ID: aiam4736

"Dear Mr. Martin: This responds to your letter to this agency's Publi Affairs Office asking about the application of Safety Standard (FMVSS) No. 301, Fuel System Integrity, to a van used by a correctional institution to transport inmates. Your letter has been referred to me for reply. I regret the delay in responding. As you may know, the National Highway Traffic Safety Administration (NHTSA) is authorized by the National Traffic and Motor Vehicle Safety Act to issue safety standards for new motor vehicles and motor vehicle equipment. NHTSA issued Standard No. 301 to reduce deaths and injuries resulting from fuel spillage in crashes. The standard applies to new vans manufactured on or after September 1, 1976, that have a gross vehicle weight rating (GVWR) of 10,000 pounds or less. Under the Vehicle Safety Act, each manufacturer of a motor vehicle or item of motor vehicle equipment is responsible for certifying that its products meet all applicable safety standards. Thus, if the vans in your letter were manufactured on or after September 1, 1976, the van manufacturer was required to certify their compliance with Standard No. 301. However, even if the vans did not comply with that standard, the Act does not place any responsibility for that noncompliance on the first purchasers and subsequent owners of the vans. Since some states do require that vehicles used for certain purposes comply with our standards, you may wish to address your question to appropriate State authorities in Tallahassee. We regret we cannot provide the testing you seek. NHTSA obtains and tests new vehicles for compliance with FMVSS No. 301. However, since the standard applies only to new vehicles, NHTSA does not conduct compliance tests on vehicles that have already been sold to a consumer. The agency also cannot test every new type or model of vehicle, since it would be impracticable to do so. For your information, Safety Standard No. 217 specifies emergency exit requirements for vans designed to carry 11 or more persons. However, the standard excludes vans purchased for transporting prison inmates. This exclusion resulted from a determination that the standard's requirements were incompatible with the necessity that buses used for transporting inmates be able to confine their occupants in transit. I have enclosed a copy of Standard No. 217 for your information. You also asked whether we require roll bars on vehicles used to transport 12, 13 or 14 passengers. The answer is no. However, NHTSA does have a standard for roof crush protection (Standard No. 216) which requires the roof over the front seating area of cars to meet certain strength requirements. NHTSA has proposed to extend the standard to light trucks and buses (GVWR of 10,000 pounds or less). I have enclosed a copy of that proposal for your information. Sincerely, Stephen P. Wood Acting Chief Counsel Enclosure";

ID: aiam0288

Dear Mr. Rocker: This is in reply to your letter of January 28, 1971, requesting a interpretation of Motor Vehicle Safety Standard No. 213. Although your letter refers to S4.11(d) as the paragraph with which you are concerned, it appears from the text of your letter that you are requesting an interpretation of paragraph S5.1(d).; S5.1 of the standard specifies the test procedure that will be used b NHTSA to determine whether the child seating system meets the force resistance requirements specified in S4.1 of the standard. S5.1(d), the passage in question, reads as follows:; >>>'Apply an increasing load to the torso block in a forward direction not more that 15 degrees and not less that 5 degrees above the horizontal, until a load of 1,000 pounds is achieved. The intersection of the load application line and the back surface of the torso block, at the time that the force removes the slack from the load application system, shall not be more that 8 inches or less that 6 inches above the bottom surface of the torso block. Maintain the 1,000-pound load for 10 seconds.'<<<; Your question is whether the angle at which the force is applied, eve though initially between 5 degrees and 15 degrees above the horizontal, may move outside the range during application of the specified force.; The answer to your question is no. The relevant wording of th standard, that the force is to be applied in a forward direction 'not more than 15 degrees and not less than 5 degrees above the horizontal, *until a load of 1,000 pounds is achieved*,' clearly requires that the direction of the test force remain within the specified angular limits throughout the period of force application.; Please write if you have further questions. Sincerely, Lawrence R. Schneider, Acting Chief Counsel

ID: maxon_threshold7346

S. Lafferty, Manager, Engineering
Maxon
16205 Distribution Way
Cerritos, CA 90703




Dear Ms. Lafferty:

This responds to you letter in which you asked about the threshold warning requirements under Federal Motor Vehicle Safety Standard (FMVSS) No. 403, Platform lift systems for motor vehicles. You stated that there is an apparent discrepancy between the threshold warning system requirement and the associated test procedure, and asked which takes precedent. As explained below, the specified test procedure for the threshold warning system requirement is consistent with that requirement.

As part of FMVSS No. 403, the agency established a threshold warning signal requirement for platform lifts in part to minimize the risk of a lift user backing off a vehicle before a lift is properly positioned. S6.1 of FMVSS No. 403 requires an appropriate threshold warning signal to be activated when any portion of a passengers body or mobility aid occupies the platform threshold area defined in S4 of that standard, and the platform is more than 25 mm (1 inch) below the vehicle floor reference plane. A platform lift must meet this requirement when tested in accordance with S7.4 of the standard.

In your letter you stated that it is possible to design a threshold warning system that "will pass a test that is performed as described in S7.4 and not completely fulfill the requirements of S6.1.3". You described a threshold warning system designed with an optical sensor at the interior boundary of the platform threshold area. You stated that such a system would activate the warning signal only when a passenger is crossing the boundary of the threshold at the same time as the platform is lower than 25 mm from the vehicle floor. You further stated that such a system would not activate a signal if a passenger were completely within the threshold area when the platform reached the specified distance from the vehicle floor. Your letter indicated that you believe that such a system would "pass" the test procedure, but not comply fully with the requirement.

A system as you described would not comply with the requirements of S6.1.3 when tested as specified in S7.4. As stated above, S6.1 requires the appropriate warning signal to activate when tested in accordance with S7.4. S7.4.2 specifies that, with the platform lift at the vehicle floor loading position:

[P]lace one front wheel of the unloaded wheelchair test device [specified in S7.1.2] on any portion of the threshold area defined in S4. Move the platform down until the alarm is actuated. Remove the test wheelchair wheel from the threshold area to deactivate the alarm. Measure the vertical distance between the platform and the threshold area and determine whether that distance is greater than 25 mm (1 in).

Thus, S7.4.2 specifies placing the front wheel of the test device on any portion of the threshold area. As explained in 49 CFR 571.4, the use of the term "any" in connection with a range of values or set of items means generally, "the totality of the items or values, any one of which may be selected by the [agency] for testing". Accordingly, the procedure specified in S7.4.2 includes placement of the front wheel that could result in the entire test device being within the threshold area prior to the platform being lowered. This also includes placement that results in a portion of the test device being on the platform.

Given the discussion above, a system such as you described would not comply when tested under S7.4.2. As such, there is no discrepancy between the requirement of S6.1.3 and the test procedure specified in S7.4.

If you have any additional questions, please contact Mr. Chris Calamita of my staff at (202) 366-0536.

Sincerely,

Stephen P. Wood
Acting Chief Counsel

ref:403#404
d.11/3/05

ID: nht74-5.12

DATE: 03/08/74

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

TO: Toyo Kogyo Co., Ltd.

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your February 1, 1974, request for interpretation of Standard No. 106, Brake Hoses, concerning "collapse" in S9.2.8, an incorrect value in Table VI, and proper labeling format.

Your confusion about the meaning of "collapse" in S9.2.8 points out that the requirement was inadvertently changed between notices 7 and 8 and that it should require "no leakage or separation of the inner tube from the fabric reinforcement of the hose". The language will be amended in the near future.

In our response to petitions for reconsideration of Standard 106, we corrected the 5/64 value (question 2) and we accommodated labeling of short hose by permitting labeling separated by any amount up to 6 inches (question 4). You must use one line for labeling required by Standard 106, but you may interrupt the stripe on the opposite side of the required labeling with labeling for other countries, in accordance with S5.2.1 (question 5). In answer to question 3, the fractions should read 3/16, as you indicate you wish to do it.

Your associate, Mr. Hirai, asked our office for an explanation of the certification requirements of S114 of the National Traffic and Motor Vehicle Safety Act of 1966, as they apply to items of motor vehicle equipment to which a standard applies. I have enclosed a notice of clarification.

ENC.

February 1, 1974

Richard B. Dyson

Assistant Chief Counsel

National Highway Traffic Safety Administration

Re: FMVSS 106, Hydraulic Brake Hoses, Docket No. 1-5; Notice 8.

On January 31, 1974, I talked with Miss Grace Robinson, she gave me the information I requested and informed me to send an official letter for confirmation.

Toyo Kogyo has the following question on these regulations:

(Question 1)

Section 9.2.8

"...The vacuum brake hose shall not collapse in a vacuum test of 26 inches of Hg. for 10 minutes." Its' "collapse" may be allowed, if it shall not fully collapse, is this correct?

In section 9.2.6, it shall be allowed with 1/16 inches collapse, with the less severe test condition of 26 inches Hg. and even 5 minutes.

(Question 2)

In table VI dimension of test specimen and feeler gage for deformation tests.

Inside diameter of hose Spec. D (in.) 11/32 inches 3/64 is described, but we think is 11/32 5/64 correct. Is this a misprint?

1) Based on SAE J1403 table 4, 5/64 is correct.

2) Other inside diameter is complete same as the thickness.

(Question 3)

In S9.1 of labeling, may we use the 3/16, (3 and 16 are located in the same line) shape of inside diameter, instead of 3/16?

(Question 4)

In S9.1 of labeling may we describe it with 2 lines?

The length of this labeling shall be assumed with 80mm. We are using 150mm length of hose but in some cases about 55mm length one will be considered in future.

(Question 5)

May we use another labeling on the hose along with the FMVSS 106 labeling?

We are now considering utilizing the hose in another country as well as in the U.S.A.. In that case we want to describe 2-labelings at the same time on the hose. If one more labeling is located on the backside there's no confusion.

Your earliest reply will be appreciated.

Thank you.

Gorou Utsunomiya Branch Manager Toyo Kogyo Co., Ltd. U.SA. Representative Office

cc: Miss Grace Robinson

Dr. Kazushi Sakashita Mr. Eisuke Niguma

ID: nht73-4.16

DATE: 05/03/73

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: AM General Corporation

TITLE: FMVSS INTERPRETATION

TEXT: This is in reply to your letter of March 22, 1973, concerning the conformity of buses manufactured by AM General Corporation with paragraph S5.1.1 of Standard No. 217, "Bus Window Retention and Release." Your letter states, enclosing a drawing, that the side sash construction in these buses includes an aluminum tie bar that connects the upper and lower portion of the sash, and is located on the inside and at the center of the glass. You state this configuration precludes testing as specified in S5.1.1, which specifies that the head form applying the load be placed at the center of the glazing. You request that the standard be revised to permit testing with the head form located as close as possible to the center of the glazing.

Based on the information you have provided, we are of the opinion that the configuration of this window should be treated under paragraph S5.1 as two separate windows, even though only one sheet of window glazing is used. The tie bar appears to be an integral part of the window sash, and by preventing an occupant from contacting the window at that point, performs essentially the same function as a conventional divider strip. Consequently, we would expect to test this window configuration by applying the head form to the center of each half of the glazing surface.

Yours Truly,

AM General Corporation

March 22, 1973

FEDERAL MOTOR VEHICLE SAFETY STANDARDS

(49 CFR PART 571)

MOTOR VEHICLE SAFETY STANDARD NO. 217

"BUS WINDOW RETENTION AND RELEASE"

Office of the Chief Counsel National Highway Traffic Safety Administration

AM General Corporation, a wholly-owned subsidiary of American Motors Corporation, is in the process of designing a transit bus for use by Transit Authorities in the United States.

The side window sash and rear window sash construction is so designed as to make it virtually impossible to conform to the required test procedure described in FMVSS No. 217 - Bus Window Retention and Release.

Paragraph S5.1.1 states: "An increasing force shall be applied to the window glazing through the head form specified in Figure 4, outward and perpendicular to the undisturbed inside surface at the center of each sheet of window glazing, with a head form travel of 2 inches per minute."

AM General's side sash construction is as depicted on the enclosed AMG Drawing No. 5955931. Your attention is directed to the center of the glazing which reflects that at this location you will find an aluminum "tie bar" which connects the upper and lower portion of the aluminum sash.

Since this "tie bar" is an integral functional item and its location is at the center of the glazing, but not integral with respect to the glazing, it is obvious that it precludes testing according to the aforementioned test procedure of Paragraph S5.1.1.

Therefore, AM General requests clarification whether it is permitted by this standard to locate the contact of the head form as close as possible to the normal center of the glazing, without coming in contact with the "tie bar," as shown on the enclosed drawing. Should this procedure not be allowed under the current Standard No. 217, AM General requests that the requirement be revised to permit an option to test with the head form located as close as possible to the normal center of the glazing.

A similar sash type rear window with a positive lock mechanism and with a "tie bar" as herein described will be used; and it is, therefore, requested that the offset(Illegible Word) be approved or revision to the standard apply also to rear windows.

We respectfully request your prompt attention and reply. Should you require additional information pertaining to our design, do not hesitate to call on us.

Sincerely,

F. A. Stewart Vice President Safety & Reliability

Enclosure

Copy to Docket Section

ID: nht92-5.38

DATE: June 30, 1992

FROM: Lyle Walheim -- Lieutenant, Motor Carrier & Inspection Services, Wisconsin Department of Transportation

TO: Paul Jackson Rice -- Chief Counsel, NHTSA

COPYEE: Thomas Turner -- Bluebird Body Company

TITLE: None

ATTACHMT: Attached to letter dated 9/14/92 from Paul Jackson Rice to Lyle Walheim (A39; Std. 131)

TEXT:

I am writing regarding a concern raised by Mr. Thomas D. Turner, Manager, Engineering Services, Bluebird Body Co. In his letter of April 21, 1992, he requested information regarding FMVSS Standard 131. He also asked for an interpretation of how it applies to Wisconsin as well as other states that require the four warning-light system on school buses rather than the eight warning-light system now used in several states.

Wisconsin Statute S346.48(2)(a) requires that a school bus operator shall actuate such red lights at least 100 feet before stopping to load or unload pupils or other authorized passengers, etc. As stated in 346.48(1), a driver shall stop when the bus is displaying the flashing red warning lights. In addition, when the bus comes to a atop, the "stop-arm" is actuated by the opening of the service door. The service door may not be opened until the bus comes to a complete stop as stated in Administrative Rule, Trans 300.64.

In states that require an eight warning-light system, the amber warning lights are actuated when the school bus is preparing to stop; the red lights are not actuated until the bus comes to a stop. At that point, the red lights come on; the stop lights are actuated and the service door is opened. As you can see, it would not be practical to have the stop-arm extend until the bus actually stops and the door is opened.

It was our understanding that the Bluebird proposal to install a warning device that will sound when the alternating red lights are activated until the service door is opened and the stop-arm is extended would meet the requirement found in S5.5 exception.

The Wisconsin red light system has been required since 1954 and there are no plans to change to the eight light system. Conversion would be very costly and would create a great deal of confusion for the public who is used to the four light system.

It would appear that when the standard was written and implemented, no consideration was given to states who had implemented the stop-arm requirements (for safety purposes) well before they were considered for implementation in Standard 131.

Wisconsin urges you to consider approval of the warning system proposed by Bluebird Bus Company that appears to comply with the exception found in S5.5 for states that require the four red warning-light system.

Wisconsin continues to be in full compliance with SS131 except there now appears to be a difference of how S5.5 is interpreted for states with the four light system.

As previously indicated, requiring the stop-arm to be activated when the red warning lights come on will require Wisconsin to change both Statutes and the Administrative Rule to require an eight light system. This would be both very costly to retrofit and confusing to the public until total conversion by replacement of vehicles placed in operation prior to the effective date of SS131.

I have enclosed copies of Wisconsin Statutes and Administrative Rules for your information. If you have questions or need further information, feel free to call me at (608) 266-0305.

(Enclosure omitted)

ID: 1984-2.46

TYPE: INTERPRETATION-NHTSA

DATE: 08/03/84

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Terry E. Teeter -- Transmission Division, Eaton Corp.

TITLE: FMVSS INTERPRETATION

TEXT:

Terry E. Teeter, P.E. Engineering Supervisor Transmission Division Eaton Corporation P.O. Box 4013 Kalamazoo, Michigan 49003

This responds to your May 14, 1984, letter to the National Highway Traffic Safety Administration regarding the transmissions that you manufacture for air brake equipped trucks. You stated that your transmissions use vehicle air pressure to accomplish gear changing and other transmission control functions. You stated your understanding that the transmission air system is an accessory similar to air powered wipers or air horns and therefore air lines connected to the system are exempt from Federal Motor Vehicle Safety Standard No. 106, Brake Hoses. As explained below, not all accessory lines are excluded from the standard, and the issue of whether your transmission lines are covered by the standard depends on whether a failure of the line would result in a loss of pressure in the brake system.

Federal Motor Vehicle Safety Standard No. 106, Brake Hoses, defines brake hose as:

a flexible conduit, other than a vacuum tubing connector, manufactured for use in a brake system to transmit or contain the fluid pressure or vacuum used to apply force to a vehicle's brakes.

As you pointed out in your letter, the agency has previously determined that hoses connected to accessories such as air powered wipers or air horns need not comply with Standard No. 106. However, these hoses are only excepted from the standard if they do not transmit or contain the brake air pressure used to apply force to a vehicle's brakes. To determine whether the hoses of your transmission air system are excluded from Standard No. 106, you must determine whether a failure of such a hose would result in a loss of air pressure in the brake system. If this would be the case, the hoses transmit or contain the pressure used to apply force to the vehicle's brakes and therefore would have to comply with the standard. If you use a check valve or some other device to prevent loss of pressure, then the hose would not contain or transmit the air pressure and would not be required to comply with Standard No. 106.

Sincerely, Frank Berndt Chief Counsel

May 14, 1984

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

Attention: Frank Berndt

Gentlemen:

We manufacture heavy duty truck transmissions that are used in Class 7 and Class 8 highway trucks. These trucks typically use air braking systems that utilize air brake hoses subject to FMVSS-106. Various models of our transmissions use vehicle air pressure to accomplish gear changing and other transmission control functions (see attached typical transmission drawing). This basic system has been in use for over thirty years.

It is our understanding that the transmission air system is an accessory such as the air powered wipers or the air horn (previously clarified in "Preamble to Amendment to Motor Vehicle Safety Standard No. 106-74", Docket No. 1-5; Notice 10, Part 571; S106-74-Pre 6: copy attached), and therefore exempt from FMVSS-106. Please confirm that our understanding is correct.

If you wish to discuss this in more detail, or if you desire more information, please feel free to contact me at (616) 342-3400.

Sincerely,

Terry E. Teeter, P.E. Engineering Supervisor Preamble omitted.

ID: 1984-1.18

TYPE: INTERPRETATION-NHTSA

DATE: 03/01/84 EST

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Asahi Glass Co. Ltd. -- Seiroku Miyauchi

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Seiroku Miyauchi Plastic Products Dev. & Marketing Div. Asahi Glass Co., Ltd. 1-2, Marunouchi, 2-Chome Chiyoda-ku, Tokyo, 100 Japan

This responds to your letter to Mr. Francis Armstrong asking several questions about Standard No. 205, Glazing Materials. The answers to your questions are discussed below.

Your first question concerned the requirements of Weathering Test No. 16 of American National Standard Institute Z-26. The version of ANSI Z-26 currently incorporated by reference in Standard No. 205 is ANSI Z-26.1-1977, as supplemented by Z-26.1a, July 3, 1980, rather than ANSI Z-26.1-1977 as cited in your letter. Your question has to do with the language of section 5.16.3 of ANSI Z-26, which states that after the weathering test, "the decrease in regular (parallel) luminous transmittance of the irradiated specimen shall not exceed 5 percent." You ask whether the permissible decrease is an absolute 5 percentage points (defined as A-B, where A is the luminous transmittance before the test and B is the luminous transmittance after the test) or is a relative decrease of 5 percent (defined as (A-B)/A). The permissible decrease is a relative decrease of 5 percent (defined as (A-B)/A), or stated another way, the irradiated specimen must have 95 percent of its original transmittance after the test.

You also asked if Weathering Test No. 16 applies to AS-7 glazing materials. As required by Table 1 of ANSI Z-26, the weathering test does apply to AS-7 glazing materials.

Finally, you asked which DOT number, yours or the resin maker's, should be applied to a motorcycle windshield you make with an injection machine from polycarbonate resin pellets. Your DOT number must be used, since you fabricate the actual item of glazing material that will be placed in a vehicle.

Sincerely, Frank Berndt Chief Counsel

Dec. 26, 1983

Mr. Francis Armstrong Director Office of Vehicle Safety Compliance Enforcement National Highway Traffic Safety Administration 400 Seventh Street Sw. Washington D.C. 20590 U. S. A.

Dear Mr. F. Armstrong :

This is a letter in response to your letter of December 8, 1983. We appreciate your kind cooperation very much. This time, we would like to inquire you the following questions.

(1) Concerning the weathering test (test No.16 of ANS Z26.1-1977) It describes that the decrease in luminous transmittance of the irradiated specimens shall not exceed 5%. Would you tell me the meaning cf the above mentioned decrease ? It can be defined as either way ... (A-B)/A or (A-B) A : the luminous transmittance before test B : the luminous transmittance after test We think (A-B) is correct. Because if (A-B)/A is correct, the allowable decrease (A-B) is relatively smaller in proportion to the smaller A value. And in addition, is the above criteria applied to AS-7 grade, which is defined at the level not requisite for driving visibility?

(2) Concerning the marking of safety glazing materials. We purchase the polycarbonate resin pellets from resin makers, and mold windscreens for motorcycles with injection machine. In this connection, which DOT number should we mark the resin maker's number or our number ?

Your prompt answer will be much appreciated.

Yours Sincerely,

( Seiroku Miyauchi ) Technical Manager Plastic Products Dev. & Marketing Div. Asahi Glass Co., Ltd.

SM / yy

ID: aiam2952

Dear Mr. Milby: This responds to your August 15, 1978, petition asking for changes i Standard No. 222, *School Bus Passenger Seating and Crash Protection*, as that standard applies to the measurement of contact area. In particular, you ask the National Highway Traffic Safety Administration (NHTSA) to amend the standard adopting a specific test medium for measuring contact area and deleting the existing list of acceptable contact area test mediums currently established in the agency's compliance test procedures.; On July 19, 1978, the NHTSA responded to an earlier petition (Decembe 20, 1977) submitted by you on this same issue. In that letter, the NHTSA denied your requested amendment of the standard. Your current petition presents no additional data or arguments supporting your suggested modification that were not presented and thoroughly considered in our determination of your first petition. Accordingly, for the reasons specified in our July 19, 1978, letter to you, the agency denies your suggested rulemaking.; In your August 15 petition, you suggested that Standard No. 222 shoul incorporate more detailed test procedures, because some of the agency's other safety standards specify test procedures in greater detail. Standard No. 222 currently specifies test procedures to be used by manufacturers in complying with the standard. However, like all of the agency's standards, Standard No. 222's compliance test procedures are even more detailed than the requirements specified in the standard.; The NHTSA writes safety standards as simply as possible while providin the necessary detail for manufacturers to comply with their requirements. A manufacturer is then permitted to develop its own test procedures as long as its procedures are compatible with the requirement of the standard. The NHTSA, itself, devises tests that it uses for testing a vehicle's compliance. Whenever possible, these tests are available to manufacturers, and manufacturers are free to adopt them or to proceed with their own test procedures. Your twice- submitted petition would have the NHTSA rewrite its standards in a manner that would specify test procedures in greater detail. Such an approach would increase the complexity of safety standards if done uniformly to all standards and would in fact be detrimental to small manufacturers. The purpose of allowing some variation in details of test procedures is to permit a manufacturer to develop test procedures that are tailored to that manufacturer's needs and constraints. For example, certain test procedures used by the NHTSA may be too costly for a small manufacturer. Under the current compliance system, any manufacturer can develop a less expensive alternative test methodology. Under the system that you propose, however, a manufacturer would be required to adopt the test procedures specified in the standard. Since your suggestion, if applied to all safety standards, could add costs to the agency's regulations without achieving any significant benefits, the NHTSA determines that your suggested amendment is not in the public interest.; Sincerely, Joseph J. Levin, Jr., Chief Counsel

ID: aiam3989

Dear Mr. Landgraf: Thank you for your letter of May 21, 1985, concerning Federa regulations that might affect a cargo system for hatch back cars that you are developing. You requested confidentiality for your specific product description and drawing. Since your design has not been marketed as yet, we are granting your request for confidentiality. The following discussion provides an explanation of how our standards would affect a device such as yours.; The National Traffic and Motor Vehicle Safety Act authorizes our agenc to issue Federal Motor Vehicle Safety Standards that apply to new motor vehicles and items of motor vehicle equipment. We have not issued any standard that directly applies to a cargo system such as yours. However, use of your system could be affected by Standard No. 111, *Rearview Mirrors*, which sets performance requirements for rearview mirrors, a copy of the standard and an information sheet discussing the responsibilities of vehicle and equipment manufacturers under our regulations is enclosed for your reference.; Standard No. 111 provides that each inside rearview mirror must provid a specified field of view to the rear of the vehicle. If the field of view of the inside mirror in a new vehicle is obstructed by anything other than head restraints or seated occupants, then an outside rearview mirror must be provided on the passenger's side of the vehicle. Thus, if your product were installed in a new vehicle by a manufacturer or dealer prior to its sale to a consumer, and if installation of your product would mean that the inside rearview mirror would no longer comply with the applicable field of view requirements, they would have to ensure the vehicle was equipped with the necessary additional mirror required by Standard No. 111.; In 1974, Congress amended the National Traffic and Motor Vehicle Safet Act to address the problem of persons tampering with safety equipment installed on a motor vehicle by adding section 108(a)(2)(A) to the Act. That section provides, in part, that:; >>>No manufacturer, distributor, dealer, or motor vehicle repai 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 . . . .<<<; Thus, if a manufacturer, distributor, dealer, or motor vehicle repai business adds your product to a used vehicle and if its installation would mean that the inside rearview mirror would no longer comply with the applicable field of view requirements, they would have to install an outside passenger side mirror. Section 108(a)(2)(A) does not establish any limitations on an individual vehicle owner's ability to alter his or her own vehicle. Thus, under Federal law, individual vehicle owners can themselves install any equipment they want on their vehicles, regardless of whether that equipment would render inoperative the compliance of the vehicle with the performance requirements of Standard No. 111. They would, of course, still have to comply with any applicable State laws.; I hope this information is of assistance to you. If you have furthe questions, please let me know.; Sincerely, Jeffrey R. Miller, Chief Counsel