ID: 05-009244drn

ID: nht74-1.49

DATE: 05/10/74

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

TO: Superior Trailer Works

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your April 22, 1974, question concerning the certification responsibility of a small manufacturer of trailers that must conform to Standard No. 121, Air brake systems. You ask if road testing of any or all vehicles produced would be necessary to satisfy the requirements.

A manufacturer must "exercise due care" in certifying that the vehicles manufactured by him comply with the applicable standards (National Traffic and Motor Vehicle Safety Act of 1966, @ 108(b)(2), 15 U.S.C. @ 1392(b)(2)). What constitutes due care in a particular case depends on all relevant facts, including such things as the time to elapse before a new effective date, the availability of test equipment to small manufacturers, the limitations of current technology, and above all the diligence evidenced by the manufacturer.

A small manufacturer of standard and custom trailers might fulfill his due care responsibility to assure that each of his trailers is capable of meeting the standard in several ways. For example, he could establish categories of models which share a common brake and axle system and certify them all on the basis of tests on the most adverse configuration in the category. Calculations should be written down in such a case to establish that reasonable care was taken in these decisions.

Alternatively, joint testing might be undertaken with a trade association or with a major supplier of brake and axle components. In the case of standard models, you might be able to rely on the supplier's warranty of his products' capacities.

Neither of these methods would require road testing of each vehicle manufactured, nor would every model have to be road tested. A manufacturer must simply satisfy himself that the trailer is capable of meeting the stopping performance requirements if it were tested by the NHTSA.

Yours truly,

ATTACH.

April 22, 1974

National Highway Traffic Safety Administration Attn: James B. Gregory, Administrator

Gentlemen:

We are a small trailer manufacturing firm currently producing approximately 100 trailers per year. These trailers are predominantly standard models (with some variations in body length and height), however, we also manufacture some custom trailers, principally low beds.

We do not manufacture brakes or axles or air system components, instead we purchase a complete axle-brake assembly and the air components, and assemble them into a trailer chassis. Under the Motor Vehicle Safety Standard 121 we will, of course, install components that meet the new requirements.

We are in the process of determining all the changes that we will be required to make under MVSS 121 and would appreciate clarification of the following:

1. Will we be required to road test complete trailers or will the inclusion of all certified components satify the requirements of the law?

2. If road testing of the complete trailer is required, is it required of every trailer produced, or would the test of a single prototype of a standard model be sufficient for all other trailers of the same model?

3. What road testing would be required for custom trailers that vary widely in length, width, height, capacity, etc.?

We have contacted several California trailer manufacturers, and they are in the same position that we find ourselves, i.e., no testing facilities of our own and without knowledge of any independent testing facility offering such a service. The size of the facilities required would make it all but impossible for any but a very large business firm to construct a special facility.

We are including some literature that will show the variations in equipment that we manufacture.

Your earliest possible comments would be greatly appreciated.

Very truly yours,

SUPERIOR TRAILER WORKS Charles R. Richards -- President

ID: nht76-4.16

DATE: 11/10/76

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Midland-Ross Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This responds to Midland-Ross' September 30, 1976, question whether the "method" specified by Compliance Testing, Inc., in its December 8, 1975, Technical Proposal for Solicitation NHTSA-6-A212 is consistent with the laboratory procedure contemplated by the NHTSA for its test contractors in evaluating the compliance of air-braked vehicles with Standard No. 121, Air Brake Systems. The NHTSA laboratory procedure for compliance contractors in the case of Standard No. 121 states in relevant part:

PROCEDURE:

A. Physically locate check valve or equivalent device.

B. Following manufacturer's recommendation, check the check valve or equivalent device for proper function without disconnecting any air line or fitting. Describe method and technique used.

The Compliance Testing, Inc. (CTI) solicitation was evaluated along with other proposals and has been accepted by the NHTSA. The "method" set forth by CTI as its intended course of action in evaluating the compliance of valves in accordance with the requirements of S5.1.2.3 will not appear in the manual produced for NHTSA compliance testing.

I would like to note in closing that this letter does not constitute an interpretation of the requirements of Standard No. 121. Although the laboratory procedure sets forth the method by which contractors satisfy NHTSA contracts, it does not mean that a vehicle need not meet the requirements of the standard when tested according to its terms by other methods.

MIDLAND-ROSS

September 8, 1976

Salvatore J. Nicolosi -- Office of Contracts and Procurement, National Highway Traffic Safety Administration

Gentlemen:

Subject: Laboratory Procedures for Air Brake Systems, Federal Motor Vehicle Safety Standard No. 121, Report #TP-121-00

Midland-Ross Corporation is a manufacturer of air brake actuation equipment for heavy duty trucks. We therefore manufacture components which are used by truck manufacturers for compliance with FMVSS 121. We are asking for interpretation of the requirements for check valves.

In the subject procedures, issued by the U.S. Department of Transportation, National Highway Traffic Safety Administration, Office of Standards Enforcement Motor Vehicle Programs, Section 1.3.2 states:

"This procedure must be followed by any contractor conducting FMVSS 121 tests for the National Highway Traffic Safety Administration."

Section 5.7 REQUIREMENT S5.1.2.3 -- SERVICE RESERVOIR SYSTEM AIR LOSS TEST states"

"Each service reservoir system shall be protected against loss of air pressure due to failure or leakage in the system between the service reservoir and the source of air pressure, by check valves or equivalent devices whose proper functioning can be checked without disconnecting any air line or fitting."

Under the same section PROCEDURE A and B:

"A. Physically locate check valve or equivalent devices.

B. Following the Manufacturer's recommendation, check the check valve or equivalent device for proper function without disconnecting any air line or fitting. Describe method and technique used." (Underscoring added.)

In the submission by Compliance Testing Inc., which we understand was accepted, the Contractor states:

"Method:

1. Build up air in system to maximum

2. Open bleed valve in supply tank

3. Monitor for 10 minutes pressure in primary and secondary tanks - no loss of air allowed"

We submit that on the surface this appears to be not in compliance with requirements of TP121.00 and we would like to have a clear interpretation of what the contractor plans to do with these valves in checking them for leakage. We submit that zero leakage is a physical impossibility and must be interpreted in terms of the accuracy of the equipment being used for measurement.

Further we submit that the contractor is obligated to test for compliance "following the Manufacturer's recommendation" which we in turn would consider to be the engineering specification for the appropriate valve.

We request that this question be clarified and the NHTSA position be stated so that erroneous claims of non-compliance can be avoided. An early response would be appreciated.

Sincerely,

M. J. Denholm -- Director of Engineering, Power Controls Div.

cc: J. Brewster, M-R; D. Gross, M-R; F. Nawalanic, M-R; A. Beier, IHC; R. MADISON

ID: 004718as

ID: GFES04-2-000636

The Honorable John J. Duncan, Jr.
U.S. House of Representatives
Washington, DC 20515-4202

Dear Congressman Duncan:

Thank you for your letter on behalf of your constituent, Mr. Jon Schaffer.
Mr. Schaffer is interested in marketing a new product and asks whether the Federal motor vehicle safety standards (FMVSSs) permit flashing stop lamps. As discussed below, the answer is no.

By way of background, the National Highway Traffic Safety Administration is authorized to issue motor vehicle safety standards that apply to the manufacture and sale of new motors and new motor vehicle equipment, in order to reduce the number of fatalities and injuries that result from motor vehicle crashes.

The Federal standard applicable to lighting equipment is FMVSS No. 108, Lamps, Reflective Devices and Associated Equipment.The relevant section of that standard reads as follows:

"S5.5.10 The wiring requirements for lighting equipment in use are:


(a) Turn signal lamps, hazard warning signal lamps, and school bus warning lamps shall be wired to flash;
(b) Headlamps and side marker lamps may be wired to flash for signaling purposes;
(c) A motorcycle headlamp may be wired to allow either its upper beam or its lower beam, but not both, to modulate from a higher intensity to a lower intensity in accordance with section S5.6;
(d) All other lamps shall be wired to be steady-burning" [emphasis added].

In short, S5.5.10(d) of FMVSS No. 108 mandates that all lamps be steady burning, unless otherwise permitted. In the present case, stop lamps do not fall under any exception enumerated in S5.5.10 (a) through (c). Accordingly, stop lamps must be steady burning and cannot be flashing.

We believe that motor vehicle safety is best promoted by standardization of lighting signals. The information currently provided by signal lamps, such as stop lamps, is well understood by the driving public, is instantly recognized and unambiguously informative.

While we recognize that a new idea for the operation of signal lighting might improve safety, we have taken the position that, given the safety benefits associated with the standardized operation and meaning of required lighting, the burden is on the proponents of a new signaling idea to demonstrate that the use of the new idea would yield a positive safety benefit large enough to more than offset the adverse safety effects of giving up the standardized operation and meaning of signal lights. We have enclosed a copy of a November 4, 1998, Federal Register notice which fully explains our policies concerning evaluating new signal lighting ideas.

In his letter to your office, Mr. Schaffer mentioned a Tennessee law permitting flashing stop lamps on motorcycles.For your reference, enclosed please find our January 14, 2004, letter to the manager of City of Memphis Motor Vehicle Inspection Bureau, in which we inform him that FMVSS No. 108 does not permit flashing stop lamps on motorcycles.

With respect to Mr. Schaffers question about Federal preemption of State laws, 49 U.S.C. 30103(b)(1) provides in pertinent part:

"Preemption. When a motor vehicle safety standard is in effect under this chapter, a State or a political subdivision of a State may prescribe or continue in effect a standard applicable to the same aspect of performance of a motor vehicle or motor vehicle equipment only if the standard is identical to the standard prescribed under this chapter."

This means that, under 49 U.S.C. 30103(b)(1), a State cannot authorize flashing stop lamps since the applicable Federal motor vehicle safety standard prohibits such lighting devices.

We further note that installation of a non-steady burning lamp by a manufacturer, dealer, distributor, or motor vehicle repair business after the initial sale is subject to the restrictions of 49 U.S.C. 30122, which prohibits "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 motor vehicle safety standard. Depending on the circumstances, installation of a non-steady burning lamp after the initial sale of a vehicle could be viewed as a violation of this "make inoperative" provision.

I hope you find this information helpful. If you need further assistance, please contact Stephen Wood, Assistant Chief Counsel for Vehicle Safety Standards and Harmonization,at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

Enclosures
ref:108
d.2/6/04

ID: 10855-2

Terrence S. Lockman, Investigator
Levin, Middlebrooks, Mabie,
Thomas, Mayes & Mitchell, P.A.
Attorneys-at-Law
P.O. Box 12308
226 South Palafox Place
Pensacola, FL 32581

Dear Mr. Lockman:

This responds to your request for an interpretation whether a Model Year (MY) 1981 Versa Sweeper road sweeper is a "motor vehicle" and therefore subject to the Federal Motor Vehicle Safety Standards (FMVSSs) that were in effect when the vehicle was manufactured. Further, you ask whether the Versa Sweeper had to comply with requirements for an occupant restraint system or for rollover protection. You explained that you are conducting an investigation, and that "At the time in question, the vehicle was being used in a construction zone, to sweep debris off the roadway."

I note, before beginning, that your letter had asked for certain information under the Freedom of Information Act (FOIA). NHTSA separately answered your FOIA request by letter dated May 22, 1995, from Ms. Heidi Coleman of my staff, Assistant Chief Counsel for General Law.

Yours is an unusual interpretation request. Typically, questions concerning whether a vehicle is a motor vehicle are raised around the time of manufacture of a vehicle or its importation into the country, and by a person knowledgeable about the intended use of the vehicle, such as the vehicle's manufacturer. In contrast, your question asks about another entity's vehicle 14 years after the vehicle's manufacture, which makes our response more difficult. We cannot say for certain what principles would have applied in 1981 concerning the Versa Sweeper, and our knowledge of the vehicle is limited to the information you provided. Thus, a conclusive answer is beyond our reach.

We can make the following observations, however. NHTSA applies several principles when making a determination of whether a vehicle is a motor vehicle. Section 102(3) of the National Traffic and Motor Vehicle Safety Act defined a motor vehicle as "a vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways . . . ." We are not certain, based on the information you provided, that the Versa Sweeper was manufactured for use on public highways. The literature you sent indicates that the Versa Sweeper is intended for "road maintenance sweeping and highway preparation cleaning." It appears that the vehicle might be a construction vehicle. Moreover, you indicated that the vehicle was being used in a construction zone "at the time in question." Construction-related vehicles generally are "motor vehicles" for purposes of our statute if they frequently use the highway going to and from job sites and stay at a job site for only a limited time. With regard to the 1981 Versa Sweeper, its use of the highway is unclear.

Assuming the Versa Sweeper had regularly used the highway, NHTSA's longstanding position has been that vehicles of unusual configuration that are incapable of obtaining speeds greater than 20 miles per hour (mph) are not required to comply with the FMVSSs. It is unclear how this principle applies to a 1981 Versa Sweeper. The material you enclosed indicates that the Versa Sweeper has "Infinitely variable speeds from 0-30 miles per hour...." It is unclear whether this means each Versa Sweeper can attain a speed of 30 mph or whether some, but not all, can. A Versa Sweeper that had a maximum speed of less than 20 mph is excluded. One that went over 20 mph might not have been.

You ask about requirements for occupant restraints and rollover protection. The agency has stated that "street sweepers"--that are motor vehicles--are trucks. In 1981, FMVSS No. 208, Occupant Crash Protection (49 CFR '571.208), required open-bodied light trucks to have a lap belt system. There was no rollover requirement.

If you have any further questions, please contact Ms. Dorothy Nakama of my staff at (202) 366-2992.

Sincerely,

John Womack Acting Chief Counsel

ref:VSA102(3) d:8/2/95 In 1994, the Safety Act was recodified, without substantial change, at 49 U.S.C. 30101 et seq. The motor vehicle" definition is set forth in section 30102(a).

ID: nht95-5.46

TYPE: INTERPRETATION-NHTSA

DATE: August 2, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Terrence S. Lockman -- Investigator, Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A., Attorneys-at-Law

TITLE: NONE

ATTACHMT: ATTACHED TO 4/10/95 LETTER FROM TERRENCE, S. LOCKMAN TO NHTSA CHIEF COUNSEL (OCC 10855)

TEXT: Dear Mr. Lockman:

This responds to your request for an interpretation whether a Model Year (MY) 1981 Versa Sweeper road sweeper is a "motor vehicle" and therefore subject to the Federal Motor Vehicle Safety Standards (FMVSSs) that were in effect when the vehicle was manufactured. Further, you ask whether the Versa Sweeper had to comply with requirements for an occupant restraint system or for rollover protection. You explained that you are conducting an investigation, and that "At the time in question, the vehicle was being used in a construction zone, to sweep debris off the roadway."

I note, before beginning, that your letter had asked for certain information under the Freedom of Information Act (FOIA). NHTSA separately answered your FOIA request by letter dated May 22, 1995, from Ms. Heidi Coleman of my staff, Assistant Chief Counsel for General Law.

Yours is an unusual interpretation request. Typically, questions concerning whether a vehicle is a motor vehicle are raised around the time of manufacture of a vehicle or its importation into the country, and by a person knowledgeable about the intended use of the vehicle, such as the vehicle's manufacturer. In contrast, your question asks about another entity's vehicle 14 years after the vehicle's manufacture, which makes our response more difficult. We cannot say for certain what principles would have applied in 1981 concerning the Versa Sweeper, and our knowledge of the vehicle is limited to the information you provided. Thus, a conclusive answer is beyond our reach.

We can make the following observations, however. NHTSA applies several principles when making a determination of whether a vehicle is a motor vehicle. Section 102(3) of the National Traffic and Motor Vehicle Safety Act n1 defined a motor vehicle as "a vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways . . ." We are not certain, based on the information you provided, that the Versa Sweeper was manufactured for use on public highways. The literature you sent indicates that the Versa Sweeper is intended for "road maintenance sweeping and highway preparation cleaning." It appears that the vehicle might be a construction vehicle. Moreover, you indicated that the vehicle was being used in a construction zone "at the time in question." Construction-related vehicles generally are "motor vehicles" for purposes of our statute if they frequently use the highway going to and from job sites and stay at a job site for only a limited time. With regard to the 1981 Versa Sweeper, its use of the highway is unclear.

n1 In 1994, the Safety Act was recodified, without substantial change, at 49 U.S.C. 30101 et seq. The motor vehicle" definition is set forth in section 30102(a).

Assuming the Versa Sweeper had regularly used the highway, NHTSA's longstanding position has been that vehicles of unusual configuration that are incapable of obtaining speeds greater than 20 miles per hour (mph) are not required to comply with the FMVSSs. It is unclear how this principle applies to a 1989 Versa Sweeper has "Indefinitely variable speeds from 0-30 miles per hour. . ." It is unclear whether this means each Versa Sweeper can attain a speed of 30 mph or whether some, but not all, can. A Versa Sweeper that had a maximum speed of less than 20 mph is excluded. One that went over 20 mph might not have been.

You ask about requirements for occupant restraints and rollover protection. The agency has stated that "street sweepers" -- that are motor vehicles -- are trucks. In 1981, FMVSS No. 208, Occupant Crash Protection (49 CFR @ 571.208), required open-bodied light trucks to have a lap belt system. There was no rollover requirement.

If you have any further questions, please contact Ms. Dorothy Nakama of my staff at (202) 366-2992.

ID: nht80-1.34

DATE: 03/18/80

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: G. Mack Industries, Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 18, 1980, asking about the legality in the United States of a lamp with the words "DON'T PASS" which you are presently manufacturing for school buses in Canada. The lamp is intended for mounting on both the front and rear of the bus.

Such a lamp is not required in this country under Federal law. Its use as original equipment on U.S. school buses would not be prohibited by Federal Motor Vehicle Safety Standard No. 108, Lamps, Reflective Devices and Associated Equipment, since its installation would not appear to impair the effectiveness of required lighting equipment. Its legality would be determined by that of the State in which the bus is registered and operated, and therefore, you should contact the individual State for their opinion in this matter.

SINCERELY,

G. MACK INDUSTRIES LTD.

February 18, 1980

Frank Berndt, Chief Counsel National Highway Traffic Safety Administration, U.S. Department of Transportation,

Dear Sir:

In a letter I received from Mr. David Soule he suggested that I write you directly as to finding out the legality of our "DON'T PASS" light, we are presently manufacturing for the school buses in Canada.

The "DON'T PASS" light features consist of one or two flashing thirty-five candlepower seal beam units or six thirty two candlepower bulbs. The base is made out of A.B.S. a hard tough space age material that is weather resistant, and is suited for outdoor applications. The lens is made out of san and is a chemical scratch resistant plastic. Dimensions are 10" x5" x2" with a simple six screw molding which will adapt to any school bus. As to the electrical hook up we are presently using the four way flashing switch.

Enclosed is a picture and a newspaper clipping as to our headway we have made in Canada.

Appreciating your valued opinion in your early reply as to our position in the United States. I remain,

J. Leftrook Jr. President

ENC.

The Big Safety Lamp has been included in the Manitoba school bus specifications and the Manitoba Highway Traffic Act has been amended to give approval of the light. It is now in use in all of the 52 Manitoba school divisions. Application to have the lamp made standard equipment will go before the next meeting of the Canadian Standards Association.

The lamp which is produced for the company by Melet Plastic Ltd., 670 Golspie Street, Winnipeg, is injection moulded on custom made steel dies. The lens is made of SAN, a scratch and chemical resistant plastic, and the back of the unit is made of ABS, a hard, tough, space age material that is weather resistant and specially suited to outdoor applications.

Gerry Leftrook is optimistic about the future. Negotiations are underway to have the light standardized in the United States as well as Canada. It is estimated that there are some 25,000 school buses operating in Canada and 348,000 in the United States. Production of new buses has been projected at about 7,000 per year in Canada and 35,000 per year in the United States over the next five years.

The light can be adapted to transport trailers and trucks, house trailers and campers, all of which provide a wide market potential.

(Graphics omitted)

ID: nht73-5.19

DATE: 03/09/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: General Motors Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of February 8, 1973, concerning the use of a "comfort clip" on the shoulder belt portion of GM's 1974 seat belt system.

In response to questions from other manufacturers concerning the use of high friction buckles in continuous loop belt systems, we have indicated that the requirement of Standard 208 that the belts adjust to fit specified occupants precludes the use of such buckles. In the case of systems with separate lap and shoulder belt retractors, however, the shoulder belt does not affect the tension in the lap belt and therefore does not present the risk of submarining that exists with the single loop systems. Accordingly, we are of the opinion that a comfort clip would be acceptable under S7.1.1 of the standard, so long as the shoulder belt is otherwise capable of adjustment as required by S7.1.1.

At a meeting with you on this subject on January 24, 1973, the NHTSA expressed its concern about possible reductions in shoulder belt effectiveness due to excessive belt slack. On the whole, we find that this possibility is more than offset by the prospects of greater usage due to the added convenience of the system with the clip. However, we strongly support your proposal to include instructions for the use of the clip both on the clip itself and in the owner's manual.

ID: nht74-4.26

DATE: DATE:05/07/74

FROM: FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: TO: Perkasie Vulcanizing Co., Inc.

TITLE: TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 25, 1974, asking whether, consitently with Federal Motor Vehicle Safety Standard No. 117, maximum permissible load may be labeled in two lines, viz.:

MAXIMUM PERMISSIBLE LOAD XXXXXXXX LBS.

You ask further whether there is a maximum height requirement for the lettering used in the label.

Standard No. 117 does not specify labeling format, and the two-line format you submit conforms to the standard. Paragraphs S6.3.1 and S6.3.2 of Standard No. 117 require all safety labeling, both permanent and affixed, to be at least 0.078 inches in height. No other requirements regarding labeling size are specified.

PERKASIE VULCANIZING CO., INC.

[Illegible Words]

SUBJECT: Federal Motor Vehicle Safety Standards FMVSS-117 - Auto Tire Retreads

In our letter to you dated January 4, 1974 on the subject we gave you information regarding the requirement that on February 1, 1974 certain information must be permanently molded into or onto the sidewall of an auto tire retread.

As you may have noticed in news releases, the U.S. Court of Appeals on January 8, 1974 modified the requirements as to what information must appear on the sidewall.

The result is -- on Auto Tire Retreads all that is required as of February 1, 1974 is --

"Maximum permissible load"

This information must be permanently molded into or onto the sidewall of Auto Tire Retreads.

All the other information such as tire size, inflation pressure, ply rating, tubeless or tube type, bias ply, bias/belted or radial must be on the tire, or may be labeled onto the tire, either permanently or by the addition of a label that is not easily removable, during the retreading process as we mentioned in a previous letter to you dated May 9, 1973, may still be used.

We will keep you advised of future rulings or changes.

TITLE: FMVSS INTERPRETATION DATE:05/07/74 FROM: AUTHOR UNAVAILABLE; Lawr

JAS. H. MATTHEWS & CO.

February 18, 1974

Perkesie Vulcanizing Company

ATTENTION: Ralph Perkesie

SUBJECT: Retread Law FMVSS-117

In response to our phone conversation recently in which you had requested us to investigate the retread law FMVSS-117 concerning the character size and length as specified in this law for the labeling of the maximum permissible load designation.

It is our position that we can not presume to interpret or have access to this particular law. This specification should be interpreted by the department of transportation with Perkesie Vulcanizing Company. Any questions concerning this particular law or its' requirements stated in this law should be passed upon the department of transportation. We hope that you can understand that the Jas. H. Matthews & Company is simply the supplier of the tags as specified by a customer. If these tags must meet a specific regulation or a variance of this regulation, this must be interpreted by the customer.

We have our facilities at your disposal in supplying and fulfilling your particular requirements for tags once these specifications have been determined.

We hope this information is of value to you and if we can be of any further service to you in any way please do not hesitate to contact us.

C. R. Parfitt Industry Specialist