ID: 1982-2.22

DATE: 07/23/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Regal Tire Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

July 23, 1983

Regal Tire Corporation 4309 County Line Road Chalfont, PA 18914

Dear Sir:

At the request of the office of the Honorable Peter Peyser, M.C., we are writing this letter to you to explain the significance of certain items of information molded on the sidewall of new tires.

Part 574, Tire identification and recordkeeping (49 CFR 574), requires that each new tire to be sold in the United States have a serial number molded on one of its sidewalls. That number identifies the tire's manufacturer, date of manufacture, and size. This information is designed to ensure the proper identification of all tires subject to a recall by the manufacturer for correction of a safety-related defect or of a failure to comply with a safety standard. The serial number is not a guarantee of quality or of compliance with any safety standard.

Each new tire is also required by Federal Motor Vehicle Safety Standards Nos. 109, New pneumatic tires, and 119, New pneumatic tires for vehicles other than passenger cars (49 CFR 571.109 and 571.119), to have the symbol "DOT" appear on one of its sidewalls. This symbol is a certification by the tire's manufacturer that the tire fully complies with all requirements of the applicable safety standard. The symbol does not guarantee the quality of a tire in areas of performance unregulated by the safety standards.

Neither the serial number nor the DOT symbol constitute a representation that a tire is free from any safety-related defect.

If you have any questions regarding these matters, please contact me.

Sincerely,

Frank Berndt Chief Counsel June 2, 1982

Ms. Carol Walls U. S. Dept. of Transportation Office of Congressional Relations 400 7th Street, SW Room 10408 Washington, D.C. 20590

Dear Ms. Walls:

Attached is the request for certification about which we spoke today. Regal Tire is interested in receiving a letter or other appropriate document on DOT letterhead confirming the intent of the DOT serial number on the tires themselves.

Thank you for your help in this matter.

Sincerely,

F. H. Brewer, III Administrative Assistant to the Congressman

FHB/lb

CERTIFICATE

TO WHOM IT MAY CONCERN:

WE CONFIRM THAT TIRES MANUFACTURED IN U.S.A. HAVING D.O.T. SERIAL NUMBERS BRANDED ON SIDEWALL MEANS FOLLOWING:

A. EACH TIRE MEETS OR EXCEEDS U. S. DEPARTMENT OF TRANSPORTATION SAFETY STANDARDS.

B. EACH TIRE HAS BEEN TESTED AND GUARANTEED BY MANUFACTURER TO THE U.S. DEPARTMENT OF TRANSPORTATION THAT IT IS FREE FROM ANY DEFECT AND OF FIRST QUALITY.

ID: 1982-2.23

DATE: 07/23/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Ron Gustafson

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your letter of June 28, 1982, asking about requirements applicable to child restraints sold in the United States as well as any necessary permits or licenses. You also asked about any U.S. testing organizations, procedures or standards for child restraints.

All child restraints sold in the U.S. must conform with the minimum performance requirements of Federal Motor Vehicle Safety Standard No. 213, Child Restraint Systems. The standard also sets out the test procedures that are used to measure the performance of child restraints. There are no other performance requirements or test procedures applicable to child restraints. I am enclosing a copy of the standard.

You are not required to obtain a permit or license from this agency prior to selling a child restraint in the U.S., nor are you required to obtain approval from any U.S. testing organization. As a manufacturer of motor vehicle equipment, you are required by Part 566, Manufacturer Identification, of our regulation to submit certain identifying information to the agency. I have enclosed a copy of Part 566.

In addition, you would be required by the National Traffic and Motor Vehicle Safety Act (15 U.S.C. @ 1392 et seg.) to certify that your child restraint complies with all applicable Federal Motor Vehicle Safety Standards. Under the Act, you would also be responsible for conducting a notification and remedy campaign for any safety-related defect in your product. I am enclosing a copy of the Act, which defines your responsibilities as a manufacturer.

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

ENCLS.

June 28, 1987

Furudals Bruks Kursinternat 790 70 FURUDAL Sweden

National Highway Safety Administration

To Whom it May Concern:

I am interested in receiving information concerning rules, regulations, requirements, procedures for testing, etc. concerning child safety seats in automobiles. There is interest in introducing a such a product in the USA. Therefore I would like to know of any minimum requirements (re: design, construction, materials, etc.) as well as any permits or licenses regarding those requirements. Also if there are any US testing organizations, procedures, or standards for this type of product please inform me. Thank you.

Ron Gustafson RON GUSTAFSON

ID: 1982-2.24

DATE: 07/26/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Puerto Rico Marine Management, Inc.

TITLE: FMVSS INTERPRETATION

TEXT:

U.S. DEPARTMENT OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

JULY 26, 1982

Mr. William Croix Technical Maintenance, Manager Puerto Rico Marine Management, Inc. G.P.O. Box 71306 San Juan, Puerto Rico 00936

Dear Mr. Croix:

This is in response to your letter of July 9, 1982, to Mr. Elliott of this agency.

You have asked about Federal requirements for lighting of portable containers secured to flat bed trailers. As those containers are the cargo of the trailers and not an integral part of them, the Federal lighting requirements (Motor Vehicle Safety Standard No. 108) apply only to the trailer. However, the individual States in which the trailers are operated may impose their own lighting requirements.

Sincerely,

Frank Berndt Chief Counsel

PUERTO RICO MARINE MANAGEMENT, INC. SAN JUAN, PUERTO RICO 00936

July 9, 1982

Department of Transportation Mr. Elliogt, Safety Standard Eng.

400-7th. Street South West, Room #5307 Routing NRM-11 Washington, D.C. 20590

Dear Mr. Elliogt:

I refer to our telephone conversation on July 7, 1982, in which my question pertained to lighting on the chassis of a container and chassis comnbination.

In transit our containers are secured to the cahssis for safety purposes. My prime question is are we in conformance with the lighting regulation set forth by your department with proper lighting on the chassis only, when the container is secured to the chassis.

Per your request I put in writing the substance of our conversation. Your response to this subject will be appreciated.

Cordially yours,

Mr. William Croix Technical Maintenance Manager

WC/umc

c: SAN JUAN - A. Colon, Executive J. Dillon, Corp. Maint.

W. Smith, Corp. Maint.

ID: 1982-2.25

DATE: 07/26/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: P. S. Woolley

TITLE: FMVSS INTERPRETATION

TEXT:

JUL 26 1982

Mr. Phillip S. Woolley 10769 63rd Way N. Pinellas Park, FL 33565

Dear Mr. Woolley:

This is in reply to your letter of July 8, 1982, to Mr. Vinson of this office asking what you must do pursuant to Federal regulations as a manufacturer of taillamps for boat trailers.

The Federal motor vehicle safety standard you must consider is Standard No. 108, Lamps, Reflection Devices, and Associated Equipment. (Title 49, Code of Federal Regulations, S571.108) Under its terms, every vehicle taillamp must meet the requirements of SAE Standard J585e Tail lamps (Rear Postion Lamps), September 1977, and the SAE materials referenced in J585e, except that paragraph S4.1.1.12 of Standard No. 108 establishes alternative photometric equipment. The standard does not establish per se a minimum lens area for a taillamp. However, a vehicle manufacturer is required to ensure that when a tail lamp is installed, "the lamp must provide an unobstructed projected illuminated area of outer lens surface, excluding reflex," at least 2 square inches in extent, measured at 45 deg. to the longitudinal axis of the vehicle" (paragraph 4, J585e).

As a manufacturer, you are required to certify compliance of each taillamp with all applicable Federal motor vehicle safety standards, which may be by labelling the lamp with the symbol DOT, or by a statement on the lamp or on its shipping container (paragraph S4.7.2, Standard No. 108). You are also required to file an identification statement with the agency (49 CFR Part 566). In the event any taillamp fails to comply with Standard No. 108, or incorporates a safety-related defect, you must notify purchasers and remedy the problem in the manner specified by 49 CFR Part 577, after filing a report with the agency (Part 573).

You may obtain a copy of all Federal requirements by sending a check for $8 to the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402 and asking for "Title 49 Code of Federal Regulations - Parts 400 to 999, revised as of October 1, 1981."

For further information on the SAE materials, write "Technical Division, SAE, 400 Commonweath Drive, Warrendale, PA 15096 (or call 412-776-4841). In addition to J585e, you will need copies of J575e Tests for Motor Vehicle Lighting Devices and Components, August 1970; J576d Plastic Materials for Use in Optical Parts Such as Lenses and Reflection of Motor Vehicle Lighting Devices, June 1976; and J578c Color Specification for Electric Signal Lighting Devices, June 1977.

Sincerely,

Frank Berndt Chief Counsel

Phillip S. Woolley 10769 63rd Way N. Pinellas Park, Fl. 33565

July 8, 1982

Mr. Taylor Vinson - F.M.V.S.S. - 108 Legal Counsel National Highway Traffic Safety Assoc. Room 5219 400 7th Street S.W. Washington, DC. 20590

Dear Mr. Vinson:

Our company intends to manufacture tail lights for boat trailers and we need to know in laymans terms exactly what we have to do to comply with the rules and regulations set by the Federal Department of Transportations section 108. Are there any rules regarding square inches of lens surface area?

Thank you very much,

Phillip S. Woolley

P.S. Your name was referred to me by the National Highway Transportation Dept.

PSW/kw

ID: 1982-2.26

DATE: 07/26/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: B. S. Horton

TITLE: FMVSS INTERPRETATION

TEXT:

JUL 26 1982

Mr. Bernard S. Horton 100 Memorial Drive Cambridge, MA 02142

Dear Mr. Horton:

This responds to your recent letter regarding the roof crush requirements of Federal Motor Vehicle Safety Standard No. 216. You ask why convertibles are excluded from the requirements of the standard, yet the BMW 318 which has a "targa" roof is not excluded.

Convertibles were excepted from Safety Standard No. 216 when the standard was first issued in 1971 because it was impossible for most convertibles to comply with the requirements. The legislative history of the National Traffic and Motor Vehicle Safety Act of 1966 (15 U.S.C. 1381, et seq.), which authorizes the issuance of our safety standards, clarifies that Congress did not intend for the safety standards that would be issued to effectively preclude any type of existing motor vehicle. If no exception had been provided, the requirements of Safety Standard No. 216 would have caused the production of convertibles to cease. For this reason alone, they were excepted from the requirements.

The agency has limited the convertible exception to vehicles for which it is truly impractical to comply. While our regulations do not include a formal definition of "convertible", the agency has stated that it considers a convertible to be a vehicle whose "A" pillar or windshield peripheral support is not joined with the "B" pillar (or rear roof support rearward of the "B" pillar position) by a fixed, rigid structural member. Therefore, passenger cars equipped with a "sun roof", "hurst hatch roof" or "targa roof" do not qualify as convertibles, because they have a fixed, rigid structural member in the described location. This interpretation applies, moreover, whether the rigid structural member joining the "A" and "B" pillars is a hidden reinforcing component or whether the structural member is part of the exterior roof panel.

I am sorry that you are unable to obtain the BMW 318, but this is primarily due to the fact that the manufacturer has chosen not to bring this model into compliance with Safety Standard No. 216. As you probably know, there are other models with "targa roofs" and "hurst roofs" that are in compliance with the standard and currently in use.

You also mention the fact that many vehicle custom shops cut one or more panels from vehicles to make them into convertibles or "targas". You state that there seems to be no prohibition to this. There are certain prohibitions, however. Section 108(a)(2)(A) of the Vehicle Safety Act specifies that 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 in compliance with a motor vehicle safety standard. This means that custom shops cannot cut panels from a used vehicle's roof if such operation would impair the vehicle's compliance with Safety Standard No. 216. Failure to observe this prohibition could result in civil penalties up to $1,000 for each violation. Please note, however, that the custom shops are not precluded by this section from totally removing a vehicle roof, thereby converting the vehicle into a convertible. The prohibition does not apply to such a conversion since the vehicle would not have had to comply with Standard No. 216 if it had originally been manufactured as a convertible.

I realize that these various distinctions may be confusing. If you have any further questions, please contact Hugh Oates of my staff at 202-426-2992.

Sincerely,

Frank Berndt Chief Counsel

100 Memorial Drive Cambridge, MA 02142 July 13, 1982

Frank Berndt, Esq. Office of the Chief Counsel NATIONAL HIGHWAY TRANSPORTATION SAFETY ADMINISTRATION 400 7th Street S.W. Washington, D.C. 20590

Dear Mr. Berndt:

I am trying to determine why one automobile or another might or might not meet Standard 216 or some other standard for roof crush resistance.

Specifically, I have been interested in buying an Americanized version of a BMW 318 cabriolet. I am told that it can't be imported here because it doesn't meet roll-over or roof crush requirements. Yet, as indicated by the enclosed article, convertibles are becoming popular again. They, at least the soft top ones I've seen, have no roof crush resistance.

By my way of thinking, a cabriolet, which is often called a "targa" because it has a section of roof which can be removed, and perhaps a drop down back window behind a bar, should be safer than a soft top convertible. In fact, customizing shops offer the cutting of one or more panels from the many makes of cars to make them into convertibles or "targas". There seems to be no prohibition to this.

Can you clarify why the BMW Cabriolet, in the light of what is on our roads, seems to be singled out as unacceptable?

Thank you very much for your help.

Sincerely,

Bernard S. Horton

BSH/lp

ID: 1982-2.27

DATE: 08/01/82 EST

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Hon. Bob McEwen - H.O.R.

TITLE: FMVSR INTERPRETATION

TEXT:

This responds to your July 8, 1982, letter to Mr. William Dabaghi of the Department enclosing correspondence from your constituent Mr. Donald M. Robinson. Mr. Robinson would like to know whether Federal regulations prohibit him from purchasing a pickup cab and chassis without the body attached. The answer to his question is no.

The National Highway Traffic Safety Administration only requires that all vehicles be manufactured in compliance with the applicable motor vehicle safety standards. We have no requirement, nor do we know of any other Federal regulation, that would prevent Mr. Robinson from purchasing just the cab and chassis of a vehicle that he desires. When he adds his own utility body to the cab and chassis, he would become the final-stage vehicle manufacturer and would be required to certify that the completed vehicle complies with all applicable Federal safety standards. I am enclosing copies of the regulations pertinent to such an operation.

If I can be of further assistance to you or Mr. Robinson, please contact me.

Sincerely,

Administrator

Enclosures: Constituent's Correspondence 49 CFR Parts 567 & 568

Mr. William K. Dabaghi Director of Congressional Affairs U.S. Department of Transportation 400 7th Street, S.W. Washington, D.C. 20590

Dear Mr. Dabaghi:

The enclosed correspondence regarding regulations governing truck equipment sales was sent to me by Mr. Donald M. Robinson, Manager, Buckeye Rural Electric Cooperative, Inc., P.O. Box 279, Gallipolis, Ohio 45631.

If you could assist me in replying to this inquiry by asking someone on your staff to investigate the matter and provide to me the appropriate information, I would be most grateful.

Again Mr. Dabaghi, thank you for your cooperation in this matter. If I may provide any additional information necessary to you, please do not hesitate to call upon me.

With personal regards,

Sincerely,

Bob McEwen Member of Congress

BM:ly Enclosure

June 23, 1982

Congressman Robert McEwen 124 Joy Avenue Hillsboro, Ohio 45133

We have asked truck dealers in the area for bids on two one-half ton cab and chassis and one three-quarter ton cab and chassis trucks upon which we intended to install utility beds so that the trucks would be equipped properly to be used as service trucks on our distribution system.

We have been told by the dealers that they cannot order just the cab and chassis but have to include the pickup bed for which we have absolutely no use. This is our first knowledge of this and, quite frankly, it shocks me.

We are told that this is a federal law, regulation or whatever.

Could you check into this matter at your convenience to see if there is any recourse?

We will appreciate whatever you can do.

Yours truly,

Donald M. Robinson, Manager

DMR/mb

ID: 1982-2.28

DATE: 08/01/82

FROM: AUTHOR UNAVAILABLE; Diane K. Steed; NHTSA

TO: Larry Pressler; U.S. Senate

TITLE: FMVSS INTERPRETATION

TEXT:

Dear Senator Pressler:

This responds to your July 23, 1982, letter enclosing correspondence from your constituent, Mr. Clyde Pritchard. Mr. Pritchard questioned the applicability of the National Highway Traffic Safety Administration's Standard No. 121, AirBrakes, to certain "heavy hauler trailers." He also questioned a portion of that standard that indicated that manufacturers of some vehicles may comply with the standard or, alternatively, with Part 393.43 of the regulations of the Bureau of Motor Carrier Safety (BMCS).

Only some types of heavy hauler trailers must comply with Standard No. 121. The applicability section of the standard states that a vehicle with a width in excess of 102 inches or a heavy hauler trailer with a gross vehicle weight rating (GVWR) in excess of 120,000 pounds need not comply with any of the requirements. Therefore, any vehicle designed by Mr. Pritchard falling within these categories would be excepted from the standard. A heavy hauler trailer with a width less than 102 inches and a GVWR less than 120,000 must comply with the standard.

Mr. Pritchard appears most interested in the specific requirements for parking brakes on heavy hauler trailers. Paragraph S5.6 of Standard No. 121 states that heavy hauler trailers shall comply with the requirements of Standard No. 121 for parking brakes or, alternatively, with BMCS regulation 393.43 for breakaway. Accordingly, the manufacturer of such a vehicle has the option of complying with either provision; parking brakes under Standard No. 121 or the breakaway and emergency braking section of the BMCS regulation. The citation in Standard No. 121 to BMCS regulation 393.43 is correct. The agency did not intend to permit optional compliance with BMCS regulation 393.41 as suggested by Mr. Pritchard. That regulation does not require separate brakes on trailers which the agency has always deemed necessary.

I hope this clarifies the air brake issue for your constituent. Please contact me if you need additional information.

Diane K. Steed Administrator

ID: 1982-2.29

DATE: 08/02/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Harris Enterprises

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 1, 1982, to Mr. Vinson of this office with regard to your "new motorcycle lighting system" and asking about possible conflicts with the Federal motor vehicle safety standards.

Your device is an "aftermarket accessory" light which may be mounted to a motorcycle helmet, and which is integrated by a cord into the motorcycle's headlighting system, providing an auxiliary beam of light in conjunction with the beam of light projected by the main headlamp.

Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices, and Associated Equipment, is the standard on vehicle lighting and lighting equipment while Standard No. 218, Motorcycle Helmets, is the other standard of relevance. Neither standard directly addresses an aftermarket device such as yours and as your lamp is intended to be installed by the helmet owner, it does not appear to conflict with any other regulatory prohibition of this agency. It would, therefore, be subject to regulation by the individual States in which the device is worn.

We see nothing in your correspondence that legally qualifies as "sensitive proprietary information", and our interpretation will be given its usual circulation.

SINCERELY,

Harris Enterprises

Taylor Vincent Chief Counsel DOT/NHTSA

July 1, 1982

Dear Sir;

Enclosed you will find a description of a new motorcycle lighting system and a copy of the utility patent protecting it.

At the suggestion of Dr. Carl Clark, NHTSA inventor contact, at our meeting of 4/15/82 at DOT, I am contacting you in order to clarify any possible areas of conflict with existing Federal regulations that this system presents.

One possible conflict that was discussed concerned Motor Vehicle Safety Standard Number 218 with regard to motorcycle helmets. Paragraph S5.5 states that "Rigid projections outside any helmet's shell shall be limited to those required for operation of essential accessories, and shall not protrude more than 0.19 inch." As evidenced by the enclosed descriptive material. the system clearly employs a detachable helmet mounted light source whose housing projects substancially beyond the 0.19 inch limit.

This helmet light is an aftermarket accessory which is detachably installed by the operator by means of Velcro- like, 3M Dual Lock self adhesive fasteners. This mounting system is to be engineered so as to allow the helmet light accessory to shear away from the helmet surface upon application of a force substantially less than that which might cause injury. Indeed, the only somewhat permanent projections applied to the helmet itself are the three self adhesive strips of Dual Lock fastener which engage three complimentary strips on the underside of the helmet light. These strips don't project more than 0.19 inch.

As there are not currently any standards directly regarding a helmet mounted light as described, which integrates with the standard lighting system, and may be mediated by a photo electric dimming system to prevent the blinding of oncoming drivers, I would appreciate your opinion as to whether standard headlamp regulations apply.

Dr. Clark has seen the product and is most aware of the properties it exhibits. Any questions you may have may be directed either to Mr. Clark or this office. Your opinions on the above points are of significant commercial interest to us, and your earliest consideration would be appreciated. Please treat everything exclusive of the patent itself as sensitive proprietary information.

William R. Harris, Jr.

ID: 1982-2.3

DATE: 04/12/82

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Nebraska Department of Education

TITLE: FMVSS INTERPRETATION

TEXT:

APR 12 1982

NOA-30

Mr. Vernon J. Clark Transportation Supervisor Nebraska Department of Education 301 Centennial Mall South Box 94987 Lincoln, Nebraska 68509

Dear Mr. Clark:

This responds to your March 23, 1982, letter asking whether it is permissible to install side-facing seats in school buses designed to transport the handicapped. The answer to your question is yes.

Standard No. 222, School Bus Passenger Seating and Crash Protection, specifies the requirements for school bus passenger seats and, in general, requires those seats to be forward facing. However, the definition of "school bus passenger seat" in section S4 of the standard excludes seats installed to accommodate handicapped or convalescent passengers as evidenced by installing those seats longitudinally. Therefore, seats installed in the buses to which you refer in your letter need not comply with the school bus seat requirements if they are designed to accommodate the handicapped and are side facing.

We caution, however, that side-facing seats afford less protection than forward facing seats. Accordingly, only those seats necessary to accommodate the handicapped should be altered in this manner.

Sincerely,

Frank Berndt Chief Counsel

March 23, 1982

Mr. Roger Tilton Office of Chief Council National Highway Safety NTS 400 7th St. Washington, D. C. 20590

Dear Mr. Tilton:

We are interested in obtaining an opinion from your office regarding the placement of seats in a school bus used for transporting handicapped students. Is it legal or permissible to place a seat or seats in a longitudinal position to provide space for moving wheel chairs through the isles? We have several schools in our state that have a problem with this and are requesting permission to make these alterations.

I would appreciate any information you could give me on this matter as soon as possible.

Sincerely,

VERNON J. CLARK Transportation Supervisor

ak

ID: 1982-2.30

DATE: 08/02/82

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Roberts Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of July 16, 1982, asking for an interpretation of Motor Vehicle Safety Standard No. 108.

You enclose photos of a 1982 Kenworth truck which has two pairs of front turn signal lamps: one set (incorporating a side reflector) mounted 58 1/2 inches above the road surface and which are 83 inches apart; the other, mounted approximately 81 1/2 inches above the road surface and which are 110 inches apart. You have asked whether the vehicle would comply if the lower mounted set were removed and an amber reflex reflector placed on each side of the fender as far forward as practicable.

The answer is yes. The mounting height of 81 1/2 inches does not exceed the limit of 83 inches imposed by Table II of Standard No. 108. In addition, the lamps appear to meet the two further requirements that they be located as far apart as practicable and at the same height.

Sincerely,

ATTACH.

July 16, 1982

Administrator -- National Highway Traffic Safety Administration, Department of Transportation

Subject: Federal Motor Vehicle Safety Standard Number 108 Lamps, Reflective Devices and Associated Equipment

Gentlemen:

Enclosed please find two photographs of a 1982 Kenworth, Model W900. You will note from the photographs that two sets of turn signals are on the vehicle, one set on the hood and another set on the bottom of the mirror brackets.

On the vehicle shown, which is typical of the Model, the center of the fender mounted signals are approximately 58 1/2" above the road surface and approximately 83" apart.

The center of the mirror mounted turn signals are approximately 81 1/2" above the road surface and approximately 110" apart.

Our question concerns Federal Motor Vehicle Safety Standard Number 108(571.108), specifically, Table II, "Location of Required Equipment", "Turn Signal Lamps". Considering the dimensions above, would the vehicle be in conformance with the Standard if only the mirror mounted turn signals were installed on the vehicle and an amber reflex reflector placed on each side of the fender as far forward as practicable?

We would appreciate your consideration and reply to this matter at your earliest opportunity.

Yours truly, Ronald E. DeVolder -- Vice President

enclosures

(Graphics omitted)