ID: nht91-2.30

DATE: March 13, 1991

FROM: Jamie McLaughlin Fish -- Director, Intergovernmental Affairs, NHTSA

TO: Bill McCollum -- U.S. House of Representatives

TITLE: None

ATTACHMT: Attached to letter dated 6-18-81 from Frank Berndt to Roy Littlefield (Std. 119); Also attached to letter dated 1-7-90 from Perry E. Faulkner to William "Bill" McCollum

TEXT:

Thank you for your inquiry on behalf of your constituent, Mr. Perry Faulkner. Mr. Faulkner requested a written interpretation about whether casings imported into this country are required to have the "DOT number." A "casing" means a used tire to which additional tread may be attached for the purpose of retreading. As explained more fully below, casing for retreaded passenger car tires must have the DOT symbol, but casings for tires for use on vehicles other than passenger cars (referred to as "truck tires" in this letter) are not required to have the DOT symbol.

At the outset, I note that Mr. Faulkner's letter stated that the "DOT number" on a tire indicates that the Federal excise tax has been paid. That statement is inaccurate. The "DOT number" on a tire only represents the manufacturer's or retreader's certification of compliance with this agency's standards and regulations. If Mr. Faulkner wants further information about Federal excise taxes on tires, he may wish to contact the Internal Revenue Service, since that agency administers the Federal excise taxes.

Mr. Faulkner is mixing two different types of markings when he refers to a "DOT number." The first type of marking is the symbol "DOT." This marking by a tire manufacturer or retreader on a tire is a certification that the tire complies with an applicable Federal motor vehicle safety standard. Federal safety standards applicable to tires include Standard No. 109 for new passenger car tires, Standard No. 117 for retreaded passenger car tires, and Standard No. 119 for new truck tires.

Standard No. 117 (the retreaded passenger car tire safety standard) includes a requirement that all passenger car tire casings to be retreaded must include the symbol "DOT." See S5.2.3(a). Therefore, it is illegal to sell or import into this country any passenger car tire casings that are not marked with the symbol "DOT." However, none of our Federal safety standards set forth requirements for retreaded truck tires. Since there is no standard for retreaded truck tires, there is no requirement that casings for retreaded truck tires be marked with the DOT symbol. I have enclosed a June 18, 1981 letter to Mr. Roy Littlefield that offers a more detailed discussion of this issue.

The second type of marking to which Mr. Faulkner referred was the tire identification number specified in Part 574. This number identifies the manufacturer or retreader of the tire, along with the date of manufacture or retread and other attributes of the tire. A tire identification number is not required on any casing: Standard No. 117 does not require this marking on passenger car casings, and as explained above, there is

no Standard for casings for truck tires. Please note, however, that Part 574 requires all finished retreads, including retreaded truck tires, to be marked with the retreader's identification number.

I hope this information is helpful. Please let me know if you have any further questions or need some additional information on this subject.

ID: nht91-2.31

DATE: March 14, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Delbert N. Pier -- Legislation and Compliance Coordinator, Hyundai America Technical Center, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 2-11-91 from Delbert N. Pier to Paul Jackson Rice (OCC 5720)

TEXT:

This is in reply to your letter of February 11, 1991, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

With respect to a contemplated headlamp design using a standardized replaceable light source, you have asked "whether the bulb fixture can be rotated approximately 11 degrees", and have informed us that this will not change the "constants . . . or the relationship of the terminals to the constants."

Standard No. 108 does not specify the orientation of replaceable light sources in headlamps; the socket in the reflector may be in any orientation. In the configuration you present, for the bulb assembly, the terminals appear to remain perpendicular to the base and parallel within plus or minus 1.5 degrees as required in Figure 3-3. The rotation of the socket (in the reflector of Figure 3-7, is not regulated and, therefore, is acceptable under Standard No. 108.

ID: nht91-2.32

DATE: March 14, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Loren Thomson -- Thomson & Weintraub

TITLE: None

ATTACHMT: Attached to letter dated 9-14-90 from Loren Thomson to Dorothy R. Nakama (OCC 5213)

TEXT:

This responds to your letter to Dorothy Nakama of my staff in which you asked for an explanation of the responsibilities of installers and repairers of motor vehicle glazing. I apologize for the delay in this response. In as subsequent telephone conversation with Ms. Nakama, you asked that we provide a response to the following two questions:

1) Would it be a violation of Federal law if, after fixing a broken or cracked windshield, an aftermarket business still did not make the wind- shield comply with Federal Motor Vehicle Safety Standard No. 205?

2) What would be the consequences if an installer knowingly installed in a motor vehicle new glazing that did not comply with Standard No. 205?

Your questions are addressed below.

By way of background information, section 103 of the National Traffic and Motor Vehicle Safety Act of 1966 (Safety Act, 15 U.S.C. 1392) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue safety standards for new motor vehicles and new motor vehicle equipment. One of the safety standards we have issued under this authority is Standard No. 205, Glazing Materials (49 CFR S571.205). Standard No. 205 establishes performance requirements for all windows (called "glazing" in the standard) in new motor vehicles and for all new replacement windows for motor vehicles.

Section 108(a)(1)(A) of the Safety Act (15 U.S.C. 1397(a)(1)(A)) specifies that no person may manufacture, import. sell, or introduce into interstate commerce any new vehicle or new replacement window that does not conform with the performance requirements of Standard No. 205. Pursuant to section 108(b)(1) of the Safety Act (15 U.S.C. 1397(b)(1)), this prohibition no longer applies to the motor vehicle after the vehicle is sold to a consumer. However, both before and after the first sale to a consumer, section 108(a)(2) of the Safety Act (15 U.S.C. 1397(a)(2)) provides that: "No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . . . "

Your first question asked whether it would be a violation of Federal law if, after fixing a broken or cracked windshield (by repairing instead of replacing it), an aftermarket business still did not make the windshield comply with Federal Motor Vehicle Safety Standard No. 205. The answer depends upon whether or not the vehicle with the broken or cracked

windshield has already been sold to a consumer.

If the vehicle has not yet been sold to a consumer, the "aftermarket business" would violate section 108(a)(1)(A) of the Safety Act if the vehicle with the repaired or replaced windshield did not comply with Standard No. 205 in all respects. As noted above, that section of the Safety Act prohibits any person from manufacturing, selling, importing, or introducing into interstate commerce any new vehicle that does not comply with Standard No. 205. Thus, even if a windshield is broken while a vehicle is being delivered from the factory to a new car dealer, the windshield that is in the new vehicle when it is delivered to the first purchaser must meet all requirements of Standard No. 205.

Once the vehicle has been sold to a first purchaser for purposes other than resale, any repairs or replacement of the windshield would not violate the "render inoperative" prohibition in the Safety Act. I have enclosed a September 3, 1981 letter to the National Glass Dealers Association explaining that NHTSA does not consider repairing a damaged windshield to constitute rendering inoperative with respect to Standard No. 205, EVEN IF the repaired windshield does not meet the requirements of the standard once repaired. This is because the agency considers the object or event which damaged the windshield in the first place, not the repair shop, to have rendered the windshield inoperative with respect to Standard No. 205. Upon reconsideration, we reaffirm this interpretation.

Your second question asked about the consequences of an installer knowingly installing in a motor vehicle new glazing that did not comply with Standard No. 205. This would be a violation of section 108(a)(1)(A) of the Safety Act, because the installer would be introducing into interstate commerce an item of motor vehicle equipment (the windshield) that did not comply with the applicable safety standard. By so doing, the installer would be subject to a civil penalty of up to $1,000 for each time it installed a noncomplying windshield, per section 109 of the Safety Act (15 U.S.C. 1398).

I hope this information is helpful. If you have further questions or need additional information on this subject, please feel free to contact Dorothy Nakama of my staff at this address or by telephone at (202) 366-2992.

ID: nht91-2.33

DATE: March 14, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: William F. Canever -- Staff Attorney, Office of General Counsel, Ford Motor Company

TITLE: None

ATTACHMT: Attached to letter dated 6-1-90 from William F. Canever to Stephen P. Wood (OCC 5713)

TEXT:

This responds to your letter concerning Ford's plan to allocate MY 1986 light truck credits to cover MY 1985 and MY 1989 shortfalls. For each of those model years, manufacturers have the option of complying with separate 4x4 and 4x2 standards or a combined standard. Ford elected to comply with the separate standards for MY 1985 and the combined standard for MY 1986 and MY 1989. The MY 1986 credits are applied in the plan on a prorated basis to MY 1985.

In response to your letter, we have reviewed Ford's credit allocation plan in light of 49 CFR S 535.4(e). That section provides, among other things, that "(c)redits may not be applied between classes of light trucks, except as determined by the Administrator to account for changes made in the definitions of classes between model years." Since Ford's plan involves applying credits earned by exceeding the MY 1986 combined standard to shortfalls incurred against the MY 1985 separate 4x4 and 4x2 standards, we have considered whether the plan represents a cross-class application of credits that is prohibited by S 535.4(e). As discussed below, we have concluded that Ford's allocation plan is not prohibited.

In your letter, you suggest that the regulatory scheme creates two methods of complying with light truck CAFE standards and not three classes of light trucks. You also state that the term "class" is nowhere applied to the combined light truck fleet. You conclude that there is no cross-class application of credits.

We do not agree with your suggested analysis. Section 535.3(a)(4) states that the term "class of light trucks" is used in accordance with the determinations in Part 533 of this chapter. Section 535.4(b) then indicates that credits are earned "whenever the average fuel economy for a class of light trucks manufactured by a manufacturer exceeds an applicable average fuel economy standard established in Part 533 of this chapter." The term "class" in Part 535 thus refers to each possible grouping of light trucks that is averaged together for determining compliance with CAFE standards. Looking at Part 533, there are, in fact, six classes of light trucks for the model years in question: (1) Combined captive import, (2) Combined other, (3) 2-wheel drive captive import, (4) 2-wheel drive other, (5) 4-wheel drive captive import, and (6) 4-wheel drive other.

While we do not agree with your suggested analysis, we believe that there is ambiguity with respect to how S 535.4(e) applies to the factual sitation at issue. First, Ford's plan involves overlapping classes.

Thus, while there is a degree of cross-class application of credits, it is limited. Second, NHTSA has never addressed in rulemaking the issue of

whether manufacturers should, in effect, forfeit credits as a result of choosing particular compliance options for particular years. This situation is analagous in some respects to the issue of whether forfeiture of credits should occur where NHTSA changes the definitions of classes between model years. In that situation, the agency decided, based on its understanding of statutory intent, against forfeiture. Third, in a letter dated April 26, 1988, NHTSA approved a Ford carryback plan for MY 1985 light trucks which set forth Ford's proposed allocation methodology. While the agency did not expressly address that methodology in the letter approving the plan, Ford could have assumed that the agency considered the proposed allocation to be permissible.

Given the ambiguity surrounding this issue, NHTSA believes that it is appropriate to decide the issue, for now, in favor of the manufacturer. The agency believes that this is a type of ambiguity that should be resolved, for the future, by rulemaking. However, the issue will become moot, at least for the time being, since, beginning with the MY 1992 light truck CAFE standards, NHTSA decided not to set optional separate two-wheel drive and four-wheel drive standards. Should the agency decide to issue optional CAFE standards at some future time, it will address this issue in rulemaking.

For now, NHTSA will treat situations where a manufacturer changes compliance options between model years in the same manner as situations where the agency changes the definitions of classes between model years. In both types of situations, NHTSA will follow the policy first announced in a November 8, 1979 notice of interpretation (44 FR 64943), and reaffirmed in a December 18, 1980 Federal Register notice (45 FR 83233), of attempting to assure that credits are applied to offset shortfalls on the same types of vehicles which generated the credits.

Ford's plan to apply, on a prorated basis, credits earned by exceeding the MY 1986 combined standard to shortfalls incurred against the MY 1985 separate 4x4 and 4x2 standards, is consistent with the examples set forth in the November 1979 and December 1980 notices. Ford's plan then to apply remaining MY 1986 credits to its MY 1989 shortfall, incurred against the MY 1989 combined standard, does not involve any cross-class application of credits. I therefore conclude that Ford's allocation plan is not prohibited.

ID: nht91-2.34

DATE: March 14, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: George Smyth -- Municipal/Refuse Fleet Sales, Palm Peterbilt-GMC Trucks, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 7-30-75 from Richard B. Dyson (signed by Z. Taylor Vinson) to Byron A. Crampton; Also attached to letter dated 8-27-68 from Eugene B. Laskin to Barry G. Seitz (Std. 203; Std. 204); Also attached to letter dated 3-4-68 from George C. Nield to Earl Allgaier; Also attached to letter from Joseph R. O'Gorman to Nathan Darby

TEXT:

This responds to your letter requesting an opinion on the legality of modifying left-hand drive trucks by adding right-hand drive. I apologize for the delay in our response.

We assume that your question is directed towards municipal refuse trucks. Because of budget constraints, we understand that refuse trucks with dual controls are increasing in popularity because they allow one-man trash collection, rather than the two or three man crews on older trucks, and that 3,000 to 4,000 such trucks are manufactured annually. We also understand that about 80% of these trucks are equipped with a fold-down seat at the auxiliary driving position, and that the right hand driving position is used in start-stop slow speed operation in residential neighborhoods, while the left hand position is used in driving to and from work sites.

According to your letter, the trucks are manufactured with left-hand drive only, and are then modified by body companies for the end user. The modification, as we understand it, is to add a steering wheel to the right-hand side, along with an accelerator, brake pedal, horn, hazard warning, and turn signals. This indicates that the vehicle may be operated from both sides. You commented that "the unsafe part of the conversion, as we see it, is that the windshield wiper controls, parking brake, start and stop switch, along with all gauges are on the lefthand side out of reach when the driver is in the drivers position." The following represents our opinion based on the facts provided in your letter.

Standard No. 101, Controls and Displays, specifies requirements in relation to the driver. It requires that if certain controls are furnished, they must be operable by the driver, and that if certain displays are furnished, they must be visible to the driver. See section S5.1. (Since your letter concerns trucks, it should be noted that Standard No. 101's display requirements do not apply to vehicles with a GVWR of 10,000 pounds or higher.) However, Standard No. 101 does not require that the driver's position be on a particular side of a vehicle. Thus, it permits a vehicle to be either left-hand or right-hand drive. The issue raised by your letter is how our standards apply when a vehicle is both left-hand drive and right-hand drive, i.e., the vehicle has two driver positions.

The term "driver" is defined as "the occupant of a motor vehicle seated immediately behind the steering control system." See section 571.3. It is our opinion that the providing of a steering control system is ordinarily sufficient to create a driver's position, but that for vehicles with two driver's positions, the requirements specified in relation to the driver need be met only from the position intended by the original manufacturer as the primary driving position. However, if that manufacturer, or a subsequent converter, intends the driving positions to be used interchangeably under similar driving conditions so that neither driving position could be considered as primary over the other, then all Federal requirements would have to be met, e.g., the requirement in Standard No. 207 Seating Systems that a seat be provided for the driver.

We addressed this issue previously in a letter sent July 30, 1975 to Byron A. Crampton of the Truck Body and Equipment Association, Inc., in which the agency informed Mr. Crampton that a dual-control garbage truck that contained an auxiliary driver's position on the right side of the vehicle, with a separate set of controls, need not have a seat at the auxiliary position, and that access to such controls as the heater, wipers, and lights from this position was not required. Earlier, in an interpretation issued in 1968, with respect to driver education cars with dual controls, the agency considered the "driver, of such a vehicle to be the person seated behind the primary controls.

We appreciate your concern with safety that occasioned your letter. You may be reassured to know that the National Truck Equipment Association has had no reports of accidents or injuries due to the dual control feature of refuse trucks. However, it is possible that the agency could institute rulemaking in the future that would require a full set of controls and seats in dual control vehicles.

Your second question relates to noise standards. The in-cab noise standard is administered by the Department's Federal Highway Administration (FHWA). We have forwarded a copy of your letter to that agency's Office of Motor Carrier Safety so that they can respond to your question.

I hope that this information is useful to you.

ID: nht91-2.35

DATE: March 14, 1991

FROM: David E. McAllister -- Manufacturers Representative

TO: Paul Jackson Rice -- U.S. Department of Transportation, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4-3-91 from Paul Jackson Rice to David E. McAllister (A37; Std. 108)

TEXT:

As a supplier to the U.S. Postal Service for lights, I have been asked about the legality of the High Mount Stop Light on the new Long-Life Vehicles. The only time this light comes on is when the driver steps on the brakes. Since the vehicle makes numerous stops, would it be legal for this light to flash and make drivers behind the vehicle more aware?

Thank you for a ruling on this request.

ID: nht91-2.36

DATE: March 18, 1991

FROM: George Ziolo

TO: Administrator, US DOT/NHTSA

TITLE: Re Petition for Rectification of an Error, FMVSS 208

ATTACHMT: Attached to letter dated 5-8-91 from Paul Jackson Rice to George Ziolo (A37; Std. 208)

TEXT:

I advise clients of NHTSA's requirements.

It is my understanding that the seat belt warning system furnished with manual belts need be activated only by the driver's belt in vehicles manufactured between 1-1-72 and 8-31-89 inclusive, in accordance with S7.3.

However, your 49 CFR, revised as of October 1990, requires that a seat belt warning system furnished with manual belts need be activated not only by the driver's belt but also by

the front outboard passenger's belt in vehicles manufactured between 1-1-72 thru 8-31-73 inclusive (S4.1.1.3.1(a) and S4.1.1.3.2); and by

the front outboard and front center passenger's belt, in vehicles manufactured 9-1-73 thru 8-31-89 (S4.1.2.3.1(a), S4.1.2.3.1(b), and S4.1.2.3.2).

In view of the fact that the above represents a more severe requirement than the original one in effect on 1-1-72, and the fact that NHTSA has not in the past retroactively tightened its requirements, the above appears to be an inadvertent error, particularly because S7.3 makes no mention of seating positions other than the one for the driver.

If the above is an error, please confirm this to me for my record and use.

If the above is not an error, please advise me as to when you published this change in the Federal Register. If you have not published it in the Federal Register, I request that you do, including the effective dates of the changed requirement for compliance purposes.

I make this request as a petition under provisions you find applicable. If you wish that I resubmit this petition in another format, please advise me which format is appropriate.

This matter is very important to me and my clients for reasons of both compliance and product liability.

ID: nht91-2.37

DATE: March 18, 1991

FROM: Arthur H. Neill -- Chief, Crash Avoidance Division, Vehicle Safety Standards, NHTSA

TO: Anthony J. Lalikos -- Project Engineer, Titeflex Corporation

TITLE: None

ATTACHMT: Attached to letter dated 5/12/94 from John Womack to Nicholas S. Copass (A42; Std. 106), letter dated 9/29/93 from Nicholas S. Copass to David Elias (OCC-9161), and letter dated 3/6/91 from Anthony J. Lalikos to Vernon G. Bloom

TEXT:

The designation that you recently submitted in accordance with the requirements of Federal Motor Vehicle Safety Standard No. 106, BRAKE HOSES,

(x) Has become accepted and recorded. Thank you. (Reference: Your letter dated March 6, 1991; your symbol "Stylized Logo" (=T with hose tail)).

( ) Cannot be recorded because another company has previously submitted the same or a very similar designation. Please submit a different one.

ID: nht91-2.38

DATE: March 19, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Jerry Tassan

TITLE: None

TEXT:

This responds to a telephone inquiry in which you explained to Mr. Stephen Wood, the Assistant Chief Counsel for Rulemaking, that your truck rental company is considering lowering the Gross Vehicle Weight Rating (GVWR) of some of its used trucks so that a renter need not have a commercial driver's license to operate them. You asked how the regulations of this agency, the National Highway Traffic Safety Administration (NHTSA), would apply to such an action. As explained below, because only a manufacturer can assign a GVWR, any modification of a vehicle's GVWR by parties that are not manufacturers would have no legal effect.

By way of background information, NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act) to issue Federal motor vehicle safety standards that set performance requirements for new motor vehicles and items of motor vehicle equipment. NHTSA is not authorized to certify or approve motor vehicles or motor vehicle equipment for compliance with our Federal safety standards. Instead, under the Safety Act, each manufacturer of motor vehicles and motor vehicle equipment is responsible for certifying that its products meet all applicable safety standards.

The Certification requirements in 49 CFR Part 567 require each manufacturer to affix to the vehicle a label containing, among other things, the vehicle's GVWR. Under Part 567, the only parties that can assign or modify a vehicle's GVWR are the original manufacturer (S567.4(g)(3)), a final stage manufacturer (S567.5(c)(5)), or an alterer (S567.7(b)). Modifications of GVWR by any other parties would have no legal effect under Part 567. Accordingly, a vehicle owner that performs no manufacturing operations on a vehicle cannot modify the GVWR of the vehicle.

You should also be aware that another Federal authority - the Federal Highway Administration's (FHWA's) Office of Motor Carrier Standards - may regulate your attempts to lower a vehicle's GVWR. The FHWA regulates the licensing of operators of "commercial motor vehicles" under the Commercial Motor Vehicle Safety Act of 1986. I recommend you contact Mr. James Scapellato, Office of Motor Carrier Standards, KCS-1, FHWA, 400 Seventh Street, SW, Washington, D.C. 20590 if you have any further questions about driver licensing.

I hope this information is helpful. If you have any further questions about the GVWR assigned to vehicles, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

ID: nht91-2.39

DATE: March 19, 1991

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Leonard M. Anderson -- Vice President, Engineering, Miller Trailers, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 12-24-84 from Erika Z. Jones to Richard E. Bond (A29; Part 565); Also attached to letter dated 11-30-90 from Leonard M. Anderson to Paul Jackson Rice (OCC 5516); Also attached to letter dated 5-30-86 to Administrator, Attention VIN-Coordinator NHTSA, from Richard E. Bond (OCC 769)

TEXT:

This responds to your request for an interpretation of 49 CFR Part 565, Vehicle Identification Number - Content Requirements. More specifically, you asked whether a world manufacturer identifier (WMI) that was assigned to one manufacturer may continue to be used by a different manufacturer when it purchases the assets of the manufacturer to which the WMI was assigned. As explained below, the answer to your question is no.

Your letter set forth the following information. Miller Trailer, Inc. (Miller) is a trailer manufacturer that has been assigned a unique WMI, in accordance with 49 CFR S565.5(c). Oshkosh Truck Corporation (Oshkosh) is a manufacturer of primarily trucks and some specialized trailers. Oshkosh has also been assigned a unique WMI in accordance with 49 CFR S565.5(c). Oshkosh is purchasing Miller. Your question is whether Oshkosh can continue to use Miller's WMI to identify trailers Oshkosh produces at the facilities that were formerly used by Miller.

To answer this question, we must apply the regulatory provision of 49 CFR S565.4(a). That section provides that the WMI "shall uniquely identify the manufacturer, make and type of the motor vehicle if the manufacturer produces 500 or more motor vehicles of its type annually." NHTSA has previously interpreted the requirement that the WMI "uniquely identify the manufacturer as precluding the use of a WMI assigned to one manufacturer by any other manufacturer. For your information, I have enclosed a December 24, 1984 letter to Mr. Richard Bond, in which the agency explained that a newly-formed, wholly-owned subsidiary could not use the parent corporation's WMI to identify trailers formerly manufactured by the parent corporation.

With respect to your situation, this regulatory requirement means that the VIN assigned to each trailer manufactured by Oshkosh must identify Oshkosh as the manufacturer. This identification will facilitate the quick and accurate identification of the actual vehicle manufacturer in the event there is a need to do so.

Please note also that Oshkosh, upon manufacturing trailers that formerly were manufactured by Miller, has a responsibility to report any new types of motor vehicles that it produces. 49 CFR Part 566 requires manufacturers that have previously submitted identification information to keep their entries current by submitting revised information not later

than 30 days after the relevant changes occur. A copy of this part is also enclosed for your information.

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