ID: aiam2364

Dear Mr. Johnson: This responds to Motac's June 24, 1976, request to know why a traile with a flat cargo-carrying surface that is not more than 40 inches above the ground is considered a 'heavy hauler trailer' (as defined in Standard No. 121, *Air Brake Systems*), while a trailer with an inclined cargo-carrying surface that is more than 40 inches above the ground over the fifth wheel attachment point is not considered a heavy hauler trailer. You also request confirmation that the period for exclusion of heavy hauler trailers from the standard has been extended to September 1, 1977.; At the time that the 'heavy hauler trailer' exclusion was implemented the agency considered and rejected the addition of trailers with inclined beds to the excluded category. I have enclosed a copy of the notice that implemented the exclusion, which states 'The NHTSA has concluded that trailers with beds higher than 40 inches (including trailers whose beds are below 40 inches over the wheels but higher than 40 inches over the fifth wheel) can accommodate the new larger brake packages available at this time.' Of course, the exclusion was intended to and does apply to the traditional trailer with a gooseneck and a flat cargo-carrying surface that is not more than 40 inches above the ground. The 'double-drop semi', the 'stock drop frame flat-bed', and the '40 '-0' single axle drop frame platform semi' you describe appear to qualify as heavy hauler trailers.; I have enclosed a copy of the amendment of Standard No. 121 tha extends the date for exclusion of heavy hauler trailers to September 1, 1977.; Yours truly, Frank Berndt, Acting Chief Counsel

ID: 02388.ztv

Ms. Collette Walsh
345 University Avenue
Belleville
Ontario K8N 5T7
Canada

Dear Ms. Walsh:

This is in reply to your fax of November 12, 2002, with respect to your fax requests of September 4 and 5, 2002, for interpretations of Federal Motor Vehicle Safety Standard No. 108. Im sorry to say that we have no record of receiving your earlier faxes.

The interpretation you requested on September 4 concerns the headlamp lens marking requirement of the standard for a Type H headlighting system, specifically S7.3.9(c). Paragraph (c) requires that "The face of letters, numbers, or other symbols molded on the surface of the lens shall not be raised more than 0.020 in. (0.5 mm) . . . ." It also requires that "The marking shall be molded in the lens and shall be not less than in. (6.35 mm) in size."

You asked whether "the lens marking (pattern) [must be] in the mold at the time of manufacture" and whether "an acceptable alternative [would be] . . . to laser etch the lens after the molding process." You explained that the marking would be indelible and not raised more than 0.020 in.

We have no information on the durability of laser etching on a headlamp lens but note that a laser etching would not be "molded into the lens" as specified in S7.3.9(c). Therefore, we do not regard your alternative as one that would comply with the standard.

The interpretation you requested on September 5 again involves lens marking. You asked whether it is acceptable to place the information required to be on a lens "on the top of the housing of a tail lamp or headlamp assembly" You added that "the marking would be clearly visible only if the trunk lid or engine compartment lid was open." This would not be acceptable. The information required to be on a lens must be placed on the lens.

If you have further questions, you may call Taylor Vinson of this Office at 202-366-5263.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:108
12/10/02

ID: 1985-02.34

TYPE: INTERPRETATION-NHTSA

DATE: 05/28/85

FROM: AUTHOR UNAVAILABLE; Diane K. Steed; NHTSA

TO: The Honorable Alan K. Simpson

TITLE: FMVSS INTERPRETATION

TEXT:

May 28, 1985 The Honorable Alan K. Simpson United States Senate Washington, D.C. 20510 Dear Senator Simpson: Thank you for your letter on behalf of your constituent, Mr. B. Bruce Bennion, the Assistant Superintendent of Schools in Cody, Wyoming. I regret our delay in responding. I understand that Secretary Dole has recently written you on our regulations pertaining to the use by school districts of commercial-type buses as activity buses. I hope the following discussion will explain the application of our regulations to your constituent. According to Mr. Bennion's letter, the Park County School District No. 6 purchased a used 1982 American Eagle Model 10 bus in order to transport its students to school activities throughout Wyoming. The school district was recently informed that the operation of the bus violated a Federal regulation issued by this agency, and, accordingly, it ceased operation of the vehicle. Mr. Bennion asked for your help in allowing the school district to use its bus. To begin, I would like to explain that there are two sets of regulations, issued under different Acts of Congress, that could affect Park County's school buses. The first of these, the motor vehicle safety standards issued by our agency under the National Traffic and Motor Vehicle Safety Act of 1966 (Public Law 89-563; 15 U.S.C. 1381-1426) apply to the manufacture and sale of new motor vehicles. In a 1974 amendment to the Act, Congress expressly directed us to issue standards on specific aspects on school bus safety, including emergency exits, seating systems, and windows and windshields. The standards we issued became effective April 1, 1977, and apply to each school bus manufactured after that date. If Park County bought a new bus for use as an activity bus, the manufacturer and dealer had to certify that the bus complied with the motor vehicle safety standards applicable to school buses. Am American Eagle type bus is not manufactured to comply with these standards, and could therefore not be sold for use as a new school bus. Since Park county bought a used bus, however, the Vehicle Safety Act standards do not apply. There is nothing under the Act to prevent the school district from buying a used American Eagle bus for school use. there might, however, be an impediment under State law, if wyoming has adopted the provisions of the standard on school transportation issued by our agency under the Highway Safety Act (Public Law 89-564; 23 U.S.C. 401-408). This standard, Highway Safety Program Standard No. 17 (HSPS 17), specifies that a bus used to transport more than 16 pupils to and from school be painted yellow, be equipped with special mirrors and warning lights and be marked "School Bus." We have ruled that the States should apply these specification to activity buses as well as to the buses used for daily transportation. We have also issued instructions under HSPS 17 that any bus manufactured after April 1, 1977, the effective date of motor vehicle safety standards on school buses, should comply with those standards. I want to stress that HSPS 17 has no direct effect on the purchase of used buses by local school districts. HSPS 17 will affect Park County only if Wyoming has adopted it and if Wyoming accepts our view that the specifications apply to the activity buses. If Wyoming chooses to exempt activity buses from being painted, signed, and equipped as school buses, we might disagree with the wisdom of its decision but we would no insist on compliance with HSPS 17 to the extent of taking action against the State. Congress has given us the discretion under the Highway Safety Act not to insist that a State comply with every requirement of the highway safety standards. While we have stressed the importance of a strong pupil transportation program, consistent with HSPS 17, we have not insisted that the States comply with every feature of the standard. Having said this, I will conclude by restating the importance that our agency attaches to the use of safe buses to transport children. It remains the agency's position that a yellow school bus meeting the motor vehicle safety standards is the safest means of transportation for school children. It may not be the most comfortable for long trips, since it lacks the reclining seats and restroom facilities of the inter-city buses, but it has to cushion impacts, windows that prevent ejections, and exits that facilitate escape after crashed. In the years since buses had been a marked improvement in school features when they decide to buy a used school bus. If you have any further questions,please do not hesitate to contact my office. Again, my apologies for our delay in responding. Sincerely, Diane K. Steed Diane K. Steed

ID: nht94-1.33

TYPE: Interpretation-NHTSA

DATE: January 28, 1994

FROM: Steve Williams -- Director, Public Transportation, Mississippi Department of Education

TO: Terry L. Voy -- Consultant, Bureau of School Administration and Accreditation, Iowa Department of Education

TITLE: None

ATTACHMT: Attached to letter dated 5/31/94 from John Womack to Mike Parker (A42; Std. 222; Part 571.3), letter dated 4/18/94 from Mike Parker to Christopher Hart, and letter dated 1/31/94 from Steve Williams to William Moss

TEXT:

A school district in our state has expressed interest in installing four VCR's and TV monitors on a school bus. The equipment would be used to show films relating to drug education and would target long school bus routes. A school district in Arizona h as implemented such a program on one bus and serves as a model for the interest expressed by the district in Mississippi.

The school district proposes to mount the equipment in a school bus equipped with luggage racks. Two units would be mounted in the front of the luggage racks on each side and two in the middle on each side. This provides for maximum visibility of the TV monitor.

We all applaud these efforts to provide an educational opportunity for students that must ride lengthy and time consuming bus routes. However, to my knowledge, there has been no official test conducted to certify the wiring, mounting, and installation o f such equipment. This certainly raises various safety and liability concerns. However, it does not appear to be in conflict with the Federal Motor Vehicle Safety Standard 222, head impact zone.

The 1990 National Standards for School Buses and Operations (NSSBO) appear to most appropriately address this matter. Bus Body Standards - Interior (1), page 16, states in part:

Interior of bus shall be free of all unnecessary projections, which include luggage racks and attendant hand rails, likely to cause injury.

Based on the concerns expressed above, I am requesting an interpretation and/or opinion from the Interpretation Committee on the following questions:

1. Would the installation of VCR's and TV monitors in luggage racks on a school bus be prohibited based on the language of the 1990 NSSBO - Bus Body Standards - Interior (1), page 16.

2. Would the installation of VCR's and TV monitors in luggage racks on a school bus be prohibited based on any other standard included in the 1990 NSSBO.

3. In the committee's opinion, does installation of VCR's and TV

monitors on school buses as described above, violate any Federal Motor Vehicle Safety Standard. Although Federal Motor Vehicle Safety Standards regulate the manufacture and sale of school buses, it is the intent of national and state specifications that users (school districts) not modify or install any component contrary to Federal Motor Vehicle Safety Standards.

I appreciate your assistance and timely consideration of this matter. If you have any question, let me know.

ID: nht95-4.80

TYPE: INTERPRETATION-NHTSA

DATE: November 17, 1995

FROM: Samuel J. Dubbin -- Chief Counsel, NHTSA

TO: Jim Young -- Wheeled Coach

TITLE: NONE

ATTACHMT: ATTACHED TO 10/17/95 LETTER FROM Jim Young to John Womack (OCC 11303)

TEXT: Dear Mr. Young:

This is in reply to your FAX of October 17, 1995, asking for interpretations of Motor Vehicle Safety Standard No. 108, as in relates to "customer specifications for options incorporated into, or in addition to FMVSS lighting." You have described these op tions as:

"Brake override circuit for rear facing warning lights. The rear warning lights flash as warning lights until the brakes are applied, at which time they become stead burn. This option is in addition to the standard brake lights. If this is acceptable, should the lights be required to meet all requirements of stop lights? (ie.; maximum luminous intensity, color, etc. . .)"

As you clarified in a phone conversation with Taylor Vinson of this Office on November 2, the "rear facing warning lights" are part of the ambulance lighting system which is not a system required by Standard No. 108. This option is permissible. Althoug h there is no Federal legal requirement that governs the performance of ambulance warning systems, we recommend that the rear facing warning lights are red, the required color for stop lamps, inasmuch as the intent seems to be provide an additional indic ation that the brake have been applied.

"Brake Enhancer. Standard or additional stop lights are made to flash on/off several times before going steady burn."

This is not permissible. Standard No. 108 requires all stop lamps to be steady burning.

"Back-up alert strobes. Rear facing high intensity strobe lights that are activated when the gearshift lever is placed into reverse gear."

Optional equipment is permissible if it does not impair the effectiveness of lighting equipment required by the standard. You have not indicated the color of the strobe lamps. If they are red or amber, they could cause confusion in the eyes of an obser ver when operated simultaneously with the steady burning

P2

white backup lamp. There is a lesser possibility of confusion if they cast a white light, as long as they do not mask the steady burning backup lamp. In that event, the strobes could be fitted to the ambulances.

"Taillight flashers. Taillights or brake lights are flashed alternate to backup lights until brakes are applied, at which time they go steady burn. The option at times may be requested to only work of the rear doors on the ambulance are open."

This is not permissible. Standard No. 108 requires taillamps as well as stop lamps to be steady burning, under all circumstances.

If you have further questions, you may refer them to Taylor Vinson (202-366-5263).

Sincerely,

ID: nht89-3.40

TYPE: INTERPRETATION-NHTSA

DATE: 11/20/89

FROM: STEPHEN P. WOOD -- ACTING CHIEF COUNSEL NHTSA

TO: BUD SHUSTER -- U.S. HOUSE OF REPRESENTATIVES

ATTACHMT: LETTER DATED 10/16/89 FROM DONALD S. CLARK -- FEDERAL TRADE COMMISSION TO CONGRESSMAN BUD SHUSTER; LETTER DATED 8/8/89 FROM CONGRESSMAN BUD SHUSTER TO THE DIRECTOR OF CONGRESSIONAL RELATIONS -- DEPARTMENT OF COMMERCE

TEXT: Dear Mr. Shuster:

Thank you for your inquiry on behalf of your constituent, Mr. Lester Hoover. Mr. Hoover requested information about laws that cover the branding of tires that are not first quality. In addition, he asked whether there is any way to apply such a law to o ther consumer goods such as batteries. This inquiry has already been referred to the Federal Trade Commission (FTC), which sent you a letter dated October 16, 1989 explaining its tire labeling regulations. The FTC's letter also indicated that this agen cy's tire labeling regulations might be of interest to Mr. Hoover.

Let me begin by explaining that the National Highway Traffic Safety Administration has promulgated regulations related to tires. In particular, Federal Motor Vehicle Safety Standard No. 109, New Pneumatic Tires, applies to new tires for use on passenger cars, Standard No. 119, New Pneumatic Tires for Vehicles Other Than Passenger Cars, applies to new tires for use on vehicles other than passenger cars, Standard No. 117, Retreaded Pneumatic Tires, applies to retreaded tires for use on passenger cars, an d Part 569, Regrooved Tires, applies to all regrooved tires. Each of these regulations includes some labeling requirements.

The National Traffic and Motor Vehicle Safety Act requires that every manufacturer certify that each of the tires it produces complies with these standards, including the labeling requirements. Thus, even a tire identified as something like "blemished" or "out-of-round" must be certified as complying with all provisions of the applicable safety standard(s). None of the regulations administered by this agency require, or establish any standards for, the identification of tires as something other than " first quality."

If some Federal regulation exists that requires the identification of tires as something other than "first quality," it would be promulgated by the FTC under that agency's authority to regulate unfair and deceptive trade practices. If the FTC does not h ave any such regulation, I am not aware of any other Federal agency that would have authority in this area. Similarly, I am not aware of any such labeling regulations that could be applied to consumer goods such as batteries.

I hope you find this information helpful. Please let me know if you have any further questions or concerns in this area.

Sincerely,

ID: aiam1522

Dear Mr. Kidwell: This is in reply to your letter of May 29, 1974, concerning th labeling requirements of Standard No. 218, *Motorcycle Helmets*. You ask for our 'review, comments, interpretation, recommendations, and opinions' on two test reports you had done with respect to the placement of the DOT symbol and its attachment on helmets manufactured to the standard's requirements.; The National Highway Traffic Safety Administration does not provid approval of any item of motor vehicle equipment as conforming to any motor vehicle safety standard. Each item is required to conform, and each manufacturer must determine, by methods within his discretion, whether his product conforms to a standard. With respect to the method of affixing the DOT label to the helmet, any methods that are reasonably designed to provide a label that is clearly legible for the expected life of the helmet would be satisfactory.; We would like to point out, however, that from the photograph an drawings you enclosed, it appears that the DOT symbol on your helmet is partially obscured by a goggle snap and its related material. We do not consider this obscuring of the DOT symbol to conform to the intent of the standard. Accordingly, we recommend that you either reduce the length of the snap and its related material or raise the symbol to attain complete visibility.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: aiam1520

Dear Mr. Kidwell: This is in reply to your letter of May 29, 1974, concerning th labeling requirements of Standard No. 218, *Motorcycle Helmets*. You ask for our 'review, comments, interpretation, recommendations, and opinions' on two test reports you had done with respect to the placement of the DOT symbol and its attachment on helmets manufactured to the standard's requirements.; The National Highway Traffic Safety Administration does not provid approval of any item of motor vehicle equipment as conforming to any motor vehicle safety standard. Each item is required to conform, and each manufacturer must determine, by methods within his discretion, whether his product conforms to a standard. With respect to the method of affixing the DOT label to the helmet, any methods that are reasonably designed to provide a label that is clearly legible for the expected life of the helmet would be satisfactory.; We would like to point out, however, that from the photograph an drawings you enclosed, it appears that the DOT symbol on your helmet is partially obscured by a goggle snap and its related material. We do not consider this obscuring of the DOT symbol to conform to the intent of the standard. Accordingly, we recommend that you either reduce the length of the snap and its related material or raise the symbol to attain complete visibility.; Yours truly, Richard B. Dyson, Assistant Chief Counsel

ID: nht87-1.75

TYPE: INTERPRETATION-NHTSA

DATE: 05/13/87

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: WILLIAM E. DANNEMEYER -- HOUSE OF REPRESENTATIVES

TITLE: NONE

ATTACHMT: LETTER DATED 05/08/67 TO EARL W KINTNER, FROM WILLIAM HADDON; LETTER DATED 05/10/67, TO HAROLD T. HALFPANNY, FROM LOWELL K BRIDWELL; LETTER DATED 03/30/87 TO ED BABBITT, FROM WILLIAM E DANNEMEYER; LETTER DATED 11/06/86 TO LARRY THUNDERBIRD AND MUSTANG FROM JOHN H HEINRICH AND J. MICHAEL ZEHNER

TEXT: Dear Mr. Dannemeyer:

Thank your for your letter to Mr. Babbitt, our Director of Congressional Affairs, on behalf of your constituent, Mr. Ed Money. Mr. Money recently imported a shipment of "spinner hubcaps" from Taiwan. These hubcaps were seized by the U.S. Customs Servic e for failing to conform with the requirements of Federal Motor Vehicle Safety Standard No. 211, Wheel Nuts, Wheel Discs, and Hubcaps (49 CFR $ 571.211). You stated that it was your understanding that Standard No. 211 applies only to vehicle manufacture rs and not to aftermarket parts dealers, and that the Customs Service had erroneously applied Standard No. 211 to the products you constituent intended to import. Accordingly, you asked that we review the requirements of Standard No. 211 and state wheth er those requirements apply to "anyone other than a manufacturer of automobiles".

After carefully reviewing the language of Standard No. 211 and every prior interpretation of the standard, we have concluded that the Customs Service correctly applied Standard No. 211 to Mr. Money's hubcaps. Section S2 of Standard No. 211 specifies tha t, "This standard applies to passenger cars, multipurpose passenger vehicles, and passenger car and multipurpose passenger vehicle equipment." (Emphasis added) This language means that the standard applies to all wheel nuts, wheel discs and hubcaps for u se on passenger cars or multipurpose passenger vehicles, regardless of whether the part is to be used as original equipment or as a replacement part. This meaning has long been affirmed in this agency's letters of interpretation. We explained the appli cation of Standard No. 211 in letters of May 8, 1967, to Mr. Earl Kinter, and May 10, 1967, to Mr. Harold Halfpenny. I have enclosed copies of both these previous interpretations for your information. These letters are still accurate expressions of th e agency's opinion on this question.

Standard No. 211, which was one of the original Federal motor vehicle safety standards, became effective on January 1, 1968. As of that date, section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act [15 U.S.C. 1397(a)(1)(A)] made it ill egal to "manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States" any "spinner hubcaps" (Emphasis added). Therefore, we believe the U.S. Customs Service was

2 enforcing the law properly when it seized the hubcaps Mr. Money sought to import.

You enclosed with your letter advertisements from several other aftermarket parts suppliers offering spinner hubcaps for sale. Our enforcement personnel will investigate each of those suppliers and take appropriate actions if their hubcaps violate Stand ard No. 211.

I hope this information clarifies the law on this subject. If you have any further questions or need more information, please do not hesitate to contact me.

ENCLOSURES

Sincerely,

ID: nht79-3.6

DATE: 08/27/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Bruce Willhite

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to the questions you raised with Ms. Debra Weiner of my office on June 29, 1979, about your intention to start a business that will sell and install auxiliary diesel fuel tanks in passenger cars. You noted that you would like to install the tanks in used vehicles and possibility in new ones. Specifically, you asked what Federal law applies to your proposed activities and whether these activities would violate any Federal law.

The National Traffic and Motor Vehicle Safety Act of 1966, as amended, (the Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal Motor Vehicle Safety Standards (FMVSS's) applicable either to vehicles or to equipment for installation in vehicles. FMVSS 301-75, Fuel System Integrity, (see enclosed copy) is a vehicle standard which applies to vehicles, including passenger cars, which use fuel with a boiling point above 32 degrees F. (this includes both gasoline and diesel fuel).

Under section 108(a)(1)(A) and (b)(1) of the Act, new motor vehicles must comply with the FMVSS's applicable to them until they are first purchased by someone for purposes other than resale. That purchase is completed when the vehicle is delivered to the ultimate consumer. The NHTSA regulations include two measures designed to ensure compliance with applicable FMVSS's until this delivery. First, manufacturers of new vehicles are required to affix to each vehicle they produce a label which certifies the vehicle's compliance with all applicable FMVSS's. Second, any person who prior to the first sale, alters a certified vehicle in a manner that significantly affects either its configuration or purpose is considered to be not only an alterer but also a manufacturer and therefore, must recertify the entire vehicle as complying with all applicable FMVSS's. (49 Code of Federal Regulations (C.F.R.) 567.7).

Should a noncompliance due to an alterer's modification be discovered in a recertified vehicle, the alterer would be liable for a civil penalty unless he or she could establish that he or she did not have actual knowledge of the noncompliance, and that he or she did not have reason to know in the exercise of due care that the vehicle did not comply. (Section 108(b)(2) of the Act.) The civil penalty imposed could be up to $ 1000 for each violation of an applicable FMVSS. (Section 109 of the Act.)

Since the installation of an auxiliary fuel tank significantly affects the configuration of an automobile, the legal provisions summarized above would apply to you as an installer of auxiliary fuel tanks in new cars (i.e., cars not yet purchased for purposes other than resale and delivered to that purchaser). Thus, upon installing an auxiliary fuel tank in a new vehicle you would be required to affix a label to the vehicle stating that the vehicle as altered conforms to all applicable FMVSS's including FMVSS 301-75 in effect on a date not later than the date on which the alterations were completed (49 C.F.R. Part 567.7). This means that not only must the original gasoline fuel system meet the performance requirements encompassed by FMVSS 301-75 but that the system as supplemented by the auxiliary tank added by you to a new car must meet them also.

As an installer of auxiliary fuel tanks in new vehicles, you will also be subject to the provisions of sections 151 et seq. of the Act (see enclosure). If you or this agency finds that there is a safety defect in the manner in which you have installed auxiliary tanks in new vehicles, you would be required to notify purchasers and remedy the defect. Under sections 108(a)(1)(D) and 109(a) of the Act, any person who fails to provide notification of or remedy for a safety defect is liable for a civil penalty of up to $ 1000 per violation.

As a dealer in and installer of auxiliary fuel tanks in used vehicles, you would be subject to section 108(a)(2)(A) of the Act. Section 108(a)(2)(A) in essence prohibits the entities and persons listed below from knowingly removing, disconnecting or reducing performance of equipment or elements of design installed on a vehicle in accordance with applicable FMVSS's. There is no prohibition against an individual person modifying his or her own vehicle. Specifically, the section provides:

No manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . .

A person or entity found to have violated this section would be liable for a civil penalty of up to $ 1000 for each violation. (Section 109 of the Act.)

If one of the persons or entities listed above adds an auxiliary gasoline tank to a vehicle manufactured in accordance with FMVSS 301-75, and in the process knowingly reduces the performance of the fuel system originally installed in the motor vehicle, he or she has violated section 108(a)(2)(A). (H.R. No. 1191, 93d Cong., 2d Sess. 34 (1974)). Such reduction of performance could occur, for example, if gasoline from the original system (a fuel system includes the filler pipe, tank, gasoline lines, fuel pump, carburetor, and engine) could be leaked through a rupture in the auxiliary tank and fuel lines, and if the design, materials, construction, installation or location of the auxiliary tank and fuel lines made them more susceptible to rupture than the original fuel system.

In closing, I would like to point out that, in addition to the Federal law discussed above, there may be State products liability laws applicable to your proposed activities. As an installer of auxiliary fuel tanks, you could be liable for the manner and location in which the tanks are installed. Therefore, you may wish to consult a local lawyer before starting your new business.

I hope that you will find this response helpful.