ID: 10177

Mr. Paul Frink
Engineering Manager
Avionic Structures, Inc.
1429 North State College Boulevard
Anaheim, CA 92806

Dear Mr. Frink:

This responds to your letter and telephone call asking several questions about Federal Motor Vehicle Safety Standard (FMVSS) No. 206, Door Locks and Door Retention Components (49 CFR 571.206).

Your letter stated that your company manufactures a door and frame system designed for installation on a "recreational motor home," which you described as a self-propelled, self-contained recreational vehicle seating six and with a gross vehicle weight rating of under 10,000 pounds. The door system is installed on the right front side of the vehicle and is the primary means of ingress/egress. You stated that the door's latch/striker assembly is purchased from Tri-Mark Corporation, and that Tri-Mark assures you that the latch/striker assembly conforms to the requirements of FMVSS No. 206. You ask what the classification of the vehicle would be and whether FMVSS No. 206 would apply to the door in question.

By way of background information, 49 U.S.C. 30101, et seq. authorizes the National Highway Traffic Safety Administration (NHTSA) to issue Federal motor vehicle safety standards applicable to new motor vehicles and new items of motor vehicle equipment. The statute establishes a self-certification system in which manufacturers certify that their products comply with all applicable FMVSSs. This agency ensures compliance by purchasing vehicles and/or equipment in the retail market and testing them as set forth in the applicable standards. If the vehicle or equipment is found to meet the requirements of the standards, no further action is taken. If the vehicle or equipment fails to meet the standards, the manufacturer is responsible for correcting the noncompliance(s) at no cost to the purchaser. NHTSA also investigates defects relating to motor vehicle safety. If a manufacturer or NHTSA determines that a safety-related defect exists, the manufacturer must notify purchasers of its product and remedy the defect free of charge.

For the purposes of the FMVSSs, NHTSA classifies motor vehicles as passenger cars, multipurpose passenger vehicles (MPVs), trucks, buses, motorcycles, and trailers. From your description, the vehicle concerned would be classified as an MPV, which is defined in the definitions section of our FMVSSs (49 CFR 571.3; see enclosed) as a motor vehicle "designed to carry 10 persons or less which is constructed either on a truck chassis or with special features for occasional off- road operation."

You first ask about the classification of the vehicle and whether FMVSS No. 206 would apply. FMVSS No. 206 (copy enclosed) applies to passenger cars, MPVs and trucks. Since the vehicle on which your door and frame system will be installed is an MPV, the standard would apply to the vehicle. The standard requires that, with certain exceptions not applicable here, components on any side door leading directly into a compartment containing one or more seating accommodations must comply with the requirements of the standard (see S4 of FMVSS No. 206). The door in question meets this description of S4. According to your letter, there is a step area extending from the door opening into the coach and the passenger seat closest to the door is behind this step area. The presence of the step area does not negate the fact that the door in question leads directly into a compartment that contains passenger seating accommodations. Thus, the components of the door must comply with the requirements of FMVSS 206.

To clarify your understanding of the applicability of FMVSS No. 206, the standard applies to new completed vehicles. Therefore, it would be the vehicle manufacturer who would "certify" compliance with the standard, not the various manufacturers of the components of the door lock system. Sometimes the vehicle manufacturer will rely on the assurances of the suppliers, such as Avionic and Tri-Mark, that the components conform to the requirements of the applicable standards, in making the certification to FMVSS No. 206. However, the vehicle manufacturer is ultimately responsible for ensuring that the vehicle complies with FMVSS No. 206, and therefore must determine whether those assurances are bona fide.

Also enclosed for your information are fact sheets issued by this agency entitled "Information for New Manufacturers of

Motor Vehicles and Motor Vehicle Equipment" and "Where to Obtain NHTSA's Safety Standards and Regulations," respectively. I hope this information is helpful to you. Should you need any additional information or have any further questions, please feel free to contact Mr. Myers of my staff at this address or at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

Enclosures

ref:206 d:9/2/94 Please note that the "National Traffic and Motor Vehicle Safety Act" and the "Motor Vehicle Information and Cost Savings Act" to which the information sheet refers have recently been recodified in Title 49 of the United States Code. This means that the citations used in the information sheet are outdated; however, the substantive requirements described in the sheet have not changed.

ID: nht93-1.29

DATE: 02/09/93

FROM: JOHN WOMACK -- ACTING CHIEF COUNSEL, NHTSA

TO: DONALD RAY MCCRAY -- 620694, DARRINGTON UNIT

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11-16-92 FROM DONALD RAY MCCRAY TO ANDREW CARD

TEXT: This responds to your letter of November 16, 1992 to former Secretary Card. Your letter has been referred to my office for reply, because the National Highway Traffic Safety Administration (NHTSA) administers Federal regulations for motor vehicle safety.

Your letter expresses concern about the buses that the Texas Department of Criminal Justice (DCJ) uses to transport inmates. You believe the buses are unsafe and operated in violation of Federal law. As explained below, it appears the DCJ did not violate any NHTSA regulation.

The National Traffic and Motor Vehicle Safety Act (15 U.S.C. @1381 et seq., the Safety Act) authorizes this agency to issue Federal motor vehicle safety standards (FMVSS's) that apply to the manufacture and sale of new motor vehicles and new items of motor vehicle equipment. Under the Safety Act, each person selling a new bus must ensure that the bus complies with the FMVSS's for buses. NHTSA's requirements for vehicle seats are set forth in FMVSS No. 207, Seating Systems. However, that standard does not require seat covers or pads for any bus seat. Also, there is no FMVSS that requires buses to be heated.

NHTSA does not regulate the use of motor vehicles, such as the speed at which the DCJ must operate the bus. Individual states, not the Federal government, have authority over the use of vehicles. Texas state officials would be best able to answer your concerns about the manner in which you were transported.

I hope you find this information helpful. If you have any other questions, please contact us.

ID: 002523Lear_marking_flaps

Mr. Scott Willard
Seating Systems Division
Lear Corporation
21557 Telegraph Road
Southfield, MI 48034

Dear Mr. Willard:

This responds to your letter concerning the lower anchorage marking requirements in S9.5(b) of Federal Motor Vehicle Safety Standard (FMVSS) No. 225, "Child Restraint Anchorage Systems" (49 CFR 571.225).

FMVSS No. 225 requires vehicle manufacturers to install child restraint anchorage systems in vehicles, consisting of two lower bars and a tether anchorage. The standard contains "marking and conspicuity" requirements for the lower bars to increase the likelihood that consumers will know that a child restraint anchorage system is present in their vehicle and that they will use it. The standard requires manufacturers to mark the vehicle seat back with a small circle where the bars are located (S9.5(a)), or to install a child restraint anchorage system such that the bars are visible (S9.5(b)). S9.5(b) includes a provision that: "The bars may be covered by a removable cap or cover, provided that the cap or cover is permanently marked with words, symbols or pictograms whose meaning is explained [in] the owners manual."

You ask whether S9.5(b) permits the bars to be covered by "a small fabric flap"; that is, whether such a flap could constitute a permissible "removable cover" over the lower anchorage bar. You state that, to use the lower anchorages, "the flap(s) would need to be folded out of the way, thus exposing the lower anchorages (otherwise visible per section 9.5(b))." You also state that the flaps would be permanently attached to the vehicle seat. They would be marked with words, symbols or pictograms, as required by S9.5(b), the meaning of which would be explained in writing in the vehicle owners manual.

Our answer is the marked fabric flaps you describe would be permitted by S9.5(b) of FMVSS No. 225. We also note that the standard does not require the marked covers for otherwise visible lower anchorages to be permanently attached to the vehicle.

In an April 19, 2004, telephone conversation with Ms. Deirdre Fujita of my staff, you asked whether a strap or other means must be provided with the flaps to hold them out of the way of the anchorage bars when a consumer wants to use the bars to attach a child restraint. The answer is there is no requirement in the standard that a means must be provided to hold the covers out of the way of the bars.

I hope this information is helpful. Please contact us if you have further questions.

Sincerely,

Jacqueline Glassman
Chief Counsel

ref:225
d.5/4/04

ID: 2665o

The Honorable Charles Wilson
House of Representatives
Washington, D.C. 20515

Dear Mr. Wilson:

This is in response to your letter of December 9, 1987, to Ms. Brenda Brown, Office of Congressional Affairs, Department of Transportation, which has been forwarded to this Office for reply. Unfortunately, the Department has no record of receiving your previous letter of August 19, 1987.

You have written on behalf of your constituent Mr. W. P. Brandon of Palestine who has designed a "Wide Right Turn" signal for installation on the rear of trailers. The device consists of the words "Wide Right Turn" and an arrow, in black on a "caution yellow" background. The device is attached to the lower right rear of a trailer, and flashes when the turn indicator is positioned for a right turn. Mr. Brandon asks three questions with respect to his device, which I shall answer shortly.

Preliminarily let me note that the applicable Federal law and regulation are, respectively, the National Traffic and Motor Vehicle Safety Act of l966, and Federal Motor Vehicle Safety Standard No. l08 Lamps, Reflective Devices, and Associated Equipment. Standard No. l08 permits a supplementary lighting device such as Mr. Brandon's as original trailer equipment if it does not impair the effectiveness of the lighting equipment that Standard No. 108 requires, such as the standard turn signal system. The Vehicle Safety Act permits it as aftermarket trailer equipment if its installation by a person other than the trailer owner does not render inoperative, wholly or in part, equipment installed on the trailer pursuant to Standard No. l08 or any other safety standard.

With these general remarks in mind, we reach the three questions that Mr. Brandon asked.

"l. Is there any rule regarding the placement of a flashing 'Wide Right Turn' signal on the lower right rear of a trailer?"

The answer is no, as long as there is no impairment of the effectiveness of the other rear lamps (i.e., the standard turn signal must continue to operate when the lever is in the position indicating a right turn, but the wide turn signal should not operate when the hazard warning signals (which operate through the turn signal lamps) are on). "2. Can the signal be black letters on a safety yellow background or should it be another color"?

The agency does not prescribe the color of supplementary lighting devices, and color is subject only to the "impairment" restriction. Required lighting equipment on the rear of trailers may be white (back up lamps), amber (turn signals), or red (the alternative color for turn signals, and the required color for taillamps and stop lamps). I am unsure what "safety yellow" is, but it would not appear to impair the effectiveness of the red, amber, or white lamps on the trailer's rear.

"3. Are there any restrictions on manufacturing of the signal insofar as materials or construction are concerned?"

There are no Federal restrictions or requirements. However, supplementary lighting devices such as Mr. Brandon's are subject to regulation in all their aspects by the States in which they will be sold and used. We are not conversant with State regulations on this subject, and suggest that, for further advice, Mr. Brandon contact the American Association of Motor Vehicle Administrators, 120l Connecticut Ave., N.W., Washington, D.C. 20036.

We appreciate Mr. Brandon's interest in safety, and your writing us with respect to his "Wide Turn Signal" device.

Sincerely,

Erika Z. Jones Chief Counsel

ref:l08 d:2/19/88

ID: aiam0627

Dear Mr. Barlow: This is in reply to your letter of February 10, 1972, regardin interpretation of certain parts of Federal Motor Vehicle Safety Standard No. 209, Seat Belt Assemblies.; In regard to your question on performance of retractors, the standar specifies that an emergency- locking retractor or a non-locking retractor attached to upper torso restraint shall be subjected to 45,000 additional cycles of webbing withdrawal and retraction between 50 and 100 percent extension.' This requirement applies to all emergency-locking retractors whether attached to the pelvic or upper torso restraint and only to those non-locking retractors that are attached to the upper torso restraint.; In regard to the 45,000 additional cycles, one cycle consists o extending the webbing from 50 to 100 percent extension and return to 50 percent.; Please do not hesitate to contact us if we can be of furthe assistance.; Sincerely, Robert L. Carter, Acting Associate Administrator, Moto Vehicle Programs;

ID: 20479.ztv

Mr. Wayne J. Highley
1701 Pontiac Road
Fairview Heights, IL 62208-1432

Dear Mr. Highley:

This is in reply to your letter of July 30, 1999, to Taylor Vinson of this Office asking several questions about motor vehicle lighting.

You are "inquiring into the legitimacy of testing a supplemental rear lighting system which would be in addition to and placed to the sides or proximity of the third brake light." This system consists of amber lights that are energized when the accelerator pedal is released "and would be non-operational and over-ridden by red lights when the brakes are applied."

The possibility of advance brake warning systems is one that has intrigued the public and which has concerned us for many years. In response to these concerns, we published a policy statement of November 4, 1998, setting forth our position on evaluation of new signaling ideas (63 FR 59482-92). I enclose a copy for your information. The discussion on p. 59489 explains the process that we follow.

We first ask whether a new signal lighting idea requires a change in the standardized operation of appearance of a required lamp or piece of lighting equipment required by Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment. The answer in your case is no; you would provide a supplementary lighting system. Because S5.1.3 of Standard No. 108 allows auxiliary lighting equipment provided there is no impairment of the effectiveness of lamps and reflectors required by the standard, our next question is whether your system would have an impairing effect, e.g., by masking the operation of required lighting or introducing ambiguity into the meaning of required lighting. Because the lamps in your system operate only when the accelerator is released and are extinguished when the brake pedal is applied, there would be no impairing effect. This means that installation and use of your system, as you have described it, would not violate a Federal regulation.

You have asked whether we are aware of any current or pending fleet studies that would utilize the system you describe. We know of no such studies.

You have also asked whether you might begin such a study, and what criteria would we suggest to insure the validity and integrity of such a fleet study. You may begin such a study, but the opinions of this office are legal in nature and we are not in a position to advise you as to how to conduct the study. We suggest that you review our policy statement for some guidance.

Finally, you have asked whether there is any funding available for such an item or such a study. There is no funding available; the agency funds only its own research lighting projects.

If you have further questions, you may call Taylor Vinson (202-366-5263).

Sincerely,
Frank Seales, Jr.
Chief Counsel
Enclosures
ref:108
d.11/5/99

ID: nht94-8.45

DATE: January 24, 1994

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Jerome Cysewski

TITLE: None

ATTACHMT: Attached to letter dated 10/20/93 from Jerome Cysewski to NHTSA Office of Chief Counsel (OCC-9250)

TEXT:

This responds to your letter asking about the applicability of Federal requirements to two vehicles. I apologize for the delay in our response. According to your letter, one vehicle is a 13,600 pound cement silo that has tandem axles. The second vehicle is a 6,400 pound aggregate batch plant that has a single axle. The cement silo and batch plant are mounted on their own trailers, and are equipped with electric brakes. Each vehicle is pulled by a one ton truck with hydraulic brakes. You also stated that both vehicles are mobile but are designed to be towed for off-the-road set and positioning. I am pleased to have this opportunity to explain our regulations to you.

By way of background information, this agency, the National Highway Traffic Safety Administration (NHTSA), issues Federal motor vehicle safety standards under the National Traffic and Motor Vehicle Safety Act (Safety Act). The Safety Act defines the term "motor vehicle" as follows:

"any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails." (Section 102(3))

If a vehicle is a motor vehicle under the definition, then the vehicle must comply with all applicable Federal motor vehicle safety standards. However, if a vehicle is not a motor vehicle under this definition, then the vehicle need not comply with the agency's safety standards because such a vehicle is outside the agency's scope of authority.

Whether NHTSA considers a construction vehicle, or similar equipment, to be a motor vehicle depends on the use for which it is manufactured. It is the agency's position that this statutory definition does not encompass mobile construction equipment, such as cranes and scrapers, which use the highway only to move between job sites and which typically spend extended periods of time at a single job site. In such cases, the on-highway use of the vehicle is merely incidental and is not the primary purpose for which the vehicle was manufactured. In instances where vehicles, such as dump trucks, frequently use the highway going to and from job sites, and stay at a job site for only a limited time, such vehicles are considered motor vehicles for purposes of the Safety Act, since the on-highway use is more than "incidental."

Your letter does not provide sufficient information for us to determine the extent to which the two vehicles would use the public roads. Nor can we determine whether the on-highway use of the vehicles would be merely incidental and not the primary purpose for which they are manufactured.

However, you should be able to determine whether the vehicles are considered motor vehicles based on the information set forth above.

If the vehicles are considered motor vehicles under the Safety Act, they would be required to meet all safety standards applicable to trailers. Enclosed is an information sheet which identifies Federal statutes and NHTSA standards and regulations affecting motor vehicle and motor vehicle equipment manufacturers.

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.

ID: 3276yy

Edward F. Conway, Jr., Esq.
Assistant General Counsel
Recreation Vehicle Industry Association
P.O. Box 2999
1896 Preston White Drive
Reston, VA 22090

Dear Mr. Conway:

I have been asked to respond to your letter to Administrator Curry, in which you asked about the application of Federal Motor Vehicle Safety Standard No. 216, Roof Crush Resistance, to van conversions and motor homes with raised roofs. In your letter, you suggested that the currently specified roof crush resistance test procedure is inappropriate for such vehicles because of their unique physical characteristics. Additionally, referring to the greater floor to roof height of a van conversion or motor home as compared to a typical passenger car, you questioned whether the five inch roof displacement pass/fail criteria are appropriate for these vehicles. I am pleased to have the opportunity to address these issues.

As you know, on April 17, 1991, NHTSA published a final rule extending the application of Standard No. 216 to multipurpose passenger vehicles (MPVs), trucks and buses with a GVWR of 6,000 pounds or less, manufactured on or after September 1, 1993 (56 FR 15510). That rule requires that the roof of any such vehicles be moved not more than five inches when a force of one and a half times the vehicle's unloaded weight is applied to either side of the forward edge of the vehicle's roof. This is the same test procedure specified for passenger cars, with one exception. For passenger cars, the standard specifies applying a force of one and a half times the vehicle's unloaded weight or 5,000 pounds, whichever is less. As indicated above, the alternative 5,000 pound crush force limit that applies for passenger cars was not adopted for light trucks, buses, and MPVs.

During the rulemaking process that led to this extension of Standard No. 216, NHTSA received comments requesting that the agency consider modifying the roof crush resistance test procedure to accommodate the particular physical characteristics of some motor homes, vans and van conversions, including those with raised roofs. More specifically, some commenters including RVIA suggested that the specified test procedures could not be used to position the test device on some vehicles with raised roofs. Other commenters, especially Ford, questioned the need for a five-inch roof crush limitation for vehicles with full standing headroom and suggested that NHTSA consider relating the maximum roof crush requirement to the available occupant headroom.

After carefully evaluating these comments, NHTSA concluded that, based upon the available information, the roof crush resistance test procedure was practicable, met the need for motor vehicle safety, and was appropriate for MPVs, trucks, and buses, if those vehicles had a GVWR of 6,000 pounds or less. The issues identified by the commenters were significant primarily for such vehicles with a GVWR of more than 6,000 pounds. NHTSA acknowledged that it was possible that there could be some light trucks with a GVWR of 6,000 pounds or less that would experience the same problems with the specified roof crush resistance test procedure as larger vehicles would. However, the agency had no information showing that those difficulties would actually be experienced by particular light trucks with a GVWR of 6,000 pounds or less. See 56 FR 15514; April 17, 1991.

In your letter, you raised the same issues that had previously been raised in these comments; that is, you suggested that the test device could not be positioned properly on vehicles with a raised roof and that the five inch crush displacement limit was inappropriate for vehicles with a raised roof. As was the case with those comments, your letter did not provide any specific information identifying particular vehicles with a GVWR of 6,000 pounds or less whose physical characteristics would cause it to experience some particular compliance difficulties or testing difficulties.

If you have some information showing compliance or testing difficulties for actual light truck models with a GVWR of 6,000 pounds or less, we would appreciate it if you would forward that information to the agency. At this time, NHTSA is not aware of any compliance or testing difficulties for light trucks subject to the extended requirements of Standard No. 216. Absent such information, NHTSA has no basis for changing its previous conclusion about the specified test procedures and requirements.

Sincerely,

Paul Jackson Rice Chief Counsel

/ref:216 d:1/17/92

ID: nht92-9.47

DATE: January 17, 1992

FROM: Paul Jackson Rice -- Chief Counsel, NHTSA

TO: Edward F. Conway, Jr., Esq. -- Assistant General Counsel, Recreation Vehicle Industry Association

TITLE: None

ATTACHMT: Attached to letter dated 11/14/91 from Edward F. Conway, Jr., Esq. to Jerry R. Curry

TEXT:

I have been asked to respond to your letter to Administrator Curry, in which you asked about the application of Federal Motor Vehicle Safety Standard No. 216, Roof Crush Resistance, to van conversions and motor homes with raised roofs. In your letter, you suggested that the currently specified roof crush resistance test procedure is inappropriate for such vehicles because of their unique physical characteristics. Additionally, referring to the greater floor to roof height of a van conversion or motor home as compared to a typical passenger car, you questioned whether the five inch roof displacement pass/fail criteria are appropriate for these vehicles. I am pleased to have the opportunity to address these issues.

As you know, on April 17, 1991, NHTSA published a final rule extending the application of Standard No. 216 to multipurpose passenger vehicles (MPVs), trucks and buses with a GVWR of 6,000 pounds or less, manufactured on or after September 1, 1993 (56 FR 15510). That rule requires that the roof of any such vehicles be moved not more than five inches when a force of one and a half times the vehicle's unloaded weight is applied to either side of the forward edge of the vehicle's roof. This is the same test procedure specified for passenger cars, with one exception. For passenger cars, the standard specifies applying a force of one and a half times the vehicle's unloaded weight or 5,000 pounds, whichever is less. As indicated above, the alternative 5,000 pound crush force limit that applies for passenger cars was not adopted for light trucks, buses, and MPVS.

During the rulemaking process that led to this extension of Standard No. 216, NHTSA received comments requesting that the agency consider modifying the roof crush resistance test procedure to accommodate the particular physical characteristics of some motor homes, vans and van conversions, including those with raised roofs. More specifically, some commenters including RVIA suggested that the specified test procedures could not be used to position the test device on some vehicles with raised roofs. Other commenters, especially Ford, questioned the need for a five-inch roof crush limitation for vehicles with full standing headroom and suggested that NHTSA consider relating the maximum roof crush requirement to the available occupant headroom.

After carefully evaluating these comments, NHTSA concluded that, based upon the available information, the roof crush resistance test procedure was practicable, met the need for motor vehicle safety, and was appropriate for MPVs, trucks, and buses, if those vehicles had a GVWR of 6,000 pounds or less. The issues identified by the commenters were

significant primarily for such vehicles with a GVWR of more than 6,000 pounds. NHTSA acknowledged that it was possible that there could be some light trucks with a GVWR of 6,000 pounds or less that would experience the same problems with the specified roof crush resistance test procedure as larger vehicles would. However, the agency had no information showing that those difficulties would actually be experienced by particular light trucks with a GVWR of 6,000 pounds or less. See 56 FR 15514; April 17, 1991.

In your letter, you raised the same issues that had previously been raised in these comments; that is, you suggested that the test device could not be positioned properly on vehicles with a raised roof and that the five inch crush displacement limit was inappropriate for vehicles with a raised roof. As was the case with those comments, your letter did not provide any specific information identifying particular vehicles with a GVWR of 6,000 pounds or less whose physical characteristics would cause it to experience some particular compliance difficulties or testing difficulties.

If you have some information showing compliance or testing difficulties for actual light truck models with a GVWR of 6,000 pounds or less, we would appreciate it if you would forward that information to the agency. At this time, NHTSA is not aware of any compliance or testing difficulties for light trucks subject to the extended requirements of Standard No. 216. Absent such information, NHTSA has no basis for changing its previous conclusion about the specified test procedures and requirements.

ID: nht72-3.48

DATE: 10/18/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. Charles E. West

TITLE: FMVSS INTERPRETATION

TEXT: Your letter of September 18, 1972, to Senator Warren G. Magnuson, Chairman, Committee on (Illegible Words) your automatic seat belt system has been referred to this office for reply.

Federal Motor Vehicle Safety Standard No. 208, Occupant Crash Protection, (copy enclosed) requires complete passive restraint systems in cars manufactured after August 15, 1973. This standard, as well as most of our standards, is written in performance terms and does not require the use of any specific device. Manufacturers are free to employ any system that will meet the requirements of the standard without any voluntary section on the part of the occupant, such as fastening a seat belt.

The National Highway Traffic Safety Administration is not generally engaged in hardware development, but rather, directs its research efforts toward the development of technical data to form the basis for motor vehicle safety performance standards. Perhaps you might care to contact vehicle manufacturers to see if they would be interested in your automatic belt system.

I am placing a copy of your letter in our Public Docket No. 69-7, which contains information relative to occupant restraint systems. We appreciated receiving the description of your system and your interest in motor vehicle safety.