ID: 77-4.47

TYPE: INTERPRETATION-NHTSA

DATE: 12/05/77

FROM: AUTHOR UNAVAILABLE; Joan Claybrook; NHTSA

TO: International Harvester

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your October 3, 1977, letter questioning the position of the National Highway Traffic Safety Administration (NHTSA) concerning the public dissemination of defect and noncompliance information by press release prior to a manufacturer's notification as required by Part 577, Defect and Noncompliance Notification. In your letter, you refer to a press release issued by the agency concerning defects in some of your vehicles. This release was made prior to your providing notification to the vehicle owners.

The NHTSA through Part 577 requires that manufacturers provide notification to the owners of vehicles involved in defect or noncompliance recalls. This notification must be provided, in the case of a manufacturer-initiated recall, within a "reasonable time" after a manufacturer discovers the existence of a defect or noncompliance. You conclude that the publication of an agency press release prior to the time that a manufacturer notifies owners of a defect or noncompliance in effect shortens the "reasonable time" allowed for such notification. This in turn, you suggest, results in unnecessary public concern before the manufacturer is capable of implementing the recall.

The publication of an agency press release does not shorten the time period allotted a manufacturer under Part 577 for providing notification. A manufacturer is still permitted a "reasonable time" to comply with the requirements. The NHTSA has adopted the "reasonable time" approach to manufacturer notification of owners, because it realizes that the amount of preparation to conduct a recall may vary depending upon the complexity of the defect or noncompliance.

The agency operates under different timing considerations than those applicable to a manufacturer. The NHTSA is under a mandate to ensure that vehicles containing potentially dangerous defects or noncompliances are corrected or removed from highway service as soon as possible. The agency understands that any recall and remedy process is somewhat time-consuming for a manufacturer, and accordingly, vehicles will not be repaired immediately. Therefore, in the interim time between a manufacturer's discovery of a defect or noncompliance and his notice and remedy, the agency must issue warnings to vehicle owners so that they can take the appropriate action. Such action might include checking their vehicle for possible signs of failure or discontinuance of use of the affected vehicle.

In summation, the agency must balance the manufacturer's need for a reasonable time to notify and remedy with the vehicle owner's need for immediate information pertaining to any potential safety problems. This balance has taken the form of the NHTSA's issuance of a warning pending a manufacturer's issuance of notification. The NHTSA concludes that through this mechanism safety is preserved and manufacturers are not unduly burdened.

SINCERELY,

INTERNATIONAL HARVESTER

October 3, 1977

Joan Claybrook, Administrator U.S. Department of Transportation National Highway Traffic Safety Administration

RE: Press Releases/Safety Recalls

As I am sure you have been informed, we met with Mr. Dugoff and other representatives of your staff on September 21 for the main purpose of discussing the recent press release issued by your office concerning IH safety recall #77 V-127 and specifically, whether releases of that nature represent a new policy of your Department. As a related issue, we also discussed the procedure used by your Department regarding defect investigations. As we advised Mr. Dugoff, we are writing this letter to confirm our understanding of certain aspects and to provide you with a short written memorandum expressing our position with respect to such press releases.

With respect to the corolary issue of defect investigation and determination, we were advised by Mr. Berndt that NHTSA did have a policy of following the procedure detailed in your proposed rulemaking on the subject and that the manufacturer would be advised if NHTSA intended to issue such a determination of defect. In other words, a manufacturer need not expect a public announcement of the defect determination to be made prior to advice to the manufacturer that such determination was being made.

With respect to the main subject of our meeting, the press release on recall #77 V-127, our Company is extremely concerned with the practical results of that release, both in its content and in its timing. The following is a sample of the problems which result therefrom:

1. No Company personnel or IH dealers were knowledgeable of the recall or its repair techniques;

2. Needless public anxiety was created -- hundreds of calls were made since the DOT did not identify the models involved;

3. U.S. Army-Germany pulled all IH vehicles off the road;

4. Two large U.S. based fleets notified IH that they would either park or deadline all IH vehicles, possibly exposing IH to damage claims for downtime due to the commercial nature of the vehicles;

5. Three other large fleets indicated that they were considering putting IH vehicles out-of-service, with the same result as 4 above;

6. IH press release issued after DOT's identifying the specific trucks involved and adding repair information is totally ignored by the U.S. Press.

All internal IH Company actions such as customer notification letters, engineering approved repair techniques, repair instructions, repair parts ordering and packaging, vehicle quantities involved and identification, and registered owner identification, as illustrated in the attached chart, necessarily start after the defect determination. It follows, therefore, that in most cases, IH could not inform its dealers and field sales and service personnel in time to handle inquiries and/or repairs if DOT persists in the practice of utilizing the initial 5 day defect report as the source information for NHTSA press releases which are made prior to our "preparing" our recall.

With respect to our position that the press release was premature, your office repeatedly queried as to whether or not it was the position of IH that safety defects should remain concealed from the public. Obviously, that is not our position, but it is our position that we should comply with the current regulations governing the subject. Specifically, Part 577, Defect the Noncompliance Notification, has recently been amended to add certain parameters to this Part which were not present in the existing Rule. Specifically, one of the purposes of the amendment was to specify "the content, timing, and form of the notification that complies with the requirements set forth in Section 153 of the Act." (Emphasis added) Section 577.7(a)(1) was specifically included and provided that the customer notification must "Be furnished within a reasonable time after the manufacturer first determines the existence of a defect which relates to motor vehicle safety. . ." (Emphasis added) It is our understanding that this timing was included since a manufacturer necessarily needs some amount of time in order to prepare for a recall. Prior to creating customer reaction when the problem is yet insolvable, we strongly believe that the referenced sub-section was intended squarely for the purpose of allowing a manufacturer the time to prepare to remedy defects prior to customer notification. It would appear to us that the "reasonable time" which the law now allows us is being shortened by means of the early press release policy.

The press release was issued based on information contained in our statutorily required 5 day defect notice. It is our understanding that the purpose of the 5 day notice, as detailed in Part 573.2, is to enable your office to analyze the adequacy of our defect notification and corrective action, owner response thereto and to compare defect incidents rates among different groups of motor vehicles. Therefore, our compliance with this Part, and for the purposes above stated, in fact result in a different purpose being accomplished, namely, public notice of the defect earlier than the time of such notice required by Part 577. It certainly appears to us to be an anomaly that information provided for one purpose in fact ended up being used for another, seemingly in derogation of our rights under Part 577.

In summary, the view we wish to express is not that we oppose all press releases, but rather that we think a properly timed press release could be far more effective if it was coordinated with the time of the manufacturer's customer recall letters, assuming, of course, that such letters are sent within the reasonable time allowed. We are in no way suggesting that a press release should be held off in all cases, even those where a manufacturer is unreasonably delaying customer notification. We do believe that coordinated timing would enhance the initiation of a campaign. We respectfully request that you give this matter your attention and consideration.

J. KEVIN SMITH -- DIRECTOR, PRODUCT RELIABILITY AND QUALITY, NORTH AMER. OPERATIONS; TRUCK GROUP (Graphics omitted)

ID: nht88-3.80

TYPE: INTERPRETATION-NHTSA

DATE: 11/01/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: CLARENCE M. DITLOW -- EXEC. DIRECTOR, CENTER FOR AUTO SAFETY

TITLE: NONE

ATTACHMT: LETTER DATED 9-9-88 TO ERIKA JONES, NHTSA, FROM CLARENCE M. DITLOW, EXEC. DIR., CENTER FOR AUTO SAFETY, OCC-2525; LETTER DATED 8-02-88 TO CENTER FOR AUTO SAFETY FROM JOANNE P. DELL'AQUILA

TEXT: This responds to your letter asking us to "investigate" a service bulletin issued by General Motors to its dealers regarding rear seat lap/shoulder belt kits to be retrofitted in models from earlier model years. You objected to General Motors' decision not to provide retrofit kits for all models, because all earlier models have shoulder belt anchorages and because you question the statement in General Motors' service bulletin that rear seat lap/shoulder belts in certain models would not offer better pr otection for rear seat occupants than lap belts alone. You concluded by alleging that General Motors' "refusal to provide shoulder belt kits for selected models is effectively frustrating" the purpose of requiring anchorages for rear seat shoulder belts to be installed in cars made since 1972 and our policy of encouraging manufacturers to provide retrofit kits for rear seat lap/shoulder belts in older vehicles.

I disagree with your allegations. Let me begin by emphasizing that we continue to support the use of rear seat lap belts, the restraint system found in most cars on the road today. While rear seat lap/shoulder belts may be even more effective, numerous studies have confirmed that rear seat lap belts are effective in reducing the risk of death or serious injuries to occupants. Therefore, NHTSA continues to urge all motorists to use the available safety belt systems in their vehicles.

However, we are encouraging vehicle manufacturers to make rear seat lap/shoulder belt retrofit kits available for those consumers who desire them, such as Ms. Dell'Aquila. General Motors has indicated to us that such a retrofit kit is available for Ms. Dell'Aquila's 1988 Buick Regal. However, General Motors' bulletin to its dealers appears to indicate that retrofit kits are not available for those cars. To clear up any confusion, we have forwarded a copy of Ms. Dell'Aquila's letter to General Motors for their response.

2

The allegations in your letter, however, go far beyond Ms. Dell'Aquila's situation to suggest erroneously that her experience shows some failure of our efforts to ensure that rear seat lap/shoulder belt retrofit kits are widely available. As you were to ld in Administrator Steed's April 28, 1987 letter to you on this subject, NHTSA does not have the statutory authority to require all manufacturers to make rear seat lap/shoulder belt retrofit kits available for all older models. Absent such authority, t he agency has sought the voluntary cooperation of the manufacturers to make retrofit kits available for those customers who desire them. The vehicle manufacturers' voluntary positive response to our encouragement is demonstrated by the current availabil ity of retrofit kits for a wide variety of model lines. In fact, the General Motors Information Bulletin enclosed with your letter shows that company has retrofit kits now available for more than 50 models of its cars, trucks, and vans.

The fact that retrofit kits are not available for all model lines produced by each manufacturer does not suggest some failure on the part of the vehicle manufacturers or of our policy. If a manufacturer makes a good faith determination that it is not ap propriate to make retrofit kits available for certain of its past models, that determination presumably reflects a thoughtful consideration of the characteristics of those individual models. We have no reason to question General Motors' determination wi th respect to a few of its past models.

ID: nht92-6.17

DATE: June 4, 1992

FROM: Bart Gordon -- U.S. House of Representatives

TO: Adele Derby -- Associate Administrator for Regional Operations, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 6/29/92 from Frederick H. Grubbe to Bart Gordon (A39; Part 571.3)

TEXT:

Pursuant to your conversation with Claudia Deane of my Washington staff, I am writing to request a clarification of NHTSA's regulations regarding the use of 11-15 passenger vans for school purposes.

In my home state of Tennessee, there is currently some confusion as to whether schools which are in possession of these vans can use them to transport students. The vans are not being used as primary transportation, but instead are used for extracurricular activities such as transporting the debate team or the cheerleading squad.

It is my understanding that there are regulation against selling these vans for school use. My question is whether schools which currently own vans can use them.

In speaking with state officials, the point of confusion seems to specifically lie in the application of NHTSA's definition of a school bus to these vans, and following on this, whether the vans are required to be in compliance with school bus class safety standards. The state's interpretation of NHTSA's regulations has led them to advise schools to stop using the vans in the 11-15 passenger category.

I appreciate your attention to this question and look forward to receiving a response in the near future. If I can answer any questions or provide you with further information, please feel free to contact my office.

ID: 9043

Mr. Tom DeLapp
Executive Coach Builders, Inc.
One Executive Blvd.
Springfield, MO 65802

Dear Mr. DeLapp:

This responds to your letter of August 18, 1993, concerning a modification you wish to make on limousines manufactured by your company. You wish to modify the hinge assembly controlling forward and reclining movement of the front seat to provide access to the area between the front of the privacy panel and the back of the front seat. (The area contains auxiliary fuse panels and relays.) The modification would involve removal of a metal pin in the hinge assembly, allowing the seat to articulate forward to a greater degree. You asked whether Standard No. 207, Seating Systems, prohibits the removal of a limiting pin or limits forward movement of a seat back.

Standard No. 207 specifies strength and other performance requirements for seats in passenger cars, multipurpose passenger vehicles, trucks, and buses. Section S4.3 of Standard No. 207 contains requirements for hinged or folding seat backs, except for passenger seats in buses or a seat adjustable only for its occupants. Section S4.3(a) requires a self-locking device for restraining the hinged or folding seat back. Section S4.3.2 contains performance requirements for this restraining device.

Section S4.3 does not limit the degree of movement of a hinged or folding seat back. Thus, you may remove the limiting pin if removing it only increases the degree of movement of the seat. However, the seat must still meet the requirements of S4.3 with the pin removed. Accordingly, the seat must have a self-locking device that can withstand the force applications specified in S4.3.2.1 and acceleration specified in S4.3.2.2.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel ref:207 d:10/25/93

ID: nht71-2.29

DATE: 04/20/71

FROM: AUTHOR UNAVAILABLE; L. R. Schneider; NHTSA

TO: Morgan Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 17, 1971, in which you requested further clarification of the test procedures of the standard on side door strength, Standard No. 214. Your diagram of the Morgan Plus 8 shows a horizontal line drawn across the door 5 inches above the lowest point of the door. This would appear to be an accurate depiction of the location of the lower edge of the loading device as specified in the standard. You express concern that the line is a considerable distance from the ground, but under the requirements of the standard, the height above the lower edge of the door is the relevant height, and not the height above ground.

I hope this will help to resolve your questions with respect to Standard No. 214.

ID: nht93-7.5

DATE: October 1, 1993 Est.

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Tom DeLapp -- Executive Coach Builders, Inc.

TITLE: None

ATTACHMT: Attached to letter dated 8/18/93 from Tom DeLapp to Chief Council, NHTSA (OCC-9085)

TEXT:

This responds to your letter of August 18, 1993, concerning a modification you wish to make on limousines manufactured by your company. You wish to modify the hinge assembly controlling forward and reclining movement of the front seat to provide access to the area between the front of the privacy panel and the back of the front seat. (The area contains auxiliary fuse panels and relays.) The modification would involve removal of a metal pin in the hinge assembly, allowing the seat to articulate forward to a greater degree. You asked whether Standard No. 207, Seating Systems, prohibits the removal of a limiting pin or limits forward movement of a seat back.

Standard No. 207 specifies strength and other performance requirements for seats in passenger cars, multipurpose passenger vehicles, trucks, and buses. Section S4.3 of Standard No. 207 contains requirements for hinged or folding seat backs, except for passenger seats in buses or a seat adjustable only for its occupants. Section S4.3(a) requires a self-locking device for restraining the hinged or folding seat back. Section S4.3.2 contains performance requirements for this restraining device.

Section S4.3 does not limit the degree of movement of a hinged or folding seat back. Thus, you may remove the limiting pin if removing it only increases the degree of movement of the seat. However, the seat must still meet the requirements of S4.3 with the pin removed. Accordingly, the seat must have a self-locking device that can withstand the force applications specified in S4.3.2.1 and acceleration specified in S4.3.2.2.

I hope you find this information helpful. If you have any other questions, please contact Mary Versailles of my staff at this address or by phone at (202) 366-2992.

ID: 15103.wkm

Mr. R. C. Brown
9030 Congressional Parkway
Potomac, MD 20854

Dear Mr. Brown:

This responds to your April 28, 1997 telephone conversation with Walter Myers of my staff and to your follow-up letters, in which you ask whether you may have a vehicle modifier move the seat in your 1996 Cadillac two inches farther to the rear to make it physically possible for you to operate the vehicle.

Modifiers are permitted to modify vehicles without obtaining this agency's permission, but are subject to certain regulatory limits on the type of modifications they may make. In certain limited situations, we have exercised our discretion in enforcing our requirements to provide some allowances to a repair business which cannot conform to our requirements when making modifications to accommodate the special needs of persons with disabilities. Because your situation is among those given special consideration by NHTSA, this letter should provide you with the relief you seek.

The National Highway Traffic Safety Administration (NHTSA) is authorized by law to issue Federal motor vehicle safety standards (FMVSS) that establish performance requirements for new motor vehicles and new items of motor vehicle equipment. Federal law further provides that manufacturers must certify that their products conform to all applicable FMVSSs before those products can be offered for sale. In addition, Federal law prohibits manufacturers, distributors, dealers, and commercial repair businesses from knowingly "making inoperative" any device or element of design installed on or in a vehicle in compliance with an applicable FMVSS. In general, the "make inoperative" provision requires repair businesses to ensure that they do not remove, disconnect, or degrade the performance of safety equipment installed in a vehicle in compliance with an applicable FMVSS. Violations of this prohibition are punishable by civil fines up to $1,100 per violation.

In this case, moving a seat, whether or not the seat belts are also moved, could affect compliance with four standards: No. 207, Seating Systems; No. 208, Occupant Crash Protection; No. 209, Seat Belt Assemblies; and No. 210, Seat Belt Assembly Anchorages. In situations such as yours, however, where the modification must be made to accommodate a disability, we have been willing to consider violation of the "make inoperative" provision a purely technical one justified by public need. Accordingly, this agency will not institute enforcement proceedings against a repair business that modifies the seat on your vehicle to accommodate your condition.

We caution, however, that only necessary modifications should be made to the seat, and the person making the modifications should consider the possible safety consequences of those modifications. For example, in moving a seat, it is essential that the modifier ensure that the seat is solidly anchored in its new location. You should also be aware that the occupant of a seat that has been moved rearward may have less protection in a crash if the seat is too far rearward relative to the anchorages of the safety belts for that seat. Finally, if you sell your vehicle, we strongly encourage you to advise the purchaser of the modifications you have made to the vehicle.

I hope this information is helpful to you. If you have any questions or need further information, please feel free to contact this office at this address or by fax at (202) 366-3820.

Sincerely,
John Womack
Acting Chief Counsel
ref:207
d:6/24/97

ID: nht68-2.2

DATE: 06/24/68

FROM: AUTHOR UNAVAILABLE; David A. Fay; NHTSA

TO: Toyota Motor Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of May 31, 1968, to Mr. George C. Hield, concerning your combination stop, tail, and turn signal lamp.

You are correct in your interpretation with respect to the combination lamp (A,B,C) fulfilling the requirement of paragraph S3.3 (a) of Motor Vehicle Safety Standard No. 108. However, the additional tail lamp (C) must also conform to the requirement of paragraph S3.1.2 which specifies that no additional lamp, reflective device, or associated equipment shall be installed if it impairs the effectiveness of the required equipment. If the intensity of tail lamp (C) is extremely high, the lamp could impair the effectiveness of lamp combination (A,B) when the combination is used as a stop or turn signal lamp. As you noted, the intensity of the tail lamps may be reduced by inserting resistance in the tail lamp circuit as provided by SAE Standard J585c.

With respect to the requirements of Standard No. 108, I must point out that this Bureau does not issue approvals on items of lighting equipment or on vehicle designs incorporating this equipment. Therefore, the above comments are for your information only and in no way relieve the vehicle manufacturer from his responsibility for certifying that the assembled vehicle meets the requirements of the standard.

ID: nht75-4.25

DATE: 08/12/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Daniel W. Lang

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of July 15, 1975, in which you inquire as to the applicability of the National Traffic and Motor Vehicle Safety Act and the regulations promulgated thereunder to your client, Star Vision, as a manufacturer and installer of see-through fiberglass replacement tops.

Section 108(a)(2)(A) prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from knowingly rendering inoperative 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. This means that the installation of the top by Star Vision must not take a vehicle out of compliance with Safety Standard No. 216 or any other applicable safety standard. You should note that the requirements of section 108(a)(2)(A) apply to modifications of vehicles following their sale to a purchaser for purposes other than resale. It appears from the literature accompanying your letter that the tops are not installed on vehicles prior to their first sale. If they are, then Star Vision is subject to the notification, remedy, certification, and recordkeeping requirements of section 108(a)(1).

There is no specific requirement for testing the replacement tops in order to determine compliance with Standard No. 216. However, since the Act prohibits knowingly rendering inoperative any vehicle or part of a vehicle in compliance with an applicable safety standard, Star Vision is under an obligation to test its product if it has reason to believe that installation of the tops will substantially degrade the performance of the vehicle roofs. If the company has no reason to believe that installation will affect the safety characteristics of the vehicle, it is not obligated to conduct compliance tests.

The replacement tops appear to be subject to Safety Standard No. 205, Glazing Materials (49 CFR 571.205). As a result, Star Vision must certify the tops in accordance with section 114 of the Act (15 U.S.C. @ 1403).

If the tops do not comply with Standards Nos. 205 or 216 or any other applicable safety standard, or if they contain a malfunction or defect related to motor vehicle safety, the company will be obligated by sections 151-60 of the Act to notify the purchasers of the kits and to remedy the defect or noncompliance without charge. In addition, section 108(c) of the Act provides that compliance with the Act will not exempt a person from common law liability.

We trust that this information will be of assistance.

SINCERELY,

July 15, 1975

James Gregory National Highway Traffic Safety Administration Attention: Office of Chief Counsel

Re: "Star Vision See Thru Tops"

This office represents Star Vision, a division of Etanter Enterprises, of Los Angeles, California.

Star Vision, as the enclosed literature indicates, sells a see-through fiberglass replacement top for most makes of automobiles, both domestic and foreign. Installation requires the cutting of a hole in the roof of a vehicle. The top may be purchased in a kit for home installation or installed by a Star Vision distributor who purchases tops from the company. Star Vision occasionally in the past has installed a top itself.

I would appreciate your consideration in answering the following questions:

1. Does @108 of the 1966 Act or @103 of the 1974 Act control the activities of the company;

2. Does the company have to test its product to determine whether or not it complies with Safety Standard #216;

3. If yes, how, where, and when can a product be tested in a manner acceptable under the law;

4. What responsibilities does the company have as a manufacturer only; as a manufacturer-installer;

5. What responsibility does the company have under the law to a do-it-yourself purchaser of a home installation kit?

The company is most anxious to be adequately informed about any standards or requirements that might affect their business. A prompt reply will help us greatly.

Daniel W. Lang Additional notes and hints to aid the installation of the STAR VISION rooftop kit.

Some cars come equipped with a beam across the roof under the headliner. Make sure that when you lay out the panel that you leave enough clearance about 1 1/2". If the panel supplied for your car should clear all beams or bars. If for any reason it does not, do not proceed with the installation, measure the space that is available, ship us back the panel that you have with the size that you need and we will ship you the proper size.

BEFORE cutting or laying out the area to be cut, carefully feel around the headliner for any obstructions. Be careful that your car does not have a double roof, such as some late model GM cars. (Illegible word) Be sure to leave room near the windshield, some cars such as some Toyotas will have about 3" of extra support so stay back from that as you will not make a clean installation.

Stay back from the sun visors but as far as possible to the front of the car. The Star Vision roof kit is most beneficial as far forward as possible than over or behind the drivers head.

We have installed our STAR VISION rooftop kit in almost every kind of car. If you have any problems with your particular car do not hesitate to contact us, we will research the problem free of charge and forward you the help that you seek.

BE SURE TO READ ALL THE INSTRUCTIONS CAREFULLY. PROCEED WITH CARE, PATIENCE AND PRIDE.

STAR VISION

TRANSPARENT ROOF TOP KITS

Your STAR VISION Transparent rooftop kit will add years of enjoyment to your driving pleasure. The installations is simple, the following instructions will help you achieve professional results.

Lay the piece of transparent panel flat on the roof of your car. DO NOT remove the protective paper until last. Place the material as for forward as possible with out interfering' with the windshield mouldings and framework. (usually about 4 to 6 inches.) Measure the distance on both sides to ensure an even fit. Now measure the distance from the edges left and right to ensure that the panel is centralized. Use some masking tape to prevent the panel from moving once the exact position has been arrived at.

Use a crayon pencil to trace out the outline of the panel. The line should be 3/8 inch away from the panel to leave room for the moulding. Drill four (4) 5/16" holes thru the roof of your car at each corner of the panel. Drill thru the headliner. Now get in the car and note the four holes. Using a single edge razor blade cut out the headliner using the holes as reference points. (NOTE some cars such as Porsche 914 and Fiat X 1/9 do not have a headliner)

NOTE: If your car has thin metal bars suspended across to hold up the headliner, cut them in the middle and remove them completely. On older cars the headliner may be brittle and subject to tearing, use extreme caution in those cases. Before going to them next step check out the total travel of your jigsaw blade, make sure that when you start to cut out the panel, that the blade will not tear into the remaining headliner. You can shorten the blade by merely breaking of the tip about one inch. Use a soft cloth on the side of the jigsaw foot that is going over the part of the roof that will remain so that it will not scratch the surface.

Using a Jig saw with a 32 tooth per inch blade cut out the outlined panel. When completed use masking tape to adhere headliner to the roof so when the molding is applied the headliner will neatly tuck away. Adhere only about 1/4 inch to the headliner and adhere the rest to the roof see illustration.

When installing the molding always use the wooden tools supplied to "Lip" over the rubber. Should your hand slip, these tools will not scratch the plexiglass or paint. Also use the blunt end of the tool to pry apart the locking slot to insert the "lock" use a weak soap solution to aid installation.

Now you are ready to install the panel. First install the rubber molding as in illustration #2. Note that the molding has two different sides to accommodate different roof thicknesses. Any side can be used for the panel. Install the molding with the "lock" side up. After the panel is in place install the "lock" to ensure leak proofing. Note that your supplied with a few extra inches of molding. Trim excess to fit, but leave extra inch. Compress this extra inch, this will expand and make a leakproof seal. If for any reason your top leaks, use the tool supplied to lift up the molding and apply any commercial windshield sealer under the molding. Wipe away any excess. Use non abrasive cleaners only!

(Graphics omitted)

Eatanter Products presents another quality product, completely new in style, and guaranteed to enhance the appearance of your car.

Our transparent 'STAR VISION' roof top kit adds a whole new feeling of freedom and comfort to your driving pleasure, experience all the skies and sights under any weather condition.

To complement the appearance of your automobile, we are offering several tints to suit your personal car.

NEW!

STAR VISION

TRANSPARENT ROOF TOP KITS

VOLVO

Ford

FIAT

CHEVROLET

Mazda

VW

LOW COST FUN!

EAST DO IT YOURSELF

your car or ?.....?

12" x 24" $ 43.95 15" x 30" size $ 64.95 15" x 40" size $ 74.95

SHIPPING NOT INCLUDED.

We accept BANKAMERICARD.

Easy Do-it yourself!!!

Complete illustrated instructions in every kit. Also HELPFUL hints & TOOLS.

Enjoy all the skies and sights under all weather conditions with our new 'STAR VISION' rooftop kit. Our 'STAR VISION' rooftop kit is a low cost practical method to add prestige and value to your automobile. Our 'STAR VISION' is a full time accessory unlike the $ 450 to $ 800 'moonroofs' and sunroofs that can only be used under ideal weather conditions. Our roofkit is in use ALL THE TIME.

On the coldest nights or downpour rainfalls, when other sunroofs and tops are unusable, our rooftop kit is in use. Our kit is a permanent installation. There are no parts to wear out, no pulleys to crank, only pure enjoyment of great views and a whole new world of new sights, previously unattainable. Our STAR VISION rooftop kit is available in SMOKE, BLUE, GREEN, AMBER and clear. The kits are designed for easy installation and come complete with a set of thorough instructions. The only tools that are not supplied are a sabre saw, and a hand-drill. Average installation time is two hours.

ID: nht91-7.5

DATE: November 11, 1991

FROM: Richard Gray -- Secretary, Sports Car Club of New Zealand, Inc.

TO: Paul Jackson Rice -- Office of Chief Council, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 1/23/92 from Paul Jackson Rice (by Stephen P. Wood) to Richard Gray (A39; VSA S108(a)(1)(A))

TEXT:

I am writing to in the hope that your Department may be able to assist our Organization in overcoming a couple of vehicle standards problems. The New Zealand Ministry of Transport is introducing new Vehicle Safety Standards similar to those in operation in the USA, United Kingdom, Europe and Australia. Their main thrust is to align the NZ Vehicle Standards with those of USA, Europe and UK. In doing so the cars built by the major manufacturers will require the local importers to ensure that the vehicles they import or assemble locally meet the Vehicle Standards of any of the above named countries.

However, certification of Low volume vehicles (those built in numbers less than 20O per year) is being entrusted to four organizations of which the Sports Car Club of New Zealand is playing a key role in helping to set up the certification system for all low volume vehicles including modified cars.

With the introduction of the Standards we are faced with two major problem areas; glazing and seat-belts. New Zealand has a number of privately imported American built sports cars such as the Montage, GT40, replicas, Cobra replicas, and Cheetahs to name just a few, which are facing the prospect of being legislated off our roads.

GLAZING:

The problem is that many of these cars are fitted with acrylic or polycarbonate side and/or rear glazing. The N.Z. Ministry of Transport is saying that unless we can provide proof from the relevant authorities that such glazing is permissible for use in Low Volume vehicles respective countries of origin, then they will have to have moulds made and new safety glass screens manufactured for fitment. This ruling will apply retrospectively back to 1976.

The cost of such an exercise would be prohibitive and would result in most of these cars being put off the road for good. The introduction of such a regulation would also rule out the possibility of any further low volume cars from being imported into NZ should they also be fitted with such glazing.

The fact that such cars were sold in their countries of origin with acrylic or polycarbonate screens does not help our case. The MOT say that we have no proof that the manufacturers of these cars actually complied with the regulations of their country, or that their countries of origin have any special exemptions in place for low volume vehicles.

To overcome this problem the NZ MOT require us to provide proof from the appropriate authorities in USA and UK to this effect.

A prompt reply from your Department is a matter of urgency as the introduction of the N.Z. Standards governing alternative glazing materials is set for January 1992.

Could you please reply stating if such materials are permissible, and if so, what types are allowed for use (e.g. acrylic, polycarbonate, abrasion resistant films etc), and under what circumstances, placement or conditions they are permitted.

FULL HARNESS SEATBELTS:

The fitment of 3-point dual sensitive seatbelts to the outboard front seating positions on new cars has been mandatory for some time in NZ, but there has been nothing stopping people from fitting full harness seatbelts if they so desired. However, the NZ MOT are about to stop this practice and in fact retrospectively apply the new ruling.

We believe that any person should be allowed to take extra safety precautions to protect themselves over and above those standards set down by the authorities, provided they do not endanger other people. in this regard we have noticed that quite a number of Low Volume American built sports cars come fitted with full harness seatbelts.

Again it would greatly help our case if we could have the official ruling on the provisions for fitment and use of full harness seatbelts in America.

FRONT NUMBER PLATES:

This problem is not quite so urgent, but the NZ MOT have recently decided not to allow the fitment of flexible registration plates to the front of vehicles. This is creating quite a problem with cars such as E type Jaguars, Cobra Replicas and even modern production sports cars like the MX5 to name just a few. The shape of their nose section does not allow for the fitment of rigid metal plates without them either interfering with radiator cooling or becoming a dangerous protrusion.

It would appear that the American regulations allow for the fitment of either alternative flexible registration plates, or none at all. If this is so, a copy of your registrations governing their fitment would be most helpful.

In anticipation of an early reply, I would like to take this opportunity to thank you for your time and assistance.