ID: nht69-1.3

DATE: 06/02/69

FROM: AUTHOR UNAVAILABLE; Robert Brenner; NHTSA

TO: Hon. Jacob K. Javita -- U.S. Senate

COPYEE: Mr. Delve; Mr. O'Mahoney

TITLE: FMVSS INTERPRETATION

TEXT: This is in further reply to your transmittal memorandum and attached letter from Mr. Robert W. Muller, New York, New York, inquiring about consumer information on passenger car tires.

The Department of Transportation does not presently have a publication which would guide the consumer in selecting tires most suitable to his needs.

To provide the consumer with an indication of the performance characteristics of tires, the Federal Highway Administration is obtaining research data and has established Docket 25, Uniform Tire Quality Grading System - Passenger Cars. A copy of the notice from the Federal Register is enclosed.

As soon as a meaningful system of tire quality grading can be developed to assist the public, it will be made available.

Enclosure

ID: nht72-3.41

DATE: 02/24/72

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Lempco Industries, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of January 18, 1972, on the subject of an automobile dealer's obligations regarding seatbelts in new cars.

Motor Vehicle Safety Standard No. 208 requires seatbelts to be installed at all seating positions. Under the requirements of the National Motor Vehicle and Traffic Safety Act, which we administer, it is a violation of the law to sell a vehicle that does not conform to an applicable standard. A dealer may not, therefore, sell an automobile that does not have the required number of seatbelts.

Although the act does not prevent the purchaser of a vehicle from removing the belts, after he has completed the purchase, we strongly advise him to leave the belts in and to wear them. A dealer who removes the belts after he has sold the vehicle does not violate the law, but he does his customer a disservice.

ID: 10119

Mr. Ralph Harpster
Laguna Manufacturing, Inc.
P.O. Box 3236
Turlock, CA 95381

Dear Mr. Harpster:

This responds to your letter of June 21, 1994, requesting information on whether a "replacement rear seat used for the transport of prisoners in police cars" complies with the Federal motor vehicle safety standards. During a July 1, 1994 phone conversation with Mary Versailles of my staff, you explained that the seat could be installed either before or after the first retail sale of the police car.

I am pleased to have this opportunity to explain our regulations to you. Some background information on Federal motor vehicle safety laws and regulations may be helpful. Our agency is authorized under 49 U.S.C. '30101 et seq. to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, each manufacturer is responsible for "self-certifying" that its products meet all applicable safety standards. The following represents our opinion based on the facts provided in your letter.

NHTSA has exercised its authority to establish five safety standards that may be relevant to a prisoner transport seat. The first is Standard No. 207, Seating Systems (49 CFR '571.208), which sets forth strength requirements for all "occupant seats" in passenger cars. The second relevant standard is Standard No. 208, Occupant Crash Protection (49 CFR '571.208), which sets forth requirements for occupant protection at the various seating positions in vehicles. The third relevant standard is Standard No. 209, Seat Belt Assemblies (49 CFR '571.209), which sets forth strength, elongation, webbing width, durability, and other requirements for seat belt assemblies. The fourth relevant safety standard is Standard No. 210, Seat Belt Assembly Anchorages, which establishes strength and location requirements for seat belt anchorages. The final relevant safety standard is Standard No. 302, Flammability of

Interior Materials. This standard specifies burn resistance requirements for materials used in the occupant compartment of motor vehicles.

Because federal law operates differently depending on when the installation of the prisoner transport seat occurs, I will separately discuss three possible scenarios.

Installation as Original Equipment

Standards No. 207, No. 208, No. 210, and No. 302 apply, with certain exceptions that are not relevant to your product, to vehicles and not directly to items of equipment. Thus, the vehicle manufacturer, and not the equipment manufacturer, would be responsible for certifying that the vehicle complies with these standards with the prisoner transport seat installed in the vehicle.

Unlike the other four standards, Standard No. 209 applies to seat belt assemblies as separate items of motor vehicle equipment, regardless of whether the belts are installed as original equipment in a motor vehicle or sold as replacements. The manufacturer of the seat belt system provided with the prisoner transport seat is responsible for certifying that the seat belt complies with Standard No. 209.

Your letter specifically asks whether the safety belt system installed with the prisoner transport seat complies with all applicable requirements. Currently, Standard No. 208 requires an integral Type 2 (lap and shoulder) seat belt assembly at all forward-facing rear outboard seating positions, and either a Type 1 (lap) or Type 2 seat belt assembly at all other rear seating positions. Standard No. 208 also requires the lap belt portion of the Type 2 seat belt assembly installed at any forward-facing rear outboard seating position to have an emergency locking retractor. Thus, because the seat belt assembly for the prisoner transport seat has a manual retractor, the seat cannot be installed at a forward-facing rear outboard seating position.

We note that Standard No. 208 requires emergency locking retractors to ensure improved comfort and convenience for safety belts. The purpose is to make it more likely that the typical vehicle occupant will use his or her safety belts, and also to reduce the likelihood of excessive slack in safety belts during use. You wish to use manual retractors because of special circumstances that arise when the rear seats of police vehicles are used to transport prisoners, i.e., a desire to keep the prisoners solidly restrained in the seats. However, Standard No. 208 specifies the same occupant crash protection requirements for police vehicles as other vehicles, and does not include an exception in this area.

A possible solution to your problem may be to install your belt system (with manual retractors) in addition to the safety belts required by Standard No. 208. Provided that the installation did not interfere with the required safety belts, such installation would not affect the compliance of the vehicle with Standard No. 208, since the standard's requirements would be fully met by the original belts. Your belt system would, of course, still have to meet the requirements of Standard No. 209, since it would be considered a "seat belt assembly."

Installation Prior to First Sale

If a prisoner transport seat were added to a new vehicle prior to its first sale, e.g., by the dealer, the person who modified the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration.

Installation After First Sale

After the first purchase of a vehicle for purposes other than resale, the only provision in Federal law that affects the vehicle's continuing compliance with an applicable safety standard is set forth in 49 U.S.C. '30122. That section provides that:

A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor vehicle safety standard.

This provision would prohibit any of the named commercial entities from installing a prisoner transport seat if such installation rendered inoperative the compliance of the vehicle with any applicable safety standard. For example, if the material used in the seat did not meet the burn resistance requirements of Standard No. 302, installation of the system would make inoperative compliance with that standard. Any violation of this prohibition is subject to a potential civil penalty of up to $1,000 for each violation.

Please note that this provision does not prohibit owners from modifying their vehicles, even if such modification adversely affects the compliance of the vehicle with safety standards. Thus, if a police department were to modify its own vehicles to install a prisoner transport seat, it would not be a violation of this provision, even if the original belts were replaced by belts with manual retractors.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles at this address or by phone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:208 d:9/15/94

ID: nht90-4.15

TYPE: Interpretation-NHTSA

DATE: September 19, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Martin E. Simms -- Chartered Consulting Engineer

TITLE: None

ATTACHMT: Attached to instruction sheet dated 9-85 entitled Where to Obtain Motor Vehicle Standards and Regulations (text omitted)

TEXT:

This is in response to your letter on behalf of an Australian client who is proposing to construct, in conjunction with an American company, vehicles for sale in both Australia and the United States. You asked a number of questions about the substantive and procedural requirements of the safety standards. I will answer your questions in order.

1. What standards currently apply in America to 4 wheel drive vehicles (of about the same size as your Ford F350)? Are the Federal Motor Vehicle Safety Standards still the current standards?

The Federal Motor Vehicle Safety Standards (FMVSS) are still the applicable standards. The FMVSS may be found in Part 571 of Volume 49 of the Code of Federal Regulations (49 CFR Part 571). Each standard states the classes of motor vehicles to which it applies. Examples of classes of vehicles are passenger cars, trucks, and multipurpose passenger vehicles. Definitions of those terms may be found in the definitions section of the FMVSS (49 CFR S571.3).

2. Where can those standards be purchased and at what cost?

The FMVSS may be obtained from: Superintendent of Documents U.S. Government Printing Office Washington, D.C. 20402 Phone: (202) 783-3238 Prices must be obtained from the Superintendent of Documents since they are subject to periodic change. For further information, please refer to the information sheet entitled "Where to Obtain Motor Vehicle Safety Standards and Regulations" that is encl osed with this letter.

3. What is the procedure for proving compliance with American Federal standards and how long does it take to obtain approval (from time of application) to be able to market a vehicle?

The United States does not have an approval process similar to that of some other nations. In the United States, a manufacturer of motor vehicles must certify that its products comply with all applicable safety standards. The manufacturer's certificati on need not be based on actual tests, but may, in appropriate situations, be based on engineering judgment or computer simulations. The manufacturer is required to exercise due care in making the certification. The requirements concerning certification may be found at 49 CFR Part 567.

4. What government costs/fees are associated with seeking approval to

market a vehicle in America?

As explained above, the United States does not have an approval system.

5. Is there a classification system for vehicle types under U.S. Federal standards?

There is a classification system for motor vehicle types. Examples of classifications are passenger cars, trucks, and multipurpose passenger vehicles. These terms are defined at 49 CFR S571.3.

6. In instances where our Australian design rule standards are based on FMVSS rules, would testing done in Australia to FMVSS standards be acceptable in America?

As discussed above, there is no requirement in the United States that manufacturers submit test data for approval. Instead, manufacturers must exercise due care in certifying their compliance with the FMVSS. In appropriate cases, manufacturers may be a ble to rely on testing done in Australia to certify compliance with some United States safety standards.

7. Is there any requirement for testing laboratories to meet specific standards for compliance with FMVSS standards?

There is no explicit requirement that testing laboratories meet specific standards. However, an element of the due care that manufacturers must exercise in certifying compliance with FMVSS would be to use appropriate testing laboratories.

8. What requirements exist for the retention and/or submission of test data to American Federal agencies?

As mentioned above, manufacturers are not required to submit test data to have their vehicles approved. However, manufacturers would be well advised to retain such data as evidence of their due care in certifying compliance with the FMVSS. In addition, manufacturers must retain records concerning nonconformity with the FMVSS and possible defects relating to motor vehicle safety. Requirements concerning record retention may be found at 49 CFR Part 576.

9. In Australia, compliance with certain FMVSS standards will be accepted as compliance with Australian standards in some instances (subject to actual test data being submitted to the Australian authorities). Does such an arrangement exist in America?

As discussed above, manufacturers are not required to submit test data as part of any vehicle approval process. Manufacturers, in their exercise of due care in certifying compliance with the FMVSS, may rely on compliance with Australian standards in app ropriate instances. This would be most appropriate when the Australian standard is identical to the FMVSS requirement.

You also asked if there is other information about which your client should be aware. Your client should know that all manufacturers

headquartered outside of the United States must designate a permanent resident of the United States as the manufacturer's agent for service of all process, notices, orders, and decisions. This designation is to be mailed to the Chief Counsel of NHTSA. In accordance with 49 CFR S551.45, the designation must include the following information:

1. A certification that the designation is valid in form and binding on the manufacturer under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made;

2. The full legal name, principal place of business, and mailing address of the manufacturer;

3. Marks, trade names, or other designations of origin of any of the manufacturer's products which do not bear his name;

4. A statement that the designation shall remain in effect until withdrawn or replaced by the manufacturer;

5. A declaration of acceptance duly signed by the agency appointed, which may be an individual, a firm, or a U.S. corporation; and

6. The full legal name and address of the designated agent.

7. The signature of one with authority to appoint the agency. The signer's name and title should be clearly indicated beneath his signature.

I have enclosed, for your review, a designation letter which has been accepted by the agency.

In addition, your client should know that the Vehicle Safety Act requires manufacturers to notify purchasers concerning safety-related defects and failures to comply with the FMVSS and to remedy such defects and noncompliances without charge. Please ref er to 49 CFR Parts 573, 577, and 579 for further details.

We are enclosing an information sheet entitled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment." This document highlights the major regulatory provisions that may be applicable to your client.

I hope that you find this information useful. Please feel free to contact us if you have any further questions.

ID: nht94-4.27

TYPE: INTERPRETATION-NHTSA

DATE: September 15, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Ralph Harpster -- Laguna Manufacturing, Inc., Turlock, CA

TITLE: NONE

ATTACHMT: Attached to letter dated 6/21/94 from Ralph Harpster to NHTSA Office of the Chief Counsel (OCC 10119)

TEXT: This responds to your letter of June 21, 1994, requesting information on whether a "replacement rear seat used for the transport of prisoners in police cars" complies with the Federal motor vehicle safety standards. During a July 1, 1994 phone conversat ion with Mary Versailles of my staff, you explained that the seat could be installed either before or after the first retail sale of the police car.

I am pleased to have this opportunity to explain our regulations to you. Some background information on Federal motor vehicle safety laws and regulations may be helpful. Our agency is authorized under 49 U.S.C. @ 30101 et seq. to issue safety standards applicable to new motor vehicles and items of motor vehicle equipment. NHTSA, however, does not approve motor vehicles or motor vehicle equipment, nor do we endorse any commercial products. Instead, each manufacturer is responsible for "self-certifyin g" that its products meet all applicable safety standards. The following represents our opinion based on the facts provided in your letter.

NHTSA has exercised its authority to establish five safety standards that may be relevant to a prisoner transport seat. The first is Standard No. 207, Seating Systems (49 CFR @ 571.208), which sets forth strength requirements for all "occupant seats" in passenger cars. The second relevant standard is Standard No. 208, Occupant Crash Protection (49 CFR @ 571.208), which sets forth requirements for occupant protection at the various seating positions in vehicles. The third relevant standard is Standard No. 209, Seat Belt Assemblies (49 CFR @ 571.209), which sets forth strength, elongation, webbing width, durability, and other requirements for seat belt assemblies. The fourth relevant safety standard is Standard No. 210, Seat Belt Assembly Anchorages, which establishes strength and location requirements for seat belt anchorages. The final relevant safety standard is Standard No. 302, Flammability of Interior Materials. This standard specifies burn resistance requirements for materials used in the oc cupant compartment of motor vehicles.

Because federal law operates differently depending on when the installation of the prisoner transport seat occurs, I will separately discuss three possible scenarios.

Installation as Original Equipment

Standards No. 207, No. 208, No. 210, and No. 302 apply, with certain exceptions that are not relevant to your product, to vehicles and not directly to items of equipment. Thus, the vehicle manufacturer, and not the equipment manufacturer, would be respo nsible for certifying that the vehicle complies with these standards with the prisoner transport seat installed in the vehicle.

Unlike the other four standards, Standard No. 209 applies to seat belt assemblies as separate items of motor vehicle equipment, regardless of whether the belts are installed as original equipment in a motor vehicle or sold as replacements. The manufactu rer of the seat belt system provided with the prisoner transport seat is responsible for certifying that the seat belt complies with Standard No. 209.

Your letter specifically asks whether the safety belt system installed with the prisoner transport seat complies with all applicable requirements. Currently, Standard No. 208 requires an integral Type 2 (lap and shoulder) seat belt assembly at all forwa rd-facing rear outboard seating positions, and either a Type 1 (lap) or Type 2 seat belt assembly at all other rear seating positions. Standard No. 208 also requires the lap belt portion of the Type 2 seat belt assembly installed at any forward-facing re ar outboard seating position to have an emergency locking retractor. Thus, because the seat belt assembly for the prisoner transport seat has a manual retractor, the seat cannot be installed at a forward-facing rear outboard seating position.

We note that Standard No. 208 requires emergency locking retractors to ensure improved comfort and convenience for safety belts. The purpose is to make it more likely that the typical vehicle occupant will use his or her safety belts, and also to reduce the likelihood of excessive slack in safety belts during use. You wish to use manual retractors because of special circumstances that arise when the rear seats of police vehicles are used to transport prisoners, i.e., a desire to keep the prisoners soli dly restrained in the seats. However, Standard No. 208 specifies the same occupant crash protection requirements for police vehicles as other vehicles, and does not include an exception in this area.

A possible solution to your problem may be to install your belt system (with manual retractors) in addition to the safety belts required by Standard No. 208. Provided that the installation did not interfere with the required safety belts, such installati on would not affect the compliance of the vehicle with Standard No. 208, since the standard's requirements would be fully met by the original belts. Your belt system would, or course, still have to meet the requirements of Standard No. 209, since it wou ld be considered a "seat belt assembly."

Installation Prior to First Sale

If a prisoner transport seat were added to a new vehicle prior to its first sale, e.g., by the dealer, the person who modified the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration.

Installation After First Sale

After the first purchase of a vehicle for purposes other than resale, the only provision in Federal law that affects the vehicle's continuing compliance with an applicable safety standard is set forth in 49 U.S.C. @ 30122. That section provides that: A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle or motor vehicle equipment in compliance with an applicable motor veh icle safety standard.

This provision would prohibit any of the named commercial entities from installing a prisoner transport seat if such installation rendered inoperative the compliance of the vehicle with any applicable safety standard. For example, if the material used i n the seat did not meet the burn resistance requirements of Standard No. 302, installation of the system would make inoperative compliance with that standard. Any violation of this prohibition is subject to a potential civil penalty of up to $ 1,000 for each violation.

Please note that this provision does not prohibit owners from modifying their vehicles, even if such modification adversely affects the compliance of the vehicle with safety standards. Thus, if a police department were to modify its own vehicles to inst all a prisoner transport seat, it would not be a violation of this provision, even if the original belts were replaced by belts with manual retractors.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles at this address or by phone at (202) 366-2992.

ID: aiam2777

Dear Mr. Friedlander: This responds to your February 23, 1978, letter asking whether a tub can be installed in a tubeless tire without any adverse effects upon safe operation of that tire. In our January 6, 1978, letter to Mr. Philip Taft of your Association, the National Highway Traffic Safety Administration (NHTSA) indicated that a retreader could not change a tire originally labeled 'tubeless' to a tire labeled 'tube type,' because such an alteration would violate the labeling requirements of Standard No. 117, '*Retreaded Pneumatic Tires - Passenger Cars.*' The NHTSA did not state, as you indicate in your letter, that tubes could not be installed in retreaded tubeless tires.; You ask whether the use if tubes in tubeless tires creates any safet problems. The agency is unaware of safety problems resulting from the use of tubes in tubeless tires. The NHTSA has determined, however, that tubes should not be placed in damaged tubeless tires in lieu of permanent repairs to those tires. This determination applies to those instances where tubes were used in tubeless tires after failure of the tire. In such cases, the tire casing could have been fractured or some other damage to the tire could have been sustained that would cause excessive wear of a tube inserted in the tire. Excessive wear of a tube could cause further tire failure. Therefore, tubes should not be inserted as a permanent repair of a damaged tubeless tire. Nothing in this finding, however, is intended to indicate that tubes in undamaged tubeless tires create safety problems. At this time the agency has no data to support your theory that the use of tubes in undamaged tubeless tires poses a safety problem.; Sincerely, Joan Claybrook

ID: aiam5335

Dear Mr. Freund: This responds to your letter addressed to th attention of Walter Myers of my staff in which you asked whether Table II of Federal Motor Vehicle Safety Standard (FMVSS) No. 119, New pneumatic tires for vehicles other than passenger cars, contains certain errors. You pointed out in your letter that Table I of FMVSS 119 specifies a plunger diameter of 5/16 inch for motorcycles, and 3/4 inch for 12-inch or smaller rims other than motorcycles. Table II, on the other hand, leaves blank the plunger diameter space in the motorcycle column, but lists 5/16 inch plunger diameter in the 12-inch or smaller rim column. You indicated your belief that the inconsistency is due to a typographical error in those columns of Table II and asked us to confirm your interpretation. Your observation is correct. A November 13, 1973 rule adopting Tables I and II (38 FR 31299) (copy enclosed) specifies the 5/16-inch diameter plunger for motorcycle tires, and the 3/4-inch diameter plunger for 12-inch or smaller tires and 17.5-inch or smaller light truck tubeless tires. Accordingly, the plunger diameter for the motorcycle column in Table II should read 5/16. Similarly, the 12-inch or smaller column in the current Table II is in error in specifying a plunger diameter of 5/16 inch. The correct plunger diameter for that column in Table II should be 3/4 inch to correspond with the plunger diameter specified for 12-inch or smaller rims in Table I. Thank you for bringing this error to our attention. The agency will issue a correction to avoid any further confusion. Sincerely, John Womack Acting Chief Counsel;

ID: aiam5096

"Dear Sir/Madam: Your letter of November 5, 1992 addressed to th Department of Transportation Publications Department was forwarded to this office for response. In your letter you requested a copy of the Federal motor vehicle safety standards pertaining to school buses 'and other Transit type vehicles.' The Federal motor vehicle safety standards issued by this agency, the National Highway Traffic Safety Administration (NHTSA), apply to all classes and categories of motor vehicles, including passenger cars, trucks, buses of all types including school buses, multipurpose passenger vehicles, and the like. Excluded from the definition of motor vehicles are such vehicles as farm tractors, earth-moving equipment, and other off-road vehicles. For your information, I am enclosing a pamphlet issued by this agency entitled Federal Motor Vehicle Safety Standards and Regulations, which summarizes our safety standards. Also enclosed are copies of two fact sheets issued by this office entitled Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment and Where to Obtain NHTSA's Safety Standards and Regulations. You did not elaborate on what was meant by 'Transit type vehicles.' If you were referring to intercity buses, you should contact the Office of Motor Carrier Standards, Federal Highway Administration, Room 3404, this address for information on their pertinent standards and regulations. For information on intracity buses, you should contact the Federal Transit Administration, Room 9328, this address. Finally, for information regarding implementation of the Americans with Disabilities Act, you should contact the Office of Technical and Information Services, U.S. Architectural and Transportation Barriers Compliance Board, 1331 F Street N.W., Suite 1000, Washington, DC 20004-1111. I hope this information is helpful. If after examining this material you have more specific questions, please feel free to contact Mr. Walter Myers of my staff at this address or by telephone at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel Enclosures";

ID: aiam2323

Dear Mr. Ellenberger: I am writing to confirm your May 19, 1976, telephone conversation wit Mark Schwimmer of this office, concerning the effective dates of Federal Motor Vehicle Safety Standard No. 120, *Tire Selection and Rims for Motor Vehicles Other Than Passenger Cars.*; You were particularly concerned with one paragraph in the preamble o Notice 4 (41 FR 18659, May 6, 1976, Docket No. 71-19). That notice delayed the effective dates of certain requirements of the standard. The paragraph in question is:; >>>Manufacturers should note that, apart from the changed effectiv date for the requirement in S5.1.1 that vehicles be equipped with properly marked rims, there is no delay in the September 1, 1976, effective date of the standard's basic requirements, S5.1 (*Tire and Rim Selection*).<<<; Section S5.2, *Rim Marking*, is the only section of the standard tha applies directly to rims. Section S5.1 applies directly to vehicles. As Mr. Schwimmer explained, however, two aspects of S5.1 (both found in S5.1.1) involve rims as well.; The first sentence of S5.1.1 includes a 'suitability' requirement: >>>...each vehicle...shall be equipped with...rims that are listed b the manufacturer of the tires as suitable for use with those tires...<<<; The second sentence, as amended by Notice 4, reads: >>>On and after September 1, 1979, each such vehicle shall be equippe with rims that meet the requirements of this standard.<<<; The paragraph in question is simply a reminder that the 'suitability requirement, among others, is effective September 1, 1976, as originally established in Notice 3 (41 FR 3478, January 23, 1976).; Yours truly, Stephen P. Wood, Assistant Chief Counsel

ID: aiam0060

Dear Mr. Cipriano: Your letter of April 22, 1968, to Mr. Bridwell has been referred to m for reply.; You state that it is your understanding that the proposed rule makin in Docket 2-16 will require door locks on trailers and mobile homes to be so constructed 'as to be recessed flush on exterior doors.' Federal motor vehicle safety standard No. 206, Door Latches, Hinges, and Locks - Passenger Cars, was originally issued on January 31, 1967 and became effective on January 1, 1968. An amendment to this standard was issued on April 24, 1968 with an effective date of January 1, 1969.; Neither the standard as presently written or the proposed amendment i Docket 2-16 is applicable to trailers and mobile homes. Moreover, there is no provision either in the standard or in the proposed amendment which requires that door locks must be so constructed 'as to be recessed flush on exterior doors,' even as to those motor vehicles to which the standard applies presently or to which it is proposed to apply in Docket 2-16. For your information, we are enclosing a copy of the recent amendment to Standard No. 206 as attachment No. 1, and a copy of the proposed amendment for Docket 2-16 as attachment No. 2.; In view of the foregoing, you may wish to reconsider your request tha we forward to you the comments contained in Docket 2-16. The cost to you for forwarding those comments would be fifty cents a page and the number of pages contained in Docket 2- 16 is considerable. Since your understanding of the thrust of Docket 2-16 is not correct, your request for an extension of time to May 25, 1968 is denied.; Sincerely, Robert M. O'Mahoney, Assistant Chief Counsel