ID: aiam2386

Dear Mr. Bishop: This is in response to your July 7, 1976, request for informatio regarding the applicability of Federal motor vehicle safety standards to 'rumble seat kits' for installation in passenger cars. The answers to your questions are as follows:; (1) 'Is there any Federal Motor Vehicle Safety Standards or Regulation that would preclude the installation of rumble seats in passenger cars?'; >>>The answer to your question is no.<<< (2) 'What are the current Federal Motor Vehicle Safety Standards an Regulations that would be specifically applicable to the installation of rumble seats in passenger cars?'; >>>Installation of the rumble seats could affect compliance of th vehicle with the following safety standards: Standard No. 207, *Seating Systems*, Standard No. 208, *Occupant Crash Protection*, Standard No. 209, *Seat Belt Assemblies*, Standard No. 210, *Seat Belt Assembly Anchorages*, and Standard No. 110, *Tire Selection and Rims*.; We are assuming that the rumble seats would be installed in complete vehicles that are already certified, in which case the alterer would be required to meet the requirements of 49 CFR Part 567. Section 567.7 requires one who alters a previously certified vehicle, prior to its first sale, (by other than readily attachable components) to affix an additional label to the vehicle, stating that the vehicle remains in compliance with all applicable safety standards after the alteration. It should be noted that any additional weight created by the rumble seats or a change in the distribution of weight could also affect the vehicle's compliance with other safety standards whose test procedures require a barrier crash test.; We also would point out that 49 CFR Part 575 requires manufacturers t provide consumer information regarding vehicle stopping distance, tire reserve load, and acceleration and passing ability, at the point of first sale of the vehicle and along with the purchased vehicle. The increased weight created by the rumble seats could require modification of the information that would have to be provided.<<<; (3) 'Is there any State or Local Motor Vehicle Safety Standards that t your knowledge may preclude the installation of rumble seats in passenger vehicles?'; >>>We are not aware of any State or local regulations that woul preclude installation of rumble seats in passenger vehicles.<<<; (4) Can you furnish a list of Government approved independent testin facilities for FMVSS compliance testing?'; >>>The National Highway Traffic Safety Administration (NHTSA) does no approve independent testing facilities, nor will it recommend that any particular testing center be utilized. You might wish to contact the American Association of Motor Vehicle Administrators concerning this subject, at 1201 Connecticut Avenue, N.W., Washington, D.C.<<<; (5) 'Can the NHTSA make any design recommendations related to th installation of rumble seats in passenger vehicles?'; >>>The NHTSA does not provide engineering expertise regarding th manufacture of motor vehicles or motor vehicle equipment. However, the agency will answer specific questions that a manufacturer might have concerning the basis for a particular performance requirement.<<<; (6) 'Is there any future or pending legislation that may be related t the installation of rumble seats in passenger vehicles?'; >>>At the present time there is no pending Federal legislation relatin to the installation of rumble seats in passenger vehicles, nor is any such legislation anticipated by the NHTSA in the immediate future.<<<; The statements made above are directed primarily to the situation i which rumble seats would be installed prior to first sale of the vehicle, and in which the vehicle would have to be certified as being in compliance with all applicable motor vehicle safety standards. Please note, however, that the aftermarket installation of rumble seats might also be subject to Federal requirements.; Section 108 (a) (2) (A) of the National Traffic and Motor Vehicl Safety Act of 1966 provides that, with one exception, 'no manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or 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. . . .' Therefore, no manufacturer, distributor, dealer, or repair business may install the rumble seats in a motor vehicle if he knows that such installation would alter the vehicle's compliance with any safety standard. For example, installation of rumble seats could possibly affect components of the vehicle that are subject to the requirements of safety standards such as Standard No. 108, *Lamps, Reflective Devices, and Associated Equipment*, or Standard No. 301, *Fuel System Integrity*.; Sincerely, Frank Berndt, Acting Chief Counsel

ID: aiam3529

Dear Mr. McCalmon: This responds to your letter to Mr. Kratzke of my staff concerning th Federal requirements for vehicle wheels that are to be imported into the United States. You noted in your letter that the wheels would be for 'original equipment on passenger vehicles and non-passenger vehicles (recreation vehicles).' There are two Federal Motor Vehicle Safety Standards which apply to wheel rims. There are no standards applicable to the rest of the wheel assembly, however.; The two applicable standards are No. 110, *Tire selection and rims passenger cars,* and No. 120, *Tire selection and rims for motor vehicle other than passenger cars*. I have enclosed copies of both standards, along with Standard Nos. 109 and No. 119, which are applicable to tires. For those passenger car rims you manufacture there are two requirements, specified in section S4.4 of Standard No. 110. First, the rim must be constructed to the dimension of one of the rims that is listed under definition of a test rim in Standard No. 109. This means that the rim must comply with the dimensional specifications shown for that rim size in the current publications of specified standardization organizations, such as the Tire & Rim Association, the European Tyre and Rim Technical Organization, or the Deutsches Institut fur Normung. Second, in the event of a rapid loss of inflation pressure with the vehicle travelling in a straight line at 60 miles per hour, the rim must retain the deflated tire until the vehicle can be stopped with a controlled braking applications.; For those rims you manufacture for use on vehicles other than passenge cars, Standard No. 120 also specifies two requirements: The first requirement, set forth in section S5.1.1, is that the rims on a vehicle must correspond with the size tire on the vehicle, i.e., be listed as suitable by the tire manufacturer, pursuant to either Standard No. 109 or No. 119. This would be done in the publications of the standardization organizations, as explainted (sic) above. This requirement is the responsibility of the vehicle manufacturer, since only it knows what size tires will actually be on the vehicle. The second requirement, set forth in section S5.2, is that the second requirement,, set forth in section S5.2, is that the rim must be marked with certain specified information.; When a rim manufacturer determines that its rims comply with th requirements outlined above, it may certify the rims and sell them in the United States. In your letter, you inaccurately stated that there is no a(sic) specific DOT certification for rims. While there is no specific DOT certification number, as required by some other standards for item of equipment other than rims, a manufacturer must always certify that each item of motor vehicle equipment complies with all applicable Federal motor vehicle safety standards, pursuant to section 114 of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1403)(copy enclosed). That section specifies that the certification for items of motor vehicle safety equipment, including rims, may be in the form of a label or tag on the item, or on the outside of a container in which the item is delivered. All of your rims to be sold in this country must contain such a certification.; The United States does not use a certification process similar to th EEC, in which the manufacturer delivers the item to be certified to the governmental entity, and that entity tests the item to determine if it can be certified. Instead, in the United States, the individual manfuactuer(sic) must certify that the product complies with all applicable standards. Further, this agency does not require that a certification be based on actual tests of the equipment, we only require that the certification be made with the exercise of due care on the part of the manufacturer. It is up to the individual manufacturer to determine in the first instance exactly what data or information it needs to allow it to certify that the equipment meets all applicable Federal standards. Obviously, with respect to the requirements for rims, a manufacturer is not expected to test if the rims have the necessary markings or if the rim size is listed in one of the publications of a standardization organization.; Should you have any further questions about these standards, feel fre to contract me. If you need further information about the actual process of importing the rims into the United States or the form for the certification, you can contact the U.S. Customs Service Duty Assessment Division at 1301 Constitution Avenue, N.W., Washington, D.C. 20229.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam4428

Dear Mr. Anderson: This responds to your letter about Federa requirements for trailers. According to your letter, you are in the planning stages of becoming a manufacturer of, and dealer for, automobile trailers. The trailers would hitch to the back of automobiles and be designed to carry cargo. You noted that in response to an earlier inquiry, you received a copy of the handout entitled 'Information For New Manufacturers of Motor Vehicles and Motor Vehicle Equipment.' You stated that you are unclear just how this applies to automobile trailers. You asked what you need to do to comply with any applicable Federal regulations, and what regulations apply to trailers of the kind you plan to build. Trailers are considered motor vehicles under Federal law. As a manufacturer of motor vehicles, you would be required to submit identification information to the National Highway Traffic Safety Administration (NHTSA) under 49 CFR Part 566, Manufacturer Identification. You would also be required to certify that each trailer complies with all applicable Federal safety standards. The procedure is specified in 49 CFR Part 567. The following safety standards apply to trailers: Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, Safety Standard No. 115, Vehicle Identification Number--Basic Requirements, Safety Standard No. ll9, New Pneumatic Tires for Vehicles Other Than Passenger Cars, Safety Standard No. l20, Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars. The content requirements for the vehicle identification number are found at 49 CFR Part 565. In addition, trailers with certain braking systems must meet Safety Standard No. l06, Brake Hoses, Safety Standard No. 116, Motor Vehicle Brake Fluids, and Safety Standard No. l2l, Air Brake Systems. All of these safety standards are found in 49 CFR Part 57l. I hope this information is helpful. Sincerely, Erika Z. Jones Chief Counsel;

ID: aiam2319

Dear Mr. Buzzi-Ferraris: I am writing in response to your March 12, 1976, letter to Mr. Rober Aubuchon of this agency, concerning the application of Federal Motor Vehicle Safety Standard No. 119, *New Pneumatic Tires for Vehicles Other than Passenger Cars*, to motor driven cycles whose speed attainable in 1 mile is 30 mph or less.; You have inquired whether such vehicles may be equipped with tires tha --; >>>(i) 'Carry all the inscriptions required by labeling, plus th marking 'MAX SPEED' because speed restricted to less than 55 MPH -- S.6.5.'; (ii) 'Have passed the endurance test -- S.6.1, S.7.2 in accordance wit table III --- speed restricted service: 35 MPH'; (iii) 'have not been tested for high speed S.6.3-- in fact they ar speed restricted ...'<<<; an otherwise comply with the requirements of Standard No. 119. I assume that, where your letter refers to the marking 'MAX SPEED', yo intended 'MAX SPEED 35 MPH'. Although such labeling is not prohibited, the standard does not presently recognize a category of speed-restricted motorcycle tires. Tires for motor driven cycles are subject to the same performance requirements as other motorcycle tires. In particular, the schedule for endurance testing is that found in the 'motorcycle' entry of Table III, rather than the '35 m.p.h.' entry. Similarly, these tires are subject to the high speed performance requirements of S.6.3 without exception. An amendment of Standard No. 119 on this subject is being considered, but no firm decision has been made.; Standard No. 119 prohibits the manufacture of the tires that you hav described on and after March 1, 1975. Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other than Passenger Cars*, prohibits the manufacture of motor-driven cycles equipped with such tires on and after September 1, 1976.; Sincerely, Stephen P. Wood, Assistant Chief Counsel

ID: aiam3197

Dear Mr. Lust: This is in response to your conversation with Mr. Hugh Oates of m office concerning the manufacture and installation of replacement fuel tanks.; Enclosed please find (1) a copy of a letter concerning the lega implications of replacing a vehicle's fuel tank with a larger tank, (2) a copy of a letter concerning the legal implications of building and installing auxiliary fuel tanks which discusses issues also relevant to replacement fuel tanks and (3) a notice describing how to obtain copies of motor vehicle safety standards and regulations.; In addition to the points raised in the enclosed letters, I would lik to point out two additional factors. First, please note that if you go into the business of manufacturing replacement fuel tanks you must submit identifying information and a description of the items you produce to this agency in accord with 49 CFR Part 566 (copy enclosed).; Second, as you will note from the enclosed letters, a manufacturer o other person specified in the National Traffic and Motor Vehicle Safety Act who installs an auxiliary or replacement fuel tank in a new or used vehicle must not compromise the vehicle's compliance with relevant safety standards. Thus, in installing replacement fuel tanks you should be aware not only of any effect that your installation may have upon the vehicle's fuel system (see Federal Motor Vehicle Safety Standard 301-75, *Fuel System Integrity*), you should also be aware that your installation might affect, among other things, the vehicles braking system (see Safety Standard No. 105-75, *Hydraulic Brake Systems*) or the vehicle's weight as it relates to safety standards concerning tires (see Safety Standard No. 110, *Tire Selection and Rims*, applicable to passenger cars, and Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*).; I hope that you will find the enclosed material helpful. If you hav any further questions, please feel free to call Ms. Debra Weiner at my office at 202-426-2992.; Sincerely, Frank Berndt, Chief Counsel

ID: aiam1585

Dear Mr. Vidoli: This responds to your August 8, 1974, request for our opinion of th legality of the manufacture and sale of a device which frustrates the ignition function of seat belt assemblies in 1974 model passenger cars. The device, to be manufactured by the Chadamy Corporation under the name 'Buzz-Off', consists of two devices that are inserted in the ends of a seat belt assembly to simulate a buckling action.; The National Highway Traffic Safety Administration has promulgated n safety standard regulating the manufacture of your product. A standard does exist, however, which specifies requirements for occupant restraint systems. If one of your devices were installed in a vehicle prior to its first purchase for purposes other than resale, causing the interlock system not to be in compliance with the occupant crash protection standard, the person installing the device or offering the vehicle for sale would be in violation of Section 108(a)(1) of the National Traffic and Motor Vehicle Safety Act. That section prohibits the manufacture for sale, sale, or offer for sale of any motor vehicle or item of motor vehicle equipment that does not comply with applicable safety standards in effect on the date of their manufacture.; I would like to point out, that we estimate 10,000-15,000 individual died needlessly during 1973 because they were not wearing their seatbelts. Obviously, any device which disconnects a seat belt interlock could gravely increase the risk faced by the occupants of the motor vehicle. We cannot agree with your conclusion that people would not utilize your device to frustrate the interlock in highway driving.; I would also like to point out the recent Congressional action in whic the House of Representatives passed a law which would prevent a requirement for ignition interlock systems in future passenger cars. The final form of this law, pending Senate action, is not clear.; Yours truly, Richard B. Dyson, Acting Chief Counsel

ID: aiam2340

Dear Senator Hatfield: This is in response to your March 10, 1976, letter concerning th application of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other than Passenger Cars*, to the paver manufactured by Layton Manufacturing Company. The standard requires that the paver be equipped with ties of sufficient load rating and that these tires be certified by their manufacturer as complying with Standard No. 119, *New Pneumatic Tires for Vehicles Other than Passenger Cars*. Your constituent, Mr. Earl Sievers, has met with representatives of this agency to discuss the need for his company's paver to comply with Standard No. 120 and his difficulties in procuring the proper tires.; Your letter suggests that, generally, the paver is moved simply withi the confines of a construction site rather than in traffic. Nevertheless, the paver is designed and expected to be towed on the public highways. Indeed, Layton's own promotional materials stress this point:; >>>For municipalities who do not own their dump trucks or need extrem mobility without sacrificing hauling weight! ... Any truck can tow paver safely at highway speeds. ('exhibit 'C'' accompanying Mr. Sievers' letter of January 14, 1976.)<<<; This usage of the paver leads to the conclusion that the paver is 'motor vehicle' subject to all applicable Federal motor vehicle safety standards, including Standard No. 120. The conclusion is compelled by the definition of 'motor vehicle' in the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1391 et seq.). As a manufacturer of fewer than 10,000 motor vehicles in its most recent year of production, Layton is eligible to petition for a temporary exemption from Standard No. 120 on the basis of substantial economic hardship. For your convenience, I am enclosing a copy of 49 CFR Part 555, *Temporary Exemption from Motor Vehicle Safety Standards*, which sets out procedures for filling and processing such petitions.; Sincerely, Frank Berndt, Acting Chief Counsel

ID: nht92-8.17

DATE: March 26, 1992

FROM: Michael J. Sens -- Researcher, S.E.A., Inc.

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 4/17/92 from Paul J. Rice to Michael J. Sens (A39; Std. 206; Part 571; Part 567)

TEXT:

By way of this letter, I am seeking an interpretation of FMVSS 206, 214, and 216 as they would pertain to a 1985 Jeep CJ-7. The Jeep CJ-7 was classified (it is no longer in production) by its manufacturer, American Motors Corporation, as a "sport-utility vehicle". The vehicle came with a soft top and a removable fiberglass top option. The side doors are easily removable.

FMVSS 206, "Door Locks and Door Rentention Components," requires at S4. that "components on any side door leading directly into a compartment that contains one or more seating accommodations shall conform to this standard." It goes on to say, "However, components on folding doors, roll-up doors and doors that are designed to be easily attached to or removed from motor vehicles manufactured for operation without doors need not conform to this standard". My first question is: since the 1985 Jeep CJ-7's side doors are easily attached and removed by design for operation in a doorless manner, is it exempt from conformity to FMVSS 206?

FMVSS 214, "Side Door Strength," states at S2. that "this standard applies to passenger cars." The 1985 Jeep CJ-7 is defined by its manufacturer as a "sport-utility vehicle." This classification is not that of a "passenger car." My second question is: since the 1985 Jeep CJ-7 is classified as a "sport-utility vehicle," does FMVSS 214 apply to it?

FMVSS 216, "Roof Crush Resistance-Passenger Cars," states at S3. that "This standard applies to passenger cars." After stating that it does not apply to vehicles that conform to the rollover test requirements of S5.3 of standard 208, it continues, "It also does not apply to convertibles." My third question is: since the 1985 Jeep CJ-7 is classified as a "sports-utility vehicle" and is a convertible, does FMVSS 216 apply to it?

Please find enclosed two views of the type vehicle under discussion. The 1985 CJ-7 shows the soft-top package with the top down and the side doors removed. Unfortunately, I do not have an illustration of the 1985 CJ-7 with the optional hard snap-on top. However, the 1981 CJ-7 model photograph enclosed is typical of how the 1980's CJ-7 line appeared with the optional top.

Thank you in advance for your time and considerations on this issue. If you require additional information, do not hesitate to contact me.

Attachment

Photos and text pertaining to the 1981 and 1985 CJ-7 vehicles.

(Text and graphics omitted)

ID: nht88-3.67

TYPE: INTERPRETATION-NHTSA

DATE: 10/13/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: PAUL UTANS -- VICE PRESIDENT, GOVERNMENTAL AFFAIRS SUBARU OF AMERICA

TITLE: NONE

ATTACHMT: LETTER DATED 08/11/88 TO ERIKA Z. JONES FROM PAUL UTANS, OCC - 2405; LETTER DATED 12/01/86 TO FRANCOIS LOUIS FROM ERIKA Z. JONES, STANDARD 208; LETTER DATED 08/18/78 TO D. BLACK FROM JOSEPH J LEVIN, STANDARD 210, RE NOA 30

TEXT: Dear Mr. Utans:

This responds to your request for an interpretation of Standard No. 210, Seat Belt Assembly Anchorages (49 CFR S571.210). Specifically, you stated that Subaru would like to offer lap/shoulder belts at the rear outboard seating positions on mid-1989 mode l year station wagons sold in the United States. Standard No. 210 requires these station wagons to be equipped with an anchorage for the upper end of the upper torso portion of a lap/shoulder belt assembly at each forward-facing outboard seating position (S4.1.1) and requires such anchorages to be located within a specified range (S4.3.2). You stated that the station wagons would have a complying anchorage located in the specified area.

However, the upper torso portion of the lap/shoulder belt assemblies would not be attached to the required anchorages in the vehicles. Instead, Subaru would provide another anchorage outside of the range specified in Standard No. 210, and the upper tors o portion of the rear seat lap/shoulder belt assemblies would be attached to these additional anchorages. You stated your belief that, since Standard No. 208, Occupant Crash Protection (49 CFR S571.208) does not require manufacturers to install lap/shou lder belts in rear seating positions of passenger cars, Subaru's voluntary installation of rear seat lap/shoulder belts and additional anchorages for those belts is not subject to any of this agency's regulations, provided that the voluntarily installed items do not impair the functioning of any devices or elements of design required to be installed in the vehicles. Your belief is correct.

The anchorage location requirements in Standard No. 210 apply to all anchorages required by the safety standards, except for those anchorages explicitly exempted by S4.3 of Standard No. 210 (anchorages for automatic and dynamically tested manual belt ass emblies that meet the frontal crash protection requirements of S5.1 of Standard No. 208). The question then becomes whether the voluntarily provided rear seat shoulder belts must be attached in these vehicles to the anchorage that is required by the

safety standards. As discussed below, we conclude that a voluntarily provided lap/shoulder belt may be attached to an anchorage located outside the area specified by Standard No. 210.

S3 of Standard No. 210 defines a "seat belt anchorage" as "the provision for transferring seat belt assembly loads to the vehicle structure." S4.1.1 of Standard No. 210 requires shoulder belt anchorages to be installed for each forward-facing rear outboa rd seating position in passenger cars. This requirement has been interpreted as meaning that an anchorage point capable of transferring shoulder belt loads to the vehicle structure had to be provided for such seating positions, and that required anchora ge point had to comply with the applicable requirements of Standard No. 210.

According to your letter, your station wagons would be equipped with an anchorage point capable of transferring shoulder belt loads to the vehicle structure, and that point would comply with the anchorage strength and location requirements set forth in S tandard No. 210. Thus, Subaru could satisfy all the requirements of the safety standards by installing lap belts only at the rear outboard seating positions in these cars. Subaru's decision to install lap/shoulder belts at these seating positions and a n additional anchorage point for the shoulder belts is a voluntary choice, not a response to any regulatory requirement.

NHTSA has long said that systems or components installed in addition to required safety systems are not required to comply with Federal safety standards, provided that the additional systems or components do not destroy the ability of the required safety systems to comply with the safety standards. In a December 1, 1986 letter to Mr. Francois Louis (copy enclosed), I said that manufacturers are permitted to locate the anchorage for voluntarily-installed lap belts outside of the area specified in Standa rd No. 210 for lap belts required to be installed by Standard No. 208, provided that the voluntarily installed lap belts do not destroy the ability of the required belt systems to comply with the requirements of the safety standards. The same reasoning would apply in this situation. That is, manufacturers are permitted to locate the anchorage for the upper end of voluntarily installed shoulder belts outside of the area specified in S4.3.2 of Standard No. 210, provided that the voluntarily installed an chorages and shoulder belts do not destroy the ability of the required anchorages and lap belts to comply with the requirements of the safety standards. There is no reason to believe that shoulder belts and the additional anchorages would in any way imp air the ability of required equipment to comply with the requirements of the safety standards.

You are already aware of the fact that NHTSA has initiated a rulemaking to require rear seat lap/shoulder belts; 52 FR 22818, June 16, 1987. You should note that if the agency adopts a final rule requiring rear seat lap/shoulder belts in passenger cars, this interpretation would no longer apply, because it relies on the voluntary nature of the installation.

ENCLOSURE

Sincerely,

ID: aiam3640

Dear Confidential: This responds to your recent request for an interpretation of th requirements of Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars*. Specifically, you asked if that standard allows a manufacturer to equip a motorcycle with passenger car tires and rims.; Standard No. 120 permits a motorcycle to be equipped with passenger ca tires and rims, provided that those tires and rims meet all the requirements of the standard. Section S5.1.1 of Standard No. 120 requires all motorcycles equipped with pneumatic tires for highway service to be equipped with tires that meet either the requirements of Standard No. 109, which applies to new passenger car tires, or Standard No. 119, which applies to new tires for use on motor vehicles other than passenger cars. Thus, passenger car tires can be used on new motor cycles, as long as those passenger car tires are certified as complying with Standard No. 109.; Motorcycle rims are subject to two requirements. First, section S5.1. requires that the rims be listed by the manufacturer of the tires installed on the motorcycle as suitable for use with those tires. If you use rims which are the proper size for the passenger car tires to be used, this requirement is easily met by passenger car rims. Second, rims used on motorcycles must meet the rim marking requirements in section S5.2 of Standard No. 120. Passenger car rims generally do not meet these marking requirements, because the rim manufacturers do not mold the required information onto passenger car rims. However, if you can obtain passenger car rims marked with the information set forth in section S5.2 and listed by the passenger car tire manufacturer as appropriate for use with the passenger car tires, those rims could be used on new motorcycles.; A copy of this letter with your name and address deleted, along wit your request for an interpretation of Standard No. 120, has been placed in the public docket under interpretations of Standard No. 120. Should you have any further questions or need further information on this matter, please contact Mr. Stephen Kratzke of my staff at (202) 426-2992.; Sincerely, Frank Berndt, Chief Counsel