ID: aiam3676

Dear Mr. Grant: This responds to your February 25, 1983, letter asking whether a chil seat that you would like to import would comply with Standard No. 213, *Child Restraint Systems*. Your child seat attaches to a vehicle by use of several of its own anchorage straps which are attached to existing vehicle belt anchorages or by drilling new anchorages. The seat does not use the existing car seat belt system.; Paragraph S5.3.2 of the standard states: 'When installed on a vehicl seat, each child restraint system, other than child harnesses, shall be capable of being restrained against forward movement solely by means of a Type I seat belt assembly (defined in S571.209) that meets Standard No. 208 (S571.208), or by means of a Type I seat belt assembly plus one additional anchorage strap that is supplied with the system and conforms to S5.4.' Since your system has its own harnesses and does not utilize the existing car seat belt system (Type I seat belt), it would not comply with this portion of the standard.; The agency requires child seats to be attachable by use of the existin car seat system for ease of installation and to assist in proper installation and usage. The agency determined in rulemaking that to permit other systems that were more complex and that require the proper attachment of several harness straps would not be in the interest of safety, since it would likely result in improper child seat installation.; Sincerely, Frank Berndt, Chief Counsel

ID: nht70-2.21

DATE: 08/11/70

FROM: AUTHOR UNAVAILABLE; Rodolfo A. Diaz; NHTSA

TO: Recreational Vehicle Institute Inc.

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your letter of July 23, 1970, in which you asked for the Bureau's interpretation of the phrase, "designated seating position that includes the windshield header within the head impact area."

The phrases "designated seating position" and "head impact area" are both defined in the general Definitions section of the standards, 49 CFR 571.3. The remaining substantive phrase, "windshield header," is not defined in the standards. It is intended to refer to the portion of the interior of the vehicle immediately above the top of the windshield, usually but not necessarily a strip of molding separating the glass from the interior roof.

ID: 571.205-Plexiglass Barriers Clarification-Klos

Mr. Thomas Klos 
AROW Global Corp. 
924 N. Parkview Circle Mosinee, WI 54455
 
Dear Mr. Klos:
 
This responds to your email to the National Highway Traffic Safety Administration (NHTSA) asking about a letter of interpretation NHTSA issued to Mr. Mike Collingwood of the Illinois DOT on August 11, 2020. The letter concerned the installation of plexiglass barriers installed to the right of the driver in school buses to help minimize the spread of the Coronavirus Disease 2019 (COVID-19). Please note that our answer below is based on our understanding of the specific information provided in your email.
 
Background
 
NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act, 49 U.S.C. Chapter 301) to issue Federal motor vehicle safety standards (FMVSS) that set performance requirements for new motor vehicles and new items of motor vehicle equipment. The Safety Act requires manufacturers to self-certify that their vehicles and equipment conform to all applicable FMVSS in effect on the date of manufacture. NHTSA also investigates safety- related defects.
 
On August 11, 2020, NHTSA responded to Mr. Collingwood’s request regarding the installation of “plexiglass barriers” installed to the right of, and behind, the driver’s seating position on school buses.1 In the letter, NHTSA concluded that the barriers were items of motor vehicle “glazing” that must comply with FMVSS No. 205, “Glazing material.” FMVSS No. 205 applies to glazing installed in motor vehicles prior to first purchase and to aftermarket glazing for use in motor vehicles. The standard incorporates by reference an industry standard, the “American National Standards Institute American National Standard for Safety Glazing Materials for Glazing Motor Vehicles and Motor Vehicle Equipment Operating on Land Highways-Safety Standard” (ANSI/SAE Z26.1-1996).
 
In the August 2020 letter, NHTSA stated that the barriers located to the right of the driver would be “interior partitions” located in an area requisite for driving visibility. As interior partitions located in an area requisite for driving visibility, the barriers would be required to be of one of the following types of glazing: Items 1, 2, 4, 4A, 10, 11A, 11C, 14, 15A, or 15B.
 
In your letter, you ask about Table A1 in the ANSI/SAE Z26.1-1996 standard, which provides a list of glazing types that may be used for “[g]lazing to the immediate right and left of the driver” for buses. You state that, because of this category, you historically have not used glazing with AS4 or AS4A designations (hereafter referred to as Item 4 and 4A glazing) on barriers installed to the right of the driver. You ask for guidance to ensure you are using the correct glazing types for interior barriers located to the immediate right and left of the driver.
 
Items 4 and 4A glazing may be used on barriers (partitions) installed to the right of the driver. Table A1 is located in the appendix to ANSI/SAE Z26.1-1996, and the appendix, as stated in its heading, is not a part of the ANSI standard, but is included for information purposes only.2 Accordingly, when there is any disparity between the language in Table A1 and the standard, the information within the standard prevails.
 
Subsection 4.2 of the ANSI standard specifies that Item 4 and Item 4A glazing may be used in “interior partitions” and does not specifically address the category of “glazing to the immediate right and left of the driver.” Because NHTSA considered the plexiglass barriers referenced in the August 11, 2020 letter to be interior partitions, and because the standard does not exclude the use of Items 4 and 4A glazing in glazing located to the immediate right of the driver, NHTSA concluded that Items 4 and 4A glazing may be used in the partitions.
 
I hope this information is helpful. If you have any further questions, please feel free to contact Callie Roach of my staff at this address or at (202) 366-2992.
 
Sincerely,
 
                       Digitally signed by ANN
ANN ELIZABETH ELIZABETH CARLSON
  Date: 2022.05.31
  13:07:01 -04'00'
CARLSON
 
Ann Carlson 
Chief Counsel

Dated: 5/31/22
Ref: FMVSS No. 205
 
1 Letter to Mr. Mike Collingwood, (August 11, 2020) available at https://isearch.nhtsa.gov/files/571.205%20Plexiglass%20Barriers%20(002).htm. 
2 The ANSI standard states: “(This Appendix is not a part of American National Standard Safety Code for Safety Glazing Materials for Glazing Motor Vehicles Operating on Land Highways, Z26.1-1996, but is included for information purposes only.)”

ID: 2522y

AIR MAIL

Mr. Ed McCarron Western Star Trucks Inc. 2076 Enterprise Way Kelowna, British Columbia, Canada V1Y 6H8

Dear Mr. McCarron:

This responds to your letter asking about the application of Safety Standard No. 302, Flammability of Interior Materials, to a particular mattress design, and how the mattress would be tested under the standard. I regret the delay in responding.

Paragraph S4.1 of Standard 302 sets forth a listing of the vehicle occupant compartment components that must be certified as complying with the flammability resistance requirements of paragraph S4.3. Paragraph S4.1 includes a reference to "mattress covers." You ask whether NHTSA would consider six components of your mattress design to be included in the term "mattress cover" and thus subject to Standard 302. (The first five components you ask about, and a portion of the sixth, satisfy the criterion in S4.2 of being within 1/2 inch of the occupant compartment air space.)

As we understand your sketch, the first three components (which you called the "cover," "foam" and "foam backing") encase the mattress core, or filling. As such, if our understanding is correct, these three constitute the mattress ticking, which we consider as the fabric case permanently enclosing the filling of a mattress. NHTSA has said in past interpretations of Standard 302 that the term "mattress cover" includes both a removable covering put over a finished mattress and the mattress ticking. Thus, the first three components would be subject to the standard.

These three components, which you said in a telephone conversation are quilted together, would be tested separately under S4.2.1 of the standard if they do not adhere to other materials at every point of contact. (The fact that these three are quilted, or stitched, indicates to us that they do not so adhere.) If any of these components adhere to other material at every point of contact, then it would be tested as a composite with the other material.

The fourth component in your sketch is the mattress "fill." Paragraph S4.1 of the standard lists mattress covers only. NHTSA has consistently interpreted S4.1 as not including the mattress filling.

The fifth component is a fabric "corner reinforcement" that appears to be approximately two inches in length and stitched on the outside of the mattress cover. NHTSA indicated in interpretative letters of Standard 302 dated December 15, 1972 and May 1, 1972 that a component that is "incorporated into" a component that is listed in S4.1 is subject to the standard. (The agency said in the December 1972 letter that "mattress cover" includes tufting, since tufting is incorporated into mattress covers.) Since the fifth component is sewn to the corner of the mattress and appears to be made part of the mattress cover, we believe that the corner reinforcement is incorporated into the mattress cover. Thus, the fifth component would be subject to the standard. If it does not adhere to another material at every point of contact, it is tested separately under S4.2.1.

The sixth component is the "fill backing" which appears to be an internal divider between the mattress fill and the springs. It appears from your sketch that the fill backing is not part of the mattress ticking, because the backing is inside the mattress and is separate from the mattress ticking. Thus, we conclude the sixth component is excluded from the standard.

I hope this information is helpful.

Sincerely,

Paul Jackson Rice Chief Counsel

/ref:302 d:6/29/90

ID: 2621y

AIR MAIL

Mr. Ed McCarron Western Star Trucks Inc. 2076 Enterprise Way Kelowna, British Columbia, Canada V1Y 6H8

Dear Mr. McCarron:

This responds to your letter asking about the application of Safety Standard No. 302, Flammability of Interior Materials, to a particular mattress design, and how the mattress would be tested under the standard. I regret the delay in responding.

Paragraph S4.1 of Standard 302 sets forth a listing of the vehicle occupant compartment components that must be certified as complying with the flammability resistance requirements of paragraph S4.3. Paragraph S4.1 includes a reference to "mattress covers." You ask whether NHTSA would consider six components of your mattress design to be included in the term "mattress cover" and thus subject to Standard 302. (The first five components you ask about, and a portion of the sixth, satisfy the criterion in S4.2 of being within 1/2 inch of the occupant compartment air space.)

As we understand your sketch, the first three components (which you called the "cover," "foam" and "foam backing") encase the mattress core, or filling. As such, if our understanding is correct, these three constitute the mattress ticking, which we consider as the fabric case permanently enclosing the filling of a mattress. NHTSA has said in past interpretations of Standard 302 that the term "mattress cover" includes both a removable covering put over a finished mattress and the mattress ticking. Thus, the first three components would be subject to the standard.

These three components, which you said in a telephone conversation are quilted together, would be tested separately under S4.2.1 of the standard if they do not adhere to other materials at every point of contact. (The fact that these three are quilted, or stitched, indicates to us that they do not so adhere.) If any of these components adhere to other material at every point of contact, then it would be tested as a composite with the other material.

The fourth component in your sketch is the mattress "fill." Paragraph S4.1 of the standard lists mattress covers only. NHTSA has consistently interpreted S4.1 as not including the mattress filling.

The fifth component is a fabric "corner reinforcement" that appears to be approximately two inches in length and stitched on the outside of the mattress cover. NHTSA indicated in interpretative letters of Standard 302 dated December 15, 1972 and May 1, 1972 that a component that is "incorporated into" a component that is listed in S4.1 is subject to the standard. (The agency said in the December 1972 letter that "mattress cover" includes tufting, since tufting is incorporated into mattress covers.) Since the fifth component is sewn to the corner of the mattress and appears to be made part of the mattress cover, we believe that the corner reinforcement is incorporated into the mattress cover. Thus, the fifth component would be subject to the standard. If it does not adhere to another material at every point of contact, it is tested separately under S4.2.1.

The sixth component is the "fill backing" which appears to be an internal divider between the mattress fill and the springs. It appears from your sketch that the fill backing is not part of the mattress ticking, because the backing is inside the mattress and is separate from the mattress ticking. Thus, we conclude the sixth component is excluded from the standard.

I hope this information is helpful.

Sincerely,

Paul Jackson Rice Chief Counsel

/ref:302 d:7/ll/90

ID: nht90-3.3

TYPE: Interpretation-NHTSA

DATE: June 29, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Ed McCarron -- Western Star Trucks Inc.

TITLE: None

ATTACHMT: Telefax dated 6-22-90 to Dee Fujita from Ed McCarron attached.

TEXT:

This responds to your letter asking about the application of Safety Standard No. 302, Flammability of Interior Materials, to a particular mattress design, and how the mattress would be tested under the standard. I regret the delay in responding.

Paragraph S4.1 of Standard 302 sets forth a listing of the vehicle occupant compartment components that must be certified as complying with the flammability resistance requirements of paragraph S4.3. Paragraph S4.1 includes a reference to "mattress cove rs." You ask whether NHTSA would consider six components of your mattress design to be included in the term "mattress cover" and thus subject to Standard 302. (The first five components you ask about, and a portion of the sixth, satisfy the criterion i n S4.2 of being within 1/2 inch of the occupant compartment air space.)

As we understand your sketch, the first three components (which you called the "cover," "foam" and "foam backing") encase the mattress core, or filling. As such, if our understanding is correct, these three constitute the mattress ticking, which we cons ider as the fabric case permanently enclosing the filling of a mattress. NHTSA has said in past interpretations of Standard 302 that the term "mattress cover" includes both a removable covering put over a finished mattress and the mattress ticking. Thu s, the first three components would be subject to the standard.

These three components, which you said in a telephone conversation are quilted together, would be tested separately under S4.2.1 of the standard if they do not adhere to other materials at every point of contact. (The fact that these three are quilted, or stitched, indicates to us that they do not so adhere.) If any of these components adhere to other material at every point of contact, then it would be tested as a composite with the other material.

The fourth component in your sketch is the mattress "fill." Paragraph S4.1 of the standard lists mattress covers only. NHTSA has consistently interpreted S4.1 as not including the mattress filling.

The fifth component is a fabric "corner reinforcement" that appears to be approximately two inches in length and stitched on the outside of the mattress cover. NHTSA indicated in interpretative letters of Standard 302 dated December 15, 1972 and May 1, 1972 that a component that is "incorporated into" a component that is listed in S4.1 is subject to the standard. (The agency said in the December 1972 letter that "mattress cover" includes tufting, since tufting is incorporated into mattress covers.) S ince the fifth component is sewn to the corner of the mattress

and appears to be made part of the mattress cover, we believe that the corner reinforcement is incorporated into the mattress cover. Thus, the fifth component would be subject to the standard. If it does not adhere to another material at every point of contact, it is tested separately under S4.2.1.

The sixth component is the "fill backing" which appears to be an internal divider between the mattress fill and the springs. It appears from your sketch that the fill backing is not part of the mattress ticking, because the backing is inside the mattres s and is separate from the mattress ticking. Thus, we conclude the sixth component is excluded from the standard.

I hope this information is helpful.

ID: 1984-1.43

TYPE: INTERPRETATION-NHTSA

DATE: 05/01/84 EST

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: National Truck Equipment Association -- Steven D. Herringshaw, Coordinator of Technical Services

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Steven D. Herringshaw Coordinator of Technical Services National Truck Equipment Association 25900 Greenfield Road Oak Park, Michigan 48257

Dear Mr. Herringshaw:

This is in response to your letter of February 24, 1984, with respect to mounting requirements for clearance and identification lamps under Federal Motor Vehicle Safety Standard No. 108.

Your Exhibit A depicts a body mounted on a chassis-cab, with clearance lamps mounted both on the body and chassis-cab, but identification lamps mounted on only the chassis-cab. You have asked whether the truck body must have a set of identification lamps in order to meet Standard No. 108. The answer is yes. In order to comply with the requirements that identification lamps be located as closely as practicable to the top of the vehicle, a set of identification lamps must be provided for the truck body. You may be interested to know that there is a pending proposal which was published on February 22, 1982; a vehicle such as shown in Exhibit A would comply with a single set cf identification lamps mounted on the cab. enclose a copy of the proposal. The agency has taken no further action with respect to it.

In comparing the vehicles in Exhibit A and Exhibit B you have asked whether theone in Exhibit A is "compliant with the intentions of FMVSS 108." As I have just explained, this vehicle is currently noncompliant with the standard, but would comply if the proposal were adopted. The vehicle in Exhibit B meets the standard.

I hope that this answers your questions.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

February 24, 1984

Office of Chief Counsel Room 5219 National Highway Traffic Safety Administration 400 Seventh St., SW Washington, DC 20590

Dear Sirs:

The National Truck Equipment Association (NTEA) is a national trade association representing over 900 members of the truck body and truck equipment industry. Our members include manufacturers and distributors of truck bodies, chassis, and every imaginable type of truck accessories and equipment.

On behalf of one of our members, a rather substantial manufacturer of van bodies designed to be mounted on a chassis-cab, we would like to request a ruling or official interpretation cf FMVSS 108, Lights. The bodies in question are at least 80 inches wide, so that the vehicles do require both clearance and identification lamps. The issue being questioned is the clause "...as high as practicable".

Following are some specifics on both the bodies and the chassis. -- The bodies range from approximately 81 inches wide to 102 inches wide. -- The bodies range in height from 18 inches above the top of the cab to 75 inches above the cab (on a 13' 6" vehicle). -- The bodies range from 8 feet to 28 feet in length. -- The chassis used with the bodies in question come equipped from the manufacturer with both clearance and identification lights mounted on the roof of the cab.

The question being posed is: "If the chassis is equipped with clearance and identification lights, and the front of the body is equipped with clearance lights mounted at the highest point and the widest point of the vehicle (see exhibit A), is this a compliant vehicle with FMVSS 108, or does the body require an additional set of identification lights on its front end?"

FMVSS 108 allows the clearance lights on the front of the vehicle to be lower than the top of the vehicle if the widest point is lower (see exhibit B). FMVSS 108 also allows the rear clearance lights to be lower if the identification lights are at the top. The NTEA opinion in the past has been that the vehicle in exhibit A is a safer vehicle than the vehicle in exhibit B, and that the overallsize of the vehicle in exhibit A would be more easily recognizable to approaching motorists than a vehicle with lower clearance lights. This would seem to make vehicle A compliant with the intentions of FMVSS 108. Is this a just opinion?

One additional piece of information which may or may not be relevant is that the cost difference to the final customer could be upwards of $100 without the additional I.D. lights.

Thank you for your consideration.

Yours Truly,

Steven D. Herringshaw Coordinator of Technical Services

ID: aiam0411

Dear Mr. Meton: By letter of May 11, 1971, you requested our opinion as to how Standar No. 207, Seating Systems, would apply to a seating system in which the seat belt is attached, to an eyebolt anchored on the seat frame and the eyebolt, in turn, is anchored by another length of webbing to the floor. The evident purpose of such a method attachment on suspension-type seats is to eliminate the shocks which would otherwise be transmitted to the occupant and to augment the strength of the seat, which might be unable by itself to withstand the occupant's weight in a crash.; As you correctly indicate in your letter, a system in which the belt i attached only to the floor requires a force under S4.2(a) and S4.2(b) of 20 times the weight of the seat in a forward and rearward direction, while a system with a lap belt anchored to the seat requires in addition, a force of 5000 pounds to be applied simultaneously to the seat belt in accordance with Standard No. 210 (S4.2(c)). It is our opinion that the hybrid seat belt installation shown by Oshkosh will be likely to impose significant loads on the seating system in the event of a crash, and that it should therefore be treated under S4.2(c) as a system with a seat mounted belt. The webbing running from the eyebolt to the floor is considered to be a part of the seat anchorage and should be employed during the test.; If you have further questions, please advise us. Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: aiam4936

"Dear Mr. Yamamoto: This responds to your letter concerning Federa Motor Vehicle Safety Standard 113, Hood Latch System. You ask two questions about the applicability of the standard's requirements to your vehicle. As explained below, the vehicle must have a hood latch system, but need not have a second latch position on the system or a second hood latch system. By way of background information, NHTSA does not provide approvals of any vehicle or equipment. Under the Vehicle Safety Act, it is your responsibility as a manufacturer to determine whether your vehicles and equipment comply with all applicable safety standards and regulations, and to certify your products in accordance with that determination. The following interpretation represents the agency's opinion based on the information provided in your letter. Standard 113 requires that a vehicle's hood must have a hood latch system (S4.1). The standard also requires a front opening hood to have a second latch position on the latch system or a second hood latch system, if the hood has any open position that partially or completely obstructs a driver's forward view through the windshield (S4.2). The standard defines 'hood' as 'any exterior movable body panel forward of the windshield that is used to cover an engine, luggage, storage, or battery compartment' (S3). Your first question asks about the general applicability of Standard 113's requirements to your vehicle. You believe your vehicle is not subject to any of the standard's requirements because the front panel of the vehicle is not forward of the windshield, and is therefore not a 'hood' as defined by Standard 113. We disagree. According to the drawing you provided with your letter, the body panel appears to be forward of the windshield. We would consider the panel to be a hood, and subject to S4.1's requirement for a hood latch system. Whether the hood must have a secondary latch for the hood (either a second latch position on the hood latch system or a second latch system) is the subject of your second question. The answer is that the hood need not have the secondary latch. The secondary latch is required by S4.2 only for a front opening hood. According to the drawing you provided, your hood is essentially vertical, with the opening on the bottom of the hood. We consider a hood such as yours that is essentially vertical not to be a front opening hood. We note that a secondary latch for front opening hoods is required because such a hood is particularly hazardous if it were to unlatch during vehicle operation. The front opening design of the hood lends itself to flying open while the vehicle is moving, obstructing the driver's view through the windshield. However, an essentially vertical hood such as yours does not lend itself to such openings if it were to become unlatched. The secondary latch is therefore not required by the standard. I hope this information is helpful. If you have further questions, please contact Deirdre Fujita of my staff at (202) 366-2992. Sincerely, Paul Jackson Rice Chief Counsel";

ID: 86-6.12

TYPE: INTERPRETATION-NHTSA

DATE: 12/15/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Adam Humes -- General Manager, Marquis Coachcrafters

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter to Stephen Oesch of my office concerning the effect of our regulations on the conversion of hardtop vehicles into convertibles. You explained that your company will be performing such conversions on new Cadillac Sedan De Villes and you are specifically concerned about how Standards No. 208, Occupant Crash Protection, and Standard No. 209, Seat Belt Assemblies, would affect such conversions. I regret the delay in our response.

Under the National Traffic and Motor Vehicle Safety Act, each manufacturer is required to certify that its vehicles comply with all applicable Federal Motor Vehicle Safety Standards. Under Part 567.7 of the agency's certification regulation, a copy of which is enclosed, a person who alters a new vehicle prior to its first sale to the consumer must certify that the vehicle, as altered, still conforms with all applicable standards. Thus, your company would have to certify that the vehicle you have altered into a convertible still complies with all applicable standards.

In the case of Standard No. 208, S4.1.2.3.2 of the standard permits convertibles to have either a lap or lap/shoulder belt at each front outboard designated seating position. Thus, when you alter a hardtop passenger car, you may remove the lap/shoulder belt and replace it with a lap belt that meets the requirements of S4.1.2.3.2.

Please note that beginning on September 1, 1986, manufacturers must begin phasing-in the installation of automatic restraint systems, such as automatic belts and airbag systems, in their vehicles. For example, S4.1.3.1 of Standard No. 208 requires manufacturers to install automatic restraints in ten percent of their passenger cars manufactured on or after September 1, 1986, and before September 1, 1987. The agency has temporarily excluded convertibles from the automatic restraint requirement during the phase-in period. Instead of automatic restraints, convertibles may have either a manual lap or lap/shoulder belt.

Please note that the agency's final decision in the ongoing rulemaking on applying the automatic restraint requirement to convertibles may affect the conversion of hard-top cars into convertibles in subsequent years. If the agency does not exempt convertibles permanently from the automatic restraint requirement, then a person changing an automatic restraint equipped hardtop car into a convertible would have to ensure that the altered cars still complied with the automatic restraint requirement. Likewise, if the agency applied a dynamic test requirement to the manual safety belts used in convertibles, a person altering an automatic restraint equipped hardtop car into a convertible would have to either retain the automatic restraints or equip the altered vehicles with manual safety belts meeting the dynamic test requirements.

If you have any further questions, please let me know.

Sincerely,

Enclosure

ATTACH.

Steve Oesch -- Office Chief Concel, National Highway Traffic Safety Administration

Dear Mr. Oesch:

The increasing popularity of convertibles in recent years has led to many questions on the effect of Federal auto safety laws on this practice.

Marquis Coachcrafters manufacture convertible conversions on new O.E.M. front wheel drive Cadillac Sedan De Villes. As a manufacturer of new vehicles, my question to you pretains to Standard 208 and 209, Title #49 of the U.S. Code. Standard 208 states that a seat belt must cover 95% of a persons body to meet Federal standards. But in Standard 209, paragraph 54.1.1.2 states that any automobile that is open aired or a convertible has the option of paragraph 4.1.2.3.2. This option states that Type 1 (lap belt) or Type 2 (combo lap and shoulder) conforms to Federal safety laws 208 and 209.

The information I obtained was from a Mr. Tom Grubbs. He may be reached at the following number. (202) 426-2807.

Thank you for your time, consideration and reply.

Your truly,

Adam Humes General Manager -- MARQUIS COACHCRAFTERS