ID: 12218.drn

Mr. Juergen Halfmann
Philips Research Lab Aachen
Department EL
P. O. Box 1980
D-52021 Aachen
Germany

Dear Mr. Halfmann:

This responds to your request for an interpretation of Standard No. 124, Accelerator control systems. You note that the Standard is "well adapted" to mechanically driven throttle plates, but not to electronically operated ones. You ask for an interpretation of how S5.1 of Standard No. 124, that specifies "at least two sources of energy capable of returning the throttle to the idle position," applies to electronic systems.

In an interpretation letter of August 8, 1988 to Isuzu (copy enclosed), the National Highway Traffic Safety Administration (NHTSA) interpreted Standard No. 124 to apply to electronic accelerator control systems. Among other matters, Isuzu described what it considered to be the "two sources of energy" that were capable of returning the throttle to the idle position. Based on the Isuzu's information, NHTSA gave an interpretation as to whether Isuzu's system met S5.1 of Standard No. 124.

As NHTSA did for Isuzu, if you would provide specific information about Philips' electronic acceleration control system, we will address whether the system meets S5.1 or any other part of Standard No. 124.

NHTSA has announced that it is considering amending Standard No. 124 to include requirements specific to electronic accelerator control systems. In a Federal Register notice of December 4, 1995 (60 FR 62061, copy enclosed), NHTSA noted that the standard was last amended in 1973, when only mechanical systems were common on motor vehicles. Although the comment deadline has passed, your company may submit comments on the issues raised in the notice. Any further actions NHTSA may take to amend Standard No. 124 will be announced in the Federal Register.

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

Sincerely,

Samuel J. Dubbin

Chief Counsel

Enclosures

ref:124

d:8/7/96

ID: 12221.ztv

Mr. J. Yoshimoto
Deputy General Manager
Technical Admin. Dept.
Koito Mfg. Ltd.
Shizuoka Works
500, Kitawaki
Shimizu-shi, Shizuoka-ken
Japan

Dear Mr. Yoshimoto:

This responds to your letter of July 11, 1996, asking for an interpretation of Federal Motor Vehicle Safety Standard No. 108 with respect to the permissibility of a combination turn signal lamp, taillamp, and stop lamp.

In this design, a bulb in Chamber A functions as a turn signal and taillamp. Chamber B functions as a stop and taillamp. A partition partially separates the two Chambers, but ends at a point 10 to 15 mm from the lens.

Standard No. 108 incorporates by reference SAE Standard J586 FEB84 "Stop Lamps" and SAE Standard J588 NOV84 "Turn Signal Lamps for use on Motor Vehicles Less Than 2032 MM in Overall Width". Paragraph 5.4.2 of each of the SAE Standards provides that "[w]hen a stop signal is optically combined with the turn signal, the circuit shall be such that the stop signal cannot be turned on if the signal is flashing." You ask for confirmation that the design of your lamp is such that the stop signal is not optically combined with the turn signal, and that, therefore, the stop signal can remain turned on even if the turn signal is flashing.

We confirm your interpretation. In your design, the stop signal is not optically combined with the turn signal. The bulbs providing the turn signal and the stop signal are in separate chambers, and ought to be perceived as separate signals through the respective lighted areas of their common lens, even though there may be some small incidental spillover between chambers because the chamber partition does not extend all the way to the lens.

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

Sincerely,

Samuel J. Dubbin

Chief Counsel

ref:108

d:8/7/96

ID: 12236.ztv

Mr. Roy Dickinson
Controller
Falken Tire Corporation
10404 Sixth Street
Rancho Cucamonga, CA 91730

Re: Petition for Exemption for an Inconsequential Noncompliance With Federal Motor Vehicle Safety Standard

Dear Mr. Dickinson:

This is in response to your petition of May 20, 1996, for exemption from the notification and remedy requirements that apply when a manufacturer has determined that a noncompliance exists in motor vehicles or motor vehicle equipment that it has produced.

Falken Tire has determined that a noncompliance with paragraph S4.3(d) of Motor Vehicle Safety Standard No. 109 exists in 13,000 tires that it has produced. The plies in the tread are shown as "1 polyester + 2 Stel" instead of "1 polyester + 2 Steel."

Paragraph S4.3(d) requires that tires be labeled with the generic name of each cord material used in the plies. In the opinion of the agency, Falken Tire has provided this information, albeit in a slightly misspelled form. Since there is no generic cord material called "stel," readers who observe the misspelling will understand that steel is meant. Therefore, in our opinion, the Falken tires in question conform with paragraph S4.3(d) of Standard No. 109, and its petition is moot.

This situation is to be distinguished from those in which a mistake is made in a numerical value on a tire sidewall label, such as reversal of ply counts, inflation pressure, or load rating. In these instances, a noncompliance exists because the typographical error provides incorrect and misleading information. The correct information may be vital to safety, and, when such an error occurs, it requires the manufacturer to notify and remedy, if not excused pursuant to the petition process.

We appreciate your concern over your minor mistake. If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

Sincerely,

John Womack
Acting Chief Counsel

ref:556

d:8/22/96

ID: 12247.ztv

Mr. Shlomo Zadok
Zadok Research Laboratories
739 North Occidental Blvd., Suite #6
Los Angeles, CA 90026

Dear Mr. Zadok:

This replies to your letter of July 25, 1996, asking for an interpretation as to the applicability of Federal laws to a "third brake light" that you have designed.

Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment (Title 49 Code of Federal Regulations Sec. 571.108) is the Federal regulation that prescribes lighting equipment for new motor vehicles. Standard No. 108 refers to this item of equipment as a "center highmounted stop lamp" which is frequently abbreviated to "CHMSL." As Mr. Vinson explained to you in several phone talks on the subject, Standard No. 108 has required the CHMSL on all passenger cars manufactured on and after September 1, 1986, and on light trucks and vans manufactured on and after September 1, 1993. Both original and replacement CHMSLs for these vehicles must meet the requirements specified in Standard No. 108. Further, if you sell a CHMSL in the aftermarket for replacement of an original equipment CHMSL, you are required to certify that it meets the original equipment requirements, either by a DOT symbol on the lamp, or a statement on a label or tag attached to it or its container.

The unusual feature of your CHMSL is that it will carry a message in "big block letters" that don't flash or blink. Whether a "message" of this nature is permissible on original CHMSLs and their replacements depends on whether your CHMSL conforms to paragraph S5.1.1.27 of Standard No. 108. The most important of these requirements is that a CHMSL have an effective projected luminous lens area of not less than 4 square inches, that it have a signal visible to the rear through a horizontal angle from 45 degrees to the left to 45 degrees to the right of the vehicle's longitudinal axis, and that it have the minimum photometric values in the amount and location listed in Figure 10 of Standard No. 108 (the most difficult requirement to meet with a "message" imposed on the lens).

Your CHMSL as original equipment or its replacement is also subject to the prohibition of paragraph S5.1.3 that it not "impair the effectiveness" of any lighting equipment required by

Standard No. 108. This means that the message must not distract or confuse following drivers from reacting to the CHMSL and other stop signals exactly as they would were the message not there.

You also state that the CHMSL "is not so large as to block the driver's rear view." The Federal requirement is that, with the CHMSL in place, a vehicle must continue to conform to the rear field of view requirements of Safety Standard No. 111 Rearview Mirrors.

If you sell your CHMSL in the aftermarket as a replacement only for use on older vehicles that did not carry a CHMSL as original equipment, there is no Federal requirement that it comply with Standard No. 108. The sole Federal restriction is that a manufacturer, dealer, distributor, or motor vehicle repair business may not install the CHMSL if it " makes inoperative" any equipment originally installed to meet a Federal motor vehicle safety standard. We interpret this as meaning that your CHMSL must not detract from the stop signal provided by the two original equipment stop lamps, and that it must not create a noncompliance with Standard No. 111. Nevertheless, even if it meets these tests, your aftermarket CHMSL is subject to the laws of each state in which it will be used. We regret that we are unable to advise you on state laws, and suggest that you consult state Departments of Motor Vehicles.

Taylor Vinson will be pleased to answer any further questions you may have. You may call him at 202-366-5263.

Sincerely,

John Womack
Acting Chief Counsel

ref:108

d:8/20/96

ID: 12248-2.pja

Mr. Frank Dennis
Vice President, Marketing
United Distribution, Inc.
P.O. Box 103
W. Milford, NJ 07480

Dear Mr. Dennis:

This responds to your July 26, 1996, letter asking how Federal regulations would affect your product, the "Vizoret." You describe the Vizoret to be "an auxiliary sun visor" that attaches behind the inside rear view mirror. One of your questions is whether a car dealer could hand a Vizoret to a vehicle purchaser.

According to your letter, the purpose of the Vizoret is to block direct sunlight that passes above the mirror and between the two sunvisors. From the promotional brochure that you enclosed, it appears that the Vizoret is made of some kind of thin, flat, opaque material, about 12 inches wide by 4 inches high, and can be trimmed to size. It has a notch in the center that slides over the mirror mounting bracket, so that the Vizoret hangs behind the mirror. You say that it takes 5 seconds to attach or remove the Vizoret.

The applicability of this agency's standards to your product, and the legality under the National Highway Traffic Safety Administration's (NHTSA's) regulations of a dealer handling the Vizoret to a purchaser, depend on when your product is provided to the consumer. If the Vizoret is sold or given to a consumer after a vehicle's sale, there is no Federal motor vehicle safety standard that directly applies to the product. NHTSA has issued a standard (Standard 302, copy enclosed) requiring certain materials in a vehicle's interior to be flame resistant, including sun visors and shades, but this standard applies to new, completed vehicles and not to items of equipment.

If the Vizoret were made part of a new vehicle, such as by installation by a vehicle manufacturer or a dealer before a vehicle's sale, our standards would be a factor. The vehicle, with the Vizoret installated, must be certified as complying with all applicable standards, including Standard 302. A dealer could not install the product before the vehicle's sale unless the Vizoret met the flammability resistance requirements of Standard 302. You are correct that the Vizoret would not be considered a part of the windshield, and therefore Standard 205, Glazing materials, would not

apply. You should also be aware that new requirements in S4 of Standard No. 201, Occupant protection in interior impact, will be phased-in beginning in about two years. They will require head impact protection at specified locations on the upper interior of the vehicle.

We do not regulate vehicle owners adding to or otherwise modifying their vehicles. If the dealer hands the Vizoret to the vehicle purchaser for the purchaser to use in the vehicle after the sale, our standards would not prohibit this.

However, bear in mind that manufacturers of motor vehicle equipment (such as the Vizoret) are subject to the requirements of our statute concerning the recall and remedy of products with safety related defects. I have enclosed an information sheet that briefly describes those responsibilities. In the event that 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.

Finally, you should know that individual states have the authority to regulate the use of vehicles and may have requirements affecting the Vizoret. For information on state requirements, we suggest you contact the Department of Motor Vehicles in the states where the Vizoret will be sold or used.

If you have any further questions, please feel free to contact Paul Atelsek of my staff at (202) 366-2992.

Sincerely,

John Womack

Acting Chief Counsel

Enclosures

ref:111#205#302

d:9/5/96

ID: 12249-5.pja

Mr. Per Karlsson
SCANDMEC AB
P.O. Box 504
S-565 28 Mullsjö, Sweden

Dear Mr. Karlsson:

This letter responds to your July 26, 1996, facsimile asking whether the automatic transmission gear selector design you are developing for GM/Opel complies with the June 7, 1995, amendment to Federal Motor Vehicle Safety Standard No. 114, Theft Protection (60 FR 30006). Vehicles manufactured after September 1, 1996, are required by S4.2.1(a)(2) of Standard No. 114 to "prevent removal of the key unless the transmission or transmission shift lever is locked in 'park' . . . ." Your transmission shift lever has a thumb button on top that must be depressed in order to move the lever out of any of the shift positions. Once the lever is between positions and the hand is removed, it will be pulled into one of the positions due to a spring-loaded device. You were concerned that the National Highway Traffic Safety Administration (NHTSA), while conducting compliance testing, might try to "fool" the system by putting the lever into the park position but keeping the thumb button depressed, removing the key with the left hand, and then pulling the lever back with the thumb button still depressed. Your concern is unfounded.

There are two tests relating to performance of the shift lock. The first, in S5.3(a), is for testing in all positions except park. Its purpose is to assure that the key can't be removed in those positions. The test procedure specifies that the lever shall be placed in "any position where it will remain without assistance" (emphasis added). This means that the hand will be removed from the lever (and the thumb button) prior to attempting to remove the key.

The second test, in S5.3(b), is for testing in the park position. Its purpose is to assure that, when a driver removes the key with the lever in park, the lever will be locked in that position and that children left behind in the vehicle won't be able to pull the lever back from the park position and cause a rollaway crash. The test procedure states: "[m]ove the shift mechanism to the 'park' position . . . Remove the key. Verify that the transmission shift mechanism or transmission is locked in 'park.'" We interpret the test procedures at issue as addressing only the actions that drivers might take as part of the normal driving task. This would include actions that drivers might take inadvertently, e.g., attempting to remove the key thinking that the vehicle is in park when it is not, but not deliberate actions to defeat the transmission shift lock.

In S5.3(b), the purpose of "mov[ing] the shift mechanism to the 'park' position" is to put the vehicle in park. Therefore, the normal procedure for accomplishing this action will be used, i.e., the hand will be removed from the shift lever before the key is removed. The action of putting the lever into the park position but keeping the thumb button depressed, removing the key with the left hand, and then pulling the lever back with the thumb button still depressed, would not be taken as part of the normal driving task. Indeed, the only conceivable reason for taking such a complicated action would be a deliberate effort to defeat the transmission shift lock.

I note, however, that when taking the next step in the S5.3(b) procedure and verifying that the shift lever is locked in park, any reasonable means to pull the lever back may be used, including depressing the thumb button. While Standard No. 114 is not intended to address deliberate misuse by a driver, it is intended to address broadly the various kinds of actions unsupervised children might take while playing in a car.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

John Womack

Acting Chief Counsel

ref:114

d:9/20/96

ID: 12259.drn

Mr. Andreas Geis
Robert Bosch GmbH
Automotive Division
K4/EVR5
Postfach 1163
D-77813 Bühl
Germany

Dear Mr. Geis:

Thank you for your letter about Standard No. 104, Windshield Wiping and Washing Systems. You note several typographical errors in your version of the standard that you would like us to correct.

The version of the standard to which you refer is not the National Highway Traffic Safety Administration's version. The official version of Standard No. 104 is set forth in Title 49 of the Code of Federal Regulations, Parts 400 to 999, dated October 1, 1995 (copy enclosed). This version does not contain the errors you found.

Please note that English system measurements in Standard No. 104 have been converted to the metric system. The metric measurements took effect on March 14, 1996. The conversions are not intended to change the stringency of Standard No. 104.

If you have further questions or need additional information, please contact Dorothy Nakama of my staff at (202) 366-2992. Our fax number is (202) 366-5820.

Sincerely,

John Womack
Acting Chief Counsel

Enclosure
ref:104
d:8/26/96

ID: 12261GM.fix

Mr. Milford R. Bennett
Director, Safety Affairs & Regulations
General Motors Corporation (GM)
Mail Code 480-111-S56, Box 9010
Engineering Building 1-11
30200 Mound Rd.
Warren, MI 48090-9010

Dear Mr. Bennett:

This responds to a question you had in a petition for rulemaking concerning a "uniform child restraint anchorage" (UCRA) system that your company developed for attaching add-on child seats in vehicles. You ask whether the UCRA system may be installed prior to completion of the requested rulemaking. The answer is yes.

The UCRA system consists of two lower anchorages near the intersection of the vehicle seat back and cushion (the "bight" line), and an upper tether anchorage. The lower anchorages are each equipped with a latchplate that is smaller than and incompatible with the latchplate provided in seat belt systems for adult passengers. Child seats would be manufactured to have equipment that is compatible with the UCRA system, such as small buckles and a tether to attach to the small latches at the vehicle seat bite line and top tether anchorage.

Your company, as a member of the American Automobile Manufacturers Association, along with specified companies of the Association of International Automobile Manufacturers and the Juvenile Products Manufacturer's Association, petitioned the National Highway Traffic Safety Administration (NHTSA) to require vehicle manufacturers to provide a UCRA system in their vehicles, and require child restraint manufacturers to provide child seats that are "compatible with both the UCRA system (used alone) and the existing vehicle seat belt systems (used alone)."

Among other things, the petition asks whether "1) the proposed UCRA system can be incorporated into future vehicles, and 2) compatible CRSs can be offered for sale, provided the CRS and vehicle belt systems continue to comply with current Federal Motor Vehicle Safety Standard (FMVSS) requirements." From various conversations between Jack Havelin and Dick Humphrey of GM and George Mouchahoir and Deirdre Fujita of NHTSA, we understand you to ask whether the UCRA system may be installed on

vehicles, and compatible componentry installed on child seats, before completion of the requested rulemaking on UCRAs, if the vehicles and child seats meet the standards currently applying to them.

Our answer is the UCRA may be installed. The preamble for the 1979 final rule adopting dynamic test requirements in Standard 213 (44 FR 72131) addressed the issue of "vehicle specific" child restraints, i.e., "systems uniquely designed for installation in a particular make and model which do not utilize vehicle seat belts for anchorages." 44 FR at 72136. The agency emphasized in the preamble that standardizing all child restraints, including vehicle specific ones, by requiring them to be capable of being secured to a vehicle seat by a lap belt is an important way to prevent misuse. However, the agency also stated:

[S]ince vehicle specific child restraints can provide adequate levels of protection when installed correctly, NHTSA is not prohibiting the manufacture of these devices. The new standard requires them to meet the performance requirements of the standard when secured by a vehicle lap belt. As long as child restraints can pass the performance requirements of the standard secured only by a lap belt, a manufacturer is free to specify other 'vehicle specific' installation conditions." 44 FR 72131, 72136; December 13, 1979.

We believe that the system you describe is a "vehicle specific" system similar to that discussed in the preamble. While the discussion quoted above pertained to vehicle specific child seats, by implication the child seat could be attached to the vehicle in a way other than by use of a lap belt. Generally speaking, our standards do not prohibit manufacturers from voluntarily installing items and features on their vehicles or equipment that are not regulated by the safety standards. The only limit is that the vehicle or equipment must meet applicable safety standards when equipped with the voluntary items and features, and must contain no safety-related defect.

Thus, the UCRA system you wish to voluntarily install would be permitted, provided that the vehicle meets all standards currently applying to the vehicle, e.g., standards for seat belt assemblies and anchorages, occupant crash protection and seat strength. Components may be voluntarily installed on a child seat to make the seat compatible with a UCRA, provided that the child seat can pass all requirements of the standard, including the requirement that the seat meet the dynamic test requirements when secured only by a lap belt.

However, please note the following concerns. First, under S5.6 of Standard 213, child seat manufacturers are required to provide step-by-step instructions for securing the child restraint in vehicle-specific applications, as well as providing such instructions for securing the child restraint when it is used in vehicles for which no vehicle-specific installation is recommended.

Second, under NHTSA's defect authority, manufacturers must ensure that their design and production of the UCRA system does not result in unsafe attachments between vehicle and child seats.

Third, assuming that NHTSA issues a rule specifying requirements for a universal child restraint attachment system, such a rule could have requirements that differ from those suggested in your petition. Manufacturers would be responsible for ensuring that UCRA systems installed on vehicles and child seats on or after the effective date of the rule comply with the adopted requirements.

If you have any further questions, please do not hesitate to contact Ms. Fujita at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel

ref:213
d:8/27/96

ID: 12262.jeg

Erika Z. Jones, Esq.
Mayer, Brown & Platt
2000 Pennsylvania Avenue, N.W.
Washington, DC 20006-1882

Dear Ms. Jones:

This responds to your letter requesting an interpretation of 49 CFR Part 583, Automobile Parts Content Labeling. You noted that the regulation specifies that the U.S./Canadian content of components is defaulted to zero when outside suppliers fail to respond to a manufacturer's or allied supplier's request for content information. You requested clarification concerning how a manufacturer should treat the value and content of such defaulted components for purposes of determining the "major foreign sources of passenger motor vehicle equipment."

More specifically, you suggested two alternative general rules regarding the treatment of defaulted components:

A review of the regulation prescribing the manner of determining the "major foreign sources" suggests at least two ways that this question could be answered. . . .

One possibility is that the value of the defaulted components would be excluded entirely from the "major foreign source" calculation, since the origin of the defaulted components is undocumented and therefore not reasonably assumed to be either foreign or non-foreign for purposes of Line Two of the label.

Another possibility is that the value of the defaulted components would be included in the total value computation under 583.7(d)(1), but excluded from any country-specific value calculation under 583.7(d)(2).

As discussed below, it is difficult to provide generalizations that apply in all instances. We disagree with the first of the

two suggested rules. We agree with the first portion of the second suggested rule, but not necessarily with the second portion of that rule.

Section 583.7 specifies the procedure for determining major foreign sources of passenger motor vehicle equipment. One of the steps in that procedure, set forth at 583.7(d)(1), reads as follows:

Adding up the total value of all of the passenger motor vehicle equipment (regardless of country of origin) expected to be installed in that carline during the next model year.

While the U.S./Canadian content of components is defaulted to zero when suppliers fail to respond to a manufacturer's or allied supplier's request for content information (583.6(c)(5)⁽¹⁾), the components do not cease to be passenger motor vehicle equipment. Therefore, the value of those components is included as part of the "total value of all of the passenger motor vehicle equipment" expected to be installed in a carline, as you suggest in the first portion of your second suggested rule. I also note that 583.7(d)(1) makes it clear that all such equipment is included "regardless of country of origin."

The second portion of your second suggested rule provides that the value of defaulted components would be excluded from any country-specific value calculation under 583.7(d)(2). While this would often be the case, it would not be a necessary result. While Part 583 provides that the U.S./Canadian content of components is defaulted to zero when suppliers fail to respond to a manufacturer's or allied supplier's request for content information, it does not address whether the origin could be determined to be from another country.

As we discussed in our September 15, 1995 notice, manufacturers may possess the information necessary to make origin determinations for equipment that was manufactured in countries other than the U.S. or Canada and then imported into the U.S. or Canada. See 60 FR at 47893. In such instances, manufacturers may use any available information to make determinations of zero U.S./Canadian content, country of manufacture, and purchase price, as an alternative to relying on supplier certifications.

If a manufacturer in such instances requested, but did not receive a certificate from a supplier, the manufacturer might nonetheless be able to make a determination of origin for a country other than the U.S./Canada.

If you have further questions about this subject, please call Edward Glancy of my staff at (202) 366-2992.

Sincerely,

John Womack

Acting Chief Counsel

ref:583

d:9/13/96

1. Please note that NHTSA recently made a limited, temporary amendment to this section to provide vehicle manufacturers added flexibility in making content determinations where outside suppliers have not responded to requests for content information. This added flexibility affects the application of the "default-to-zero" provision.

ID: 12292.drn

The Honorable Ernest F. Hollings
United States Senate
1835 Assembly Street
Columbia, S.C. 29201

Dear Senator Hollings:

Thank you for your letter to Mr. John Horsley, Deputy Assistant Secretary for Governmental Affairs, at the U.S. Department of Transportation. Since you request an interpretation of the National Highway Traffic Safety Administration's (NHTSA's) regulations, Mr. Horsley has asked me to respond.

Your letter informs us that your constituent, Mr. Pritchard, wishes to disable a "dashboard warning light" on his motor vehicle. Mr. Wyeth Ruthven of your Columbia office has informed my staff that Mr. Pritchard owns a model year 1992 Chrysler Town and Country minivan. After the vehicle is driven 60,000 miles, a light actuates on the front dashboard, as a reminder that the vehicle should undergo a maintenance inspection. Mr. Pritchard apparently wishes to disable the maintenance inspection reminder display light.

NHTSA has issued a number of safety standards that apply to new motor vehicles. None of our standards, however, regulates a maintenance inspection reminder display. Thus, our requirements do not restrict anyone from disabling the display or arranging with a commercial business to disable it. We would like to note, however, that certain other displays, such as an air bag readiness indicator, are required by our safety standards and thus could not be disabled by a commercial business. In addition, state laws may restrict the changes a vehicle owner may make to his or her vehicle. Mr. Pritchard might want to contact South Carolina state officials for information on that issue.

I hope this information is helpful. If you need any other information, please let me know.

Sincerely,

John Womack
Acting Chief Counsel

ref:101
d:8/29/96