ID: 7675

Mr. Spencer A. Darby
Vice President, Engineering
Sate-lite Manufacturing. Co.
6230 Gross Point Road
Niles, IL 60648

Dear Mr. Darby:

This responds to your inquiry about whether a warning device would comply with Federal Motor Vehicle Safety Standard No. 125, Warning devices (49 CFR 571.125). You were specifically concerned about the implications of adding a battery operated flashing light to a warning device that otherwise complies with the Standard. You stated that placing flashing lights between the reflex reflectors would enhance the device's conspicuity at night. I am pleased to have this opportunity to explain our requirements to you.

By way of background information, the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq., the "Safety Act") gives the National Highway Traffic Safety Administration (NHTSA) the authority to issue safety standards applicable to new motor vehicles and new items of motor vehicle equipment. We have exercised this authority to establish Standard No. 125. The Safety Act provides that no person shall "manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States" any new motor vehicle or new item of motor vehicle equipment unless the vehicle or item of equipment complies with the applicable standard. (See 15 U.S.C 1397(a)(1)(A).) NHTSA has no authority under the Safety Act to approve, certify, or otherwise endorse any commercial product. Instead, the Safety Act establishes a self-certification process under which each manufacturer is required to certify that each of its products meets all applicable Federal Motor Vehicle Safety Standard. (See 15 U.S.C. 1403.) I am enclosing a general information sheet explaining NHTSA's regulations.

As your letter states, Standard No. 125 applies to "devices, without self-contained energy sources, that are designed to be carried in motor vehicles and used to warn approaching traffic of the presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle." (emphasis added; see section S3) In other words, Standard No. 125 does not apply to warning devices with self- contained energy sources. In previous interpretations, the agency has determined that the phrase "self-contained energy sources" includes such things as battery powered lights. Accordingly, a warning device to which a battery operated flashing light was added would not be subject to Standard No. 125.

You also asked whether a vehicle required to have three "125 warning triangles" would be required to have three non- lighted complying triangles set out as well. Please be aware that NHTSA does not regulate the use of warning devices. I am forwarding your letter to the Federal Highway Administration (FHWA) which is authorized to regulate some motor vehicle operators and vehicle operations.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Marvin Shaw of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Paul Jackson Rice Chief Counsel Enclosure

Ref: 125 d:10/28/92

ID: nht93-6.19

DATE: August 18, 1993

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

TO: Chief Council -- NHTSA

TITLE: F.M.V.S.S. #207

ATTACHMT: Attached to letter dated 10/1/93 Est. from John Womack to Tom DeLapp (A41; Std. 207)

TEXT:

As a manufacturer of quality limousines we expect to meet or exceed any safety regulation which would affect our vehicles. To this end, we request an interpretation to Federal Motor Vehicle Safety Standard (F.M.V.S.S.) = 207, specifically the section addressing folding or hinged seats.

During and after production of 1993 Ford/Lincoln Town Cars, access to the area rearward of the front seat is limited due to the inclusion of a privacy panel installed to separate the passenger compartment from the drivers compartment. To allow ourselves and our customers access to the area between the front of the panel and the back of the front seat (containing auxiliary fuse panels and relays), we wish to modify the hinge assembly controlling forward and reclining movement of the seat. As constructed by Ford/Lincoln, the seat hinge is limited in it's forward movement by a metal pin in the hinge assembly. By removal of the pin, the seat would articulate forward to a greater degree, thereby providing access to the area in question. This modification is as provided on two door vehicles to allow passengers access to the rear seating.

No change or modification of the O.E.M. recliner latch is performed by our company. The recliner latch provides for a self locking mechanism (and release) for the articulation of the seat back.

Research by myself of the F.M.V.S.S. standards does not reveal a prohibition to removal of the limiting pin or a forward travel limit to the seat back. Additionally, a phone conversation with Clark Harper of the F.M.V.S.S. staff on 8-17-93 failed to locate a prohibition to this modification.

Please address this matter at your earliest convenience. Should you require further information or engineer drawings, please contact me by phone or FAX.

Phone (417) 831 3535 FAX (417) 831 0834

ID: nht90-4.87

TYPE: Interpretation-NHTSA

DATE: December 17, 1990

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: M. Iwase -- General Manager, Technical Administration Department, Koito Manufacturing Company

TITLE: None

ATTACHMT: Attached to letter dated 11-13-90 to Paul Jackson Rice from M. Iwase

TEXT:

This is in reply to your letter of November 13, 1990, with respect to photometric measurement procedures for a L.E.D. center high-mounted stop lamp (CHMSL).

According to your letter, "photometric output of L.E.D. lighting device decreases as the time passes after activation, as shown in Figure 1." Your Figure 1 demonstrates that L.E.D.s at five minutes have a relative photometric output of slightly more than 70 percent of the output when the lamp is activated. After 20 minutes, it would appear to be only slightly more than 60 percent of initial output. You have asked at what time after activation of the CHMSL its photometrics are to be measured; in your opinion, five minutes is a reasonable time. You support your opinion with three arguments, which I will not summarize here since they are not relevant to my response.

Standard No. 108 does not specify when the CHMSL photometric test is to occur. Neither SAE Recommended Practice J186a, Supplemental High Mounted Stop and Rear Turn Signal Lamps, January 1977, the applicable standard that is incorporated by reference, nor any other section of Standard No. 108, requires the photometric test to be conducted at any particular time. The standard does require that CHMSLs and other lamps be designed to conform to its requirements; therefore, we expect the CHMSL to meet the minimum photometric specifications at whatever point in time it is tested after its activation. If Koito wishes to test at five minutes after activation, it may do so.

The purpose of the CHMSL is to reduce the frequency and severity of rear end collisions. Thus, its initial activation is the one that is most critical to highway safety. Although the short survey of continuous brake application times that Koito conducted, and which is referenced in your letter, showed one continuous brake application that exceeded four minutes, at such a period in time the warning message of the light would have been long delivered to the driver following. Thus, the fact that the L.E.D. diminishes over a continuous period of time would not appear to affect its purpose, as long as the CHMSL conforms to the minimum photometric requirements upon each application of the brake pedal, no matter how long the previous brake application and no matter how short the interval between brake applications.

I hope that this answers your question.

ID: nht76-4.22

DATE: 08/02/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: MOTAC Inc.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Motac's June 24, 1976, request to know why a trailer with a flat cargo-carrying surface that is not more than 40 inches above the ground is considered a "heavy hauler trailer" (as defined in Standard No. 121, Air Brake Systems), while a trailer with an inclined cargo-carrying surface that is more than 40 inches above the ground over the fifth wheel attachment point is not considered a heavy hauler trailer. You also request confirmation that the period for exclusion of heavy hauler trailers from the standard has been extended to September 1, 1977.

At the time that the "heavy hauler trailer" exclusion was implemented, the agency considered and rejected the addition of trailers with inclined beds to the excluded category. I have enclosed a copy of the notice that implemented the exclusion, which states "The NHTSA has concluded that trailers with beds higher than 40 inches (including trailers whose beds are below 40 inches over the wheels but higher than 40 inches over the fifth wheel) can accommodate the new larger brake packages available at this time." Of course the exclusion was intended to and does apply to the traditional trailer with a gooseneck and a flat cargo-carrying surface that is not more than 40 inches above the ground. The "double-drop semi", the "stock drop frame flat-bed", and the "40'-0" single axle drop frame platform semi" you describe appear to qualify as heavy hauler trailers.

I have enclosed a copy of the amendment of Standard No. 121 that extends the date for exclusion of heavy hauler trailers to September 1, 1977.

Yours truly,

Enclosures

ATTACH.

June 24, 1976

Frank Berndt -- Acting Chief Counsel, DEPT. OF TRANSPORTATION

Subject: Clarification regarding installation of FMVSS-121 brakes on "Low Bed Heavy Hauler Trailers."

Dear Sir,

We would appreciate further clarification if FMVSS-121 brakes are required or are exempt on the Drop Frame Platform Semi-Trailer per our attached drawing SK-7229-W3. This Drop Frame Platform Semi-Trailer is also made with Tandem axles and a platform height of 39".

In accordance with my letter of Aug. 7, 1975 addressed to Mr. James B. Gregory and his reply "N40-30 of Sept. 8, 1975 (copies attached) I interpret that this type of trailer is exempt from the S-121 brakes as it complies to the definition of a Low Platform Heavy Hauler Trailer."

We also received from T.T.M.A., a copy of your letter, file No. N40-30 RFBPI (copies attached) with two sketches of similar type trailers, stating that they do not qualify for exemption of the S-121 brake system.

Since the greater majority of the load is carried on the main deck, which I interpret as the "Primary Cargo Carrying Surface" and only a small portion of the load can be carried on the gooseneck platform, I analyze that this complies with your definition of Low Platform Heavy Hauler Trailers.

Also please advise if your Docket No. 75-16, Notice 5 has become effective to extend the installation of the S-121 brake system on Heavy Hauler Trailers until Sept. 1, 1977 as I do not have a confirming copy in my files.

Yours very truly,

Jack A. Johnson -- Chief Engineer, MOTAC, INC.

Enc.

ID: nht68-3.39

DATE: 07/09/68

FROM: AUTHOR UNAVAILABLE; Robert M. O'Mahoney; NHTSA

TO: Mr. Philips B. Boyer

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of June 24 to the Department of Transportation asking if manufacturers of motor homes are "required to equip the seats in such units with seat belts."

The self-propelled motor home is classified as a "multipurpose passenger vehicle" for purpose of the Federal motor vehicle safety standards. Currently seat belt installations and seat belt assembly anchorages are not required for multipurpose passenger vehicles, but if a seat belt assembly is(Illegible Word) by the vehicle manufacturer it must meet the requirement of Federal standard No. 209.

On October 14, 1967 the Federal Highway Administrator established dockets to receive comments on possible requirements for seat belt installations and seat belt assembly anchorages in multipurpose passenger vehicles. These comments are now under evaluation.

ID: nht90-2.49

TYPE: Interpretation-NHTSA

DATE: May 22, 1990

FROM: Bob Abernethy -- Idea's Inc.

TO: Office of Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9-7-90 from P.J. Rice to B. Abernethy (A36; Std. 108)

TEXT:

I realize that a change or deviation from Standard # 108 is like changing the Constitution. However, some technical data could aid in your decision. This may be obtained from the Electrical Testing Laboratory.

I have written a proposed variance in your Standard # 108 in my letter to you dated 3/21/90. However I am not accustomed to a committee response.

Enclosed "REGULATION AT ITS BEST" from Automotive Engineering magazine stating the benefits of high mounted stoplamps. Please think further by changing this to an analog response.

If you need further assistance or information, feel free to write; or call me at my new number.

Enclosure

Editorial "Regulation At It's Best" Regular readers of this page will recall that, on occasion, I have criticized the Federal government's regulation of various aspects of the automobile and the automotive industry. So I think it's only fair to pay a compliment to the regulators in Washin gton when they produce a regulation with a clearly outstanding cost-benefit ratio. I refer to the FMVSS No. 108 amendment which requires new passenger cars to be equipped with a center high-mounted stoplamp beginning on September 1, 1985.

At the first of this summer's crop of long-lead press previews, I made it a point to follow as many cars as possible which were equipped with this center stoplamp. Even in bright sunlight I found it remarkably effective in getting a driver's immediate a ttention, alerting him to the braking of the car in front. Although I didn't get a chance to try it at night, I imagine it's all the more effective then. Some of its effectiveness may be due to the fact that it's brand-new, I admit, but even after the driving public has become accustomed to it there should be a significant net gain.

SAE Paper 851240 by Digges, Nicholson, and Rouse, titled "The Technical Basis for the Center High Mounted Stoplamp," says that "The long run costs of the center stoplamp are estimated at about $4 per car. The property damage reduction for a complete fle et equipped with these lamps is estimated at $434 million per year. Comparison of the long run costs and

the property damage savings produces a net benefit of almost $400 million per year."

The paper goes on to say that "Field tests have shown that the center high mounted stoplamp is about fifty percent effective in reducing relevant accidents. Based upon analysis, NHTSA estimates that on the order of 900,000 accidents per year would be av oided, and 40,000 injuries would be reduced."

Is this an example of Federal regulation at its best? It think it is, and I tip my hat to the people at NHTSA who produced it.

Larry Givens Editor "Automotive Engineering" July 85 Volume 93, Number 7

ID: 1985-01.28

TYPE: INTERPRETATION-NHTSA

DATE: 02/06/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Binichi Doi NSK Representative Office

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Binichi Doi NSK Representative Office 3861 Research Park Drive P.O. Box 1507 Ann Arbor, Michigan 48106

This responds to your letter of December 21, 1984, concerning several questions about Standard No. 209, Seat Belt Assemblies.

In all of your questions, you in essence asked whether automatic safety belts are required to meet the marking requirements of section 4.1(j) of Standard No. 209. The answer is that automatic belts complying with the frontal crash protection requirements of Standard No. 208 are not required to meet the marking requirements of Standard No. 209.

As explained in detail in the enclosed agency interpretation letter of August 7, 1981, to Volkswagen, automatic safety belts that meet the perpendicular frontal crash protection requirements of section S5.1 of Standard No. 208 are only required to meet the requirements of Standard No. 209 that are incorporated by reference in section S7.1 of Standard No. 208. Section S7.1 of Standard No. 208 only incorporates provisions directly related to retractor performance and does not incorporate the marking requirements of S4.1(j) of Standard No. 209.

If you have further questions, please let me know.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

December 21, 1984 NHTSA Room 5219 400 7th Street S.W.

Washington, D.C. 20590 Mr. Frank Berndt, Chief Counsel Interpretation of Marking Requirement for Passive Seat Belts

Dear Mr. Berndt:

I am writing this request for NHTSA's opinion on this subject on behalf of NSK-Warner Co. Ltd. (NWC) of Japan, which is a producer of automotive seat belts and is one of NSK's subsidiaries.

Question 1) Are the passive seat belts required to have the identification marking label sewn or glued on the belt similar to the active seat belts, for ever-ready viewing of such? or is ever-ready viewing of the identification label not required although the I.D. label must be on the seat belt?

2) Is it sufficient to have the identification marking on components other than the belt, such as the retractor or buckle frame, where ever-ready viewing of such could not be practical?

3) Are there other interpretations of the marking requirement than the above?

Background information:

1) NWC needs to know NHTSA's interpretation on the above subject matter for planning the production of its passive seat belts which would be somewhat similar in external appearance to the Toyota Cressida type or the diagonal belt of the VW Rabbit.

2) NWS's customer auto-manufacturers are indicating their dislike far sewing the identification label onto the belt webbing.

3) The probable alternate method would be gluing the I.D. seal label or mark-stamping it onto the retractor frame or the mounting bracket. In this case, the retractor or bracket might be hidden under some form of cover or be located in the center console box, for which ever-ready viewing of such I.D. marking is not practical.

Your kind attention to this request for NHTSA's interpretation of the marking requirement for passive seat belts would be appreciated by us.

Very truly yours,

Binichi Doi NSK Representative

BD/lgc

ID: nht93-3.26

DATE: April 27, 1993

FROM: Scott R. Dennison -- Vice President-Production, Excalibur Automobile Corporation

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: None

ATTACHMT: Attached to letter dated 9/27/93 from John Womack to Scott R. Dennison (A41; VSA Sec. 102 (illegible)

TEXT:

Thank you for your letter of April 19 in response to my fax to Mr. Robert Helmuth. I apologize if I misled my intentions of the letter. I am fully aware that the Motor Vehicle Safety Act of 1972 is quite clear and concise. I am also proud of the fact that Excalibur Automobile Corporation has been one of the manufacturers to comply with the Act as a specialty car, low volume manufacturer.

The point of my letter is that as one of the most well known specialty car manufacturers, I am constantly contacted by other low volume manufacturers and builders, as an "expert," who ask questions regarding compliance with both the FMVSS and EPA. My response is always the standard that if a person builds a vehicle to enter into commerce in the U.S., it must comply with the current standards in effect as of the year of manufacture. The most difficult area to offer more advice and direction is the treatment of FMVSS with regards to a '23 T-Bucket Hot Rod for instance. This is a car that would never comply yet there is a demand and someone will build one to sell.

My goal in all of this is to help all of the people in our industry comply with the standards and stay in business. It is just that at times I do not feel I have the right answers for some of these manufacturers and I would like to have some additional direction from Mr. Helmuth's office. Many of these builders, of course, will call me or someone like me, because they are afraid to call you for fear of reprisal. I would appreciate any advice you may have for me to pass one.

The "debate" I refer to in my letter is perhaps a misnomer but refers to the development of policy as currently being pursued by the National Hot Rod Association (NHRA) lobbyists and the Specialty Equipment Market Association (SEMA) regarding hot rods, muscle cars, and replicars. The debate appears to be more of can a new, more specific policy be developed which will allow these builders to produce an authentic replica and stay within the standards?

I would reference the policy which was developed by the U.S. EPA in order to allow specialty car builders the ability to utilize previously certified engine systems and not have to go through the expensive and intricate certification procedure. I have enclosed a copy of this policy for your review.

After you have had an opportunity to reflect on the situation that I face with these builders and manufacturers, please let me know your thoughts and any advice that you might offer me. I thank you for your time and effort

and hope that my requests do not place an undo burden on you or your department.

Enclosure (EPA KIT CAR POLICY) omitted.

ID: nht75-1.36

DATE: 11/10/75

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Amerace Corporation

TITLE: FMVSS INTERPRETATION

TEXT: I am writing to confirm your telephone conversation of July 21, 1975, with Mark Schwimmer of this office, concerning the labeling requirements of Federal Motor Vehicle Safety Standard No. 106-74, Brake Hoses.

Your letter of June 12, 1975, explained that you supply hose in lengths as short as 1 1/2 inches. You found it possible to include a complete legend of the information required by S5.2.2 of the standard only by utilizing two lines of printing, parallel to each other and separated by approximately 1/8 inch. As Mr. Schwimmer explained, such a labeling procedure would satisfy the standard's requirements.

I would like to point out, however, that the standard was amended by Notice 18 (40 FR 38159, August 27, 1975), to facilitate the depletion of inventories of brake hose which complies with all requirements except the labeling requirements of S5.2. One effect of that amendment was to delay until September 1, 1976, the requirement that at least one complete legend appear on any hose used in an assembly, regardless of its length. For your convenience, I have enclosed a copy of the notice.

Sincerely,

Enclosure

June 12, 1975

Office of Chief Counsel N. H. T. S. A.

Attention: Mark Schwimer

Subject: FMVSS-106

Dear Sir:

In reference to our phone conversation of June 3, 1975, Notice 16 of FMVSS-106 is quite explicit in requiring that a complete legend appear on each and every piece of brake hose regardless of length. The Standard itself, and various notices, appear to be less explicit as to whether this legend must appear on only one line. Notice 11 does state "only the required information may appear along one side of the hose". Your clarification is requested on this since we are not able to incorporate a complete legend on each hose length using existing equipment, nor are we able to incorporate it into just a single line.

We currently furnish some OEM parts down to 1-1/2" in length. Current equipment will allow us to repeat a complete legend every 4". On parts shorter than 4" we have found it necessary to hand stamp each piece individually, at a considerable cost penalty I might add, but even using this technique we are not able to include a complete legend on a single line within 1 1/2". However, we can apply a complete legend within 1 1/2" with a hand stamp by utilizing two lines of printing. These two lines are on "one side of the hose", parallel to each other and separated by approximately 1/8".

Since we have a considerable amount of inventory on parts under 4" which have been held up from being shipped since the effective date of Notice 16, which was March 17, 1975, we would appreciate your interpretation of the standard as to whether more than one line is permissible for a complete legend. A reply at your earliest convenience would be appreciated.

Very truly yours,

SWAN HOSE DIVISION -- Amerace Corporation; R. E. Ruda -- Technical Services Manager

ID: nht95-1.53

TYPE: INTERPRETATION-NHTSA

DATE: February 6, 1995

FROM: Philip R. Recht -- Chief Counsel, NHTSA

TO: Frances J. Chamberlain

TITLE: NONE

ATTACHMT: Attached to 1/1/94 (EST) letter from Frances J. Chamberlain to John Womack

TEXT: Dear Ms. Chamberlain:

This responds to your letter asking about how this agency's regulations might apply to your product. I apologize for the delay in sending this letter. You explained in a telephone conversation with Paul Atelsek of this office that your product is an em ergency kit the size of an "oversize notebook." The kit contains a radio. In completing your design, you are considering whether to attach it to the back side of the front seats or under those seats. You asked whether the National Highway Traffic Safet y Administration (NHTSA) has any regulations as to the distance that must be kept clear between the back side of the driver's seat and the back seat. You are considering marketing the kit for passenger cars and light trucks through retail outlets, and p ossibly also through automobile dealerships as an optional accessory.

The short answer to your question is that, while there are no regulations concerning clearance between the front and back seats, there are Federal requirements that may affect the sale of this product. I am pleased to have this opportunity to explain our regulations. I am also enclosing a copy of a fact sheet titled "Information for New Manufacturers of Motor Vehicles and Motor Vehicle Equipment."

By way of background information, NHTSA is authorized to issue Federal motor vehicle safety standards (FMVSS's) for new motor vehicles and new items of motor vehicle equipment. These are contained in title 49, part 571 of the Code of Federal Regulations . As you recognize in your letter, your safety kit is an accessory and thus an item of motor vehicle equipment.

While your emergency kit is an item of motor vehicle equipment, NHTSA has not issued any standards for such an item. Nevertheless, there are other provisions of law that may affect the manufacture and sale of your product. Installation of your product o n the back of front seats could have an impact on compliance with Standard No. 201, Occupant protection in interior impact. S3.2 of that standard basically requires that seat backs have a certain amount of cushioning to provide protection when struck by the head of rear seat passengers during a crash. If your emergency kit were installed so that a hard object (e.g., the radio) contained within it were to be struck by the head, the requisite amount of cushioning might not be achieved. We note that the re are no safety standards regulating the underside of the seats, which you have said is another interior space where you are considering mounting the emergency kit.

Which legal requirements apply depends on how your product is marketed. If your product were installed by a vehicle manufacturer as original equipment, the vehicle manufacturer would have to certify that the vehicle with the emergency kit installed comp lies with all FMVSS's, including Standard No. 201.

A commercial business that installs your emergency kit would also be subject to provisions of the U.S. Code that affect modifications of new or used vehicles. Section 30122(b) of Title 49 provides that:

A manufacturer, distributor, dealer, or motor vehicle repair business may not knowingly make inoperative any part of a device or element of design installed on or in a motor vehicle . . . in compliance with an applicable Federal motor vehicle safety s tandard . . .

This means that a manufacturer, distributor, dealer, or motor vehicle repair business must not install your device if the system renders inoperative the vehicle's compliance with the FMVSS's. For instance, compliance with Standard No. 201 might be degra ded if the emergency kit were mounted in front of rear seat passengers. Any violation of this "make inoperative" prohibition would subject the violator to a potential civil penalty of up to $ 1,000 for each violation.

The "make inoperative" prohibition does not apply to modifications that vehicle owners make to their own vehicles. Thus, Federal law would not apply in situations where individual vehicle owners install your emergency kit in their own vehicles, even if the installation were to result in the vehicle no longer complying with the safety standards. However, NHTSA encourages vehicle owners not to degrade any safety device or system installed in their vehicles. In addition, individual States have the autho rity to regulate modifications that individual vehicle owners may make to their vehicles, so you might wish to consult State regulations to see whether your device would be permitted.

You as the product's manufacturer are subject to the requirements in sections 30118-30122 of Title 49 of the U.S. Code concerning the recall and remedy of products with defects related to motor vehicle safety. In the event that the manufacturer or NHTSA determines that the product contains a safety related defect, the manufacturer would be responsible for notifying purchasers of the defective equipment and remedying the problem free of charge.

I hope this information is helpful. If you have any further questions about NHTSA's safety standards, please feel free to contact Mr. Atelsek at this address or by telephone at (202) 366-2992.

Sincerely,