ID: 11695JEG

Mr. William G. Larrabee
141 Cotton Brook Road
Dover-Foxcroft, Maine 04426

Dear Mr. Larrabee:

This responds to your letter asking in what year it was mandated that the U.S. auto industry begin to install safety belts in new cars. I am pleased to provide this information to you.

The National Highway Traffic Safety Administration (NHTSA, then called the National Traffic Safety Agency) required all new passenger cars to have safety belts beginning on January 1, 1968. This requirement was included in one of the agency's initial Federal motor vehicle safety standards, which was based on the laws of 32 states. NHTSA required other types of new motor vehicles, such as sport utility vehicles, vans, and trucks, to have safety belts beginning on July 1, 1971.

I hope this information is helpful.

Sincerely,

Samuel J. Dubbin Chief Counsel

ref:208 d:4/26/96

ID: nht72-6.33

DATE: 07/13/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Airport Truck Center Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of May 23 to Mr. Schneider regarding incomplete vehicle certification and your responsibility as a truck dealership.

The regulation to which you refer is 49 CFR parts 568, Vehicles Manufactured in Two or More Stages. It applise to incomplete vehicle manufacturers, intermediate manufacturers, and final-stage manufacturers of vehicle manufactured to two or more stages. Truck dealers who perform these manufacturing functions are required to meet these requirements, a copy of which is enclosed for your information. The regulations do not apply to a truck dealer who does not modify completed vehicle received from a manufacturer or distributor.

Other federal motor vehicle safety regulations and standards are (Illegible Word) in Chapter V of Title 49, Code of Federal Regulations.

ID: nht89-1.1

TYPE: INTERPRETATION-NHTSA

DATE: 01/01/89 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: MARK JANSEN -- CHEVY DUTY PICKUP PARTS

ATTACHMT: LETTER DATED 11-03-88 TO M.J. MIZEJEWSKI, FOREIGN MARKETING SPECIALISTS, INC., FROM E.Z. JONES, CHIEF COUNSEL, NHTSA

TEXT: This is in reply to your letter of September 17, 1988, to Taylor Vinson of this Office. You would like to have parking lamp and tail lamp lenses "remanufactured" for use on 1947-66 Chevrolet and GMC pickup trucks, and have requested our views.

We assume that you wish to have lenses manufactured to replace original equipment lenses on the trucks produced in the years indicated. Essentially, your operation appears unaffected by the requirements of this Department. The Federal motor vehicle lig hting standard applies only to lenses intended to replace original lenses on vehicles manufactured on and after January 1, 1972, and would not cover lenses for use on 1947-66 trucks. However, if the lenses you intend to manufacture are interchangeable w ith those on vehicles manufactured on and after January 1, 1972, you may have an obligation to ensure that they meet Federal requirements. If this is the case, we would be pleased to advise you further.

Notwithstanding the foregoing, all replacement lenses are equipment that is subject to Federal notification and remedy provisions if they incorporate a defect that relates to motor vehicle safety. In your case, this likelihood may be remote as the item concerned is a simple one, but attention should be paid to quality control.

ID: nht73-6.12

DATE: 06/08/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: RVI Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of May 18, 1973, concerning a defect notification campaign involving furnaces manufactured by Suburban Manufacturing Company of Dayton, Tennessee, that have been used in recreational vehicles. You ask whether the obligation of the individual vehicle manufacturers under the Safety Act and applicable regulations may be met if the appropriate documents and notices are sent or filed by Suburban Manufacturing.

Suburban Manufacturing Company may prepare and submit to NHTSA or mail to purchasers, on behalf of the individual vehicle manufacturers, the information required by 49 CFR Part 573 "Defect Reports," 49 CFR Part 577, "Defect Notification," and Section 113 of the Safety Act (15 U.S.C. 1402). However, the requirements must be met as they apply to manufacturers of motor vehicles, and not manufacturers of equipment. Moreover, the vehicle manufacturers themselves will still be responsible if any of the documents filed or sent by Suburban Manufacturing Company fail to fully conform to all applicable requirements.

Sincerely yours,

May 18, 1973

Lawrence R. Schneider, Esq. Chief Counsel, NHTSA

Dear Larry:

At present a notification of defect campaign is being carried on in regard to NT32 furnaces manufactured by Suburban Manufacturing Company of Dayton, Tennessee. These furnaces have been sold to many different recreational vehicle manufacturers. We are pleased to note that Suburban Manufacturing Company has indicated a willingness to send all of the notices to purchasers, supply the parts required to repair the defect and bear the entire cost.

The only concern various manufacturers have expressed is that they want to be sure that their obligations under Section 113(d) of the Safety Act and Part 573 - Defect Reports - have been met if the necessary reports are filed by Suburban Manufacturing Company.

It would be appreciated if you would verify our belief that Suburban's reporting will be sufficient. I will undertake to convey your opinion to the RV companies involved.

Sincerely, David J. Humphreys RVI Washington Counsel

cc: Messrs. F. M. Radigan, P. Shrake, A. Spreen and W. Bigelow

ID: 19795.rbm

Ms. Kristin M. Werth
Weinberger & Kanan
Mile High Center, Suite 1910
1700 Broadway
Denver, CO 80290

Dear Ms. Werth:

This responds to your letter requesting an interpretation of Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection. Specifically, you asked for a description of how the date of manufacture is defined under the standard. You expressed particular concern about the parts of the standard that mandate the installation of air bags and warning labels.

For purposes of Standard No. 208, as well as the other Federal motor vehicle safety standards, the date of manufacture is the date on which the assembly and other manufacturing operations are completed for a motor vehicle. See 49 CFR Part 571.7 and 49 CFR Part 567.4(g)(2) and (5). Therefore, the "manufactured date" of a vehicle would typically be the production date at the vehicle manufacturer's factory.

The exception is a vehicle manufactured in two or more stages for which special provisions apply. "Incomplete vehicles" may be completed to 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. ⁽¹⁾

I hope the above information is responsive to your inquiry. Should you have any further questions or need any additional information regarding this matter, please feel free to contact

Ms. Rebecca MacPherson of my staff at this address or by telephone at (202)366-2992.

Sincerely,
Frank Seales, Jr.
Chief Counsel
ref:208
d.4/17/2000

1. See 49 CFR sections 567 and 568. Note that section 568.6 specifies that this provision shall be superseded by any conflicting provisions of a standard that applies by its terms to vehicles manufactured in two or more stages. FMVSS No. 208 has no such provision.

ID: ward.ztv

L. Taylor Ward, III, Esq.
Vice President & General Counsel
Southeast Toyota Distributors, LLC
100 N.W. 12^th Avenue
Deerfield Beach, FL 33442

Dear Mr. Ward:

This is in reply to your letter of February 7, 2003, relating to motor vehicle distributors who add accessory equipment to new vehicles before they are sold. You are concerned specifically about accessory equipment produced by someone other than the manufacturer of the vehicle. This equipment includes "audio systems, tires, wheels, cruise control, trailer hitches, luggage racks, running boards, spoilers, truck bed liners, and convenience equipment." You are unclear "where [distributors] fit under the [TREAD] Acts definitions, and what reports are required of them for the non-Toyota, domestic accessories they install." You believe that distributors of Toyota cars and trucks "should logically only be responsible for reporting information on non-Toyota parts and accessories they install."

The early warning reporting (EWR) obligations of the TREAD Act (Subpart C of 49 CFR Part 579) apply to manufacturers of motor vehicles and motor vehicle equipment. They do not apply to distributors and dealers who only add accessory equipment to a vehicle before its first sale, in the nature of the equipment you listed: "audio systems, tires, wheels, cruise control, trailer hitches, luggage racks, running boards, spoilers, truck bed liners, and convenience equipment." The fact that the accessory equipment may not be factory authorized is irrelevant to this conclusion.

The manufacturer is responsible under EWR for reporting certain information it receives from distributors and dealers in the ordinary course of business, such as the number of field reports and warranty claims. But there is no independent obligation under EWR for distributors and dealers to report this, or any other information, to NHTSA under the EWR regulations.

If you have any questions, you may call Taylor Vinson of this Office (202-366-5263).

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:579
d.5/16/03

ID: nht74-5.10

DATE: 03/06/74

FROM: AUTHOR UNAVAILABLE; Francis Armstrong; NHTSA

TO: Flagg; Cooper; Hayner; Miller; Long & Owen

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of January 17, 1974, in which you enclose a sample of the wording your client intends to use on his certification label, and solicit our comments.

The proposal that would allow an alternative to the required listing of individual axles (Docket No. 73-31, Notice 1) would become effective on the date of publication of the final rule. Consequently, certification labels using a single value for identical weight ratings may not be used until that time. The label you submit for approval does conform to the current proposal. However, we are considering requiring the inclusion of tire-size designations on the certification label when the gross axle weight ratings are combined.

We have no objection to the additional information contained on the label on the right of the required information. As we understand it, this will lessen the likelihood of mislabeling by the assembler in the field. It would not be possible for him to use a label that would overrate the trailer.

ID: nht68-2.44

DATE: 12/17/68

FROM: AUTHOR UNAVAILABLE; Charles A. Baker; NHTSA

TO: Perley A. Thomas Car Works, Incorporated

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of November 19, 1968, to Mr. E. Leysath of this Bureau, concerning a clarification of the requirements of paragraph S3.4.3 of Federal Motor Vehicle Safety Standard No. 108.

As you indicated, paragraph S3.4.3 of initial Standard No. 108, which was published in the Federal Register on February 3, 1967, required that tail lamps, license plate lamps, and side marker lamps be illuminated when the headlamps are illuminated. The effective date of the initial standard was January 1, 1968. However, on December 16, 1967, an amendment to the initial standard was published in the Federal Register. This amendment delayed the effective date of paragraph S3.4.3 until May 1, 1968, and in addition revised that paragraph to require, as a minimum, that the fail lamps be illuminated when the headlamps are illuminated. Therefore, the requirements of paragraph S3.4.3 were not applicable to vehicles manufactured during the period of January 1, 1963 through April 30, 1968. During that period, selection of the lamp switching arrangement was at the option of the vehicle manufacturer.

Thank you for writing.

ID: nht88-1.38

TYPE: INTERPRETATION-NHTSA

DATE: 02/11/88

FROM: JERRY SMITH -- MINNESOTA BODY AND EQUIPMENT CO

TO: SHARON L. FORD -- HEAD START DIRECTOR SOUTHEAST IOWA ACTION ORGANIZATION, INC.

TITLE: FEDERAL INTERPRETATION OF SCHOOL BUS USER'S

ATTACHMT: ATTACHED TO LETTER DATED 08/26/88 TO R.C. ROAST FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 108; LETTER DATED 03/18/88 TO CHIEF COUNCIL -- NHTSA, FROM R C ROST RE REQUEST THAT HEADSTART BUSES NOT BE REQUIRED TO HAVE ROOF WARNING LIGHTS IF A COLO R OTHER THAN SCHOOL BUS YELLOW IS USED, OCC - 1763; LETTER DATED 12/21/77, TO JAMES TYDINGS FROM JOSEPH J LEVIN; LETTER DATED 02/25/88 TO SHARON FORD, FROM JERRY SMITH; UNDATED BROCHURES ON SCHOOLBUS BY WAYNE CORPORATION

TEXT: Dear Sharon:

As per our telephone conversation of February 9, 1988, I am enclosing copies of communications regarding and/or effecting what type of bus that can be sold to, or purchased by the Head Start organization.

Please note that this is not Minnesota Body Company's policy, nor is it our wish to cause you any inconvenience. However, due to the interpretation by the U.S. Department of Transportation, we are bound to provide a vehicle that meets all applicable sch ool bus criteria including warning lights CATCH 22. I further realize that warning lights are not allowed in Iowa for non-school use. Therefore, the warning lights would have to be removed or de-activated before you placed the bus in service.

Please let me know if you have any questions, or if I can be of further service

Sincerely,

Dear Sharon,

I have contacted the following people in an effort to resolve the interpretation of school bus user's etc.

Dwight R. Carlson Assistant Chief Bureau of School Administration and accreditation Grimes State Office Bldg Des Moines, Iowa 50319-0146 (515) 281-5811

J.P. Golinvaux District Representative Iowa Department of Transportation Air and Transit division State Capitol Des Moines, iowa 50319 (515) 281-4265

Jerry Smith

ID: nht75-2.13

DATE: 06/04/75

FROM: AUTHOR UNAVAILABLE; James C. Schultz; NHTSA

TO: Volvo of America

TITLE: FMVSS INTERPRETATION

TEXT: Please forgive the delay in responding to your letter of March 24, 1975, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 110, Tire Selection and Rims -- Passenger Cars.

You have inquired whether the placard required by S4.3 of the standard may display information in addition to the items specified in S4.3(a) through (d). The NHTSA has no objection to such placarding, provided that the additional information is set apart from, not placed among, the required items.