ID: 9311

Mr. Leo Chung
Operational Services
Genstar Container Corporation
505 Montgomery Street
San Francisco, CA 94111-2584

Dear Mr. Chung:

This responds to your letter of November 3, 1993, to Mr. Vinson of this Office, with respect to calculation of the application of conspicuity treatment to container chassis trailers.

The length of the gooseneck is included in determining the overall length of the trailer for purposes of calculating the half length that must be covered by the conspicuity treatment (which, of course, would be greater than half the length behind the gooseneck). For example, let us say that the overall length of the trailer is 40 feet, including an 8-foot gooseneck. The amount of the side to be covered is not less than 20 feet. The area to be covered is the 32 feet between the rear bolster to the point immediately behind the gooseneck's terminus. Thus, at least 20 feet of this 32-foot length must be covered in order to comply with Standard No. 108.

There is nothing in Standard No. 108 that precludes the application of retroreflective sheeting to the gooseneck. Indeed, some manufacturers may wish to do so to provide conspicuity of the trailer side when the trailer is traveling without its cargo. However, any conspicuity treatment on a gooseneck is not counted in determining whether at least half the trailer side is covered. I hope that this clarifies the matter for you.

Sincerely,

John Womack Acting Chief Counsel ref:108 d:11/29/93

ID: nht92-2.39

DATE: November 10, 1992

FROM: Duane Bartels -- Commercial Vehicle Inspector III, MN State Patrol

TO: Chief Counsel -- NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 5-21-93 from John Womack to Duane Bartels (A41; Part 566; Part 567)

TEXT: A person in the State of Minnesota has requested to change the seating in a 12 or 15 passenger van to a maximum of 10 passenger. This would change the original manufacturers rating of a "Bus" because the vehicle carries more than 10 to a vehicle classification of "MPV" which is designed to carry 10 or less persons.

His proposal to do this type of work is to remove and or modify seats so the van can only carry a maximum of 10 people. When seats are removed all fastening devices and holes in the floor will be removed or covered as not to allow a seat to be readily put back in the vehicle. When a seat is modified he either modifies the seat frame or does upholstery work to reduce the number of people that can sit in the seat. (ie: a 3 passenger seat to a 2 passenger seat or a 4 passenger seat to a 3 passenger seat). Extra seat belts are removed to comply with the new seating. There is no other work done to the structure of the vehicle.

This person will then affix an additional label of the type and in the manner as prescribed in 49 CFR 567.4.

By doing the above work to a vehicle, this person believes he is allowed to do such work and recertify the vehicle according to 49 CFR 567.7. 49 CFR 567.7 are requirements for persons who alter a certified vehicle by other than addition, substitution or removal of readily attachable components.

Before he is given permission to do this type of work, some questions need to be answered.

1. By doing this altering to seats, is he doing enough work to the vehicle to qualify under 49 CFR 567.7?

2. Will this person become a manufacturer and if so, does he need to comply with 49 CFR 566.5?

3. Can he purchase a new vehicle, do the altering and resell the vehicle or must an owner bring the vehicle to him and have the altering done?

4. Can this altering and recertifying be done only to a new vehicle or can this be done to a used vehicle?

Please review 49 CFR 567.7 and return back to me your opinion on the questions I have listed.

Thank you in advance for your help in this matter.

ID: nht81-2.49

DATE: 07/17/81

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Department of Transportation; Michigan

TITLE: FMVSR INTERPRETATION

TEXT: This responds to your March 30, 1981 letter pertaining to the mounting of an old school bus body on a new chassis. The National Highway Traffic Safety Administration (NHTSA) has stated that such a mounting constitutes the manufacture of a new motor vehicle and must comply with all applicable safety standards in effect at the time of that manufacture. This statement comes from previous agency interpretations of the National Traffic and Motor Vehicle Safety Act and from the rationale underlying the provisions of section 571.7(e) of our regulations. You state that section 571.7(e) applies only to trucks and, accordingly, has no application to school buses.

The agency has had a longstanding position that a vehicle combining an old body and new chassis is a new vehicle. This position was developed and applied long before the proposal of section 571.7(e) in May 1975. See, for example, the enclosed 1972 letter of interpretation and the discussion of pre-proposal interpretations in the enclosed copy of the May 1975 proposal.

The codification in section 571.7(e) of the agency's position as regards trucks did not alter its simiar position as regards other vehicle types. I am enclosing a 1978 interpretation stating that school buses will be treated under the National Traffic and Motor Vehicle Safety Act in the same fashion as trucks are under section 571.7(e). The reason for this interpretation is the similarity of the practice of manufacturing school buses and trucks on new truck chassis. Accordingly, the agency has applied the same rationale in determining those vehicles, e.g., buses, that are to be considered newly-manufactured.

In light of these existing interpretations and in the interest of safety, the agency is retaining its position that vehicles using old bodies and new chassis be treated as newly manufactured vehicles.

ENCLS.

STATE OF MICHIGAN

DEPARTMENT OF EDUCATION

March 30, 1981

Roger Tilton, Chief Counsel National Highway Traffic Safety Administration

Dear Mr. Tilton:

The State of Michigan is in the grips of a financial crisis which is now threatening the children of this State through the local school's inability to provide new school buses to replace those which have reached the end of their life expectancy.

New school bus purchases are off by about 75% due to budget constraints which have also reduced the State's assistance to the school district from 68% during the last reimbursement period to an expected 30% for the 80-81 fiscal year. In this State, we turn over 1,900 school buses each year.

As a means to provide safe, dependable and economical school bus transportation, the local school districts are contemplating rehabilitation of these older school buses.

Rebuilding an old school bus is easy and economically rewarding. However, there are many old school bus bodies (approx. 20% or 350 each year) that would better serve the fleet if they were mounted on new chassis.

We, in the State of Michigan, are fully aware of previous interpretation of Part 571.7(e) of the Federal Motor Vehicle Safety Standards which relates to combining new and used components. The interpretations which are printed for all who ask, come from Joan Claybrook's office and from Frank Berndt do not say one shall not put an old school bus body on a new chassis, BUT that when an old school bus body is placed on a new chassis, the entire re-manufactured vehicle must comply with all of the FMVSS's in effect on the date of re-manufacture. The interpretation leads us to Part 571.7(e).

The Part 571.7(e) relates to "TRUCKS" and does not address "BUS" or school bus. Since there is "TRUCK" listed in definitions, Part 571.3 and the word "BUS" is also in definitions Part 571.3; we contend that 571.7(e) does not apply to Bus or School Bus since 571.7(e) does not refer to "BUS" in its content.

We do not accept the interpretation provided by Joan Claybrook or Frank Berndt. We completely understand that by allowing these used buses manufactured prior to April 1, 1977 to wash out of the system that in a few years the only buses on the road will be those which were manufactured in compliance with 220, 221, & 222.

The Part 571.7(e) also tells us that the re-manufactured truck must meet the current FMVSS "unless the engine, transmission, and drive axle(s) (as a minimum) of the assembled vehicle are not new, and at least two of these components were taken from the same vehicle." Therefore, if we in Michigan make these drive line changes we do not have a re-manufactured truck and we can continue to use a pre April 1, 1977 school bus body which still does not meet 220, 221, & 222; while mounted on a post April 1, 1977 chassis.

I submit to you that your office, NHTSA, is saying that we may not put a pre April 1, 1977 school bus body on a post April 1, 1977 chassis unless the body is updated to meet the post April 1, 1977 FMVSS 220, 221, & 222, OR instead of updating the body, we may install a used engine, transmission, and rear end in the new chassis; two of those three components must come from the same used vehicle.

Your interpretation is illogical and seemingly does not apply where school buses are concerned. We respectfully request a new interpretation keeping in mind that it is President Reagan's philosophy that those Federal Regulations which are non-productive, yet require great expense in order to comply; are Regulations with which we need to deal.

The State of Michigan, the State Department of Education, and I personally feel bound to comply with Federal Law; however, we do not feel bound to comply with an interpretation which smacks of pressure from the manufacturers and dealers who are in the business to sell new bodies.

We eagerly await your response.

Larry Louderback, Safety Specialist Pupil Transportation

cc: PHIL O'LEARY - SAFETY & TRAFFIC PROG; MR. WEINHEIMER - MICH. SCH. BD. ASSOC.; MR. TEBBE - UNION CITY SCH. DIST.; SENATOR DON RIEGLE; ROD LAMORE - GRAND RAPIDS STATE POLICE; DREW LEWIS - TRANS. SEC.; NHTSA

ID: nht69-2.39

DATE: 09/12/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: The Flexible Company

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of August 21, 1969, to Mr. George C. Nield, Acting Assistant Director, Motor Vehicle Safety Performance Service, concerning the requirements of Federal Motor Vehicle Safety Standard No. 108 with respect to activation of stop lamps when the emergency brakes are applied.

Paragraph S3.4.4 of Standard No. 108 specifies that "Except as provided in S3.4.4.1 through S3.4.4.3 stop lamps shall be actuated upon application of any service or emergency broken." The emergency-parking brakes as described in the 2nd paragraph of your letter are not considered "emergency" brakes within the weaning of paragraph S3.4.4 of Standard No. 108. Therefore, actuation of stop lamps need not be provided upon application of such brakes. I should point out, however, that the Bureau now has under development a proposed standard for brakes which will be applicable to trucks. If under this proposed standard, the emergency-parking brakes as used on your vehicles are defined as "emergency" brakes, then the requirement of paragraph S3.4.4 of Standard No. 108 will be applicable.

ID: NJP Engineering Letter of Interpretation FMVSS No. 121signed

October 4, 2024

Mr. Nick Paulick, PE
Owner, NJP Engineering, LLC
P.O. Box 2161
Oshkosh, WI 54903 

Dear Mr. Paulick, 

This responds to your letter, dated October 31, 2022, regarding removing the third axle from a used three axle semitrailer and reducing both the trailer’s load-carrying capacity and its braking capacity. More specifically, we understand you to be asking whether the reduction in braking capacity would violate the “make inoperative” prohibition in 49 U.S.C. § 30122 with respect to Federal motor vehicle safety standard (FMVSS) No. 121, Air Brake Systems. 

Please note that our answer below is based on our understanding of the specific information provided in your letter. This interpretation letter does not have the force and effect of law and is not meant to bind the public in any way. This letter is intended only to provide clarity regarding existing requirements under the law and represents the opinion of the agency on the questions addressed in your letter at the time of signature. 

In your letter, you stated that you are requesting an interpretation regarding the modification of semi-trailers after first sale to add or remove axles to change their load-carrying capacity and the overall capacity of a combination motor vehicle. You note that you reviewed existing interpretations (specifically, our letter to John Paul Barber on May 24, 1993) and believe that the National Highway Traffic Safety Administration (NHTSA) “is not opposed” to aftermarket modifications such as removing an axle, “so long as they are done properly and that an explanatory label is affixed, advising the user of what these changes will mean in terms of gross weight rating.” 

You ask about the specific example of a three-axle semi-trailer with each axle having a gross axle weight rating (GAWR) of 20,000 pounds and the trailer having a gross vehicle weight rating (GVWR) of 75,000 pounds. You suggest the removal of one axle from the trailer, reducing its GVWR to 65,000 pounds. You further state that a “dataplate” would be permanently affixed to the modified trailer advising the user of the revised payload capacity. Because removing an axle from the trailer also removes the brakes associated with it, you ask whether the reduced “braking capacity” of the trailer would bring the vehicle out of compliance with NHTSA’s braking standards and potentially violate the “make inoperative” prohibition. For the purposes of this letter of interpretation, we understand “braking capacity” as used in your letter to mean the ability of the vehicle to meet the stopping distance requirements in FMVSS No. 121. 

By way of background, NHTSA is authorized by the National Traffic and Motor Vehicle Safety Act (Safety Act, 49 U.S.C. Chapter 301) to issue FMVSS that set performance requirements for new motor vehicles and new items of motor vehicle equipment. The Safety Act requires manufacturers to self-certify that their vehicles and equipment conform to all applicable FMVSS in effect on the date of manufacture. NHTSA also investigates safety-related defects. 

Your letter indicates that the modifications occur after first sale other than for resale.1 As you correctly note, the only legal requirement that is imposed on entities that make modifications to used vehicles is that a manufacturer, distributor, dealer, rental company, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed in furtherance of compliance with an applicable motor vehicle safety standard. 49 U.S.C. § 30122(b). A modifier subject to this prohibition must therefore ensure that the vehicle’s brakes and other systems remain in compliance with all applicable Federal motor vehicle safety standards once the modifications are performed. Civil penalties can be imposed under 49 U.S.C.
§ 30165(a) for violations of section 30112(b). 

We assume, for the purposes of this letter, that the trailer you intend to modify is equipped with an air brake system. FMVSS No. 121 establishes requirements for vehicles equipped with air brake systems. Under S5.3.1 of FMVSS No. 121, truck tractors must meet the stopping distance requirements specified in Table II of that standard, when loaded to their GVWR and tested using an unbraked control trailer.2 We note, however, that such requirements are applicable to the truck tractor. FMVSS No. 121 contains no stopping distance requirements applicable to trailers. FMVSS No. 121 does contain other requirements applicable to trailers, such as parking brakes, and certain as-equipped requirements should the trailer axles have brakes, such as that the braked trailer axles be equipped with anti-lock braking systems and have the required air reservoirs. 

We also assume for the purposes of this letter that the entity performing the modifications is subject to the “make inoperative” prohibition. You state that NJP Engineering provides engineering services for the evaluation of new and modified cargo tank motor vehicles. From this description, it is not clear what role NJP Engineering has in the actual performance of any modifications. We also note that even if an entity not subject to the “make inoperative” prohibition modifies the vehicles, such modifications may be subject to the laws and regulations administered by the Federal Motor Carrier Safety Administration and the States in which the vehicles are operated.

1 Because the trailer is a used trailer, you are not an alterer. An alterer is defined as a person who alters by addition, substitution, or removal of components (other than readily attachable components) a certified vehicle before the first purchase of the vehicle other than for resale. 49 C.F.R. § 567.3.
2 The following vehicles may meet the stopping distance requirements specified in Table IIa instead of Table II: Three-axle tractors with a front axle that has a GAWR of 14,600 pounds or less, and with two rear drive axles that have a combined GAWR of 45,000 pounds or less, that were manufactured before August 1, 2011; and all other tractors that were manufactured before August 1, 2013. For such vehicles, the analysis in this letter of interpretation is the same. 

In your letter, you state that a three-axle trailer would be modified to remove an axle and you ask about the applicability of the “make inoperative” prohibition with respect to the trailer’s braking capacity. FMVSS No. 121 does not contain stopping distance requirements applicable to trailers. Therefore, a reduction in braking capacity alone would not affect compliance with the FMVSSs and would not violate the “make inoperative” prohibition.3 Regarding other braking performance requirements applicable to trailers, such as parking brake requirements and as- equipped requirements for trailer axles, modifications to the trailer as stated must not take the trailer out of compliance with requirements that would be applicable to the modified trailer. You do not ask about, nor does this letter address, any other aspect of compliance with FMVSS No. 121, or other applicable FMVSS. 

I hope this information is helpful. If you have any further questions, please feel free to contact Eli Wachtel of my staff at (202) 366-2992.

Sincerely,
ADAM RAVIV
Adam Raviv Chief Counsel

Dated: 10/4/24
Ref: Standard No. 121

3 You note that you intend to affix a “dataplate” indicating the revised weight capacity of the trailer. We note that such a “dataplate” is not required by our regulations; however, we believe it is appropriate to add a label to the vehicle which indicates the appropriate loaded weight of the modified vehicle in situations where certain modifications that might be made to a used vehicle (e.g., adding or deleting an axle) which could make the originally assigned GVWR inappropriate for the vehicle as modified.
 

ID: nht95-3.49

TYPE: INTERPRETATION-NHTSA

DATE: July 20, 1995

FROM: Thomas A. Placey -- Senior Assistant District Attorney, Office of the District Attorney, Cumberland County

TO: Office of the Chief Counsel, NHTSA

TITLE: Re: Commonwealth v. One 1994 GMC Jimmy 95-258 Miscellaneous Term; VIN: 1GKDT13WR2508404 (true); 1GKDT13W4R2511523 (altered); PSP ID: X4-15565

ATTACHMT: ATTACHED TO 08/11/95 LETTER FROM STEPHEN P. WOOD AND JOHN WOMACK (TO THOMA A. PLACEY (A43; PART 591)

TEXT: Sir/Madame:

Corporal James Drenning, of the Pennsylvania State Police (PSP), has referred me to you for information on a case currently within my jurisdiction.

The nutshell facts are as follows: Auto thief steals a Canadian owned GMC Jimmy in Canada. Thief, without any import or export license, delivers GMC Jimmy to conspirator in Pennsylvania. Conspirator alters VIN and sells to buyer. Police in both cou ntries break auto theft ring. PSP, pursuant to state law, seize vehicle from buyer. Buyer wants GMC Jimmy back and files with local state court for return.

The issue, on the federal level, is can this vehicle ever be properly registered in the United States. What are the specific federal laws or regulations that govern such situations.

My hearing on the state issue is in September. I know the judge will ask about federal ramifications. It would be extremely helpful if you could point me in the right direction so I may answer the judge's question with specific law or regulation.

Thank you for your time and assistance in this matter.

ID: nht95-5.28

TYPE: INTERPRETATION-NHTSA

DATE: July 20, 1995

FROM: Thomas A. Placey -- Senior Assistant District Attorney, Office of the District Attorney, Cumberland County

TO: Office of the Chief Counsel, NHTSA

TITLE: Re: Commonwealth v. One 1994 GMC Jimmy 95-258 Miscellaneous Term; VIN: 1GKDT13WR2508404 (true); 1GKDT13W4R2511523 (altered); PSP ID: X4-15565

ATTACHMT: ATTACHED TO 08/11/95 LETTER FROM STEPHEN P. WOOD AND JOHN WOMACK (TO THOMA A. PLACEY (A43; PART 591)

TEXT: Sir/Madame:

Corporal James Drenning, of the Pennsylvania State Police (PSP), has referred me to you for information on a case currently within my jurisdiction.

The nutshell facts are as follows: Auto thief steals a Canadian owned GMC Jimmy in Canada. Thief, without any import or export license, delivers GMC Jimmy to conspirator in Pennsylvania. Conspirator alters VIN and sells to buyer. Police in both countries break auto theft ring. PSP, pursuant to state law, seize vehicle from buyer. Buyer wants GMC Jimmy back and files with local state court for return.

The issue, on the federal level, is can this vehicle ever be properly registered in the United States. What are the specific federal laws or regulations that govern such situations.

My hearing on the state issue is in September. I know the judge will ask about federal ramifications. It would be extremely helpful if you could point me in the right direction so I may answer the judge's question with specific law or regulation.

Thank you for your time and assistance in this matter.

ID: nht69-2.48

DATE: 10/16/69

FROM: AUTHOR UNAVAILABLE; C. A. Baker; NHTSA

TO: Seagrove Corporation

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 29, 1969, to Mr. Julien B. Leysath concerning the mounting location of lamps and reflectors on fire trucks.

The lamps and reflectors shown on your print of drawing number 2207 B 43.3 dated September 29, 1969, appear to meet the requirements of MVSS No. 108 with the following exception:

1. Front side marker lamps are not indicated on either the "F" or "S" cab. The front clearance lamps on the "F" cab may be combination clearance and side marker lamps, but are not so labeled.

2. The rear reflex reflectors on the 4 wheel aerial truck and the trailer do not appear to be located as far apart as practicable.

3. Backup lamps are not required on trailers.

Since no dimensions are specified on your drawing, we can only assume that the locations are otherwise as specified in MVSS No. 108.

With respect to the requirements of MVSS 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 consants 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 Standard No. 108.

ID: nht92-1.32

DATE: 12/09/92

FROM: DANIEL K. UPHAM -- PRESIDENT, SYS TEK CORPORATION

TO: CHIEF COUNSEL, NHTSA

TITLE: SUBJECT: COMPLIANCE WITH NATIONAL SAFETY STANDARDS, NEW PRODUCT

ATTACHMT: ATTACHED TO LETTER DATED 12-28-92 FROM PAUL J. RICE TO DANIEL K. UPHAM (A40; STD. 108); ALSO ATTACHED TO LETTER DATED 8-17-89 FROM STEPHEN P. WOOD TO ALAN S. ELDAHR (STD. 108)

TEXT: We are a new company located in Southern California involved in new product development and manufacturing. We are currently designing a new product that can be used in motor vehicles as an advertising or silent communications device and we would like to be sure that we are not violating any local or federal laws. That being the case I spoke on the telephone with Mr. George Shefflett who suggested that we contact your office for an official opinion even though he believed there did not appear to be a problem.

The product we have in mind is a portable lighted message display using LED technology, that could be mounted inside the vehicle to the side rear or rear window. It will be either battery powered or it will be powered using the vehicle power source via cigarette lighter or directly to the cars electrical harness. This is an after market product sold through auto parts stores or various other consumer outlets.

We have reviewed the California Vehicle Code and are aware of the general constraints such as colors, view obstruction, light brightness, etc. Frankly we have found no serious obstacles to our endeavor at this point and we would like to hear your concerns and suggestions with regard to our idea. We would also appreciate any suggestions you may have as to what other agencies or organizations we might need to confer with before we make our final decisions.

Thank you very much for your time and help.

ID: 6978

Mr. Douglas Kubehl
Safety Engineering Associates, Inc.
2798 S. Fish Hatchery Rd.
Madison, Wisconsin 53711-5398

Dear Mr. Kubehl:

This responds to your letter of February 4, 1992, concerning the requirements of Federal motor vehicle safety standard No. 209, Seat belt assemblies. You asked for verification of your understanding of the requirements of two sections of Standard No. 209. Your discussion of these two sections and our response follows.

In 209-S.4.4a(1), it is clearly stated that a loop force of 5000 pounds is required to produce a force of 2500 pounds on each structural component. However, part 209-S4.4b(4) seems to be a bit ambiguous. It states: "The length of the pelvic restraint between anchorages shall not increase more than 20 inches or 50 centimeters when subjected to a force of 2500 pounds". My interpretation of this statement is that one must employ a loop force of 5000 pounds to achieve 2500 pounds of force on each component, as specified in S4.4a(1). I am concerned that one could misinterpret the above statement as requiring a 2500 pound loop force, rather than the intended value of 5000 pounds.

Your statements indicate a common misunderstanding of the requirements of S4.4 of Standard No. 209. A seat belt assembly would not be subject to the requirements of S4.4(a) and to the requirements of S4.4(b). If the seat belt assembly is a Type 1 seat belt assembly, defined in S3 as "a lap belt for pelvic restraint," the assembly is subject to the requirements of S4.4(a). Section S4.4(a)(1) requires a Type 1 seat belt assembly loop to withstand a force of 5,000 pounds. Section S4.4(a)(2) states that the length of the assembly between the anchorages shall not increase more than 14 inches or 36 centimeters when the load required in S4.4(a)(1) is applied.

If the seat belt assembly is a Type 2 seat belt assembly, defined in S3 as "a combination of pelvic and upper torso restraints," the assembly is subject to the requirements of S4.4(b). Section S4.4(b)(1) requires the pelvic portion of a Type 2 seat belt assembly to withstand a force of 2,500 pounds. Section 4.4(b)(4) states that the length of the pelvic portion of the assembly shall not increase more than 20 inches or 50 centimeters when the load required in S4.4(b)(1) is applied.

Part 209-S5.3a, which addresses the performance of the belt assembly, refers to Figure 5 and requires a tensile force of 2500 pounds. It goes on to say that this force is equivalent to a 5000 pound force being applied to an assembly loop. Figure five is referred to several times throughout the passage, each reference requiring a specific force. Again, because the relationship of the tensile force to assembly loop force is not explicitly stated, we are concerned that one may mistake the tensile force to be the total loop force applied.

The test procedure to determine compliance with the requirements of S4.4 of Standard No. 209 is found in S5.3 of that standard. The test procedure for seat belt assemblies subject to the requirements of S4.4(a) (a pelvic restraint) is found in S5.3(a). As you have correctly stated, a force of 2,500 pounds is applied to each component of the pelvic restraint, or a force of 5,000 pounds to the entire loop. The test procedure for seat belt assemblies subject to the requirements of S4.4(b) (a combined pelvic and upper torso restraint) is found in S5.3(b). The pelvic portion of such a seat belt assembly is tested by applying a total force of 2,500 pounds to the entire loop.

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,

Paul Jackson Rice Chief Counsel

ref:209 d:3/16/92