ID: 77-1.28

TYPE: INTERPRETATION-NHTSA

DATE: 02/22/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Blue Bird Body Company

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your January 19, 1977, question whether the requirement of S5.2 of Standard No. 222, School Bus Passenger Seating and Crash Protection, for a restraining barrier of specified size in front of certain designated seating positions necessitates the provision of an additional barrier surface in front of those portions of a bench seat that do not form part of the designated seating positions. You describe a front-row two-passenger bench seat in a bus (with a seat back that extends beyond the bench to provide adequate restraint for a three-passenger seat aft of it) and ask about the restraining barrier that is required in front of the two-passenger front-row seat.

Paragraph S5.2.2 requires that the perimeter of the restraining barrier coincide with or lie outside of the perimeter of the seat back of the seat for which it is required. This means that the restraining barrier must coincide with or lie outside of the perimeter of the seat back of the designated seating position or positions for which it is required. Therefore, a seat with only two designated seating positions must only be equipped with a restraining barrier in front of those two seating positions.

SINCERELY,

BLUE BIRD BODY COMPANY

January 19, 1977

Frank Berndt Chief Counsel National Highway Traffic Safety Administration

The purpose of this leter is to get an interpretation regarding paragraph S5.2.2, Barrier Position and Rear Surface Area, of FMVSS 222, School Bus Passenger Seating and Crash Protection. The subject paragraph reads "The position and rear surface area of the restraining barrier shall be such that, in a front projected view of the bus, each point of the barrier's perimeter coincides with or lies outside of the perimeter of the seat back of the seat for which it is required."

In the development of this standard it has been our understanding that NHTSA was contemplating a possible passenger loss on the right front seat of the school bus. This would necessitate a special seat at the right front position which would have seating provision for two passengers and a seat back wide enough to provide barrier protection for the three passengers in the second front seat on the right side. With this configuration the barrier in front of the right front seat would be a two passenger barrier.

We have designed such a seating and barrier configuration as described above. * We would like confirmation of our interpretation that paragraph S5.2.2 allows this configuration.

* See enclosed photos showing mockup of this seat and barrier arrangement.

Thank you for your early attention and reply to this matter.

W. G. Milby Manager, Engineering Services

(Graphics omitted)

(Graphics omitted)

ID: 77-2.22

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/77

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: The Bendix Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Bendix Corporation's March 29, 1977, request for confirmation that the manual adjustment of automatic adjusters is acceptable following the burnish procedures of Standard No. 121, Air Brake Systems, at the option of the manufacturer.

The procedure that you recommend is not permitted by any provision of Standard No. 121. The NHTSA would consider some provision to deal with the overadjustment of automatic adjusters upon receipt of technical data showing justification for such action. Based on consideration of the data received and a petition for amendment, the agency could commence a rulemaking proceeding in accordance with established procedures.

I have enclosed a copy of a similar interpretation made to Rockwell International.

Sincerely,

ATTACH.

Bendix

Heavy Vehicle Systems Group

John Snow -- Administrator, National Highway Traffic Safety Administration

March 29, 1977

Subject: Request for Interpretation: FMVSS '121'

Ref.: Brake Burnish Procedures S6.1.8.1 and S6.1.8.2

Dear Mr. Snow:

The Bendix Corporation, Heavy Vehicle Systems Group (HVSG) respectfully requests clarification of the portions of S6.1.8.1 and S6.1.8.2, which permit adjustment of the brakes as recommended by the vehicle manufacturer after the burnish procedure. Specifically, clarification is requested that either S-Cam or wedge brakes equipped with automatic adjusters can be adjusted as recommended by the vehicle manufacturer, as well as those equipped with manual brake adjusters.

As permitted by the subject paragraphs, vehicle manufacturers have, in the past, manually adjusted the brakes; especially S-Cam brakes, after the burnish procedure. The affect of this has been to generate a large amount of background data and vehicle compliance testing starting with given brake chamber strokes.

In an effort to promote safety by maintaining a predictable level of good braking, assuring good brake balance and eliminating the possibility of vehicles being operated with S-Cam brakes badly out of adjustment, Bendix has introduced an automatic slack adjuster. Since the adjustment maintained by an automatic slack adjuster is influenced by several factors, including brake and drum temperature, and lining and drum design and conditions, the stroke maintained by an automatic slack adjuster after the burnish procedure will likely be different than that which has been used by the vehicle manufacturers for compliance testing.

It is the opinion of the Bendix Corporation (HVSG) that the use of automatic slack adjusters does not prohibit the vehicle manufacturer from adjusting the brakes, if desired, after the burnish procedure. A vehicle manufacturer advised us that it is reluctant to introduce this device, unless assurance can be given that requalification testing will not be required with the strokes that exist after the burnish test procedure.

We would be pleased to discuss the details of this matter if any additional information is necessary.

Very truly yours,

R. W. Hildebrandt -- Group Director of Engineering

ID: 1984-2.13

TYPE: INTERPRETATION-NHTSA

DATE: 07/01/84 EST.

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Blue Bird Body Company -- Thomas D. Turner, Engineering Services

TITLE: FMVSS INTERPRETATION

TEXT:

Thomas D. Turner Engineering Services Blue Bird Body Company P.O. Box 937 AC-912/825-2O21 Fort Valley, Georgia 31030

This responds to your letter dated March 27, 1984 regarding Federal Motor Vehicle Safety Standard No. 107 Reflecting Surfaces in which you ask for an interpretation of the term "bright metal components." You asked whether these components would include only polished metal or plated components and not painted metal components, even if painted "a shiny high gloss black." In addition, you asked whether a plastic component would be covered by the standard.

The purpose of Standard No. 107 is to reduce the likelihood that unacceptable glare from reflecting surfaces in the driver's field of view will hinder safe and normal operation of the motor vehicle. The standard sets limits on the "specular gloss of the surface of the materials" used for certain "bright metal components." The standard was based on materials commonly used in vehicle at the time of the standard issuance and thus it referred to metal components. Since the requirements apply to the surfaces of those metal components, a metal interior rearview mirror frame with a painted "shiny high glass" surface would be covered by the standard.

An all-plastic component would be outside the literal requirements of the standard. But since a plastic component could produce an unacceptable glare if located in the driver's field of view, the agency urges manufacturers to use plastic materials which will not produce glare.

Sincerely,

Frank Berndt Chief Counsel

March 27, 1984

Mr. Frank Berndt Chief Counsel National Highway Traffic Safety Administration 400 7th Street. S.W. Washington, D.C. 20590

Dear Mr. Berndt:

I am writing you to reference to Motor Vehicle Safety Standard Number 107-Reflecting Surfaces. The standard specifies the specular gloss of the surface of the materials used for specified " . . . bright metal components in the driver's field of view . . polished metal or plated components and not to painted components. Thus, an inside rearview mirror frame and bracket, for example, painted black would not be subject to the requirements of the standard even if it were painted a shiny high gloss black. Likewise, a plastic component would not be subject to the standards requirements unless it was bright metal plated such as being chrome plated.

We request your confirmation of our interpretation and thank you in advance for your prompt reply.

Very truly yours,

Thomas D. Turner Manager, Engineering Services fvc c: David James FMVSS 107 File

ID: nht80-3.3

DATE: 06/11/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Flyer Industries Limited

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 7, 1980, letter asking whether you would be exercising due care if you alter the test procedures in Standard No. 121, Air Brake Systems. You propose to change the brake linings that are currently used on some of your vehicles. You would prefer to conduct decelerometer and stopping distance tests to assure compliance of your vehicles and dispense with the dynamometer test requirements.

The test requirements of Standard No. 121 are a means of establishing that you are in compliance with the performance requirements of the standard. However, like all of the agency's safety standards, it is not legally required that a manufacturer conduct the tests as they are stated in the standard if the manufacturer has an alternate procedure such as computer simulation, mathematical calculation, etc. which it is confident can equally prove the compliance of its vehicles. It is up to the manufacturer to establish in its own mind that any alternate procedure is an exercise of due care adequate to assure it would conform to the standard if the actual tests were conducted.

With respect to the particular test that you propose to conduct, the agency notes that the stopping distance and decelerometer tests are used to test for several aspects of brake performance that are regulated by the standard. The dynamometer tests are used to establish the fade resistance and recovery performance of the brake linings. The agency does not believe that stopping distance tests alone can measure, in particular, the fade resistance of the brake linings. Accordingly, we do not believe that you could certify your vehicle in compliance without some tests or analysis for fade resistance. This does not mean that you must conduct the dynamometer test, however, if you have another technique which you believe adequately measures the fade resistance of the linings.

SINCERELY,

FLYER INDUSTRIES LIMITED

April 7, 1980

The Office of Chief Council National Highway Traffic Safety Administration

Dear Sirs:

We presently manufacture a transit coach certified for FMVSS 121 at a providing ground. Due to customer request, a brake lining deviation from the certified ABB80 to Carlisle B33 is required. Local dynamometer testing is extremely difficult.

Our proposal is to conduct deoelerometer and stopping distance tests to compare lining performance. Full service tests at both loads and on both surface co-efficients would be done, as these were most marginal during the proving ground test. (See charted results.) It is not planned to outfit the new linings with themocouples. If performances are as good or better than for the linings that were certified, we would take this as sufficient evidence of compliance.

Please advise if such testing, fully documented, would be considered due care. Prompt reply to enable test scheduling, will be greatly appreciated.

Todd Smith

CC: B. MOSS

(Graphics omitted)

(Graphics omitted)

ID: nht81-2.24

DATE: 05/12/81

FROM: AUTHOR UNAVAILABLE; Stephen P. Wood for F. Berndt; NHTSA

TO: Severy, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

May 12, 1981 NOA-30

Mr. James J. Schultz Severy, Incorporated 2233 El Segundo Boulevard El Segundo, California 90245

Dear Mr. Schultz:

This responds to your recent letter asking whether a 4-wheel drive pickup truck must comply with Safety Standard No. 216, Roof Crush Resistance. You also ask whether the definitions of vehicle classifications under Federal regulations are mutually exclusive.

The application section of Safety Standard No. 216, section 3, specifies that the standard applies to passenger cars. This means that the standard applies only to passenger cars. Therefore, the standard does not apply to a pickup truck.

The definitions of the basic vehicle classifications found in 49 CFR Part 571.3 are mutually exclusive. If a vehicle falls within the definition of a "truck," the vehicle is not also within the definition of a "passenger car." The definition of a passenger car does not specifically exclude trucks because the definition is based on the function of the vehicle. Thus, a passenger car is defined as a motor vehicle designed for carrying persons. A truck, on the other hand, is defined as a vehicle designed primarily for the transportation of property or special purpose equipment. Since a pickup is designed primarily for carrying property and not persons, it is a truck and not a passenger car. Each motor vehicle has a certification label attached to its door which specifies the vehicle's classification.

I hope this has clarified any questions you had concerning vehicle classification under the Federal Motor Vehicle Safety Standards.

Sincerely,

Frank Berndt Chief Counsel

April 15, 1981

Chief Council NHTSA 400 7th St. S.W. Washington, D.C. 20590 ATTENTlON: MR. OATES

Gentlemen:

We have been retained in numerous instances in litigation which involve the Federal Motor Vehicle Safety Standards and in particular their application. The issues usually involve the definitions of various vehicle types ad to what category a given vehicle belongs. Currently we are working on a case that involves a 4-wheel drive pickup truck with bucket seats. The allegations being made are that this vehicle must conform with FMVSS 216 since the definition of passenger car does not exclude this type of pickup. In order to satisfy that question and others, please send me a letter of interpretation that is specific for this instance and also general to cover other such questions. These questions are:

(1) Does federal law require a 4-wheel drive pickup with either bucket seats or a bench seat to conform to FMVSS 216?

(2) Are the definitions of vehicles in the act mutually exclusive and if so, how does one determine which category applies to any given vehicle.

Please have the letter of interpretation made official and certified.

Very truly yours,

James J. Schultz

JJS:ln

ID: nht74-1.20

DATE: 07/23/74

FROM: AUTHOR UNAVAILABLE; R. B. Dyson; NHTSA

TO: Toyo Rubber Industry Company, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your July 8, 1974, question whether publication of a brochure that lists the rims that may be used with the tires produced by Toyo Tire Corporation would meet the requirements of S5.1 of Standard No. 119, New pneumatic tires for vehicles other than passenger cars.

Publication of such a brochure would meet the requirement of S5.1 so long as the tires are listed in accordance with S5.1(a), that is by manufacturer name or brand name, followed by a listing of rims that may be used with each tire listed. The brochure would have to be supplied to dealers of the manufacturer's tires, to any person upon request, and in duplicate to: Tire Division, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590.

Yours truly,

ATTACH.

National Highway Traffic Safety Administration -- Docket Section

SUBJECT: Federal Motor Vehicle Safety Standard No. 119, S5 Tire and Rim Matching Information

Dear Sir:

FMVSS No. 119 is requiring as follows:

S5 Tire and Rim Matching Information

S5.1 Each manufacturer of tires shall ensure that a listing of the rims that may be used with each tire that he produces is provided to the public in one of the following forms:

(a) Listed by manufacturer name or brand name in a document furnished to dealers of the manufacturer's tires, to any person upon request, and in duplicate to: Tire Division, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590; or

(b) Contained in publications, current at the date of manufacture of the tire or any later date, of at least one of the following organizations:

The Tire and Rim Association.

The European Tyre and Rim Technical Organization.

Japanese Industrial Standards.

Deutsche Industrie Norm.

The Society of Motor Manufacturers & Traders, Ltd.

British Standards Institution.

Scandinavian Tire and Rim Organization.

In case any particular tire and rim matching information is not contained in the publications mentioned in S5.1(b), and since S5.1(a) requires the tire manufacturer to provide a document to the public, we are going to use as a document a brochure which shows the tire and rim combination to be used.

We understand that such a brochure would comply with the requirement of S5.1. Please let us know your opinion as to whether our understanding is correct or not.

Should our understanding be incorrect, please let us know what kind of document we must provide to the public.

Your prompt reply would be greatly appreciated.

Sincerely, Y. Takami -- Technical Representative, TOYO RUBBER INDUSTRY COMPANY, LTD.

ID: nht78-4.22

DATE: 08/11/78

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Cars & Concepts, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

August 11, 1978

Mr. Glenn Abbott Cars & Concepts, Inc. 12500 E. Grand River Brighton, Michigan 48116

Dear Mr. Abbott:

This is in response to your letter dated June 27, 1978, asking whether fog lamps mounted to the surface of a vehicle bumper are removed prior to testing for compliance with Part 581, Bumper Standard.

Vehicles subject to the requirements of Part 581 must comply with the protective criteria of section 581.5(c) (49 CFR 581.5(c)) when tested under the conditions stated in section 581.6 (49 CFR 581.6). The test conditions make no provision for removal of fog lamps prior to testing. As was the case under Federal Motor Vehicle Safety Standard 215, Exterior Protection, the Part 581 test procedures provide for removal only of trailer hitches before testing. With the added exception of license plate brackets, excluded from the requirements of Part 581 by interpretation (42 FR 24056; May 12, 1977), other equipment (including fog lamps) attached to the bumper system prior to sale of the vehicle to its first purchaser must meet the damage limitations of the standard.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel

June 27, 1978

Mr. Joseph Levin Office of the Chief Counsel N.H.T.S.A. Department of Transportation 400 7th Street S.W.

Washington, D.C. 20590

Dear Mr. Levin:

Cars & Concepts, Inc. is preparing a prototype Dodge Omni "Rally" for a 1980 model year production program. It is proposed that Chrysler Corporation ship completed vehicles to one of our facilities where we would attach certain pieces of equipment comprising the "Rally" package. The vehicles would then be shipped back to Chrysler for distribution through their normal channels. Included in the "Rally" package is a pair of Cibie C-95 white fog lamps. These would be made inoperable for highway use by means of an easily removable fuse mounted to the instrument panel. The lamps would be mounted to the top surface of the bumper (to comply with certain state regulations) and closely enough to the vehicle centerline to avoid the normal beam path of the headlights. To avoid contact with the grille when the bumper is fully compressed, it will be necessary to mount the lamps close to the bumper face placing them in potential danger of being damaged in a 5 mph pendulum test. It is our understanding that under the provisions of FMVSS #215 such items were routinely removed before testing. We are concerned that the status of accessory lighting would change under FMVSS part 581 and would like a clarification of this.

Thank you for your assistance in this matter.

Sincerely,

Glenn Abbott Design

GA/dma

cc: D. Chrysler E. Hopp D. Draper M. Pare

ID: nht79-1.41

DATE: 08/09/79

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Porshe

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of May 25, 1979, requesting clarification of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. You asked whether the rear window defogger switch, which emits a dim light for control location and a brighter light upon activation, is considered a control or a telltale.

Although the switch might be regarded as a control, telltale, or both, it is regulated as a control insofar as its illumination is concerned. Therefore, its illumination must be continuously variable as specified in S5.3.3 of the standard.

S5.3.3 provides that

Each passenger car . . . manufactured with any control listed in S5.1 or in column 1 of Table 1, and each passenger car . . . with any display listed in S5.1 or in column 1 of Table 2, shall meet the requirements of this standard for the location, identification, and illumination of such control or display.

The rear window defrosting and defogging system appears in the control list of S5.1 and in Table 1, but not in the display list of S5.1 or in Table 2. Therefore, the control illumination requirements of S5 apply to the defogging switch and the display illumination requirements do not.

If you have any further questions, please do not hesitate to write.

SINCERELY,

UNITED STATES COMPLIANCE OFFICE

NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION Office of the Chief Counsel

May 25, 1979

Subject: PART 571, FMVSS 101-80, Docket 1-18, Notice 13 Control Location, Identification and Illumination

Dear Sirs:

In Table 1 of the above docket, the rear window defrosting and defogging system control shall be illuminated.

S 5.3.3 reads: "Light intensities for controls etc. and their identification shall be continously variable. . ."

In the same paragraph it reads: "The light intensity of each telltale shall not be variable and shall be such that, when activated, that telltale and its identification are visible to the driver under all daytime and nighttime conditions."

In one of our cars, the Porsche 928, the dashboard illumination and a dim light inside the rear window defogger switch are activated when the ignition is turned on. The dim light within the defogger switch is meant to help to locate this control. Upon activation of this switch the light intensity of the defogger switch is increased to show that the rear window defogger switch is in the "on" position. Both light intensities, dim to locate the control, and brighter for activation, are not variable.

Please clarify if w should consider the light in the rear window defogger switch a "telltale" or a "Control" and if we are in compliance with the 2 different light intensities.

We enclose 2 pictures from the owner's manual to show the location and activation of the switch.

Thank you in advance for your clarification.

Gerhard C. Waizmann

Enclosures omitted.

ID: nht92-8.41

DATE: February 28, 1992

FROM: Bill Gaines -- Engineer, Transfer Flow, Incorporated

TO: Wally Herger -- Congressman

TITLE: None

ATTACHMT: Attached to letter dated 4/27/92 from Frederick H. Grubbe to Wally Herger (A39; Std. 301); Also attached to letter dated 3/13/92 from Wally Herger to Nancy Bruce

TEXT:

The reason I am asking to speak with you on Saturday, February 29, 1992, involves my company's inability to meet Federal Motor Vehicle Safety Standard No. 301-75 as the manufacturer. This standard has to do with required testing involving the vehicle's fuel system integrity. It is required testing if the vehicle in question has not been sold to the end user.

While we have no problem with the intent of this standard, we are very concerned with the inflexibility of testing and the high cost of performing these test.

We have been quoted $30,000.00 to perform one FMVSS 301 test. Of course, if it doesn't pass then we are required to redesign the fuel system, crash another vehicle and spend another $30,000.00.

If we were selling hundreds of thousands of the same tank, $30,000.00 would be inconsequential. However, if we only sell 50 of these tanks a year then the cost is ridiculous. If we make 600 different kinds of tanks a year, 30 of one style and 100 of another, like we do, then the cost for testing is unthinkable.

A completely different and less stringent structural test is required for vehicles over 10000 GVW and for vehicles under 10000 GVW that have been sold to the end user. We at Transfer Flow, perform these test as required. While they are not as expensive as the crash test, they do effectively demonstrate the structural integrity of the fuel tank and the components attached to it.

We have been in the fuel systems business for over nine years. In that time frame, we have designed over 600 different fuel systems for pick-ups, vans, motor homes, travel trailers and industrial equipment. We have written emissions certifications for companies such as Fleetwood, Oshkosh Truck, Gillig, Bluebird and many others. The California Air Resources Board refers other tank manufacturers to us, to help them submit emissions applications.

We want to provide our customers with safe fuel systems, but we must be given some flexibility in the testing requirements. As a small volume manufacture, we can't afford to perform the FMVSS 301-75 test. We need an alternative.

Again, we are not opposed to testing our product. There are many ways to demonstrate that a product meets the required specifications. Drop testing, vibration testing and finite analysis are just a few methods that can accomplish this task. The engineering analysis that we are capable of doing today was not even taught in the early seventies.

Since we have been unable on our own to alter this requirement for companies such as ourselves, we are asking for your assistance. Please give us a hand.

ID: nht76-3.6

DATE: 11/10/76

FROM: AUTHOR UNAVAILABLE; Frank A. Berndt; NHTSA

TO: Southern California Recreational Vehicle Products, Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your September 15, 1976, letter concerning the effect of Federal Motor Vehicle Safety Standard No. 301-75, Fuel System Integrity, on manufacturers of replacement and auxiliary fuel tanks.

You are correct in your understanding that this standard applies to completed vehicles, rather than fuel tanks or other fuel system components. Therefore, for example, an auxiliary fuel tank that you manufacture is not itself subject to any performance requirements. However, a person who mounts such an auxiliary fuel tank on a new motor vehicle before the vehicle's first purchase in good faith for purposes other than resale is a vehicle alterer under National Highway Traffic Safety Administration regulations. He is required by 49 CFR 567.7 (copy enclosed) to affix a label to the vehicle certifying that, as altered, the vehicle conforms to all applicable Federal Motor Vehicle Safety Standards -- including Standard No. 301-75.

In addition, the mounting of an auxiliary or replacement fuel tank on a motor vehicle after the vehicle's first purchase in good faith for purposes other than resale is affected by Section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act of 1966, as amended (15 U.S.C. 1397(a)(2)(A)). That section specifies in relevant part 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 or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard. . . . (Emphasis added.)

Therefore, such a mounting of an auxiliary or replacement fuel tank must be performed in such a way that the vehicle's compliance with Standard No. 301-75 is not knowingly compromised.

SINCERELY,

September 15, 1976

Travis Armstrong, Director Office of Standards Enforcement National Hiway Traffic Safety Administration

We have a manufacturing plant in which our principal products are replacement and auxiliary fuel tanks for light trucks, vans and various recreational vehicles.

We have conformed to all our state emission control requirements for which we are fully accredited. We feel our products comply with all existing regulations. However, some of our customers have interpreted Federal Safety Standard FMVSS 301-75 to include our products thereby requiring test certification.

We have been advised by a Safety Engineer at the Automobile Club of Southern California that there were no standards for fuel tanks and that 301-75 does not apply to manufacturers of parts and other accessories for the aftermarket. He further advised us to write to you for confirmation of this fact.

We would, therefore, appreciate a reply clarafying the standard and to whom it applies.

SOUTHERN CALIFORNIA RECREATIONAL VEHICLE PRODUCTS, INC.

Charles G. Atkinson President

CC: BOBBY A. BOAZ -- OFC. OF PUBLIC AFFAIRS