ID: GF009385

Mr. Karl Genest
518 Jodoin
St-Bruno, Quebec
CANADA
J3V 6G8




Dear Mr. Genest:

This responds to your letter of December 9, 2004, asking if any Federal regulations apply to your invention, which you describe generally as an accessory that attaches to the seatback of a vehicles front seat. You did not provide a description of your product except to note that it attaches to the seatback, and that "when attached to the back of a cars front seat, [my device] would intrude somewhat into the space occupied by passengers of the back seat". You state that the intrusion would be similar to those of two "car seat organizers," the photographs of which you enclose in your letter. In a phone conversation with George Feygin of my staff, you indicated that you intend to market your product in stores directly to consumers (in the "aftermarket").

By way of background, the National Highway Traffic Safety Administration (NHTSA) issues Federal motor vehicle safety standards applying to the manufacture and sale of new motor vehicles and certain items of motor vehicle equipment sold in or imported into this country. NHTSA does not provide approvals of motor vehicles or motor vehicle equipment. Under 49 U.S.C. Chapter 301, manufacturers are required to certify that their vehicles and equipment meet applicable requirements.

Because you did not describe your product, we are unable to provide an interpretation of the standards that could apply. However, we have the following general observations. Most of the Federal motor vehicle safety standards (FMVSSs) apply to the completed motor vehicle. Some FMVSSs apply to aftermarket equipment, including lamps and reflective devices, seat belt systems, and child restraints. Even if an FMVSS does not directly apply to your aftermarket product, there are several requirements that may affect you.

First, 30122 of the Safety Act (49 U.S.C. Chapter 301) prohibits a manufacturer, distributor, dealer, or motor vehicle repair business from "making inoperative, in whole or in part" any part of a device or element of design installed on or in a motor vehicle in compliance with an applicable safety standard. That is, your device could not be installed by such businesses if they determine that the installation of your invention would adversely affect the vehicles compliance with any safety standard.

With regard to your question about "possible intrusion zone" requirements affecting your product, it is possible that installation of this device could affect compliance with Federal Motor Vehicle Safety Standard (FMVSS) No. 201, Occupant protection in interior impact. This standard establishes performance requirements designed to reduce the risk of injury in the event an occupant strikes the interior of a vehicle during a crash. S5.2 of FMVSS No. 201 specifies that an area of the seat back that is within the "head impact area," as defined in 49 CFR 571.3 (enclosed), is subject to the head impact protection requirements of the standard. In addition, installation of your product could affect the vehicles compliance with the flammability resistance requirements of FMVSS No. 302, Flammability of interior materials (enclosed). That standard establishes flammability resistance requirements for certain vehicle components, including seat backs.

The make inoperative provision does not apply to vehicle owners modifying their own vehicles. However, we recommend that owners not degrade the safety of their vehicles.

Second, please note that motor vehicle accessories are items of "motor vehicle equipment" subject to the notification and remedy (recall) provisions of 49 U.S.C. 30118-30120. If a manufacturer or NHTSA determines that the product contains a safety-related defect, the manufacturer is responsible for notifying purchasers of the product and remedying the problem free of charge.

Third, I am enclosing a copy of a procedural rule that applies to all manufacturers subject to the regulations of this agency. 49 CFR Part 551, Procedural Rules, Subpart D, requires all manufacturers headquartered outside of the United States to designate an agent for service of all process, notices, orders and decisions. This designation should be mailed to the Chief Counsel, National Highway Traffic Safety Administration, 400 Seventh Street, S.W., Washington, D.C. 20590, and must include the following information:

1. A certification that the designation of agent is valid in form and binding on the manufacturer under the laws, corporate-by-laws, or other requirements governing the making of the designation at the time and place where it is made;
2. The full legal name, principal place of business and mailing address of the manufacturer;
3. Marks, trade names, or other designations of origin of any of the manufacturer's products which do not bear its name;
4. A statement that the designation shall remain in effect until withdrawn or replaced by the manufacturer;
5. A declaration of acceptance duly signed by the agent appointed, which may be an individual, a firm or a United States corporation; and,
6. The full legal name and address of the designated agent.

In addition, the designation must be signed by a person with authority to appoint the agent. The signer's name and title should be clearly indicated beneath his or her signature.

If you need further assistance, please contact George Feygin of my staff at this address or at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosures
ref:201
d.2/16/05

ID: aiam0372

Dear Mr. Thoman: This is in reply to your letter of June 15, 1971, concerning the Tir Identification and Record Keeping Regulation (49 CFR Part 574).; As stated in the interpretation published in the *Federal Register* o May 28, 1971, under section 113(f) of the National Traffic and Motor Vehicle Safety Act, 'it is the tire manufacturer who has ultimate responsibility for maintaining the records of first purchasers'.; Under the Act and the Regulation, we have no authority to require tire manufacturer to choose someone as his designee. I have asked Goodyear's counsel for their position with regard to the possible use of tire dealers customer's lists and was forwarded a letter dated June 8, 1971, from the Goodyear Tire and Rubber Company which sets forth the company's policy with regard to the prohibition in the regulation. I enclose the letter for your information.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: nht80-2.37

DATE: 05/13/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Rubber Manufactures Association

TITLE: FMVSR INTERPRETATION

TEXT:

MAY 13, 1980

Mr. Thomas E. Cole Tire Division Rubber Manufacturers Association 1901 Pennsylvania Avenue, N.W. Washington, D.C. 20006

Dear Mr. Cole:

This is in response to your letter of April 14, 1980, regarding two apparent discrepancies in the revised Uniform Tire Quality Grading tread label format, published on November 29, 1979, in Docket 25, Notice 35 (44 FR 58475). As you note, the word "Vehicle" was omitted from the term "Federal Motor Vehicle Safety Standard No. 109" under the heading "Temperature" in Figure 2, Part II, of the regulation as published. This was an inadvertent omission which the National Highway Traffic Safety Administration (NHTSA) plans to correct in a future notice.

You also point out that paragraph (d)(1)(i)(B)(1) of the regulation (49 CFR 575.104(d)(1)(i)(B)(1)), applicable to tires manufactured prior to October 1, 1980, provides for use of the heading "DOT QUALITY GRADES" in capital letters, while Part I of Figure 2 of the regulation contains the heading "DOT Quality Grades" using lower case letters. The label format specified in paragraph (d)(1)(i)(B)(1) parallels the label format originally announced in Docket 25, Notice 24 (43 FR 30542; July 17, 1978), the heading of which used all capital letters. Since Part I of Figure 2 is not required on labels printed in accordance with paragraph (d)(1)(i)(B)(1), the use of lower case letters in the heading of Part I does not affect the requirements of paragraph (d)(1)(i)(B)(1). NHTSA will permit, at the manufacturer's option, the use of all capital letters in the heading of Figure 2, Part I, in printing labels to comply with the new two-part label format.

Sincerely,

Frank Berndt Chief Counsel

April 14, 1980

National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

SUBJECT: 49 CFR Part 575.104

Gentlemen:

Docket 25; Notice 35 was published in the November 29, 1979 Federal Register. The amended labeling requirements permit the use of labels employing the original format, at the manufacturers' option, until October 1, 1980. As the tire manufacturers have prepared their new labels using the format specified in Notice 35, two minor discrepancies have been noticed.

In the explanatory information under Figure 2 for Temperature, the word "vehicle" has been left out of the term "Federal Motor Vehicle standard No. 109." We assume the omission of the word "vehicle" is not intended and will undoubtedly be included in the labels prepared by tire manufacturers.

The second discrepancy noted is concerned with capital versus lower case letters of the term "DOT QUALITY GRADES." In Paragraph (B)(1) it says that the label shall contain information "in the form illustrated in Figure 2, Part II, bearing the heading DOT QUALITY GRADES." Figure 2 shows part of the phrase "DOT QUALITY GRADES" being in lower case letters. Thus, in one place in the regulation, it is required that all letters in this phrase be in capital letters, and in another place it is required that part of letters be in lower case.

Sincerely yours,

Thomas E. Cole Vice President Tire Division

TEC/kk

ID: 125-23956.drn

Herr Reg Auge
Dr. Weber & Co. GmbH
Lüttkoppel 4
22335 Hamburg
Germany





Dear Herr Auge:

This responds to your letter of January 17, 2002, asking for confirmation that Federal Motor Vehicle Safety Standard No. 125, Warning devices (Standard No. 125) applies only to warning devices designed to be carried in buses and trucks over 4536 kg (10,000 pounds) gross vehicle weight rating. As explained below, you are correct in your understanding of the applicability of Standard No. 125.

At S3, Application, Standard No. 125 states:

This standard applies to devices, without self-contained energy sources, that are designed to be carried in buses and trucks that have a gross vehicle weight rating (GVWR) greater than 10,000 pounds. These devices are used to warn approaching traffic of the presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle.

The standard had at one point applied to all warning devices that do not have self-contained energy sources and that are designed to be carried in motor vehicles. S3 was amended in a final rule published in the Federal Register on September 29, 1994 (see 59 FR 49586, copy enclosed). In that final rule, we amended Standard No. 125 to apply only to those warning devices that do not have self-contained energy sources and that are designed to be carried in buses and trucks that have a GVWR greater than 10,000 pounds (or 4536 kg). The amendments made in the final rule took effect on October 31, 1994.

A warning device that meets Standard No. 125 must be permanently marked with "the symbol DOT, or the statement that the warning device complies with all applicable Federal motor vehicle safety standards." (See S5.1.4(c).) If your warning devices do not meet Standard No. 125, they must not be marked with the DOT symbol or the statement about compliance with Federal motor vehicle safety standards.

Please note, however, that even if not covered by Standard No. 125, a warning designed to be carried in motor vehicles 4536 kg and under is an item of "motor vehicle equipment," and is subject to various provisions of 49 U.S.C. Chapter 301, "Motor Vehicle Safety." Manufacturers of motor vehicles and motor vehicle equipment must ensure that their products are free of safety-related defects. If a manufacturer or NHTSA should determine that the product contains a safety-related defect, the manufacturer would be responsible for notifying purchasers of the defective vehicle or item of motor vehicle equipment and remedying the problem free of charge. (This responsibility is borne by the vehicle manufacturer in cases in which your devices are installed on a new vehicle by or with the express authorization of that vehicle manufacturer.)

Some states may regulate warning devices that vehicles with a GVWR of 4536 kg or less may or must use when the vehicle is stopped. Each state in which you sell your product can provide information on whether there are any requirements in that state for warning devices to be used with vehicles with a GVWR of 4536 kg or less.

Finally, before your company can market motor vehicle equipment in the United States, 49 Code of Federal Regulations, Part 551 at Subpart D (copy enclosed) requires that you appoint a permanent resident of the United States as your agent for the service of legal process, notices, orders, decisions, or other applicable requirements. The agent can be an individual, a firm, or an American corporation.

I hope this information is helpful. If you need further assistance, please contact Dorothy Nakama of my staff at this address or at (202) 366-2992.

Sincerely,

John Womack
Acting Chief Counsel

Enclosures
ref:125
d.3/5/02

ID: 23769ogm

Mr. Sebastien Lamothe
Regulations and Standards
Heuliez
Bd Georges Pompidou
79140 CERIZAY (Poitou-Charentes)
France





Dear Mr. Lamothe:

This in response to your recent letter regarding the provisions of Standard No. 201, "Occupant protection in interior impact," as they relate to different convertible top configurations. Specifically, you wish to know if the requirements of Standard No. 201 apply to two different types of convertible roofs. One roof configuration, which your letter describes as a "coupe-convertible," consists of an articulated convertible roof in which rigid roof panels fold into the vehicle's trunk when the roof is down. The second configuration described in your letter is a "convertible" hard top, which you describe as a hard shell top that is intended to replace a folding convertible top during cold weather. Based on your understanding of Standard No. 201's definition of "convertible," and the provisions of S6.3(a) excluding convertible roof frames and linkages from Standard No. 201, you believe that the Standard would not apply either to removable hard top convertible tops or the "coupe convertible" articulated folding top.

For the reasons explained below, the National Highway Traffic Safety Administration (NHTSA) does not agree with your interpretation. It is the agency's position that both convertible hard tops and articulated rigid folding convertible tops similar to the "coupe-convertible" top must meet the requirements of Standard No. 201.

S6.3(a) of Standard No. 201 provides that a vehicle need not meet the requirements of S6.1 through S6.2 for any target located on a convertible roof frame or a convertible roof linkage mechanism. "Convertible roof frame" is defined in S3 as the frame of a convertible roof. "Convertible roof linkage mechanism" is defined in S3 as any anchorage, fastener, or device necessary to deploy a convertible roof frame.

In the case of a convertible hardtop or a rigid articulated folding top similar to the "coupe-convertible" top described in your letter, it is the agency's position that the top, with the exception of those components required to raise and lower the top or to latch it into position, must meet Standard No. 201.

NHTSA addressed the issue of detachable hard tops identical to the "coupe convertible" top you describe when it responded to a Petition for Reconsideration filed by ASC, Inc., which was prompted by the agency's April 8, 1997 final rule (62 FR 16718) establishing the requirements for Standard No. 201. The ASC petition requested that the agency modify the definition of convertible roof frame to include hardtop convertibles - i.e., convertible tops that may be raised or lowered but are constructed of rigid folding sections rather than a cloth skin on a rigid frame. In rejecting that request, the agency noted that there did not appear to be any reason to exempt hardtop convertible roofs from the requirements of Standard No. 201 (see 63 FR 19839, April 22, 1998). As we noted in a June 5, 2001 letter to Mr. Mitsuhide Kikkawa (copy enclosed), NHTSA believes that the considerations applicable to hardtop convertibles also apply to detachable hard tops. Therefore, it is our position that it is both reasonable and practicable to require a vehicle with a detachable hard top to meet the requirements of Standard No. 201.

I hope that this is responsive to your inquiry. If you have any questions or comments, please contact Otto Matheke of this office at (202) 366-5253.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosure
ref:201
d.4/5/02

ID: nht72-3.29

DATE: 03/23/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Universal Oil Products Company

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 3, 1972, in which you asked several questions concerning the effects of Motor Vehicle Safety Standard No. 207 on a type of center console seat manufactured by your company.

Before answering your specific questions about the standard, I want to clear up what seems to be a misconception in your letter about the obligations created by the National Traffic and Motor Vehicle Safety Act. The Act (Illegible Word) us authority to issue safety standards and provides, in Section 108(a), that no person shall

manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce . . . any motor vehicle or item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect. . . unless it is in conformity with such standard.

A dealer or distributor of a vehicle manufactured after the effective date of an applicable standard is thus obligated to maintain the vehicle in conformity with the standard, even though he might be in the "after-market" according to your terminology.

To answer your specific questions:

1. A seat installed on or after January 1, 1972, on a truck manufactured before January 1, 1972, will not have to conform to the standard. A truck manufactured before January 1, 1972, would not have had to conform on the date of its manufacture. Since the standard applies only to the vehicle and not to the equipment separately, the date of the vehicle's manufacture is controlling.

2 and 3. A seat installed on a truck manufactured on or after January 1, 1972, will have to conform to the standard, except that a person who has purchased a truck for his own use and not for resale may have a seat installed after purchase even though the seat does not conform. The standard does not regulate seats as a separate item of equipment and therefore does not expressly prohibit their sale and installation in this fashion.

ID: 18121.ztv

Herr P. Binder
ITT Automotive Europe
Stuttgarter Strasse 119
74321 Bietigheim-Bissingen
Germany

Dear Herr Binder:

This is in reply to your fax of June 4, 1998, to Taylor Vinson of this Office, with respect to the use of light-emitting diodes (LEDs) in a rear lamp that ITT Automotive Europe is developing.

You have asked the factors that must be taken into consideration, the photometric requirements that must be met, "which requirements exist if one LED" fails, and which regulation will be used.

The rear lamp specifications of Federal Motor Vehicle Safety Standard No. 108 Lamps, Reflective Devices and Associated Equipment are based upon incandescent bulb technology where requirements are generally met by using one bulb for each lighted section of the lamp. The specification of 32 candela per lighted section that appear in certain SAE materials incorporated by reference in Standard No. 108 is based upon the highest output of incandescent signal lamp bulbs at the time that the SAE standards were written. When requirements are intended to be met by limited flux light sources such as LEDs, the light output specification cannot be provided by a single light source but must be provided by multiple light sources. However, current interpretations of what is necessary to comply with Standard No. 108 do not contain any differentiation based on type of light source. Thus, if 20 LEDs provide the same illumination as a single filament bulb, a lamp equipped with the former is considered a lamp with three lighted sections for purposes of compliance, not a single-section lamp. To meet the photometric requirements for three-section lamps, manufacturers must use an overly bright and costly array of LEDs.

You have asked what are the requirements if one LED fails. Failure of one light source in a taillamp or a stop lamp with more than one light source is not addressed by Standard No. 108. If a light source fails in a turn signal lamp on a vehicle that is not equipped to tow a trailer, Standard No. 108 requires that the failure be indicated to the driver. We are not aware of any LED turn signals in use, or how manufacturers would design such a unit to comply with this requirement. However, we believe that a failure should be indicated to the driver at the point where an LED turn signal ceases to furnish the minimum photometric performance required by Standard No. 108. In general, the laws of the individual states require all lamps to be fully functional on vehicles in operation but the failure of a single LED is likely to pass unnoticed.

On June 24, 1998, the agency proposed to amend Standard No. 108 to accommodate LED technology (63 FR 34350). Instead of being designed to conform to the photometric requirements based on the number of lighted sections specified in relevant SAE materials, NHTSA has proposed that a lamp equipped with LEDs that needs more than one light source to achieve compliance with the photometric performance required of a single lighted section, shall be designed to conform to photometric requirements based on the dimension of the effective projected luminous lens area for the function being tested. A lamp would be regarded as having one lighted section if the maximum horizontal or vertical linear dimension of the effective projected luminous lens area of the lamp is less than 150 mm, two lighted sections if the dimension is 150-300 mm, and three lighted sections if the dimension is greater than 300 mm.

Comments are due on the proposal not later than August 10, 1998. The proposed effective date is one year after publication of the final rule. I enclose a copy of the proposed rule for your information. We are sending this response by mail, rather than by fax, to ensure that you receive a clear copy.

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosure
d.7/10/98
ref:108

ID: aiam0348

Dear Mr. Lewis: This is in reply to your telephone conversation of May 19, 1971 with member of this office concerning Part 574 - Tire Identification and Record Keeping.; In your conversation you asked what the position of the Nationa Highway Traffic Safety Administration would be if a retreader could establish he was unable to obtain, by May 22, 1971, the effective date of the regulation, the necessary tin plate for placing the required tire identification number on his retreaded tires.; Of course, each case would be considered individually, but if retreader could demonstrate that good faith attempts had been made to obtain the tin plate by May 22, 1971, and due to circumstances beyond his control he was unable to mark tires manufactured after May 22, 1971 with the required identification number, the National Highway Traffic Safety Administration would not take enforcement action against the retreader.; Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: nht80-3.21

DATE: 07/21/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Mercedes-Benz

TITLE: FMVSS INTERPRETATION

TEXT:

Dear Mr. Gerth:

This responds to your recent letter requesting an inter pretation concerning the term "overall width" as used in Safety Standard No. 104, Windshield Wiping and Washing Systems (49 CFR 571.104). You asked whether passenger car door handles would be included in the measurement of a vehicle's overall width.

Safety Standard No. 104 defines "overall width" as the maximum overall body width dimension "W116," as defined in section E, Ground Vehicle Practice, SAE Aerospace-Automotive Drawing Standards, September 1963. The "W116" standard specifies that overall width is measured across the body, excluding hardware and applied moldings, but including fenders when integral with the body. We would consider passenger car door handles to be vehicle "hardware." Therefore, door handles would not be included in the measurement of overall vehicle width.

Sincerely,

Frank Berndt Chief Counsel

June 5, 1980

Attn: Office of Chief Counsel

Subject: Motor Vehicle Safety Standard No. 104 - Windshield Wiping and Washing Systems, Request for Interpretation

Dear Madame or Sir:

Your interpretation i s requested on the definition of "overall width" as used in Motor Vehicle Safety Standard No. 104 -Windshield Wiping and Washing Systems. Section S3 of that Standard defines "overall width" as being the maximum overall body width dimension "W116" as defined in Section E, Ground Vehicle Practice, SAE Aerospace-Automotive Drawing Standards, September 1963. This second Standard contains the statement that "overall width" is measured across body, excluding hardware and applied mouldings, but including fenders when integral width body.

Your interpretation of this definition is requested as to whether or not the term "hardware" would include passenger vehicle door handles. This would exclude door handles from the measurement of the overall width of a vehicle.

Should you require additional infomation on this request, do not hesitate in contacting Mr. G. M. Hespeler of our Safety Engineering Department, (201) 573-2616. As a point of infomation, your response dated March 18, 1980, to a previous request for interpretation regarding body trim mouldings is also attached for your review.

Very truly yours,

HG:Web

ID: 9388r-2

James E. Schlesinger, Esquire
Schlesinger, Arkwright & Garvey
3000 South Eads Street
Arlington, VA 22202

Dear Mr. Schlesinger:

This responds to your letter addressed to Walter Myers of this office in which you posed certain questions relating to the Uniform Tire Quality Grading Standards (UTQGS), 49 CFR 575.104. Reference is also made to our letter to you dated February 23, 1993, in which we addressed certain other of your questions concerning the UTQGS.

In your most recent letter, you set forth a very complicated factual scenario about certain events which occurred during 1990-91, and which involved three companies. At the end of the letter you asked, with respect to each company, whether the company was in violation of one or more provisions of 49 CFR Part 575. You also asked whether, in addition to the penalties for violation of the UTQGS as set forth in 109 of the National Traffic and Motor Vehicle Safety Act, 15 U.S.C. 1381, et seq. (Act or Safety Act), there are "additional sanctions requiring the manufacturer or brand name owner to recall unlawful product or notification procedures intended to identify unlawful product in the marketplace."

The purpose of our interpretation letters is to explain or clarify the meaning of our standards and regulations. Our letters are not intended to be adjudicative in nature. Given that the issues you raise about the three companies concern past conduct, involve complicated factual issues, and ultimately relate to whether a violation of the UTQGS has occurred, we do not believe that it would be appropriate to issue an interpretation letter concerning them.

It would be appropriate, however, to clarify a statement made in our February 23, 1993, letter. The second paragraph from the bottom of page 2 of that letter states:

Although both the Act and the UTQGS are silent as to whether tires can be imported or distributed without the UTQGS information, there would be no point in doing so since the tires cannot legally be sold without that information.

Please note that 102(5) of the Safety Act defines "manufacturer" as including any person importing motor vehicles or motor vehicle equipment. Therefore, an importation of non- complying tires would be considered a manufacture of non- complying tires under the Act. Thus, if a tire is required to be manufactured with certain information molded into or onto the tire sidewall, it may not be imported without such molded information. Any person doing so would be in violation of 108(a) of the Act.

Should you wish this agency to investigate whether there has been a violation of the UTQGS, you may write to Mr. William A. Boehly, this agency's Associate Administrator for Enforcement, at this address, providing all relevant facts in detail. If you wish to discuss enforcement policies with this office, you may contact Kenneth Weinstein, Esq., our Assistant Chief Counsel for Litigation, at this address or at (202) 366-5263.

With respect to your last question, we assume you are referring to Part B of the Safety Act, 15 U.S.C. 1411, et seq., which requires manufacturers of motor vehicles and items of replacement equipment to provide notification of, and a remedy for, safety-related defects and noncompliance with Federal motor vehicle safety standards prescribed pursuant to 103 of the Act. Those provisions do not apply to tires that fail to comply with the UTQGS, since the UTQGS were not "prescribed pursuant to section 103." Rather, they were prescribed as consumer information regulations pursuant to 203 and 112(d) of the Safety Act.

I hope this information is helpful to you.

Sincerely,

John Womack Acting Chief Counsel

ref:575 d:3/21/94