ID: nht79-3.15

DATE: 08/27/79

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. William Lynch

TITLE: FMVSS INTERPRETATION

TEXT: This responds to the questions you raised with Ms. Debra Weiner of my office when you telephoned on June 19 with regard to your intention to establish a business for the manufacture of 53.6 gallon replacement gasoline tanks and for the installation of these tanks in used Cadillac limousines. You specifically asked what Federal law is applicable to your proposed activities and whether any Federal law establishes a maximum allowable capacity for gasoline tanks.

The National Traffic and Motor Vehicle Safety Act of 1966, as amended (the Act) authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal Motor Vehicle Safety Standards (FMVSS's) applicable either to entire vehicles or to equipment for installation in vehicles. FMVSS 301-75, Fuel System Integrity, (see enclosed copy) is a vehicle standard applicable to passenger cars and other vehicles which requires that fuel spillage occurring during and after any crash of the vehicle into a fixed or moving barrier not exceed established limits. As explained below, this standard indirectly affects both the installation and manufacture of replacement gasoline tanks.

Section 108(a)(2)(A) of the Act prohibits certain entities and persons from knowingly removing, disconnecting, or reducing the performance of equipment or elements of design installed on a vehicle in accordance with applicable FMVSS's. Specifically, the section provides:

No manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative, in whole or part, any device or element of design installed on or in a motor vehicle or item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard . . .

A person or entity found to have violated this section would be liable for a civil penalty of up to $ 1,000 for each violation. (Section 109 of the Act).

If a person or entity listed in section 108(a)(2)(A) removes the original gasoline tank from a used vehicle and installs a replacement tank, the section is violated unless the performance (as defined by FMVSS 301-75) of the replacement tank equals or exceeds the performance of the original tank. To determine the relative performance of the replacement tank, a number of issues would have to be examined, including the quality of the replacement tank, the connection of the tank with the filler pipe and fuel lines to the fuel pump, and the location of the tank with respect to surrounding vehicle structures. For example, if unlike the original tank, the replacement tank were sufficiently near surrounding vehicle structures so that those structures might be more readily pushed against or into the replacement tank and cause a rupture in a collision, the performance of the fuel system would have been impermissibly reduced.

Consequently, as a manufacturer of replacement gasoline tanks, you could be liable for a penalty under section 108(a)(2)(A) if you replace the gasoline tank in a used Cadillac limousine with one of your tanks, knowing that the performance of the replacement tank as installed would be inferior to that of the original tank.

Please note that should you decide to install your tanks in new vehicles prior to their first sale for purposes other than resale, you would also be required to certify that the vehicle as altered still complied with all applicable Federal motor vehicle safety standards. Should these provisions become relevant to your business, I would be happy to provide further information.

Sections 151-155 of the Act, which are enclosed, would also apply to your activities as a manufacturer of gasoline tanks. These sections provide that if the agency or you find that your tanks contain a safety-related defect, you would be required to notify purchasers of the hazard and to remedy the defect. Under sections 108(a)(1)(D) and 109(a) of the Act, any person who fails to provide notification of or remedy for a safety defect is liable for a civil penalty of up to $ 1,000 per violation.

I would like to point out that, in addition to the Federal law discussed above, there may be state products liability law applicable to your proposed activities. As a manufacturer of gasoline tanks you could be liable for their design, materials, manufacture or performance. As an installer of gasoline tanks you could be liable for the manner and location in which the tanks are installed. Therefore, you may wish to consult a local lawyer before starting your new business.

Finally, with respect to your inquiry about a maximum allowable capacity for gasoline tanks, neither the National Highway Traffic Safety Administration nor the Department of Transportation as a whole has established such a limit.

I hope that you will find this response helpful.

ID: aiam3240

Dear Mr. Achille: This responds to your letter of March 11, 1980, forwarding to Mr Schwartz of my office the proposed vehicle identification number (VIN) scheme for American Moped Associates, and in confirmation of your subsequent telephone conversation with Mr. Schwartz.; Your VIN scheme complies with the requirements of Federal Motor Vehicl Safety Standard No. 115, with the following exceptions. The fourth through eighth characters of the VIN are required by S4.5.2 and Table I of the Standard to encode certain descriptive characteristics of the vehicle. For motorcycles, which include mopeds, this information is (1) type of motorcycle, (2) line, (3) engine type and (4) net brake horsepower. While the information which American Moped Associates proposed to encode in the fourth through eighth characters will undoubtedly be useful to your company, it is not necessary to advise the agency of your internal coding. Further, While much of the information the Standard required to be decoded from these characters is self-evident because of your product line, it is nonetheless necessary to forward this information to the agency as specified in the Standard.; Based on your discussions with Mr. Schwartz, it appears this mayb easily accomplished utilizing essentially the same format as you currently propose. It is my understanding that you no longer intend to encode the color in the fifth position of the VIN, but rather utilize a single 'filler' character such as 'M'. Further, I understand that all your mopeds utilize the same engine and comprise two lines characterized by the number of speeds. Consequently, based on your product line, your submission to the agency might read:; Characters 1-3 LAM: WMI assigned to American Moped Associates. Character 4 (internal use) Character 5 M: Indicates moped type: gasoline, one cylinder, engin with a displacement of_______, net-brake horsepower measured at the crankshaft of __________.; Character 6 (internal use). Character 7 1 indicates one-speed Indian line. 2 indicates two-spee Indian line.; Character 8 (internal use). Character 9 Check digit. Character 10 Model year. Character 11 T: Indicates Taipei plant of manufacture. Y: Indicate Yuanlin plant of manufacture.; Characters 12-17 Sequential number. Please feel free to contact Mr. Schwartz should you have any furthe question on this matter.; Sincerely, Frank Berndt, Chief Counsel

ID: nht79-1.43

DATE: 01/12/79

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

TO: Mercedes-Benz

TITLE: FMVSS INTERPRETATION

TEXT: This is in response to your letter of November 27, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80, Controls and Displays. Specifically, you asked whether it is permissible to use symbols for the parking lamp functions of the headlamp switch, in addition to the headlamp symbols required in Table I of the Standard.

The answer to your question is yes. Section 5 of the standard states that each passenger car "with any control listed in S5.1 or in column 1 of Table 1, . . . shall meet the requirements of this standard for the location, identification, and illumination of such control or display." Since no symbols or other designations are required under the standard for parking lamps where their control is not combined with that for headlamps or for "lamps-off" positions on controls, it is up to the manufacturer whether to label these additional functions and whether to use words or symbols. Footnote 2 of Table 1 of the standard does provide that a manufacturer must use the single headlamp symbol to designate several functions when clearance, identification, parking and/or side marker lamps are all controlled with the headlamp switch. This footnote was not intended to preclude additional symbols for these other functions, however. In fact, S5.2.1 provides that "additional words or symbols may be used at the manufacturer's discretion for the purpose of clarity."

Regarding your drawings, clearance lamps are listed in paragraph S5.1 and in column 1 of Table 1 of the standard. Therefore, they must be identified by the symbols shown in column 3 of Table 1 or by the words "Clearance Lamps" or "Cl Lps". The "parking right and left" symbol shown on the drawing submitted with your letter would not satisfy the requirements for clearance-lamp designations. However, the symbol labeled "Clearance Lamps" that appears on the drawings which Mr. Gebhard M. Hespeler and Mr. Craig Jones submitted on December 20, 1978, would conform with the requirements. I have enclosed a copy of that drawing.

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

SINCERELY,

November 27, 1978

National Highway Traffic Safety Administration Office of Chief Counsel

Re.: Request for Interpretation - FMVSS 101-80

Dear Madam or Sir:

Federal Motor Vehicle Standard 101-80, Controls and Displays, specifies symbols for identifying certain functions of hand-operated controls, but does not address the parking lamp function of the headlamp switch other than the reference contained in Footnote 2 Table I. We suspect this footnote statement is to simplify requirements for providing symbols on those switches, all of whose functional positions cannot readily be identified, such as push-pull switches. An interpretation is therefore requested as to whether or not it is permissable to use additional symbols for the parking lamp functions in addition to the headlamp symbols required in Table I of this standard. An example of such headlamp switch markings is shown in the attached drawing. This rotary switch has the following corresponding functions:

Full counter-clockwise; parking lamps, left-hand side of vehicle, ignition off.

Next position clockwise; parking lamps, right-hand side of vehicle, ignition off.

Vertical/middle position: all lamps off.

Next position clockwise; parking lamps and side marker lamps left and right, - ignition on or off.

Full clockwise; headlamps, parking and side marker lamps.

We would appreciate receiving your interpretation of this standard at your earliest convenience. Do not hesitate to contact this office should you require further information on the switch described.

HEINZ W. GERTH

Request for Interpretation - FMVSS 101-80

Mercedes-Benz of North America, Inc.

(Graphics omitted)

ID: nht78-1.48

DATE: 12/29/78

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

TO: Ford Motor Co.

TITLE: FMVSS INTERPRETATION

TEXT:

FMVSS INTERPRETATION Dec. 29, 1978

NOA-30

Mr. J. C. Eckhold, Director Automotive Safety Office Ford Motor Company The American Road Dearborn, Michigan 48121

Dear Mr. Eckhold:

This is in response to your letter of August 29, 1978, requesting an interpretation of Federal Motor Vehicle Safety Standard No. 101-80. The answers to your specific questions are as follows:

(1) You requested an interpretation that a single telltale which monitors both the oil pressure and coolant temperature gauges could be identified by the word "Engine." You indicated that it has been Ford's practice to combine the monitoring of these two functions into a single telltale because the response by the driver to either malfunction is the same. The standard does not require that any of the displays listed in S5.1 be provided or that two or more displays, if provided, be provided separately. It is the interpretation of the NHTSA that the multipurpose telltale which monitors the two functions specified above may be identified by the word "Engine."

(2) You asked whether the NHTSA intended that the display identification requirements of FMVSS 208 would be met by use of the symbol required by FMVSS 101-80. The answer is no. However, the agency will issue shortly a notice which will provide for the use of the FMVSS 101-80 symbol for the purposes of that standard and those of FMVSS 208.

(3) You asked that the identification requirements of FMVSS 105-75 be deleted from that standard and those in FMVSS 101-80 be retained. No conflict exists between the two standards. Nevertheless, we will address this issue in the same notice mentioned in the immediately preceding paragraph.

Sincerely,

Joseph J. Boyin, Jr. Chief Counsel

Ms Joan B. Claybrook Administrator National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Ms. Claybrook:

Re: Request for Interpretation of Federal Motor Vehicle Safety Standard No. 101-80

Ford Motor Company requests clarification of three of the provisions in Federal Motor Vehicle Safety Standard (FMVSS) 101-80, Controls and Displays, as amended (Fed. Reg. 27541, et seq., June 26, 1978). The need for such clarification became evident to Ford following a review of the final rule and its implications to future model designs.

1. Engine Coolant Temperature and Oil Pressure

Ford believes that the words in S5.1 of the Standard; ". . . each of the following displays that is furnished . . ." (emphasis added) were incorporated to distinguish between those descrete and distint displays required to use a specific word(s) or symbol and "others", such as a single telltale covering both engine coolant temperature and oil pressure, not covered by the regulation. This conclusion is consistent with Ford's comments in Attachment 1 of its response to Docket No. 1-18; Notice 12 (41 Fed. Reg., 46460 et. seq.) where Ford noted that for several years it has, with satisfactory results, combined the display for adverse conditions of either of these functions with a single telltale labeled with the word *Engine". In our 1978 Fairmont and Zephyr vehicle lines we are using a symbol instead of the word "engine" (see attachment). When the "engine" telltale glows steadily, the advice given in our Owners Manual is the same for either low oil pressure or high coolant temperature: "Pull off the road and stop the engine immediately and determine the cause. If the engine is not stopped immediately, severe damage could result."

We request confirmation of our belief that a telltale, with a single symbol or word, monitoring both the engine coolant temperature and the oil pressure may be used.

2. Seat Belt Warning System

S5.2.3 of FMVSS 101-80 requires the use of the symbol for the seat belt warning telltale shown in Column 4 of Table 2, while the requirement of S4.5.3 and S7.3 of FMVSS 208 is for a warning system displaying the words "Fasten Seat Belts" or "Fasten Belts". Because the preamble to the amended 101-80 Standard states that "It is also proposed to consolidate the control and display requirements of other standards in one regulation. This notice takes final action on that proposal...." Ford believes that the Administration intended that the identification requirements of FMVSS 208 would be met by the symbol required in FMVSS 101-80 -- and use of the words "Fasten Seat Belts" or "Fasten Belts" is optional. Ford, therefore, requests confirmation of its belief and recommends that FMVSS 208 be amended to delete the labeling requirements for seat belt warning indicators in order to remove this inconsistency.

3. Brake warning System

For the same reason noted in 2 above, a clarification of the warning lamp requirements for brake systems in FMVSS 105-75 is requested. FMVSS 105-75, Section 5.3., et seq., requires a warning lamp for brake system failure, brake light proveout and parking brake "ON". In addition, FMVSS 105-75 specifies the manner in which this warning lamp must be displayed, i.e., a red lens and the word "BRAKE". Telltale requirements are also specified in FMVSS 101-80. Ford believes that the identification requirements of the brake system warning lamp should be deleted from FMVSS 105-75 and retained in FMVSS 101-80. This method of requiring the presence of a warning lamp in a system standard and specifying the form of the display in FMVSS 101-80 Would then be consistent with other standards requiring warning lamps.

In reviewing Table 2 of FM7SS 101-80, we have identified certain minor anomalies. Column 3 of Table 2 incorrectly references FMVSS 105 instead of FMVSS 121 for brake air pressure. In addition, Brake System only references FMVSS 121 in Column 3 but should also include FMVSS 105-75.

Finally, to be consistent with other reference ????????? standards, we suggest a reference to FMVSS 127 to be ???????? the speedometer and odometer displ ???????? Very truly yours,

J. C. Eckhold Director Automotive

**INSERT ATTACHMENT** FORD SYMBOL USED ON A SINGLE TELL-TALE FOR ENGINE OIL PRESSURE AND COOLANT TEMPERATURE

ID: nht73-2.42

DATE: 02/09/73

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

TO: Alfred Teves GMBH

COPYEE: PAUL UTANS; VINSON; LIMPERT; DRIVER

TITLE: FMVSS INTERPRETATION

TEXT: Mr. Paul Utans has asked us to provide you with an interpretation of paragraph S5.3.3 of Motor Vehicle Safety Standard No. 105a, Hydraulic Brake Systems, Mr. Utans asks for confirmation of his understanding

"that the indicator lamp shall remain activated ther without the application of any pedal force or with one application of a pedal force (with a range of 25 or 50 pounds, as the case may be) if a failure of the kind described in S5.3.1(a) to S5.3.1(c) exists in the service brake system."

This interpretation is only partially correct. Paragraph S5.3.3 states in pertinent part:

". . . each indicator lamp, once activated, shall remain activated as long as the condition exists, whenever the ignition switch is in the 'on' position. An indicator lamp activated when the ignition switch is truned to the 'start' position shall be deactivated upon return of the switch to the 'on' . . . position . . . unless a failure of the kind described in S5.3.1(a) to S5.3.1(c) exists in the service brake system."

Paragraph S5.3.1(a) allows a brake pressure failure to be initially indicated either before or upon application of pedal force, but thereafter the light must remain activated while the ignition switch is in the "on" position. However, if the failure is present when the vehicle is first started, the indicator lamp must immediately be activated before any application of Pedal force, until the failure condition no longer exists.

This interpretation is subject to modification by response to petitions or reconsideration of Standard No. 105a, scheduled for publication around May 1, 1973.

ID: aiam0932

Dear Mr. Henrick: This is in reply to your letter of November 8, 1972, inquiring whethe new casings, to which tread is later added, are considered to be 'tires' under the National Traffic and Motor Vehicle Safety Act. The NHTSA has taken the position that such casings are not tires until after the tread has been added, and the casings are not required to be certified as conforming to applicable standard until that occurs. Consequently, such casings may be imported without prior certification.; You also ask how best to inform Customs of our position, to avoi possible importation problems. We suggest you write to Mr. P.K. McCarthy, Chief, Restrictive Merchandise Branch, U.S. Bureau of Customs, Room 704c, 1145 19th Street, N.W., Washington, D.C. 20226, advising him of our opinion, and ask him to acknowledge this interpretation. You might also take steps to ensure that this information is relayed to the local customs officials at those ports of entry where the casings will be imported. If you need further assistance in this matter, please let me know.; Sincerely, Lawrence R. Schneider, Chief Counsel

ID: 12566-3.pja

Mr. John Breiland
Project Engineer
PIVCO AS
Stanseveien 4
N-0975 Oslo, Norway

Dear Mr. Breiland:

This responds to your letter of September 27, 1996, asking several questions about how the Federal Motor Vehicle Safety Standards, especially Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect, would apply to the electric vehicle (EV) you produce. The vehicle has only one forward gear and a regenerative braking system, and weighs less than 4,536 kg. Our response follows your letter's organization in which you group questions into four categories: regeneration, symbols and displays, reverse, and transmission shift lever sequence.

Regeneration

You first ask whether regeneration would "violate[s] any regulations." Regeneration, or use of the engine as a generator to slow the vehicle and recharge the battery, does not violate any National Highway Traffic Safety Administration (NHTSA) regulation, and Standard No. 102 does not require the regeneration system you described. The vehicle you described has only one forward speed, so the requirement for transmission braking effect in S3.1.2 of Standard No. 102 does not apply. As we indicated in our May 3, 1996 interpretation letter to you, the applicability of this requirement is restricted by the prefatory phrase "[i]n vehicles having more than one forward transmission gear ratio . . . ."

NHTSA does not have any recommendations on how regeneration should be performed or on the need for a switch to disable regeneration. Whether to equip a vehicle with these characteristics is at the manufacturer's option. However, as you are aware, NHTSA has proposed to include the regenerative braking effect in the performance of the service brakes under Standard No. 135, Passenger Car Brake Systems, only if the regenerative braking effect is actuated by the service brakes

(60 FR 49544, copy enclosed). We would consider a vehicle equipped with a disabling switch as not having the regenerative system actuated by the service brakes, since regeneration could be disabled. Therefore, if the final rule is issued as proposed, you would not be able to use regeneration in your braking performance tests.

Symbols and Displays

You also raised several questions about Standard No. 101, Controls and Displays. There is no standardization of controls, displays, and symbols unique to EVs, and no special telltales that are required for EVs. Provision of a power or current gauge is at your option. NHTSA does not regulate use of the additional EV-related telltales mentioned in your letter, and you may provide them at your option, so long as they do not result in confusion with the required telltales. A complete response to your question "how should we proceed to ensure that illumination of telltales fulfills Standard No. 101" would merely be a recitation of S5.3.4 (not S5.3.3, as cited in your letter) that specifies requirements for illumination of telltales.

Reverse

NHTSA has no recommended maximum reverse speed. However, most vehicle reverse speeds are the lowest of any gear. This is appropriate, because visibility is limited by the necessity to turn around, and drivers are less accustomed to steering in reverse. Therefore, an unreasonable increase in reverse gear speed could result in a safety problem. There are no requirements for driver "warning" signals when the shift lever is in reverse, other than the requirement in S3.1.4 of Standard No. 102 to display the shift lever position.

Transmission Shift Lever Sequence

You stated that you were unsure of which regulations exist concerning the relationship between the ignition key, shift lever sequence, and the "park lock device" on EVs. There are no special requirements in these areas that pertain only to EVs. The regulations concerning the relationship of the "park lock device" to the shift position in automatic transmission vehicles are in S4.2.1(a) of Standard No. 114, Theft Protection. Basically, they require that the key cannot be removed unless the vehicle is in the park position, and that the vehicle prevent mobility when the vehicle is in park. There is no regulatory problem with your ignition key positions (Off, Radio, On, Start). You proposed three transmission shift lever sequences and asked us to tell you if any of the proposals comply with our regulations. Note that the first sentence of S3.1.1 of Standard No. 102 requires "[a] neutral position shall be located between forward drive and reverse drive positions." Therefore your proposal A (P-R-N-D) complies with this requirement, while proposal B (P-R-D) and proposal C (R-D) do not comply. Note, however, that S4.3 prohibits the park-lock device from taking effect when the vehicle is in motion, as your description of proposal A seems to suggest.

Regarding your uncertainty on which office to send your inquiries to, it depends on the type of question you have. You should send all requests for interpretation of our standards to this office. Requests for standards or other technical information should be directed to the Office of Safety Performance Standards (that office's designation has been changed from NRM, as mentioned in your letter, to NPS). We advise against directing the letter to any particular person within the office, given reorganizations and personnel changes.

If you have any further questions, please feel free to contact Paul Atelsek of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

John Womack

Acting Chief Counsel

Enclosure

ref:102#101#135#114

d.12/17/96

ID: nht87-2.26

TYPE: INTERPRETATION-NHTSA

DATE: JUNE 29, 1987

FROM: MARTIN V. CHAUVIN -- CHIEF CARRIER SAFETY BUREAU, STATE OF NEW YORK

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

TITLE: NONE

ATTACHMT: MEMO DATED 2-11-88, FROM ERIKA Z. JONES - NHTSA, TO MARTIN CHAUVIN

TEXT: The New York State Department of Transportation is reviewing a proposal to add a requirement for the driver's seat on school buses.

The proposal being reviewed recommends that all driver's seats on school buses be equipped with a pelvic and upper torso restraint or what is referred to as a "Type 2 Seat Belt Assembly." One of the school bus manufacturing companies has indicated that t he upper torso restraint or shoulder harness cannot be provided as it would violate the requirements for head impact protection as contained in the Federal Motor Vehicle Safety Standards. As part of our overall review, we ask that this statement be addr essed by your agency.

In reports issued by organizations such as the National Transportation Safety Board, it is indicated that the Type 2 Seat Belt Assembly is far superior to the Type 1 Seat Belt Assembly in passenger car use. It is reasonable to make the assumption that t his superiority would apply equally well to school bus driver seats as well. In considering the vital role the school bus driver is expected to play in the event of an accident, it is extremely important that we provide the best protection available.

We are currently in the process of developing the legislative proposals to amend our laws and would greatly appreciate a timely response to this request. If there is any need to further discuss this request, the undersigned can be reached at (518) 457-1 010.

Thank you.

ID: aiam0002

Dear Ms. Moffitt: This responds to your letter to this office in whic you stated that your son, a 9th grade student, rides a 65-passenger school bus in which he must sit on the edge of the seat such that only half his body is on the seat. We recently addressed this issue in an October 26, 1994, letter to Ms. Debra Platt of Stuart, Florida, and have enclosed a copy of our response for your information. We have also enclosed a copy of Highway Safety Program Guideline No. 17, Pupil Transportation Safety, a copy of a report prepared by this agency entitled School Bus Safety Report, and a copy of a Report Summary prepared by the Transportation Research Board in May, 1989. The latter two reports give a good overview of the issues connected with school bus safety, and they and Guideline 17 contain recommendations to the various states in developing their own pupil transportation safety programs. I hope the enclosed information is helpful to you. Should you have any other questions or need additional information, please feel free to contact Walter Myers of my staff at this address or at (202) 366-2992. Sincerely, Philip R. Recht Chief Counsel Enclosures;

ID: aiam0152

Dear Mr. Mizuno:#Thank you for your letter of March 7, 1969, to Dr William Haddon, Jr., concerning the location and the identification of the windshield washer switch on the steering column.#The system as you describe it appears to conform to Federal Motor Vehicle Safety Standard No. 101, however, the Bureau does not issue approvals of any specific system, and the development of equipment to comply with the standard is the responsibility of the individual manufacturer.#In reference to your second question about the identification of the windshield washer switch, Paragraph S3.2 reads, in part, '.... The following controls, when mounted on the instrument panel, shall be identified to permit recognition -- >>>... (c) Windshield Washing System, ....'<<<#This section of the regulation does not apply to the identification of controls in any position other than on the instrument panel.#Sincerely, Charles A. Baker, Office of Standards on Accident Avoidance, Motor Vehicle Safety Performance Service;