ID: 1984-3.44

TYPE: INTERPRETATION-NHTSA

DATE: 11/29/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Continental Products Corporation -- Jack DiMaio

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Jack DiMaio Continental Products Corporation 1200 Wall Street West Lyndhurst, NJ 07071

This responds to your recent letter to Mr. Steve Kratzke of my staff, seeking an interpretation of Standard No. 119 New Pneumatic Tires for Vehicles Other Than Passenger Cars (49 CFR S571.119). Specifically, you asked three questions about the size markings required for truck tires. As a general matter, Standard No. 119 leaves the question of the appropriate size marking to the discretion of the individual manufacturer or to the manufacturers collectively, through the several standardization organizations. To be certain that I fully address your concerns, however, I will answer each of your questions in the order you presented them in your letter.

1 . Please clarify whether it is allowed to market a low profile tire with a size marking of 280/80 R22.5.

At the outset, I wish to clarify one point. In this and your other questions, your size designations do not include a letter designating the tire load range. In prior interpretations of Standard No. 120, which relates to tire selection and rims for vehicles other than passenger cars, I have indicated that the load range is considered a part of the size designation. This conclusion was based on the fact that many truck tires have identical dimensions, but widely varying load carrying capacities, depending on the load range. Hence, this answer and the two following assume that the size markings on the sidewall of these tires would include a letter indicating the load range assigned to the tires, as required by paragraph S6.5(j) of Standard No. 119.

Paragraph S6.5(c) of Standard No. 119 specifies that each tire subject to that standard shall be marked with the tire size designation shown "in the documents and publications designated in S5.1." Paragraph S5.1 of Standard No. 119 requires that tire manufacturers provide the public with a listing of the rims that may be used with each tire size the manufacturer produces. The manufacturer is given the option of itself individually furnishing such a listing to each of its dealers, to this agency, and to the public upon request or relying on the listings shown in the publications of the standardization organizations. A standardization organization is a voluntary association composed of representatives of each of its member tire companies. The purpose of standardization organizations is to establish and promulgate sound engineering standards for tires, rims, and their allied parts.

In the case of the 280/80 R22.5 size marking, you may rely on the listings published for that size by any of the standardization organizations shown in S5.1(b) or submit the listings directly to this agency and to each of your dealers. A check of the 1984 publications of the Tire & Rim Association and the Japan Automobile Tire Manufacturers Association by this agency did not show any listing for this size designation. It is possible that this size marking is listed by one of the other standardization organizations shown in S5.1(b). If not and if you wish to sell tires with this size designation, you will have to submit a listing of the size rims which may be used with this tire to this agency and to each of your dealers, as specified in S5.1(a).

2. Can the marking 280 R22.5 be used eventually?

If you wish to submit the rim matching information directly to your dealers and to this agency, pursuant to S5.1(a) of Standard No. 119, that marking may be used at the present time. However, it would be preferable if the tire manufacturers, through the standardization organizations, could agree on one size marking for tires with the same physical dimensions and load carrying capacity. This would lessen confusion on the part of consumers and tire service shops. The confusion on the part of those persons was one of the reasons the National Highway Traffic Safety Administration published the tire tables for passenger car tires subject to Standard No. 109. Notwithstanding the agency desire that tire manufacturers use the standardization organizations to resolve tire sizing questions, there is no requirement that they do so, provided that they satisfy the requirements of S5.1(a) for disseminating the sizing information.

3. Do standardization instructions exist which say that only marking 275/80 R22.5 is possible?

No such instructions exist in Standard No. 119. It is possible that this is the only size marking which has been approved by a standardization organization and thus the only marking which can be used if the manufacturer wants to meet the sizing dissemination requirements under S5.1(b) of Standard No. 119. However, as stated above, the individual manufacturer is free to follow the dissemination requirements of S5.1(a) for tire sizes not listed in standardization organization publications.

Should you have any further questions, or need further information on this subject, please do not hesitate to contact Mr. Kratzke at this address or by a telephone at (202) 426-2992.

Sincerely,

Frank Berndt Chief Counsel

September 28, 1984 NHTSA Rm. 5219 Office of Chief Counsel 400 7th St. S.W. Washington, D.C. 20590 Attn: Steve Kratzke Dear Mr. Kratzke, We at Continental are in preparation of our own version of the new Low Profile truck tire. Some questions have arisen that you may be able to answer regarding size markings. 1. Please clarify whether it is allowed to market a low profile with marking 280/80 R22.5. 2. Can the marking 280 R22.5 be used eventually? 3. Do standardization instructions exist which say that only marking 275/80 R22.5 is possible? Should you have any questions or need more information, please contact the undersigned. Sincerely, Jack Di Maio Continental Products Corporation Main Office 1200 Wall Street West Lyndhurst, NJ 07071 (201) 460-0200; Telex: 133 391

ID: 1984-3.8

TYPE: INTERPRETATION-NHTSA

DATE: 08/17/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Burt McMillian

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent letter to Mr. Steve Kratzke of my staff, asking for information about rebuilt steel wheels for use on motor vehicles other than passenger cars. For the purposes of this response, I will respond only for the rim portion of the wheel, since both the regulations you inquired about apply only to rims, and not the entire wheel assembly. Specifically, you asked about the applicability of a regulation issued by the Occupational Safety and Health Administration (OSHA) and this agency's Standard No. 120, Tire selection and rims for motor vehicles other than passenger cars (49 CFR @ 571.120). This agency does not offer opinions on the applicability of other Federal agency regulations, and Standard No. 120 does not apply to rebuilt rims.

You stated in your letter that one of OSHA's regulations states that "no cracked, broken, bent or otherwise damaged rim components shall be reworked, welded, brazed, or otherwise heated", and that OSHA interprets the center disc as a rim component subject to the requirements of that regulation. You further stated that a staff member in our Office of Defect Investigations offered his opinion that the OSHA regulation did not apply to the center disc. This agency does not interpret the regulations administered by other Federal agencies, unless and until such time as that regulation appears inconsistent with our statutory authority. There is no apparent conflict between the OSHA regulation and our authority, so we defer to their interpretation of that regulation.

You further stated in your letter that "the only other regulation concerning rebuilding wheels is NHTSA Standard No. 120 concerning identification of rebuilt wheels." We have stated in several past interpretations that Standard No. 120 does not apply to remanufactured or rebuilt rims. Section S5.2 of Standard No. 120 does set forth rim marking requirements, but these apply only to new rims. Section 108(b)(1) of the National Traffic and Motor Vehicle Safety Act (hereafter referred to as "the Safety Act") (15 U.S.C. 1397(b)(1)) specifies that the requirements of our safety standards shall not apply after the first purchase of a rim in good faith for purposes other than resale. Since the components of rebuilt rims have already been used on the public roads, the requirements of Standard No. 120 do not apply to the rebuilding of those rims.

You concluded your letter with the observation that these rims are subject to significantly more stress today than they were ten years ago, and that repaired or rebuilt rims should be "looked at". There is a course of action you might wish to pursue if you believe this perceived problem presents a serious threat. You may file a petition for rulemaking with this agency, asking us to establish some strength requirements for new rims. Section 108(a)(2)(A) of the Safety Act specifies that no manufacturer, distributor, dealer, or motor vehicle repair business shall "knowingly render inoperative any . . . element of design installed on or in . . . an item of motor vehicle equipment in compliance with an applicable Federal motor vehicle safety standard, . . . " If Standard No.

120 were amended to include some strength requirements for new rims, those persons could violate section 108(a)(2)(A) of the Safety Act if they knowingly weaken the rims. For your information I have enclosed a copy of our regulation which sets forth the requirements for petitions for rulemaking (49 CFR Part 552). Should you choose to file such a petition, please pay particular attention to the requirements of @ 552.4, which explains the information which must be included in the petition.

I thank you for bringing this matter to our attention, and believe that the safety concerns of people like yourself who are daily involved with tires and rims are an invaluable help to this agency. Please do not hesitate to contact me if you have any further questions or concerns.

ENCLS.

LES SCHWAB WAREHOUSE CENTER INC.

June 26, 1984

Steve Kratzke Chief Consul National Highway Traffic Safety Administration

Dear Mr. Kratzke:

During a recent telephone conversation with Gary Woodford of NHTSA, he suggested I write to you and get your opinion on rebuilding truck wheels.

There seems to be a great deal of confusion over several regulations regarding rebuilding of steel truck wheels. OSHA regulation 1910.77 (F) 9. states "no cracked, broken, bent or otherwise damaged rim components shall be reworked, welded, brazed or otherwise heated". It is OSHA's opinion that the center disc is a rim component, therefore, cannot be welded. Mr. Woodford's opinion was that OSHA's jurisdiction only concerns lock rings or parts involved in mounting safety.

The only other regulation concerning rebuilding wheels is NHTSA standard120 concerning identification of rebuilt wheels. As I understand this regulation all that is required is some sort of stamp such as date, initials or trademark that is not registered or otherwise traceable.

My concern is that there are people welding and/or rebuilding wheels that have no concept of the engineering or design of steel wheels. As an example; recently I ran across a rebuilder who was cutting out the mounting surface of the disc and welding in a new one. When he bored the stud holes he was putting a chamfered or beveled seat instead of a ball seat. It is highly probable that unless excess amount of torque were applied to the cap nuts this wheel would come loose. The problem is that any tire service store that changes that wheel in the future then becomes liable if the wheel comes loose. The difference between a chamfered or beveled seat and a ball seat is so minute that most service people would never notice the difference.

With the advent of the radial tire, greater allowable weight limits and deregulation, wheels are subjected to a lot more stress than they were ten years ago. Therefore, wheels today must be of much better quality and it would seem that repairing of wheels or rebuilding them should be looked at.

I would appreciate you sending me any information or opinions on this subject that would help clear up this muddy situation.

Thank you.

Burt McMillan

ID: 1985-01.6

TYPE: INTERPRETATION-NHTSA

DATE: 01/04/85

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Ron Cortez -- Marketing Director, Deco International Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

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

Dear Ms. or Mr.,

Please inform me as to the proper procedure for certifying an entirely new device that will enhance the braking features of trucks and/or passenger vehicles.

Our product, when incorporated into the vehicles braking system will allow the driver to brake the vehicle to a stop once, remove his or her foot from the brake pedal and have the vehicle remain motionless, under brake pressure, until the throttle position is advance.

This will enable the driver to accelerate from a stop on a hill without the fear of a 'roll back'.

One simply brings their vehicle to a stop, and removes their foot from the brake pedal. Our device automatically engages, holding the vehicle motionless, until the accelerator is advanced.

In that this device must be installed in conjunction with the vehicles original brake system, we are concerned as how to properly certify the device.

Mechanically the device must be spliced into the hydraulic brake system of the vehicle. Sensors are attached to the speedometer cable, at the transmission, and on the throttle linkage. Disengagement is a result of either application of the throttle and/or movement of the vehicle as detected at the speedometer cable.

Please forward any and all infomation pertaining to the certification requirements of such an 'aftermarket' device.

Thank you very much for your quick response and assistance.

Sincerely,

Ron Cordez Marketing Director

Mr. Ron Cortez Marketing Director Deco International Corporation 12612 Osborne Street Pacoima, California 91331

Dear Mr. Cortez:

This response to your letter asking about Federal requirements applicable to an aftermarket device designed to enable a driver to accelerate from a stop on a hill without the fear or a "roll back." Once the device is installed, the driver may brake the vehicle to a stop once, remove his or her foot from the brake pedal and have the vehicle remain motionless, under brake pressure, until the throttle position is advanced. According to your letter, the device must be spliced into the hydraulic brake system of the vehicle. Sensors are attached to the speedometer cable, at the transmission, and on the throttle linkage. Disengagement is a result of either application of the throttle and/or movement of the vehicle as detected at the speedometer cable.

By way of background information, the agency does not provide approvals of vehicles or equipment. The National Traffic and Motor Vehicle Safety Act places the responsibility on the manufacturer to insure that its vehicles or equipment comply with applicable requirements. A manufacturer then certifies that its vehicles or equipment comply with applicable standards. The following opinion is based on the information provided in your letter.

The agency does not have any regulations covering hill-hold devices designed to be attached to the braking system of a vehicle. However, since installation of your device requires cutting into a vehicle's braking system, it may affect a vehicle's compliance with other safety standards.

If your device is added to a new motor vehicle prior to its first sale, the person who modifies the vehicle would be an alterer of a previously certified motor vehicle and would be required to certify that, as altered, the vehicle continues to comply with all of the safety standards affected by the alteration. In the case of your device, this would include Safety Standard No. 105, Hydraulic Brake Systems (49 CFR 571.105). You will find the specific certification requirements for alterers at 49 CFR Part 567.7, Certification. On the other hand, you as the manufacturer of the device would have no certification requirements, because we have no safety standards applicable to your equipment. However, an alterer would probably require information from you in order to make the necessary certification.

If your device is installed on a used vehicle by a business such as a garage, the installer would not be required to attach a certification label. However, it would have to make sure that it did not knowingly render inoperative the compliance of the vehicle with any safety standard. This is required by section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act, which states in relevant part:

No manufacturer, distributor, dealer, or motor vehicle repair business shall knowingly render inoperative, in whole or in 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. . . . .

Standard No. 105 includes various requirements that might be affected by installation of your device. We are not able to determine from the information provided in your letter whether compliance with the standard would be affected. We suggest that you carefully examine all of Standard No. 105's requirements to determine the degree to which installation of your device affects compliance with the standard. Requirements included in the standard include, among others, ones on stopping distance, split systems, and the ability of a baking system to withstand a series of spike stops, which might be affected by your device.

Moreover, should a safety-related defect be discovered in your device, whether by the agency or yourself, you as the manufacturer would be required under sections 151 et. seq. of the Act to notify owners, purchasers, and dealers and provide a remedy for the defect.

I have enclosed an information sheet which explains where to obtain copies of our standards and regulations.

Sincerely,

Frank Berndt Chief Counsel

Enclosure

ID: 1985-02.49

TYPE: INTERPRETATION-NHTSA

DATE: 06/25/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: James H. Westlake -- National Automobile Dealers Assocaition

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. James H. Westlake Associate Director American Truck Dealers Division National Automobile Dealers Association 8400 Westpark Drive McLean, VA 22102

This is in reply to your letter of February 25, 1985, to Mr. Stephen Wood of this office asking the following three questions about rebuilding and remanufacturing heavy duty trucks.

"1) When rebuilding a used truck with a glider kit, it is our understanding that the process is considered 'rebuilding' when the three major components (engine, transmission and rear axle) are reused in the rebuilding process. If one or more of these major components is new, does the production of the truck chassis change its legal character from 'rebuilding' to 'first stage manufacturer'?"

Neither the National Traffic and Motor Vehicle Safety Act ("the Act") nor the Federal Motor Vehicle Safety Standards ("safety standards") contain the terms "rebuilding" and "first stage manufacturer". Your question, however, is clear: when new and used components are used in rebuilding a heavy truck, at what point does the truck become a "new" vehicle which must comply with all safety standards that apply to trucks.

The agency's regulation on Combining new and used components, 49 CFR 571.7(e), provides:

"When a new cab is used in the assembly of a truck, the truck will be considered newly manufactured for purposes of compliance with the safety standards and other provisions of the Act unless the engine, transmission, and drive axle(s) (as a minimum) of the assembled vehicle are not new, and at least two of these components were taken from the same vehicle".

Thus, in terms of your question, if the three major components are reused in the rebuilding process and at least two of the three came from the same vehicle, the Federal motor vehicle safety standards do not apply even if a new cab is used. But if one of the three components is new, or if all are used and came from three different motor vehicles, then the standards apply and the truck must meet them, and be certified as meeting them, upon final assembly.

Your reference to "first stage manufacturer" implies that there may be rebuilding fact situations in which the process is completed by a person other than the manufacturer who initiated it. If the rebuilt truck is "new", then its assemblers are subject to 49 CFR Part 568 Vehicle Manufactured in Two or More Stages. If the truck meets the definition of "incomplete vehicle", then the "incomplete vehicle manufacturer" is required to furnish the specified compliance information necessary for certification to the "intermediate stage manufacturer" or the "final stage manufacturer" as the case may be (Sec. 568.3).

"2) When a truck chassis is built by a dealer and legally classified as 'new manufacturing' what federal regulations must be complied with that do not apply when the vehicle is considered rebuilt?"

As indicated above, the truck must be completed to comply with all safety standards that apply to trucks and be certified by its assembler as so conforming in accordance with Part 567 Certification. If more than one party is involved in the remanufacturing process, each party is subject to Part 568. In addition, any party remanufacturing a truck that must be certified as conforming is required to file a statement in the form prescribed by Part 566 Manufacturer Identification.

"3) What penalties exist for failing to comply with these Federal regulations?"

As provided by section 109(a) of the act, any person violating any provision of the Act or a regulation issued thereunder is subject to a civil penalty of up to $1000 for each violation, up to $800,000 for any related series of violations. In addition, under Section 110(a) of the Act, the agency may seek to restrain the manufacture, sale, offer for sale, introduction, or delivery for introduction into interstate commerce of any rebuilt truck that should have met Federal motor vehicle safety standards but in fact did not do so. Also, section 154 of the Act requires manufacturers to conduct recall campaigns and remedy any non-compliances with applicable safety standards.

I hope this information is helpful. Sincerely, Jeffrey R. Miller Chief Counsel

February 25 1985 Mr. Steve Wood Office of the Chief Counsel National Highway Traffic Safety Administration U. S. Department of Transportation 400 7th Street, SW Washington, DC 20590

Dear Mr. Wood:

Thank you for your telephone assistance Friday morning, and for directing our question to the appropriate individual.

The American Truck Dealers division of the National Automobile Dealers Association represents over 1,700 medium and heavy duty truck dealers. Many of our members are engaged in the business of rebuilding and remanufacturing heavy duty trucks. On their behalf, we are requesting NHTSA provide guidance on the following questions.

1) When rebuilding a used truck with a glider kit, it is our understanding that the process is considered "rebuilding" when the three major components (engine, transmission, and rear axle) are reused in the rebuilding process. If one or more of these major components is new, does the production of the truck chassis change its legal character from "rebuilding" to "first stage manufacturer"?

2) When a truck chassis is built by a dealer and legally classified as "new manufacturing", what federal regulations must be complied with that do not apply when the vehicle is considered rebuilt?

3) What penalties exist for failing to comply with these federal regulations?

Your assistance in answering these questions and providing specific citations is greatly appreciated. If our questions require additional detail, please feel free to contact me at the above number.

Sincerely, James H. Westlake Associate Director, ATD

ID: 1985-03.12

TYPE: INTERPRETATION-NHTSA

DATE: 07/09/85

FROM: AUTHOR UNAVAILABLE; Jeffrey R. Miller; NHTSA

TO: Yoshikazu Ito, Manager, Tokai Rika Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Yoshikazu Ito, Manager Technical Operations Section Overseas Operations Dept. Tokai Rika Co., Ltd. Oguchi-Cho, Aichi Pref. 480-01 Japan

Thank you for your letter concerning the buckle release requirements of Standard No. 208. Occupant Crash Protection. I apologize for the delay in responding to it. You asked for an interpretation of the requirement in S4.5.3.3(a) of the standard that automatic belts must have an emergency release mechanism that is "readily accessible to a seated occupant." The following discussion addresses the specific questions you asked.

The purpose of the "readily accessible" requirement is to ensure that a seated occupant can quickly and easily grasp and then release the buckle in an emergency. You explained that you have been reviewing the accessibility of possible installation locations for the emergency release by using a 5th percentile female and 50th percentile male test dummy in various seating positions. You ask whether in determining if the buckle is readily accessible, you can move the pelvic portion of the test dummy or move the seat back to permit the grasping of the buckle.

The purpose of S4.5.3.3(a) is twofold. First, it is intended to make sure automatic belts are adjustable to fit a wide range of vehicle occupants, as specified in S7.1 of the standard. In addition, it is meant to ensure that the emergency release mechanism for the automatic belt is readily accessible to that same range of occupants. Thus, the release mechanism should be accessible to those occupants with the seat in any design position without the occupant having to take special steps, such as moving the seat back, to grasp and operate the release. I note that the drawing you attached to your letter indicates that your emergency release is located within the latchplate access zone specified in S7.4.4 of the standard. Although S7.4.4 does not apply to the emergency release mechanism of automatic belts, its purpose is to make it easy for occupants to reach the latchplate of a safety belt system. We would consider any emergency release mechanism required by S4.5.3.3(a) that is within the latchplate access zone of S7.4.4 to be readily accessible as long as the occupant does not have to take any special steps to grasp and operate the release.

If you have any further questions, please let me know.

Sincerely,

Jeffrey R. Miller Chief Counsel

TOKAI RIDA CO., LTD.

ESL85/1-7955 February 22, 1985

Ms. Betrinere Stewart Library Technician Technical Reference Division National Highway Traffic Safety Administration U.S. Department of Transportation 400 Seventh Street, S.W. Washington D.C. 20590 U. S. A.

Dear Ms. Stewart:

Although somewhat belatedly, I would like to express my sincere appreciation to your many kindest assistances extended to me when I visited your office. The information we received from you is very valuable.

In the meantime, we have some questions regarding how a sentence of Standard No. 208 should be interpreted, and its details are explained in the attachment.

Would you therefore please give us appropriate answer, and if you are not in a position to reply, you would kindly pass this question to a competent officer so that we may receive the answer.

Your favourable consideration in this matter would be much appreciated.

Yours sincerely,

TOKAI RIKA CO., LTD.

Yoshikazu Ito, Manager Technical Operations Section Overseas Operations Dept.

YI/yi

Attachments

CC: Mr. T. Tanabe, TR/USO

Stipulation: S4.5.3.3, No. 208

An automatic belt furnished pursuant to S4.5.3. shall: (a) conform to S7.1 and have a single emergency release mechanism whose components are readily accessible to a seated occupant.

1. Background of the question:

In designing of a certain passive belt system to be installed on our customer's vehicles, a detachable type buckle for emergency release is built in.

When installing the system on the vehicles, it is difficult for a seated occupant to access to the buckle in some cases (See attachment). So we ask you to give us your appropriate interpretation on the following cases.

2. Question

-1. What is a meaning of the sentence, " ..... whose components are readily accessible to a seated occupant"?

(Our Interpretation)

"readily accessible to" means strictly that a seated occupant can grasp the buckle and then release it in case of emergency.

-2. When reviewing installation condition by using Alderson female dummy (5th percentile), at any seating position (forwardmost, neutral or rearmost), if it is difficult that the dummy access to the buckle, whether the following condition(s) are permitted or not:

a. an occupant (dummy) would be permitted to raise her pelvic portion slightly in order to grasp the buckle.

b. an occupant (dummy) would be permitted to bring down the seat-back in order to grasp easily the buckle.

-3. When reviewing installation condition by using Alderson male dummy (50th percentile), at forwardmost and neutral seating position, if it is difficult that the dummy access to the buckle, whether the followings are permitted or not:

a. the same to above condition - 2-a.

b. the same to above condition - 2-b.

ID: nht87-1.33

TYPE: INTERPRETATION-NHTSA

DATE: 02/20/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Bruce Torrey -- Product Performance Specialist, General Electric Company

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Bruce Torrey Product Performance Specialist General Electric Company One Plastics Avenue Pittsfield, MA 01201

Thank you for your letters of August 13, and 26, 1986, concerning how the requirements of Standard No. 205, Glazing Materials, apply to glazing materials installed in the side windows of some New York City Transit Authority (NYCTA) buses. As explained be low, the information you provided in your letters and in your phone conversations with Stephen Oesch of my staff and the information provided by NYCTA in a June 19, 1986 letter to the agency indicates the glazing materials installed in the NYCTA buses do not comply with the marking requirements of the standard.

You explained in your letter that the glazing material used in the side and standee windows in the buses is Lexan sheet, which is a plastic material manufactured by General Electric. According to your letter, the Lexan glazing material used in these wind ows can meet all of the performance requirements set in Standard No. 205 for "AS-5" glazing materials. However, the material apparently was not marked as "AS-5" material, but may have instead been marked "AS-4/6." (Information provided to the agency by t he NYCTA in June 1986 indicates that the windows did not contain any "AS" number. At the time of your phone conversation with Mr. Oesch, you had not been able to confirm what markings, if any, had been placed on the glazing material by General Electric).

Standard No. 205 specifies performance and location requirements for glazing used in new vehicles and glazing sold as replacement equipment. (The various types of glazing are designated as "items" in the standard): Plastic glazing materials, such as Lexa n, can be used in a number of different locations in a bus depending on which performance requirements the glazing meets. If the plastic glazing meets the requirements set for AS-5 glazing materials, it can be used in any window in a bus, except for the windshield, windows to the immediate right and left of the driver and the rearmost windows if used for driving visibility.

In addition to setting performance requirements for different items of glazing, the standard requires glazing materials to contain certain markings. The marking requirements of S6 of the standard vary depending on the intended use of the glazing and the person that is marking the glazing. At a minimum, the standard requires the glazing to be marked pith the AS number (which indicates that the material meets the performance requirements set for that "item" of glazing material), a model number and the man ufacturer's logo. The information the agency has received about the markings on the glazing installed in the NYCTA buses indicates that the glazing does not have an AS number marked on it.

Any glazing sold for use in a motor vehicle must conform to the applicable requirements of Standard No. 205. Since there appears to be an apparent noncompliance, General Electric is required by Part 573 of our regulations to file a report with the agency providing additional details about the noncompliance and General Electric's plans to remedy the noncompliance. As you requested of Mr. Oesch, I am also enclosing a copy of the agency's regulation concerning the filing of a petition for a determination t hat a noncompliance is inconsequential.

If you have any further questions, please let me know.

Sincerely,

Erika Z. Jones Chief Counsel Enclosures

August 26, 1986

Office of the Chief Council National Highway Traffic Safety Administration 400 7th Street, S.W. Washington, D.C. 20590

Re: Letter from General Electric Company - August 13, 1986

Gentlemen:

In reference to my letter dated August 13, 1986 concerning the incorrect marking of glazing materials a matter of some urgency has come to my attention. It seems that the New York City Transit Authority is exercising exceptional prudence with regard to t his matter. If this situation continues hundreds of thousands of dollars worth of perfectly good material will be excluded from use.

It would be greatly appreciated if you could respond to the following.

Mr. William Wallace New York City Transit Authority 25 Jamaica Avenue Brooklyn, NY 11207

Mr. R.J. Watters Commercial Plastics & Supply Company Transportation Division 1620 Woodhaven Drive Cornwells Heights, PA 19020

If you have any questions or concerns please feel free to contact me. I can be reached at (413)448-7629. I thank you in advance for you cooperation.

Regards,

Bruce M. Torrey Product Performance Specialist

August 13, 1986

Office of the Chief Council National Highway Traffic Safety Administration 400 7th Street S.W. Washington, D.C. 20590

Re: Incorrect Glazing Marking

Gentlemen:

In order to satisfy the Department of Transportation in New York City I need an official statement concerning the following matter.

Lexan sheet, manufactured by General Electric Company is a plastic (polycarbonate) material typically used for bus side windows and standee glazings. These products are tested per ANSI Z26.1 standards on a regular basis and submitted to AAMVA for verific ation and certification.

During this process our Lexan@ MR-5000 Bronze tinted material was assigned an AS 4/6 designation, as it appears on the Notice of Equipment Compliance from AAMVA. Apparently a misinterpretation of ANSI Z26.1 test NO. 2 which requires minimum light-transmi ssion value of 70%. (1/4" Bronze Lexan@ MR5000 has a value of 53%).

Instead of being appropriately marked, AS-5, they received the AS 4/6 marking.

The following, details pertinent information.

Material Distributor:

Commercial Plastics & Supply Corp. Transportation Division 1620 Woodhaven Drive Cornwells Heights, PA 19020

Bus Manufacturer:

Blitz Bus & Truck 4525 W. 26th Street Chicago, IL 60623

This particular situation involves some 3,000 side windows and another 390 standee windows.

Enclosed you will find supporting test data and a copy of our original Notice of Equipment Compliance.

If you have any questions please feel free to contact me. I can be reached at (413)448-7629.

Regards,

Bruce M. Torrey

Enclosures Omitted.

ID: nht87-1.53

TYPE: INTERPRETATION-NHTSA

DATE: 03/27/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Thomas R. Fahl

TITLE: FMVSS INTERPRETATION

TEXT:

Thomas R. Fahl, Esq. Brendel, Flanagan, Sendik & Fahl, S.C. 6324 West North Avenue Milwaukee, Wisconsin 53213-2099

Dear Mr. Fahl:

This responds to your letter to Dr. Richard Strombotne, the chief of our Crashworthiness Division. In your letter, you posed three questions about child restraint systems. I will answer those questions in the order you presented them.

1. Does NHTSA have information as to where a family with two children 3 years of age or under should put the second of two child restraint systems, assuming that the safest place for one is the middle of the rear seat?

NHTSA has not specifically addressed this topic in any of our regulations or recommendations. We believe, however, that in this situation both child restraint systems should be placed in the rear seat. This belief is based on the generally greater distan ce from the rear seat to the interior surface in front of that seat and the fact that the interior surface in front of the rear seat is primarily the rear of the front seats. The rear of the front seats tends to be a less hostile surface than the dashboa rd. Additionally, crash data show that all vehicle occupants (both adults and children) suffer fewer injuries and fatalities in the rear seating positions than in the front seating positions.

2. Has NHTSA developed any rules or regulations suggesting or requiring that manufacturers of child restraint systems advise the consumer where to put a second child restraint, assuming that two children under 3 years of age will be occupying a motor veh icle at the same time and also assuming that neither child restraint system is a backward facing system?

No, NHTSA has not imposed any such requirements. With respect to child restraints manufactured before August 12, 1986, section S5.6.1 of Standard No. 213, Child Restraint Systems (49 CFR S571.213) specified that: "The instructions shall state that the re ar center seating position is the safest seating position in most vehicles for installing a child restraint system." For child restraints manufactured on or after August 12, 1986, section S5.6.1 requires: "The instructions shall state that, for maximum s afety protection, child restraint systems should be installed in a rear seating position in vehicles with two rear seating positions and in the center rear seating position in vehicles with such a seating position."

NHTSA has somewhat modified its position about the rear center seating position being the safest place to install a child restraint system in a recent rulemaking action amending Standard No. 210, Seat Belt Assembly Anchorages (49 CFR S571.210). Please no te that this standard applies only to vehicle manufacturers, and not to child restraint manufacturers. However, in an August 19, 1986 rule (51 FR 29552; copy enclosed), section S6(b) of Standard No. 210 requires the owners manual for vehicles manufacture d after September 1, 1987 to state that "according to accident statistics, children are safer when properly restrained in the rear seating positions than in the front seating positions." We are currently considering whether Standard No. 213 should be ame nded to include similar language. However, neither of these requirements specifically addresses the situation where two child restraints are to be installed in the same vehicle.

3. Has NHTSA done studies to determine that the right front passenger seat is not an appropriate place for a child restraint system and, if so, what are the results of those studies?

No study of which we are aware, whether done by this agency or any other party, suggests that the right front passenger seat is not an appropriate place for a child restraint system. In fact, those studies of which we are aware indicate that a properly i nstalled child restraint system in the right front passenger seat will afford the child occupant a high level of safety protection in a crash situation. The safety protection can be maximized by properly installing the child restraint in a rear seating p osition, but we are aware of no basis for stating that the right front passenger seat is not an appropriate place for a child restraint system.

If you have any further questions on this subject or need more information, please feel free to contact Steve Kratzke of my staff at this address or by telephone at (202) 366-2992.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

September 17, 1986

Mr. Richard L. Strombotne Chief, Crashworthiness Division U.S. Dept. of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Strombotne:

In conjunction with a matter upon which I am presently working in this office I am in need of information relative to child restraint systems and pose the following inquiries to you

1. Does the National Highway Traffic Safety Administration have information as to where a family with 2 children 3 years of age or under should put the second of 2 child restraint systems assuming that the safest place for one is the middle of the rear s eat?

2. Has the National Highway Traffic Safety Administration developed any rules or regulations suggesting or requiring that manufacturers of child restraint systems advise the consumer where to put a second child restraint system assuming that 2 children u nder 3 years of age will be occupying a motor vehicle at the same time and also assuming that neither child restraint system is a backward facing system?

3. Has the National Highway Traffic Safety Administration done studies to determine that the right front passenger seat is not an appropriate place for a child restraint system and if so what are the results of those studies?

In the event the Administration has developed background information pertaining to any one of the three areas about which I am making an inquiry I would appreciate your directing me to that information or sending copies to me.

Very truly yours,

Thomas R. Fahl

TRF:mhs

ID: nht87-1.7

TYPE: INTERPRETATION-NHTSA

DATE: 01/09/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Lewis H. Goldfarb -- Assistant General Counsel, Chrysler Corporation

TITLE: FMVSS INTERPRETATION

TEXT:

Lewis H. Goldfarb, Esq. Assistant General Counsel Chrysler Corporation P.O. Box 1919 Detroit, Michigan 48288

This responds to your letters asking about Federal Motor Vehicle Safety Standard No. 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect, with regard to a design you are considering producing. You asked whether the standard's requirement that identification of shift lever positions of automatic transmissions shall be permanently displayed in view of the driver would be met by an electronic display that is activated for three minutes after the driver's door b open, whenever the key is in the ignition switch, and for three minutes after the key is removed from the ignition switch. You later asked about a variation of the proposed design. Noting that drivers sometimes leave the key in the ignition switch for long per iods of time, you stated that you planned to incorporate a timing device which would shut off the illumination after 15 minutes if the key is left in the ignition switch and the ignition switch remained in either the "lock" or "off" position. As discusse d below, it is our opinion that neither of your proposed designs would meet the standard's requirement for permanent display in view of the driver.

By way of background information, the National Highway Traffic Safety Administration (NHTSA) does not provide approvals of motor vehicles or motor vehicle equipment. Under the National Traffic and Motor Vehicle Safety Act, it is the responsibility of the manufacturer to ensure that its vehicles or equipment comply with applicable standards. The following represents our opinion based on the facts provided in your letter.

Section S3.2 of Federal Motor Vehicle Safety Standard No. 102 requires that the "(i)identification of shift lever positions of automatic transmissions and of the shift lever pattern of manual transmissions . . . shall be permanently displayed in view of the driver." (Emphasis added) NHTSA has previously interpreted this provision as requiring a display that can be seen regardless of the operating mode of the engine. Thus, it is not permissible for the display to be visible (e.g., in the case of an elect ronic display, be activated) only when the key is in the ignition switch.

Your letter raises the issue of whether it is permissible for an electronic display to become activated at the time the driver enters the car and, if so, whether it must remain activated indefinitely as long as the driver remains in the car, even if the ignition is not turned on. is our opinion that is permissible for an electronic display to become activated at the time the driver enters the car and need not be activated when there is no person in the driver's seating position. Section S3.2's requireme nt that the identification of shift lever positions of automatic transmissions be "permanently displayed" is modified by the phrase "in view of the driver." It is our opinion that no such display is required at times when no driver is in the car, i.e., n o person in the driver's seating position. We also conclude, however. that such a display must remain activated indefinitely as long as the driver remains in the driver's seating position even if the ignition is not turned on. If the display only remaine d activated for a specific period of time, such as three minutes or 15 minutes, it would not be "permanently" displayed.

Sincerely,

Erika Z. Jones Chief Counsel

October 7, 1986 Ms. Erika Z. Jones Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington. D.C. 20590

Re: Confirmation of Interpretation of MVSS 102, Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect

Dear Erika:

Chrysler Motors Corporation requests confirmation of our interpretation that the PRNDL display in a new electronic cluster we are designing for one of our 1990 model vehicles meets the requirements of paragraph S3.2 of MVSS 102, "Transmission Shift Lever Sequence, Starter Interlock, and Transmission Braking Effect." That paragraph states in part that "Identification of shift lever positions of automatic transmissions...shall be permanently displayed in view of the driver."

We believe this provision is intended to provide that the PRNDL should be displayed to a person in the driving position for the purpose of operating the vehicle. It is not intended, however, to require the display of the PRNDL when there is no one engage d in operating or "driving" the vehicle and where the continuous lighting of an electronic PRNDL display would be a serious drain on the vehicle's battery.

In our new electronic instrument cluster design, the PRNDL display illuminates and displays the transmission gear position as soon as the driver's door is opened. This feature provides the driver an immediate indication of the position of the transmissio n gear selector just as does a conventional "mechanical" PRNDL indicator. With our design the transmission gear selector position will continue to be lighted if the ignition key is inserted into the ignition lock cylinder within approximately three minut es. The only difference between our electronic PRNDL display and a mechanical one is that, to save battery strength when the vehicle is not being driven, our electronic indicator will turn off after three minutes unless the driver inserts the key in the ignition key cylinder.

Should the PRNDL display turn off after a three minute period, however, inserting the ignition key will cause it to come on immediately, and it will remain on as long as the key is in the ignition switch. The three minute period is more than sufficient t ime to allow the driver to get settled in the seat, fasten the safety belt, and insert the ignition key. When the trip is completed and the key is removed from the ignition lock, the PRNDL display remains lighted for approximately three minutes while the driver unfastens safety belts, picks up articles, exits, and locks the vehicle.

We believe that the design of our electronic PRNDL display meets the intent as well as the needs of motor vehicle safety as stated in the requirements of paragraph S3.2 of MVSS 102.

In summary, the shift lever position will be displayed to the driver while the driver enters the vehicle, while the ignition key is in the ignition lock, and while the driver exits the vehicle.

We would appreciate your early consideration and confirmation of this interpretation.

Sincerely,

Lewis H. Goldfarb

CC: R. O. Sornson

ID: nht87-1.85

TYPE: INTERPRETATION-NHTSA

DATE: 06/03/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Gabriel J. Ferber -- Nesper, McElvein, Ferber and Digiacomo

TITLE: FMVSS INTERPRETATION

TEXT:

This responds to your letter to Mr. George Shifflett of our Office of Vehicle Safety Compliance, in which you sought an interpretation of 49 CFT Part 541, Federal Motor Vehicle Theft Prevention Standard. You asked whether Part 541 markings must be inscri bed on certain Canadian vehicles not originally manufactured for sale in this country. More specifically, you referred to @541.5(a), which provides, "In the case of passenger cars not originally manufactured to comply with U.S. vehicle safety and number standards, each such car subject to this standard must have an identifying number inscribed in a manner which ..." (Emphases added). You stated that your client is a direct importer of Canadian vehicles subject to the theft prevention standard. You state d that these vehicles have identification numbers affixed to the required major parts by their original manufacturer. While these Canadian vehicles are not certified as complying with the U.S. vehicle and bumper standards, you asserted that they are orig inally manufactured to comply with U.S. vehicle safety and bumper standards. Accordingly, you believe that Part 544 does not require these vehicles to have the identification number inscribed on the parts, but instead requires the identification number t o be inscribed or affixed. Since the original manufacturer has already affixed identification numbers on these vehicles, you believe your client is not required to add any identification number markings to these vehicles before certifying that they compl y with Part 541.

The crux of your argument is that those vehicles can be shown to be originally manufactured to comply with U.S. vehicle safety and bumper standards, even though they are not certified as being so. We agree that this is possible, but it would take some ve ry convincing proof to establish this point. The Canadian safety standards are very similar to, but not identical with, the U.S. safety standards. Hence, the fact that a vehicle is certified as complying with Canadian safety standards does not establish that the vehicle was originally manufactured to comply with U.S. vehicle safety standards.

Your letter stated that "compliance with U.S. safety and bumper standards is shown by reliance on the 'V73' designation or some other method." The V73 designation to which you refer is an internal billing code used by General Motors on the sales receipts for some vehicles. While you assert that this billing code designation means that the vehicle complies with U.S. vehicle standards, we have no confirmation from General Motors of this point. Further, vehicle manufacturers assign whatever meanings they c hoose to their billing code designations, and are free to change the assigned meanings whenever they wish. Because of this, we conclude that you have not established that these vehicles were originally manufactured to comply with U.S. vehicle safety and bumper standards simply because they show a V73 designation in their billing code. Absent a more convincing showing that these vehicles were originally manufactured to comply with U.S. vehicle safety and bumper standards, S541.5(a) requires your client t o inscribe the identifying number on the various covered major parts.

I would also like to point out that your client could not certify compliance with the theft prevention standard by relying on the presence of the GM labels, even if your client were allowed to affix identifying markings. Please note that @541.5(d)(l)(vii i) requires, "The logo or some other unique identifier of the vehicle manufacturer must be placed in the material of the label in a manner such that alteration or removal of the logo visibly alters the appearance of the label." In this case, your client is considered the manufacturer, since it seeks to directly import these Canadian vehicles. The affixed GM labels presumably do not show the logo or some other unique identifier of your client, the direct importer. Accordingly, the GM labels would not sat isfy the requirements of @541.5(d)(1) for those vehicles for which your client is a direct importer.

NHTSA explained at length in the final rule establishing the theft prevention standard why it was necessary to have all required markings inscribed on directly imported vehicles subject to the theft prevention standard. See 50 FR 43166, at 43184-85: Octo ber 24, 1985. The agency also explained why it was necessary that affixed labels have the logo or some other unique identifier of the manufacturer in the labels. Ibid., at 43174-75. I have enclosed a copy of this rule for your information.

Sincerely,

Erika Z. Jones Chief Counsel

Enclosure

Mr. George Shifflett Department of Transportation NHTSA Director, Office of Vehicle Safety Compliance NEF 32 400 - 7th Street, S.W. Washington, D.C. 20590

Dear Mr. Shifflett:

I would like to offer the following for your consideration in determining whether the VID numbers must be inscribed on GM vehicles which already bear labels with such numbers affixed by the manufacturer.

Section 541.5 requires inscription in the case of passenger cars not originally manufactured to comply with U. S. vehicle safety and bumper standards. Our client only brings in vehicles which do comply with such standards. This is true notwithstanding th e fact that the manufacturers certifying label may have been modified to state that the vehicle complies with Canadian safety, bumper and anti-theft standards. In such case, compliance with U. S. safety and bumper standards is shown by reliance on the 'V 73' designation or some other method. In such case, we then comply with the certification requirements under Section 567.4.

The certification requirement under Section 567.4 is, of course, separate from the inscription requirement under Section 541.5. The inscription requirement is not triggered by a manufacturer's failure to certify compliance, it is triggered by the failure of the vehicle to be manufacturered to comply with U. S. vehicle safety and bumper standards. Since the vehicles in question are, in fact, manufactured to comply with U. S. vehicle safety and bumper standards, albeit not certified as such, it is submitt ed that there is no requirement that such vehicles be inscribed and the manufacturer's label should suffice.

Thank you for your consideration of this submission. Please let me know whether you agree.

Yours truly,

NESPER, McELVEIN, FERBER & DiGIACOMO

By Gabriel J. Ferber

GJF/gw

cc: Steven Kratzke, Esq. Superior Auto Sales, Inc.

ID: nht87-2.3

TYPE: INTERPRETATION-NHTSA

DATE: 06/09/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Wil de Groot -- President, Exoticars of Hunterdon

TITLE: FMVSS INTERPRETATION

ATTACHMT: 2/24/87 letter from Erika Z. Jones to Wil de Groot

TEXT:

Mr. Wil de Groot President Exoticars of Hunterdon 6 Washington Street Frenchtown, NJ 08825

This is in reply to your letter of April 12, 1987, with respect to your further questions on Federal regulation of kit cars.

You have presented the following facts: the engine, transmission, final drive, axles, suspension, steering, brakes, heating and defrosting equipment, windshield wiper motor and mechanisms, instruments, switches, controls, wiring harness, fuel tank, seat belts, door and ignition switch buzzer system, door handles, latches and locks, impact absorbing bumper supports, and other unnamed components, all previously used on a vehicle meeting Federal safety standards would be retained for use with a new body of your own manufacture.

Your first choice is to install these items upon a new chassis of your own manufacture, and to supply the vehicle to a purchaser fully assembled. This is what must be met under these circumstances: when a new body is mounted upon a new chassis, the resul ting vehicle must comply with all Federal motor vehicle safety standards applicable upon the date of its assembly, even if the parts that you named are used. Further, the assembler must certify that the vehicle complies with safety standards. There is no legal obligation to use new parts in order to certify compliance with the standards. The assembler is regarded as a manufacturer of motor vehicles, and must notify owners and remedy noncompliances with the safety standards or safety related defects shou ld they occur, in accordance with Federal law and regulations.

If you supply all parts, but do not complete assembly of the vehicle, we should regard you nevertheless as its manufacturer and subject to the requirements stated above. However, if you do not supply all parts, the question of whether you would be regard ed as the manufacturer would necessarily depend upon the parts that the purchaser must supply in order to compete assembly.

You have also stated your second choice: that the new body would be mounted upon the original chassis, modified to accept it. In this circumstance, when a new body is mounted upon a used chassis, the resulting vehicle is not subject to Federal motor vehi cle standards that apply to new vehicles, and there is no certification obligation. Nevertheless, its assembler is a "manufacturer" under federal law and responsible for notification of owners and remedy of any safety related defects that may occur in th e product. Further, if the assembler is the person responsible for removing the old body, he must ensure that the reassembled vehicle continues to meet the standards that originally applied to the vehicle which might have been affected by removal of the old body. For example, if the body of a 1974 Jaguar XJ6 is removed, compliance with a number of standards such as those covering glazing, lighting, and windshield retention is affected and the reassembled vehicle must then meet the standards that were in effect in 1974. But, standards covering such things as accelerator control systems and brake hoses would not appear to be affected by the disassembly of the original vehicle, and the assembler is under no obligation to ensure that the reassembled vehicle continues to meet those standards.

If the used-chassis vehicle is supplied partially disassembled, but all parts are supplied, we would nevertheless regard the supplier as subject to all obligations discussed above, assuming that he was the person responsible for removal of the old body. If all parts are not supplied, the answer remains as before: whether the supplier is a "manufacturer" depends upon the parts that the purchase must provide.

Finally, you have asked, "if actual crash tests. . .have to be made what is the cost and where is this done?" There is no express legal requirement that a manufacturer of new motor vehicles conduct crash tests in order to certify compliance with those st andards where compliance can be demonstrated through barrier impacts. A manufacturer is required to exercise due care to ensure that his vehicle, if crashed, would meet the performance requirements of those standards incorporating barrier impact test pro cedures, but his certification may be based upon computer simulations, engineering studies, mathematical calculations, etc. We cannot advise you as to the cost of such tests, and suggest you write the Motor Vehicle Manufacturers Association (MVMA) for in formation on facilities that perform them. MVMA's address is 1620 I Street, N.W., Washington, D.C.

I hope this answers your questions.

Sincerely,

Erika Z. Jones Chief Counsel

MS. ERIKA Z. JONES U.S. DEPT. OF TRANSPORTATION NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION 400 SEVENTH STREET, S.W. WASHINGTON, D.C. 20590

4.2.1987

Dear Ms. Jones,

Thank you for your reply of Feb. 24 1987 to my letter of January 12, 1987 regarding regulations for home built or car kits.

What we have in mind is to take, for example, a 1974 Jaguar XJ6 (federal version) remove the engine, transmission, final drive, suspension, steering, brakes, etc. and all safety and emission related items and after refurbishing these parts, install them on a new chassis with a new body of our own (U.S.) manufacture. We are familiar with the process of bringing a gray market car into compliance with Federal regulations, having gone through the process and wondering if this same process, complete with all applicable engineering data, photo's and paperwork could somehow be applied to a limited production rebodied and rechassied vehicle without the expense of crashing cars into a wall.

If actual crash tests have to be made what is the cost and where is this done?

The following are the specifics that I hope will allow you to give me the answers I am looking for,:

-Chassis- New made in U.S.A. (first choice) -Chassis- Used original chassis but modified to accept new body (second choice)

-Old parts used- Engine, transmission, final drive, axles, brakes, steering, heating and defrosting equipment, windshield wiper motor and mechanisms, instruments, switches, controls, wiring harnesses, seats, fuel tank, seat belts, door and ignition switc h buzzer system, door handles, latches and locks. Impact absorbing bumper supports, etc.

-Suppled to Consumer fully assembled- (first choice) -Supplied partially disassembled- all parts supplied (second choice) -Supplied partially disassembled- all parts not supplied (third choice)

-Parts- Used would come from federal version of imported cars or domestic cars. All parts including new would meet D.O.T. & E.P.A. specifications.

Thank you in advance, I hope you can help us.

Sincerely,

Wil de Groot, President