would protect vehicle occupants from impacting the steering wheel, ins trument panel, and windshield, which would be very likely if the belts elongated beyond the limits specified in Standard No. 209. Therefore, the elongation requirements are necessary to ensure that manual belts used as the sole restraint system will ade quately restrain vehicle occupants. (46 Fed. Reg. 2618, 2619, January 12, 1981).

Ford believes that the more recently promulgated rule exempting manual Type 2 belt assemblies subject to S4.6.1 or S4.6.2 of Standard No. 208 from the elongation requirements of Standard No. 209 was meant to limit the restrictions of S4.5(b) of that stan dard to manual belt assemblies not required to undergo dynamic crash testing. Clearly, the agency's reasons for restricting use of the Type 2 seat belt assemblies specified in S4.5(b) to vehicles also equipped with automatic restraints do not apply to m anual Type 2 belts subject to the dynamic crash test requirements of Standard No. 208. Contrary to the preamble language quoted in footnote 4, those manual belts are subject to "dynamic performance requirements [and] injury criteria" meant to "ensure th at a load-limiting belt system would protect vehicle occupants . . ."

Hence, the elongation requirements are no longer "necessary to ensure that manual belts used as the sole restraint system will adequately restrain vehicle occupants." Indeed the agency expressly recognized this fact in the above-quoted excerpt from the p reamble of Docket No. 74-14, Notice 53, and also in Notice 54.

For the same reasons, Ford believes that manual Type 2 belts subject to S4.6 of Standard No. 208 are intended also to be exempt from the labeling requirements of S4.5(c) of Standard No. 209 and instead to be subject to the labeling requirements of S4.6(b ) of that standard.

Ford respectfully requests your concurrence in its interpretation. If, however, the agency believes that the apparent inconsistency can be cured only by amending Standards Nos. 208 and 209, Ford asks the agency to treat this letter as a petition for rul emaking.

Sincerely,

ID: 07-002909as

ID: 9479

Lawrence P. White, Acting Director
Bureau of Motor Vehicles
Department of Transportation
Commonwealth of Pennsylvania
Harrisburg, PA 17122

Dear Mr. White:

This responds to your letter of December 13, 1993, asking several questions concerning a recent amendment to Standard No. 217, Bus Emergency Exits and Window Retention and Release (57 FR 49413; November 2, 1992). Your questions and the response to each follows.

1.The effective date - is it the chassis manufacturer's date of completion, the final stage manufacturer's date of completion, or somewhere in between?

The effective date for the November 2 final rule is May 2, 1994. Only vehicles manufactured on or after the effective date of an applicable requirement in a Federal motor vehicle safety standard must comply with that requirement. If a vehicle is manufactured in two or more stages, the final stage manufacturer is required to certify that the vehicle complies with "the standards in effect on the date of manufacture of the incomplete vehicle, the date of final completion, or a date between those two dates." (49 CFR Part 568.6).

2.Based on the formula for emergency exit space, is the area of the front service door to be included? Does this mean on a vehicle of 60 to 77 passengers, the only additional requirements beyond the front and rear doors is a left side exit door?

The November 2 final rule requires additional emergency exit area (AEEA) for some buses. The amount, if any, of AEEA which must be provided is determined by subtracting the area of the front service door and either the area of the rear emergency door or the area of the side emergency door and the rear push- out window, depending on the configuration of the bus (S5.2.3.1). These are the minimum exits required on all buses. If AEEA is required, the first additional exit which must be installed is a left side emergency door (for a bus with a rear emergency door) or a right side emergency door (for a bus with a left side emergency door and a rear push-out window). The number of exits may vary for buses which carry the same number of passengers, because the amount of area credited for each exit is the area of daylight opening, and because different variations of types of exits are possible. However, in the regulatory evaluation for the final rule, the agency estimated that a bus would not be required to have a roof exit (the second type of additional exit required) unless the capacity was greater than 62 (for a bus with a rear emergency door) or 77 (for a bus with a left side emergency door and a rear push- out window).

3.The "clear aisle space" required for exit to the proposed side emergency door, according to federal specifications, can be met with a flip-up type seat or a clear opening of 12", as measured from the back of the door forward. Are there any specifications, definitions, or descriptions provided as to what would be considered a "flip seat"?

The November 2 final rule allowed a flip-up seat to be adjacent to a side emergency exit door "if the seat bottom pivots and automatically assumes and retains a vertical position when not in use, so that no portion of the seat bottom is within" the required 12 inch aisle to the exit (S5.4.2.1(a)(2)(ii)). The agency did not otherwise define a flip-up seat, nor did it include any performance requirements for these seats.

4.Also, there is concern regarding school buses that are equipped with the "flip seat" by the emergency door opening and the possibility of school children, either intentionally or accidently, unlatching the door latch mechanism. Are the door latch mechanisms to be equipped to help prevent this from occurring?

Standard No. 217 includes requirements for the type of motion and force required to release an emergency exit (S5.3.3). One of these requirements is that the motion to release a door must be upward from inside the bus (upward or pull-type for school buses with a gross vehicle weight rating of 4,536 kilograms or less). This is intended to lessen the chance of a door accidently being opened, without unnecessarily making the exit more complicated to open in an emergency. In addition, warning alarms are required for door and window exits to notify the driver that the exit has been opened.

I hope you find this information helpful. If you have any other questions, please contact Walter Myers of my staff at this address or by phone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:217 d:3/21/94

ID: nht94-3.53

TYPE: INTERPRETATION-NHTSA

DATE: July 1, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Dietmar R. Haenchen -- Manager Vehicle Regulations, Volkswagen of America, Inc.

TITLE: NONE

ATTACHMT: Attached to letter dated 5/17/94 from Dietmar K. Haenchen to John Womack (OCC-10000)

TEXT: This responds to your request for an interpretation of marking requirements in 49 CFR part 541 Federal Motor Vehicle Theft Prevention Standard for high theft vehicle lines' replacement parts. The answer to both of your questions is VW is still required to mark the replacement parts in question.

In your letter, you explained that the Volkswagen Corrado line, a high theft line, was parts marked (pursuant to 49 CFR part 541) in model years 1990 through 1994. For model year 1995, NHTSA granted an exemption from parts marking for the Corrado line, based on the inclusion of an approved antitheft device as standard equipment on all models in the Corrado line. (58 FR 28434, May 13, 1993). However, you informed us in your letter that the Corrado will not be sold in the United States for MY 1995. Yo ur first question asks whether replacement parts for the Corrado line are exempted from the parts marking requirements of part 541.

The answer is no. Section 543.7(d) specifies that part 543 exemptions apply only to lines that are the subject of the grant, and are equipped with the antitheft device on which the line's exemption was based. You inform us that the Corrado will not be offered for sale in the U.S. in MY 1995. If the Corrado will not be offered for sale in this country, then no Corrrados sold in the U.S. will be equipped with the approved antitheft device. If no Corrado is so equipped, the part 543 exemption would not apply to the Corrado line. Thus, Volkswagen would be required to continue to mark any Corrado replacement parts, subject to part 541, offered for sale in the U.S.

In your letter, you cited an October 12, 1989 NHTSA interpretation letter to Saab-Scania of America to support your position that the Corrado's replacement parts need not continue to be marked. We do not believe that the letter to Saab supports your pos ition.

2

Saab received an exemption from parts marking for the Saab 9000 for the 1989 model year, and asked NHTSA to clarify the scope of the part 543 exemption. On page two of the letter to Saab, NHTSA stated that Saab was free to discontinue marking of origina l equipment and replacement parts for the Saab 9000 as soon as the part 543 exemption took effect, "provided that Saab actually installed the antitheft device described in its petition . . ." The letter to Saab establishes that if it does not install the antitheft device on the exempted line, a manufacturer is not free to discontinue marking replacement parts on the line.

Your second question was whether replacement parts marking may be terminated at some point after a high theft line subject to parts marking, is no longer produced. The answer is no. This issue was addressed in the final rule establishing 49 CFR part 54 1 (50 FR 43166, October 25, 1985):

Once a line is selected as a high theft line, each covered major replacement part designed for use on that line must be identified as a replacement part. That requirement remains in effect as long as those replacement parts are produced. (50 FR 43178).

Thus, as long as replacement parts are produced for a high theft line subject to parts marking, the replacement parts must continue to be marked.

I hope that this information is helpful. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992.

ID: aiam0821

Dear Mr. Lundstrom: This is in reply to your letter of August 21, 1972, on the subject o the operation of the seat belt warning system when the vehicle is in one of the free start modes allowed by S7.4.3 and S7.4.4 of Standard No. 208.; You are correct in your understanding that S7.3.5.4 does not requir the warning to operate when the ignition switch is in the 'start' position if the conditions described in S7.4.3 and S7.4.4 exist. Under those conditions, the interlock system continues to act as if the operation of the belt systems had not been followed by their release. By the same logic, the warning system activation required by S7.3.5.4 is in abeyance until the ending of the free start conditions.; Sincerely, Richard B. Dyson, Assistant Chief Counsel