ID: 1983-1.4

TYPE: INTERPRETATION-NHTSA

DATE: 01/13/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: CONSUS INTERNATIONAL, INC

TITLE: FMVSS INTERPRETATION

TEXT:

NOA-30

Mr. Robert B. Wessel Consus International, Inc. P.O. Box 594 Port Jefferson Station, NY 11776

Dear Mr. Wessel:

This is in response to your December 1, 1982, letter regarding a warning device you plan to manufacture. The device is powered by 4 AA batteries, and has a light which can stay on continuously or can flash. You have asked whether the device complies with Federal Motor Vehicle Safety Standard 125.

Standard 125 applies to warning devices "without self-contained energy sources." The four batteries in your device which power the light would constitute such a source. Therefore, Standard 125 is inapplicable to your device.

If you have further questions on this matter, feel free to contact us.

Sincerely,

Frank Berndt Chief Counsel

December 1, 1982

National Highway Traffic Safety Administration Rm 5219 U.S. Dept. Of Transportation 400 7th Street S.W. Washington D.C. 20590

To Whom It May Concern;

Please review the enclosed sample and advise complience with your standard 125. The unit is made to work with four "AA" Batteries and has reflective as well as lighted capabilities.

The light can stay on, or in the flasher mode will blink, and is visible at great distances.

Thank you in advance for your early response as we are waiting your acknowledgement before our marketing push.

I remain Very truly yours;

Robert B. Wessel

ID: 1983-1.40

TYPE: INTERPRETATION-NHTSA

DATE: 04/13/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Andial

TITLE: FMVSS INTERPRETATION

TEXT:

APR 13 1983 NOA-30

Mr. Arnold H. Wagner Andial 3207 S. Shannon Street Santa Ana, California 92704

Dear Mr. Wagner:

This responds to your February 2, 1983, letter asking whether a child seat that you plan to produce must comply with Standard No. 213, Child Restraint Systems. From the description of your child seat, it appears that the answer is yes.

Standard No. 213 states in section 4 that a child restraint system is any device used to restrain, seat, or position children who weigh not more than 50 pounds. It is not necessary that a seat be equipped with its own restraint devices to fall within the ambit of the standard. If a device is designed to seat or position a child within the designated weight range, that device must comply with the requirements.

The instructions that accompanied your letter showed how the seat should be installed for children from three to six years of age and subsequently for children in the age range of six to ten. Certainly children in the three to six age bracket would fall within the weight range (50 pounds or less) designated in the standard. Since this is the case, it appears that your child seat is designed to seat or position children of the size specified in the standard and would therefore be required to comply with the requirements of the standard.

Sincerely, Frank Berndt Chief Counsel February 2, 1983 Mr. Frank Berndt Chief Council US Department of Transportation N.H.T.S.A. 400 Seventh Street, S.W. Washington, D.C. 20590 Re: Approval of child restraint, by means of 3 point type belt system

Dear Mr. Berndt:

Enclosed please find copies of a letter from Arvin/Calspan to us, and a copy of the installation instructions of said restraint.

We understand that the application of FMVSS No. 213 restraint designs does not cover our particular system, and a formal decision is needed in order to get it safety approved.

We would like to ask you to consider our request at your earliest convenience.

Sincerely

Arnold H. Wagner Sec/Tres.

AHW/mgm

January 24, 1983

Mr. Arnold Wagner Andial 3207 S. Shannon Street Santa Ana, CA 92704

Dear Mr. Wagner:

We received your child restraint last week and have examined the restraint and the installation instructions. The design of this restraint (i.e., use of a three-point belt system) is not addressed in the Department of Transportation's Federal Motor Vehicle Safety Standard No. 213 (FMVSS 213).

We have been informed by the Department of Transportation that a formal decision is required with regard to the applicability of FMVSS No. 213 to restraint designs which are not specifically addressed in this safety standard. A request for a formal decision should be sent to:

Mr. Frank Berndt Chief Council U. S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590

I would suggest that you include a copy of your installation instructions.

A brochure of Calspan's child restraint testing capabilities is included with this letter. Our recommendation for a sled test program follows:

Sled Test #1 - Two restraints placed side-by-side on the sled (see Photograph #2 in brochure). One restraint will be occupied by a 3- year-old size dummy (15 kg) with the restraint installed as suggested for 9-18 kg children and the other restraint occupied by a 6-year-old size dummy (22 kg) with the restraint installed as suggested for 15-25 kg children. This test would be performed at 30 mph as required in FMVSS 213 Configuration 1.

Sled Test #2 - One restraint occupied by a 3-year-old size dummy with the restraint attached to the seat by means of a lap belt only, tested at 20 mph. This should satisfy the requirements of FMVSS No. 213, Configuration II.

Although FMVSS No. 215 only requires testing with the three-year-old size dummy, we have included a test with the larger six-year-old size dummy since your restraint is designed for use by larger children.

Calspan charges one thousand dollars ($1,000) U. S. funds for each sled test, regardless of the number of dummies used. This price includes high-speed movie films, electronic data, and photographs for each test and analysis and reporting of all relevant data.

I look forward to hearing from you soon. We would like to perform these sled tests in February if this is convenient for you.

Sincerely yours,

Barbara J. Kelleher Staff Associate Transportation Research/Physical Sciences

kd

Enc.

ID: 1983-1.41

TYPE: INTERPRETATION-NHTSA

DATE: 04/18/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: C. H. Percy, U.S. Senate

TITLE: FMVSS INTERPRETATION

TEXT:

APR 18 1983 NOA-30

The Honorable Charles H. Percy United States Senate Washington, D.C. 20510

Dear Senator Percy:

This responds to your letter of March 25, 1983 (Ref. 3084500004) requesting information on behalf of your constituent, Ms. Mary Ella Dockson. Ms. Dockson is concerned about the growing practice of persons installing darkly tinted film on passenger car windows. She believes this is a dangerous practice because it prevents other drivers from seeing inside the vehicles. Following is a discussion of the implications under Federal law of installing these tinting films.

A Federal regulation already exists which, under certain circumstances, precludes the practice referred to by Ms. Dockson. The National Highway Traffic Safety Administration has the authority to govern the manufacture of new motor vehicles and motor vehicle equipment. Pursuant to the National Traffic and Motor Vehicle Safety Act, we have promulgated Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70 percent in areas requisite for driving visibility, which includes all windows in passenger cars) and abrasion resistance. This specification for light transmittance precludes darkly-tinted windows in new automobiles.

The agency has stated in past interpretations that solar films such as the type referred to in Ms. Dockson's letter are not glazing materials themselves, and would not have to comply with Standard No. 205. However, installation of such films on new motor vehicles would be prohibited if the vehicle glazing no longer complied with the light transmittance or abrasion requirements of the standard. If a vehicle manufacturer or a dealer places the film on glazing in a vehicle prior to sale of the vehicle, that manufacturer or dealer has to certify that the glazing continues to be in compliance with the requirements of Standard No. 205. Section 108(a)(1) prohibits any person from offering for sale or selling any motor vehicle or equipment that fails to comply with applicable safety standards.

After a new vehicle has been sold to the consumer, he may alter his vehicle as he pleases, so long as he adheres to all State requirements. Under Federal law, the owner could install the tinting film on glazing in his vehicle whether or not such installation adversely affected the light transmittance and abrasion resistance of his vehicle's glazing. It should be noted, however, that section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act provides that no manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative any device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard. "Render inoperative" means to remove, disconnect or degrade the performance of a system or element of design installed pursuant to the Federal safety standards. Thus, none of those persons may knowingly install a solar film on a vehicle for its owner if that act would render inoperative the light transmittance or abrasion resistance of the vehicle glazing. Whether this would be the case would have to be determined by the person making the installation. Violation of this section can result in Federal civil penalties up to $1,000 for each violation.

The individual States must govern the operational use of vehicles by their owners since the agency does not have authority in this area. Thus, it would be up to the States to preclude owners from applying films or one-way glass on their own vehicles. Ms. Dockson may wish to contact the National Committee on Uniform Traffic Laws (555 Clark Street, Evanston, Illinois 60204) to find out which States have laws that would preclude owners from placing solar film on their automobile windows.

Please contact Hugh Oates of my staff if you have any further questions (202-426-2992).

Sincerely,

Frank Berndt Chief Counsel

Enclosure Constituent's Letter

ID: 1983-1.42

TYPE: INTERPRETATION-NHTSA

DATE: 04/18/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Ichikoh Industries Ltd. -- F. Takata, Manager, Technical Research and Homologation

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. F. Takata

This is in response to your letter of March 10, 1983, to Marx Elliot of this agency, In that letter, you requested our view as to whether a mirror label printed by a "screen printing process" would comply with section 5.4.2 of FMVSS 111. The screen printing process involves painting the required warning label on the reverse surface of the mirror in such a way that the warning can be read from the front of the mirror.

Section 5.4.2 of FMVSS 111 provides that certain convex mirrors must have "indelibly etched" on the lower edge of the mirror's reflective surface the warning "Objects in Mirror Are Closer than They Appear." Your screen printing process uses a painting process to place the required lettering on a mirror. Since the process does not involve etching, mirrors having a warning placed on them by that process would not now comply with FMVSS 111.

You should be aware, however, that Toyota Motor Corporation has petitioned this agency to permit processes other than etching to be used to place the FMVSS 111 warning on mirrors. We expect to respond to the Toyota petition in the very near future. Should the agency grant the Toyota petition, it could result in an amendment to the Standard permitting the process described in your letter.

Sincerely, Frank Berndt Chief Counsel

Mr. W. Mark Elliot Rulemaking Program Manager Lighting & Visibility. NHTSA

Re: Interpretation of FMVSS No. 111

Dear Mr. Mark Elliot,

First of all, we thank you very much for your kindly reply on headlamp regulation addressed to our Mr. Aihara. Your informations are very useful for us, thank you again.

We also produce the rear view mirrors for motor vehicle. We would like to ask you the interpretation of FMVSS no. 111, Section 5.4.2.. Section 5.4.2. is defined as follows:

S5.4.2 Each convex mirror shall have indelibly etched on the lower edge of the mirror's reflective surface in letters not less than 3/16 inch or no more than 1/4 inch high, the words "Objects in Mirror Are Closer Than They Appear".

The words "OBJECTS IN MIRROR CLOSER THAN THEY APPEAR" on the sample mirror enclosed this letter was printed by screen printing process as shown in the attached sheets.

Questions: May we understand that marking method of enclosed sample complies with requirements of FMVSS No. 111, Section 5.4.2?

And if your have any comments on enclosed sample, please inform us. We await your early reply.

Very Truly yours.

F. Takata, Manager Technical Research & Homologation Enclosures

ID: 1983-1.43

TYPE: INTERPRETATION-NHTSA

DATE: 04/20/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Truck Body & Equipment Association

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your March 10, 1983, letter asking whether the requirement for audible alarms at school bus emergency doors applies only to emergency exit doors or to both doors and emergency exit windows.

Paragraph S5.3 of Standard No. 217, Bus Window Retention and Release, states specifically that the alarms shall be installed for emergency exit doors. There is no similar requirements for alarms at emergency window exits. Accordingly, alarm devices need be provided for emergency doors only.

SINCERELY, TRUCK BODY & EQUIPMENT ASSOCIATION

March 10, 1983

Office of Chief Counsel National Highway Traffic Safety Administration Attn: Roger Tilton

Dear Mr. Tilton:

This will confirm our telephone conversation of March 10th regarding FMVSS 217. One of TBEA's members would like a written interpretation of whether or not buses (not school buses) with a GVWR of more than 10,000 pounds require an audible alarm system for emergency exits, in this case push out windows so designated, other than doors.

The confusion is caused by S5.2.1 of FMVSS-217 which states in part -- "by providing side exits and at least one rear exit that conforms to S5.3 through S5.5". S5.3 specifically requires the audible alarm for emergency doors only. The standard clearly and consistantly delinates between emergency doors and emergency exits.

Is it reasonable to assume that on buses (not school) with a GVWR of more than 10,000 pounds that the audible warning system applies only to emergency doors and does not apply to emergency exits?

Your kind assistance in this matter will be appreciated.

James E. Forrester Manager, Engineering Services

ID: 1983-1.44

TYPE: INTERPRETATION-NHTSA

DATE: APRIL 20, 1983

FROM: F. MICHAEL PETLER -- HEAD, ADMINISTRATION, GOVERNMENT RELATIONS DEPARTMENT, SUZUKI

TO: OFFICE OF CHIEF COUNSEL -- NHTSA

TITLE: REQUEST FOR INTERPRETATION FMVSS NO. 210; SEAT BELT ASSEMBLY ANCHORAGES

ATTACHMT: MEMO DATED 5-6-83, TO F. MICHAEL PETLER, FROM FRANK BERNDT, NOA-30

TEXT: We are in urgent need of your confirmation of our interpretation of the seat belt assembly anchorage requirements for the rear seat.

Paragraph S4.1.1 of FMVSS No. 210 states:

"Seat belt anchorages for a Type 2 seat belt assembly shall be installed for each forward-facing outboard designated seating position in passenger cars other than convertibles, and for each designated seating position for which a Type 2 seat belt assembly is required by @ 571.208 in vehicles other than passenger cars."

In your agency's November 2, 1981 denial of Toyo Kogyo U.S.A.'s petition for rulemaking (46 F.R. 54391-54392) the following statement appears:

"The standard requires all passenger cars, lightweight trucks, and multipurpose passenger vehicles to be equipped with three-point anchorages for Type 2 belts (combination lap and shoulder belts) at each forward facing outboard designated seating position. Two-point anchorages for Type 1 belts (lap belts) are required at all other designated seating positions (center front and all rear positions)."

We interpret this standard to require that only Type 1 seat belt assembly anchorages must be installed for each seating position of a rear seat, such as in the case of a passenger car. We would appreciate a prompt reply as to whether we are correct in our interpretation of this standard.

ID: 1983-1.45

TYPE: INTERPRETATION-NHTSA

DATE: 04/26/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Cummins Engine Company, Inc.

TITLE: FMVSR INTERPRETATION

TEXT:

APR 26 1983 NOA-30 Mr. J. N. Uranga Cummins Engine Company, Inc. Box 3005 Columbus, Indiana 47201

Dear Mr. Uranga:

This is in further response to your January 28, 1983, letter in which you asked about the defect reporting requirements in Part 573, Defect and Noncompliance Reports. We responded by letter to you on March 24 indicating that as an original equipment manufacturer you might have some reporting responsibilities if a component of your original equipment was found to be defective.

In a conversation with Roger Tilton of my staff, you have indicated that you manufacture the engine of a certain vehicle and another manufacturer produces the fan. Both pieces of equipment are then sent to the vehicle manufacturer for assembly with the vehicle. In this instance, you ask whether you would have reporting responsibilities if the fan were determined to be defective. The answer to your question is no.

In the situation that you pose, you do not install the fan on your equipment nor does the fan ever come within your control. Therefore, you would not have responsibility for that part. The fan manufacturer and the vehicle manufacturer would be responsible for any defects in that equipment. In instances where you might install a fan on your equipment prior to sale to the vehicle manufacturer, you might have reporting responsibilities if a defect is discovered in that part, since the part would be a component of the overall engine that you supplied to the vehicle manufacturer.

Sincerely,

Frank Berndt Chief Counsel

ID: 1983-1.46

TYPE: INTERPRETATION-NHTSA

DATE: 04/26/83

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Suzuki Motor Co. Ltd. -- Kenneth M. Bush, Staff Engineer, Government Relations Dept.

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Kenneth M. Bush Staff Engineer Government Relations Department Suzuki Motor Co., Ltd. 3251 E. Imperial Highway P.O. Box 1100 Brea, California 92621

Dear Mr. Bush:

This is in reply to your letter of February 245, 1983, asking for an intepretation of Federal Motor Vehicle Safety Standard No. 123, Motorcycle Controls and Displays.

The last sentence of paragraph S5.3.1 is:

"If a motorcycle is equipped with self-proportioning or antilock braking devices utilizing a single control for front and rear brakes, the control shall be located and operable in the same manner as a rear brake control."

You have asked if your interpretation is correct that this sentence does not preclude the use of single control braking systems which do not incorporate "self-proportioning" or "antilock" braking devices. Your interpretation is correct; The sentence establishes a requirement that applies only to those self-proportioning devices with single control. It does not require a second control nor does it preclude a single control system without proportioning devices.

You have also asked that we provide clarification as to what self-proportioning means. This term includes any brake input device the actuation of which applies braking torque to both the front and rear wheels. Use of such a self-proportioning device does not preclude additional brake actuation devices. Examples include certain current model Moto Guzzi motorcycles.

As you have requested, the publicly available copies of your letter and this response shall not include your name and address. If you have any further questions, we shall try to answer them.

Sincerely,

Original Signed By Frank Berndt Chief Counsel

Mr. Frank Berndt, Esq. Chief Counsel National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, DC 20590

Dear Mr. Berndt:

Enclosed is a request for interpretation of a Federal Motor Vehicle Safety Standard. Because this request related to specific future product designs, we ask that this letter not be made publicly available with the request. For the same reason, we ask that our name and address be deleted from publicly available copies of your response.

Your consideration in this matter is greatly appreciated. Please contact me if you have any questions.

Sincerely,

SUZUKI MOTOR CO., LTD.

Kenneth M. Bush Staff Engineer Government Relations Department

This is to request clarification of some of the language contained in Federal Motor Vehicle Safety Standard No. 123, Motorcycle Controls and Displays (49 CFR 571.123). In particular, we have two questions concerning the last sentence of S5.2.1 which states "If a motorcycle is equipped with self-proportioning or antilock braking devices utilizing a single control for front and rear brakes, the control shall be located and operable in the same manner as a rear brake control.

First, we interpret this sentence not to preclude the use of single control braking systems which do not incorporate "self-proportioning" or "antilock" braking devices. Is this interpretation correct?

Second, we ask that you provide clarification as to what "self-proportioning" means as used in S5.2.1. If you could list examples of self-proportioning devices, this would be helpful.

ID: 1983-1.47

TYPE: INTERPRETATION-NHTSA

DATE: 04/28/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Hon. C. H. Percy, U.S. Senate

TITLE: FMVSS INTERPRETATION

TEXT:

APR 28 1982 NOA-30

The Honorable Charles H. Percy United States Senate Washington, D.C. 20510

Dear Senator Percy:

This responds to your letter of April 11, 1983 (Ref. 3098500010) requesting information on behalf of your constituent, Mrs. D. Parutti. Mrs. Parutti is concerned about the growing practice of persons installing darkly tinted film on passenger car windows. She believes this is a dangerous practice because it prevents other drivers from seeing inside the vehicles. Following is a discussion of the implications under Federal law of installing these tinting films.

A Federal regulation already exists which, under certain circumstances, precludes the practice referred to by Mrs. Parutti. The National Highway Traffic Safety Administration has the authority to govern the manufacture of new motor vehicles and motor vehicle equipment. Pursuant to the National Traffic and Motor Vehicle Safety Act, we have promulgated Federal Motor Vehicle Safety Standard No. 205, Glazing Materials, which specifies performance and location requirements for glazing used in vehicles. These requirements include specifications for minimum levels of light transmittance (70 percent in areas requisite for driving visibility, which includes all windows in passenger cars) and abrasion resistance. This specification for light transmittance precludes darkly-tinted windows in new automobiles.

The agency has stated in past interpretations that solar films such as the type referred to in Mrs. Parutti's letter are not glazing materials themselves, and would not have to comply with Standard No. 205. However, installation of such films on new motor vehicles would be prohibited if the vehicle glazing no longer complied with the light transmittance or abrasion requirements of the standard. If a vehicle manufacturer or a dealer places the film on glazing in a vehicle prior to sale of the vehicle, that manufacturer or dealer has to certify that the glazing continues to be in compliance with the requirements of Standard No. 205. Section 108(a)(1) prohibits any person from offering for sale or selling any motor vehicle or equipment that fails to comply with applicable safety standards.

After a new vehicle has been sold to the consumer, he may alter his vehicle as he pleases, so long as he adheres to all State requirements. Under Federal law, the owner could install the tinting film on glazing in his vehicle whether or not such installation adversely affected the light transmittance and abrasion resistance of his vehicle's glazing. It should be noted, however, that section 108(a)(2)(A) of the National Traffic and Motor Vehicle Safety Act provides that no manufacturer, distributor, dealer or motor vehicle repair business shall knowingly render inoperative any device or element of design installed on or in a motor vehicle in compliance with an applicable motor vehicle safety standard. "Render inoperative" means to remove, disconnect or degrade the performance of a system or element of design installed pursuant to the Federal safety standards. Thus, none of those persons may knowingly install a solar film on a vehicle for its owner if that act would render inoperative the light transmittance or abrasion resistance of the vehicle glazing. Whether this would be the case would have to be determined by the person making the installation. Violation of this section can result in Federal civil penalties up to $1,000 for each violation.

The individual States must govern the operational use of vehicles by their owners since the agency does not have authority in this area. Thus, it would be up to the States to preclude owners from applying films or one-way glass on their own vehicles. Mrs. Parutti may wish to contact the National Committee on Uniform Traffic Laws (555 Clark Street, Evanston, Illinois 60204) to find out which States have laws that would preclude owners from placing solar film on their automobile windows.

Please contact Hugh Oates of my staff if you have any further questions (202-426-2992).

Sincerely,

Frank Berndt Chief Counsel

Enclosure Constituent's Letter

April 11, 1983

TO: Ms. Carole Walls Liaison Officer National Highway Traffic Safety Administration 400 Seventh Street, S.W. Washington, D.C. 20590

FROM: Charles H. Percy United States Senator

Because of the desire of this office to be responsive to all inquiries and communications, your consideration of the attached is requested. Your findings and views, in duplicate form, will be greatly appreciated.

Please reference our file number, 3098500010 and respond to:

Office of United States Senator Charles H. Percy Washington, DC 20510

Our File 3098500010

ID: 1983-1.48

TYPE: INTERPRETATION-NHTSA

DATE: 05/02/83

FROM: AUTHOR UNAVAILABLE; F. Berndt; NHTSA

TO: Truck & Body Equipment Association

TITLE: FMVSS INTERPRETATION

TEXT:

MAY 2 1983 NOA-30

Mr. James E. Forrester Manager of Engineering Services Truck Body & Equipment Association P.O. Box 70409 Washington, D.C. 20088-0409

Dear Mr. Forrester:

This responds to your March 15, 1983, letter asking whether emergency doors in school buses may be marked as "emergency exits" and still comply with Standard No. 217, Bus Window Retention and Release.

Paragraph S5.5.3 states that each school bus exit shall have the designation "Emergency door" or "Emergency exit" as appropriate. The agency has previously determined that emergency doors are considered to be emergency exits and thus can be marked as either doors or exits. Emergency windows must be marked only as emergency exits.

Sincerely,

Frank Berndt Chief Counsel

March 15, 1983

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

Attention: Mr. Roger Tilton

Dear Sir:

One of our members has become involved in a difference of opinion with his customer over the labeling of Emergency Doors and Exits of School Buses, S5.5.3 of FMVSS 217-76.

The issue is that the school bus was manufactured with the emergency doors identified and marked as "doors" and the emergency exits as "exits" in accordance with S5.5.3 of FMVSS 217, now the customer wants the manufacturer to remark the emergency doors as emergency exits. The manufacturer maintains that in so doing he would violate FMVSS-217. Is the manufacturer correct in his interpretation? Your early response will enable a timely resolution to this difficulty.

Your cooperation is greatly appreciated.

Sincerely yours,

James E. Forrester Manager of Engineering Services