ID: nht95-1.41

TYPE: INTERPRETATION-NHTSA

DATE: February 2, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Gerard Bonvin -- Auto Cheyenne USA Inc.

TITLE: NONE

ATTACHMT: Attached to 12/15/94 letter from Gerard Bonvin to Philip Recht (OCC 10566)

TEXT: Dear Mr. Bonvin:

This is in reply to your letter of December 15, 1994, with respect to the relationship of certain DOT regulations to the Cheyenne, a small front-wheel drive utility vehicle that you wish to import and distribute in the United States.

You have asked the following questions:

"What are the procedure to follow in order to be categorize Small Volume manufacturer?"

Your question assumes that we have a category of "small volume manufacturer." We do not, and there is no exclusion from the Federal motor vehicle safety standards (FMVSS) based upon the volume produced by the manufacturer. All motor vehicles must comply with all FMVSS, unless the agency has exempted them from one or more of the standards. We do recognize limited production volume in the regulation under which a manufacturer who produces less than 10,000 motor vehicles of all types may apply for a temp orary exemption on the basis that compliance would cause it substantial economic hardship, and must provide production information as part of its application.

"Is there really a big difference on the test in order to certified between small volume and over 10000 vehicles?"

As indicated above, if a manufacturer produces less than 10,000 vehicles, that fact is relevant only if that manufacturer wishes to file a hardship exemption application. If a small volume manufacturer has not been exempted, it must comply with the same requirements as apply to those whose yearly production exceeds 10,000.

"Is there any difference between two seaters or four seaters on crash test?"

That is a question to be answered by a vehicle manufacturer. If a four-seater is heavier than a two-seater, the difference in weight could make a difference in whether a vehicle with a borderline design passes or fails a crash test.

"Is there a rear crash impact?"

Yes. FMVSS No. 301 Fuel System Integrity specifies a 30 m.p.h. moving barrier rear impact test.

"Do we need Air Bags if we have Seat belts?"

Currently, vehicles like the Cheyenne are not required to have air bags. However, as explained below, air bags are one means of complying with a the automatic protection requirement which is being phased in for vehicles like the Cheyenne, and eventually the Cheyenne will be required to have air bags for both the driver and right front passenger.

Generally, Jeep-type vehicles are considered to be "multipurpose passenger vehicles" (MPVs). Based on your description, we also assume that the Cheyenne will have a GVWR of 8,500 pounds or less. A requirement in FMVSS No. 208, Occupant Crash Protection , which is being phased in requires a specified percentage (varying by year) of each manufacturer's light trucks (a category which includes MPVs with a GVWR of 8,500 pounds or less) manufactured on or after September 1, 1994 to be equipped with automatic crash protection. The two types of automatic crash protection currently offered are automatic safety belts and air bags.

A recent amendment of FMVSS No. 208 will require at least 80 percent of each manufacturer's light trucks manufactured on or after September 1, 1997 and before September 1, 1998 to be equipped with an air bag and a manual lap/shoulder belt at the driver's and right front passenger's seating positions. All light trucks manufactured on or after September 1, 1998 must be equipped with an air bag and a manual lap/shoulder belt at these seating positions.

"Do we need a buzzer for the seat belt?"

Yes, an audible warning indicator is required.

"Is the dashboard need to be padded?"

We cannot answer your question. That decision is to be made by the manufacturer if its tests show that the dashboard is within the head impact area and that some type of padding is necessary to meet FMVSS No. 201 Occupant Protection in Interior Impact. The FMVSS are performance standards and we do not impose design restrictions on the manufacturer, such as requiring that the dashboard be padded.

"Is there any specific ways on how to install the windshield?"

No, because that would be design restrictive and, as noted above, the FMVSS are performance standards. The performance requirement for windshields is in FMVSS No. 212 Windshield Retention which specifies what the windshield mounting must do in a 30 mph frontal barrier crash. However, if the MPV is an open vehicle with a fold-down windshield, FMVSS No. 212 does not apply to it.

"What is the surface of the windshield that need to wiped? As far as Windshield Wipers, how many cycles and how many different speed?"

You will find the answers to your questions in FMVSS No. 104 Windshield Wiping and Washing Systems. For a copy of these and all our regulations, you should have a copy of "Title 49 Code of Federal Regulations Parts 400-999". This is available from the U.S. Government Bookstore at ARCO Plaza, C-Level, 505 South Flower Street, Los Angeles.

Sincerely,

ID: 0566

Mr. Gerard Bonvin
Auto Cheyenne USA Inc.
6611 1/2 West 6th Street
Los Angeles, CA 90036

Dear Mr. Bonvin:

This is in reply to your letter of December 15, 1994, with respect to the relationship of certain DOT regulations to the Cheyenne, a small front-wheel drive utility vehicle that you wish to import and distribute in the United States.

You have asked the following questions:

"What are the procedure to follow in order to be categorize Small Volume manufacturer?"

Your question assumes that we have a category of "small volume manufacturer." We do not, and there is no exclusion from the Federal motor vehicle safety standards (FMVSS) based upon the volume produced by the manufacturer. All motor vehicles must comply with all FMVSS, unless the agency has exempted them from one or more of the standards. We do recognize limited production volume in the regulation under which a manufacturer who produces less than 10,000 motor vehicles of all types may apply for a temporary exemption on the basis that compliance would cause it substantial economic hardship, and must provide production information as part of its application.

"Is there really a big difference on the test in order to certified between small volume and over 10000 vehicles?"

As indicated above, if a manufacturer produces less than 10,000 vehicles, that fact is relevant only if that manufacturer wishes to file a hardship exemption application. If a small volume manufacturer has not been exempted, it must comply with the same requirements as apply to those whose yearly production exceeds 10,000.

"Is there any difference between two seaters or four seaters on crash test?"

That is a question to be answered by a vehicle manufacturer. If a four-seater is heavier than a two- seater, the difference

in weight could make a difference in whether a vehicle with a borderline design passes or fails a crash test.

"Is there a rear crash impact?"

Yes. FMVSS No. 301 Fuel System Integrity specifies a 30 m.p.h. moving barrier rear impact test.

"Do we need Air Bags if we have Seat belts?"

Currently, vehicles like the Cheyenne are not required to have air bags. However, as explained below, air bags are one means of complying with a the automatic protection requirement which is being phased in for vehicles like the Cheyenne, and eventually the Cheyenne will be required to have air bags for both the driver and right front passenger.

Generally, Jeep-type vehicles are considered to be "multipurpose passenger vehicles" (MPVs). Based on your description, we also assume that the Cheyenne will have a GVWR of 8,500 pounds or less. A requirement in FMVSS No. 208, Occupant Crash Protection, which is being phased in requires a specified percentage (varying by year) of each manufacturer's light trucks (a category which includes MPVs with a GVWR of 8,500 pounds or less) manufactured on or after September 1, 1994 to be equipped with automatic crash protection. The two types of automatic crash protection currently offered are automatic safety belts and air bags.

A recent amendment of FMVSS No. 208 will require at least 80 percent of each manufacturer's light trucks manufactured on or after September 1, 1997 and before September 1, 1998 to be equipped with an air bag and a manual lap/shoulder belt at the driver's and right front passenger's seating positions. All light trucks manufactured on or after September 1, 1998 must be equipped with an air bag and a manual lap/shoulder belt at these seating positions.

"Do we need a buzzer for the seat belt?"

Yes, an audible warning indicator is required.

"Is the dashboard need to be padded?"

We cannot answer your question. That decision is to be made by the manufacturer if its tests show that the dashboard is within the head impact area and that some type of padding is necessary to meet FMVSS No. 201 Occupant Protection in Interior Impact. The FMVSS are performance standards and we do not impose design restrictions on the manufacturer, such as requiring that the dashboard be padded.

"Is there any specific ways on how to install the windshield?"

No, because that would be design restrictive and, as noted above, the FMVSS are performance standards. The performance requirement for windshields is in FMVSS No. 212 Windshield Retention which specifies what the windshield mounting must do in a 30 mph frontal barrier crash. However, if the MPV is an open vehicle with a fold-down windshield, FMVSS No. 212 does not apply to it.

"What is the surface of the windshield that need to wiped? As far as Windshield Wipers, how many cycles and how many different speed?"

You will find the answers to your questions in FMVSS No. 104 Windshield Wiping and Washing Systems. For a copy of these and all our regulations, you should have a copy of "Title 49 Code of Federal Regulations Parts 400-999". This is available from the U.S. Government Bookstore at ARCO Plaza, C-Level, 505 South Flower Street, Los Angeles.

Sincerely,

Philip R. Recht Chief Counsel

ref:555 d:2/2/95

ID: aiam2099

Dear Mr. Ballon: This is in response to your letter of October 14, 1975, to Ms. Kare Kreshover, of this office, asking if there have been any previous interpretations of Section 580.5(b) of 49 CFR Part 580, *Odometer Disclosure Requirements*, indicating that new car dealers must provide odometer disclosure statements to purchasers of new vehicles. Your question was prompted by a September 17, 1975, letter from this agency to Mr. William C. Koch, advising him that a new vehicle dealer must complete disclosure statements for all vehicles he transfers to persons who are taking possession for purposes other than reselling the vehicles.; Although the National Highway Traffic Safety Administration takes th position that section 580.5(b) clearly expresses the requirement that new vehicle dealers must execute odometer disclosure statements when transferring new vehicles to individuals purchasing them for purposes than resale, it has on two previous occasions explicitly pointed out this responsibility in correspondence. Copies of these two letters are enclosed for your information.; Sincerely, Frank Berndt, Acting Chief Counsel

ID: nht79-3.39

DATE: 12/27/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Professional Automotive Consultant

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter asking about the applicable Federal requirements for seat belts in a pickup truck that has been modified to be a convertible by removal of the top. Specifically, you ask what should be done with the shoulder portions of the seat belt assemblies in these vehicles.

I am enclosing for your information a past agency interpretation concerning this same question. You will note that the modified pickup must be in compliance with the Federal safety standards that would have been applicable to a convertible truck at the time the pickup was originally manufactured. Since Safety Standard No. 208, Occupant Crash Protection, permits convertible trucks to be equipped with either Type 1 belts (lap belts) or Type 2 belts (lap and shoulder combination belts) at front outboard designated seating positions, the modified pickup would only be required to have a lap belt. Of course, your client is certainly permitted to retain the lap and shoulder belt if he chooses. We cannot, however, recommend how the shoulder portion of the belt assembly should be attached to the modified vehicle.

Sincerely,

ATTACH.

November 7, 1979

Francis Armstrong, Director -- Office of Vehicle Compliance Enforcement, National Highway Traffic Administration, U.S. Dept. of Transportation

Dear Mr. Armstrong:

I am currently working with a client who is involved with a "Conversion" whereby the top of a pickup truck cab is cut behind the windshield and slightly above the rear bed height. After cutting this top off of the cab, it is fitted with moulded gaskets and held by four (4) aircraft quality latches to produce a convertible truck.

My questions are not concerned with the above process. I am now concerned about the shoulder harness and where it should be located. Naturally the harness becomes inoperable when the top is removed since the factory harnesses are pivoted in the top.

I would think that under the circumstances this finished vehicle should be treated as any other "convertible" with respect to seat belts and harnesses.

Please enlighten me as to what you suggest I should advise my client to do with respect to the relocation or elimination of the detachable upper torso portion of the seat belt assembly.

I thank you very much for your interest in this matter and look forward to your prompt reply.

Sincerely,

Don Johnson -- PROFESSIONAL AUTOMOTIVE CONSULTANT

ID: aiam3098

Dear Mr. Haenchen: This is in response to your letter of September 25, 1979, requesting a interpretation of the term 'restraint system type' as contained in Table I of S4.5.2 of Federal Motor Vehicle Safety Standard No. 115. In addition, this is in confirmation of Volkswagen's statement of the conclusions reached in the meeting with Messrs. Carson, Parker and Schwartz of the National Highway Traffic Safety Administration.; The agency has carefully considered your request that 'restraint syste type' not be interpreted to require a distinction between active and passive belt systems. The agency must deny your request. As the introduction of mandatory passive restraints approaches, information concerning restraint system type is of exceptional importance to the agency. It is important not only to evaluate the overall effectiveness of the various types of passive restraint system types. Consequently, it is necessary that passive belt systems be differentiated from other restraint systems types by decoding the vehicle identification number (VIN).; The agency has also considered the alternative Volkswagen suggeste which is to submit this information separately to the agency on a magnetic tape. Motor vehicle safety research is carried out by many organizations aside from the NHTSA, however, and Standard No. 115 is intended to make information available to these other researchers as well. Consequently, the agency can not accept the alternative you suggest.; As regards the other questions raised in the meeting with NHTSA staff this is to confirm that paragraphs 2 through 4 of our November 20, 1978, letter remain the position of the agency despite the changes in Standard No. 115 since that time. A copy of that letter is enclosed. Likewise, the agency can confirm that the World Manufacturer Identifiers assigned to Volkswagen by the Society of Automotive engineers fulfill the requirements of S6.1 of Standard No. 115.; As requested, the agency has reviewed the VIN format Volkswagen intend to utilize (attachments 2-4 of this letter) and has determined that it meets the requirements of the standard. As explained at the meeting, specific details concerning an engine need not be encoded so long as the information is available from the manufacturer and different engine types can be differentiated by means of the VIN (S4.5.2).; Volkswagen also pointed out to the agency at the meeting that the firs eight characters of the VIN for a particular model might remain the same for several model years, although the characteristics of the vehicle which they codify might change from model year to model year. For example, a 1981 Dasher might have a different engine that a 1982 Dasher, yet that part od the VIN which contained this information would remain the same. This is authorized by Standard No. 115, so long as the correct information for each model year is submitted to the agency. Volkswagen also asked at the meeting what the correct procedure would be for submitting information to the agency concerning vehicles whose line is not subdivided into several series. In this instance, indicate that the line and series are the same. However, even if the series is not divided into more than one body type, this body type must be reported to the agency (S4.5.2). The engine displacement may be indicated in cubic centimeters, and the horsepower in H.P. SAE net (S3). If only one engine make is used, this information must be submitted to the agency, but need not be directly reflected in the VIN (S6.3).; Volkswagen has also asked when information concerning vehicles importe into the United States must be submitted to the agency. Manufacturers of imported vehicles are required to report VIN codes 60 days before the vehicles are imported into the United States to comply with S6.2.; The agency is considering the petitions of a number of manufacturers t establish engine horsepower groupings for reporting purposes and to establish a flexible effective date for vehicles whose model year begins between September 1, 1980 and December 31, 1980. We expect to respond shortly to the petitions.; Sincerely, Frank Berndt, Chief Counsel

ID: 005738rbm

Mr. Paul Schockmel
Marketing Manager
International Electronics and Engineering S.A.
Zone Industrielle Findel
2b, route de Treves
L-2632 Luxembourg

Dear Mr. Schmockmel:

This responds to your letter requesting an interpretation of the advanced air bag requirements of Federal Motor Vehicle Safety Standard No. 208, Occupant crash protection (FMVSS No. 208). On May 12, 2000, the National Highway Traffic Safety Administration (NHTSA) published a final rule in the Federal Register (65 FR 30680) requiring advanced air bags in all passenger cars, multipurpose passenger vehicles, light trucks and buses with a gross vehicle weight rating (GVWR) of 8,500 lb or less. The phase-in for these new requirements begins September 1, 2003. That final rule established new, advanced air bag performance requirements to minimize the risk of injury to children, as well as new requirements to enhance protection of small and mid-size adults. The requirements in S19, S21, and S23 are designed to minimize the risk that air bags pose to infants and small children. S19 provides manufacturers with two different options for complying with the standard (low risk deployment or automatic suppression), while S21 and S23 provide three options (low risk deployment, automatic suppression, or dynamic automatic suppression). Your questions are related to the interplay between the infant low risk deployment option and the infant automatic suppression option, particularly in light of the absence of a dynamic automatic suppression option for infants. I am pleased to provide a response.

You first request an interpretation of the requirement set forth in S19, and the test procedure provided in S20.4, relating to the low risk deployment option for infants. Specifically, you ask whether a system that is certified to the low risk deployment option for infants can suppress the air bag when the applicable child restraint is in the rear-facing mode, and either suppress or deploy when the restraint is placed in the forward-facing mode. The answer to the first part of this question is no. Under the low risk deployment option, one or more stages of the air bag must deploy when the restraint is rear-facing. The answer to the second part of your question is yes. If a system is certified to the low risk deployment option for infants, we will deploy the air bag as specified in S20.4. Thus, injury measurements are only recorded when the child restraint is in the rear-facing mode.

The requirements for the infant low risk deployment option are found at S19.3, which states that "each vehicle shall meet the injury criteria specified in S19.4 of this standard when the passenger air bag is deployed in accordance with the procedures specified in S20.4." The low risk deployment option is designed to address injuries that can result when an infant is very close to the air bag.

S20.4 specifies several conditions for testing the deploying air bag. First, the manufacturer must assure compliance to S19.3 using any child restraint listed in subparts B and C of Appendix A to the standard. For purposes of S19.3, the air bag is only tested with the child restraints in their rear-facing condition. Under the specified test conditions, the vehicle seat is moved as far forward as possible, while avoiding contact with the vehicle interior. This is done to ensure that the dummy's head is placed as close to the deploying air bag as possible. The air bag is only tested with the child restraint in a belted condition.

The air bag is deployed at whatever level of force and combination of stages that would deploy in any rigid barrier crash up to 64 km/h (40 mph) when a test dummy is positioned in a restraint as specified in the test procedure, except that the vehicle seat may be at any seat track position. This level is determined by running an indicant test, as described in S20.4.9, at impact speeds up to 40 mph with a dummy-occupied restraint installed in the passenger seat.

When NHTSA runs a compliance test on a vehicle certified to S19.3, it will only deploy the air bag at the level and, if equipped with a multi-stage inflator, with the combination of stages, that would deploy in the specified indicant test. Manufacturers may not use suppression technology to ensure that there will be no air bag deployment in the indicant test if they are certifying to the low risk deployment option.

Your second question relates to the absence of a dynamic automatic suppression option in S19. Specifically, you ask whether a manufacturer may use a system whereby the air bag is suppressed in all but the forward-facing mode, where a benign deployment strategy would be used. This option is not currently allowed under S19. This is because such a system would not meet either the low risk deployment option or the automatic suppression option. Should the agency add a third, dynamic suppression option to S19, such a compliance strategy would be allowed as long as all the criteria of that option were met in full.

I hope this letter addresses your concerns. Please feel free to contact Rebecca MacPherson of my staff at (202) 366-2992 should you have any additional questions.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:208
d.10/7/03

ID: aiam2728

Dear Mr. Brennan: This responds to your November 21, 1977, letter asking whether a schoo bus that is propelled by a propane-fueled engine is required to comply with Federal Motor Vehicle Safety Standard No. 301-75, *Fuel System Integrity* (49 CFR 571.301-75).; Paragraph S3 of Safety Standard No.301-75 specifies that the standar applies to school buses that have gross vehicle weight ratings greater than 10,000 pounds and use fuel with a boiling point above 32 degrees F. Since the boiling point of propane is below 32 degrees F, Safety Standard No. 301-75 would not be applicable to a school bus propelled by a propane engine.; Please contact us if you have any further questions. Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: nht93-7.38

DATE: October 22, 1993

FROM: Jim Davis -- President, Russell Performance Products

TO: David Elias -- Chief Counsel, DOT

COPYEE: Bill Collins -- Titeflex; Rick Rohauer -- Russell

TITLE: None

ATTACHMT: Attached to letter dated 5/12/94 from John Womack to Jim Davis (A42; Std. 106), letter dated 10/22/93 from Jim Davis to NHTSA Office of Vehicle Safety Standards, Crash Avoidance Division, and letter dated 11/16/93 from Jim Davis to David Elias

TEXT:

I am writing to you to formally describe our involvement with Titeflex Industrial Americas with respect to the submission Titeflex has made to the D.O.T. with regard to brake hoses and brake hose assemblies that meet D.O.T. Specification MVSS 106.

Titeflex developed a hose, hose end, and assembly procedure to produce a brake hose assembly utilizing a Teflon inner liner hose with a stainless braided outer covering that meets D.O.T. Specification MVSS 106. These hose assemblies have passed all the pertinent tests and these test results are on file with the D.O.T. from Titeflex Industrial Americas.

Titeflex has in turn given Russell Performance Products the exclusive license to manufacture, assemble, and market these hose assemblies to the marketplace. Titeflex supplies Russell with the Teflon stainless braided hose used in these assemblies. Russell manufactures the hose ends utilizing Titeflex engineering drawings. Russell permanently assembles the Titeflex hose to the Titeflex designed and Russell manufactures hose ends using special crimping machines. Russell personnel have been trained in these assembly procedures by Titeflex personnel.

Russell has also filed a copy of our identifying logo, a stylized symbol "R", with the Office of Vehicle Safety Standards. Russell is selecting the option provided in S5.2.4.1 of MVSS 106 to identify each hose assembly produced by Russell Performance Products that will be marketed as a hose assembly that meets D.O.T. Specification MVSS 106.

We are awaiting directions from your office as to whether both the Russell "R" and the Titeflex "T" need to be stamped, etched or engraved on one hose end of the hose end assembly or whether just the Russell "R" will suffice.

The other issue which needs to be addressed is if the raw hose that we purchase from Titeflex has to be identified per S5.2.2. Due to the construction of the hose which has a stainless braided outer covering it is impossible to print any data directly on the hose as is commonly performed on rubber hose. To apply identifying labels every six inches is also impractical.

Russell and Titeflex's position is that this is not necessary for the following reasons:

1. Russell is the only marketer of this hose making the claim that it meets D.O.T. Specification MVSS 106. As a result of this exclusive arrangement the source of the hose, once it is made into an assembly by Russell and placed into use by a consumer, is directly traceable only to Titeflex in the event of any problem in the field. Titeflex will be the ONLY supplier of such hose to Russell. 2. Assuming the date of manufacture requirement has to do with determining shelf life on normal rubber hose, our position is that stainless braided covered Teflon hose has relatively unlimited shelf life and the actual date of manufacture is not an issue.

We submit that by identifying the hose assemblies with the Russell symbol "R" and additionally with the Titeflex symbol "T" provides all the traceability required to meet the intent of the D.O.T. specifications.

I believe this covers everything we discussed on the phone. If I have missed anything or you need further clarification on any points, please let me know.

ID: aiam0014

"Dear Mr. Lucki: This responds to your letter requesting a interpretation of Federal Motor Vehicle Safety Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect. You asked whether a planned gear position display for automatic transmission vehicles would meet the standard's requirement that full gear position information be provided in a single location. As discussed below, the answer to that question is yes. By way of background information, the National Highway Traffic Safety Administration does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles and equipment meet applicable standards. The following represents our opinion based on the facts provided in your letter. As you are aware, on March 26, l99l, this agency published in the Federal Register a final rule amending Standard No. l02. Among the amendments is a new S3.l.4.4 that requires, for all automatic transmission vehicles, that full gear position information, i.e., identification of shift level positions, including the position of the gears in relation to each other, and the gear position selected, be displayed 'in view of the driver in a single location.' According to a drawing enclosed with your letter, your planned gear position display would be located on the instrument panel, between the speedometer and tachometer. The current gear position, either P, R, N, D, 3, 2, or l, would be shown in a square, by means of electronic display. The position of the gears in relation to each other, i.e., P R N D 3 2 1, would be marked adjacent to the electronic display. You state that the gear positions in relation to each other will be illuminated when the headlamps are activated. It is our opinion that your planned design would meet S3.l.4.4's requirement that full gear position information be displayed in a single location. The gear position selected would be shown in the square electronic display. The position of the gears in relation to each other would be marked adjacent to the electronic display. Because the marking of the position of the gears in relation to each other would be adjacent to the electronic display, it is our opinion that all of the information would be considered to be provided in a single location. I note that this same issue was addressed in the preamble to the March l99l final rule, in connection with a comment submitted by Chrysler. The agency stated the following: If Chrysler wishes to provide a display of current gear position information on the instrument panel, it is free to do so. Under the amendment, it can either provide full gear position information at that location, e.g., include a 'P R N D L' label adjacent to the display, or it can provide a display of current gear position information only on the instrument panel and include a display of full gear position information elsewhere, e.g., on the floor console. 56 FR l2470, March 26, l99l. Your proposed design is consistent with the first of the two options discussed in that paragraph. I hope this responds satisfactorily to your concerns. If you have any further questions, please contact Dorothy Nakama of my staff at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel";

ID: aiam1402

Dear Mr. Welebir: Thank you for your letter of December 28, 1973, File No. 1041 requesting information on the Federal installation requirements for safety belts in a 1971 Toyota Land Cruiser.; Federal Motor Vehicle Safety Standard No. 208, *Occupant Cras Protection* (formerly titled 'Seat belt installation'), required safety belts in all designated seating positions of all passenger cars manufactured on or after January 1, 1968. Similar requirements were instituted for trucks and multipurpose passenger vehicles manufactured after July 1, 1971. The Toyota Land Cruiser is classified as a multipurpose passenger vehicle. If it were manufactured before July 1, 1971, no installation requirement would have applied. It should be noted that seat belts were not factory-installed in some Land Cruisers, and we know of one Arizona dealer who failed to install seatbelts in a Land Cruiser built after that date.; In answer to your second question, the Land Cruiser did not have an exemption under 15 U.S.C. S1410 or any other section of the Act.; Sincerely, Lawrence R. Schneider, Chief Counsel.