ID: nht88-2.75

TYPE: INTERPRETATION-NHTSA

DATE: 07/18/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: GARY EVANS -- PRESIDENT, WESTEX AUTOMOTIVE CORPORATION

TITLE: NONE

ATTACHMT: MEMO DATED 2-26-88, TO NHTSA, FROM GARY EVANS-WESTEX

TEXT: This is a response to your letter of February 26, 1988, where you asked the National Highway Traffic Safety Administration (NHTSA) whether a product you wish to import and sell in the United States "complies with any standards which may affect it.". You describe the product as a warning triangle that is designed to be attached to the side window of a car. You tell us that this side-mounted triangle is about 20% smaller than the warning device specified in this agency's regulations in Standard 125, War ning Devices. The answer to your question is that the device you described would not comply with Standard 125.

Standard 125 sets uniform specifications for warning devices. Paragraph S3 of Standard 125 states that the standard "applies to devices, without self-contained energy sources, that are designed to be carried in motor vehicles, and used to warn approachi ng traffic of the presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle." By its own terms, then, Standard 125 applies to all warning devices that are not designed to be permanently affixed to the vehicle. Y ou are mistaken in suggesting that because the device attaches to the vehicle, Standard 125 is inapplicable. As I understand your description, the device is not "permanently affixed" to the vehicle. Rather, it is carried in the vehicle, and the vehicle operator may attach or remove the device as necessary. Therefore, this device is subject to the requirements of Standard 125.

According to your letter, this device fails to comply with the minimum size requirements set forth in paragraph S5.2.2 of Standard 125. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A)) specifies that, " No person shall . . . import into the United States any . . . item of motor vehicle equipment manufactured on or after the date any applicable Federal motor vehicle safety standard takes effect unless it is in conformity with such standard . . ." Standar d 125 took effect on January 1, 1974. Thus, Federal law prohibits you from importing any of the devices described in your letter that were manufactured on or after January 1, 1974.

I hope you find this information helpful. If you have further questions, please contact Joan Tilghman of my staff at (202) 366-2992.

ID: nht88-2.76

TYPE: INTERPRETATION-NHTSA

DATE: 07/18/88 EST

FROM: ERIKA Z. JONES -- NHTSA CHIEF COUNSEL

TO: LISA CAPPALLI -- GAGER, HENRY & NARKIS

TITLE: NONE

TEXT: This is a response to your letter of last year to Ms. Tilghman of my staff, seeking an interpretation of Standard 125, Warning Devices (49 CFR @ 571.125). I apologize for the delay in this response. Specifically, you asked whether your client may procee d with the manufacture and distribution of a warning device, which you described further as an equilateral triangle with legs of 10 3/8 inches each. You also enclosed a diagram of the proposed device.

Let me begin by explaining that your client does not need approval from this agency to manufacture or distribute this product. Section 108(a)(1)(A) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1397(a)(1)(A); Safety Act) provides that, "No person shall manufacture for sale, sell, offer for sale, or introduce or deliver for introduction in interstate commerce, or import into the United States, any . . . item of motor vehicle equipment manufactured on or after the date any applicable Fe deral motor vehicle safety standard takes effect under this title unless it is in conformity with such standard . . ." Section 114 of the Safety Act (15 U.S.C. 1403) establishes a certification process under which each manufacturer is required to certify that its products meet all applicable Federal safety standards. Therefore, your client, as a manufacturer of motor vehicle equipmet, must certify that this product complies with all applicable standards. This agency has no authority under the Safety A ct to approve, certify, or otherwise endorse any commercial product.

The warning device your client plans to produce is motor vehicle equipment, within the meaning of section 102(4) of the Safety Act (15 U.S.C. 1391(4)). Thus, the question is whether this warning device complies with applicable safety standards.

Paragraph S3 of Standard 125 reads as follows: "This standard applies to devices, without self-contained energy sources, that are designed to be carried in motor vehicles and used to warn approaching traffic of the

presence of a stopped vehicle, except for devices designed to be permanently affixed to the vehicle." Since your client's product falls within this description, your client must certify that the product complies with all requirements of Standard 125. Se ction 108(b)(2) of the Safety Act (15 U.S.C. 1397(b)(2)) requires your client to exercise "due care" in making any such certification.

Based on the description in your letter, it does not appear that your client can certify that this device complies with one of the requirements in Standard 125. Paragraph S5.2.2 of Standard 125 states that, "Each of the three sides of the triangular port ion of the warning device shall be not less than 17 and not more than 22 inches long, and not less than 2 and not more than 3 inches wide." According to your description, the sides of your client's proposed device would be only 10 3/8 inches long. Your client will have to increase the length of the sides in order to certify that this proposed warning device complies with Standard 125. We do not have enough information to offer any opinions as to whether this product appears to comply with the other re quirements of Standard 125.

You asked for information on how your client could obtain an exemption from Standard 125 if necessary. There is no provision in the Safety Act for exempting items of motor vehicle equipment from any applicable safety standard. However, section 157 of th e Safety Act (15 U.S.C. 1417) gives this agency the authority to exempt equipment manufacturers from the requirement to give notice to owners and to remedy noncompliances with applicable standards, if the agency determines that the noncompliance is incon sequential as it relates to motor vehicle safety. The procedures for implementing this statutory authority are set forth in 49 CFR Part 556, Exemption for Inconsequential Defect or Noncompliance.

Since your client plans to become a manufacturer subject to the requirements of the Safety Act, I am enclosing a copy of a general information sheet that briefly outlines the new manufacturer's responsibilities and explains how to get copies of relevant regulations. If you have some further questions or need further information on this subject, please contact Joan Tilghman of my staff at this address, or by telephone at (202) 366-2992.

Enclosure

ID: nht88-2.77

TYPE: INTERPRETATION-NHTSA

DATE: 07/20/88

FROM: C. S. ALLEN -- COMMANDER-DEPARTMENT OF CALIFORNIA HIGHWAY PATROL

TO: STEPHEN P. WOOD -- NHTSA RULEMAKING DIVISION

TITLE: NONE

ATTACHMT: DECEMBER 30, 1988 LETTER FROM JONES TO ALLEN

TEXT: This letter is to request an interpretation of the meaning of one sentence contained in Federal Motor Vehicle Safety Standard No. 102 (FMVSS 102).

This sentence, found in Title 49 of the Code of Federal Regulations (49 CFR) Part 571, Section 571.102 S3.1.3, states, "Starter interlock. The engine starter shall be inoperative when the transmission shift lever is in a forward or reverse drive positio n".

The California Highway Patrol has become aware that a major manufacturer of school buses, Crown Coach Incorporated, of 13799 Monte Vista Avenue, Chino, California 91710-5513, has been building vehicles equipped with automatic transmissions which, althoug h equipped with the interlock required by 49 CFR 571.102 S3.1.3, are also equipped, at the driver's position, with a momentary contact push-button switch, the purpose of which is to bypass the transmission neutral safety switch.

Mr. Greg Alvarez of my staff discussed the legality of this device with Mr. James Cowan, Director of Engineering at Crown Coach, Inc., by telephone on June 24, 1988. At that time Mr. Cowan stated his opinion that the bypass switch complied with FMVSS 10 2 because it was only an emergency feature, not intended to be used for routine engine starts. He stated that the only way the bus could be started with the transmission shift level in a forward or reverse drive position would be if the driver used both hands, one to operate the bypass switch to the right of the steering column, and the other to operate the regular starter key-type switch to the left of the steering column.

Mr. Cowan stated to this Department that this starter interlock bypass switch is regarded by Crown Coach as a safety feature, intended for emergency use in

the event that the bus engine dies at an inopportune moment, as when crossing a set of railroad tracks, or in case the neutral safety switch contacts fail to close upon selection of neutral range.

Pending your reply it is our position that the bypass switch renders buses equipped with automatic transmissions in violation of FMVSS 102 (and of an identical California state regulation). Crown Coach appears to be interpreting FMVSS 102 as meaning tha t the starter shall not be capable of being started from the driver's position with the transmission in gear unless the driver intends to do that.

As for the argument that the bypass switch allows for quick restarts on rail crossings or other dangerous locations, we feel that if the amount of time required to select neutral range, restart the engine and return to drive range is anticipated to be ex cessive, why not eliminate the neutral safety switch altogether? The driver would then be able to keep one hand on the steering wheel while restarting the engine with the transmission in gear. With Crown's present arrangement, a bus can be restarted in gear only by removing both hands from the steering wheel.

It is our belief that 49 CFR 571.102 S3.1.3 is intended to prevent motor vehicles equipped with automatic transmissions from being started in gear at any time. We would appreciate your earliest possible response to our request for an interpretation on t his matter, so that our inspectors and the engineering staff at Crown Coach, Inc. will have authoritative information on which to act.

ID: nht88-2.78

TYPE: INTERPRETATION-NHTSA

DATE: 07/22/88

FROM: GARRY GALLAGHER -- VP METZELER MOTORCYCLE TIRE

TO: LARRY COOK -- OFFICE OF CHIEF COUNCIL N.H.T.S.A

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12/01/88 FROM ERIKA Z. JONES TO GARRY GALLAGHER; REDBOOK A33, STANDARD 119

TEXT: Dear Larry,

Per our phone conversation back on June 15, 1988. I am requesting a written determination in regards to specific requirements within the size designations on the side walls of motorcycle tires.

My inquiry involves code #571.119 - section S6.5-c. As you may recall, my specific question was whether the letter B was required within the size designation if the tire is of bias-belted construction.

As Metzeler Motorcycle tires are manufactured in Germany, we meet the sizing requirements and listings of the E.T.R.T.O.

A Metzeler bias-belted tire is marked with both the number of plies and material of the plies of both the tread and sidewalls of the carcas. The letter B is sometimes added to the size as an internal code.

Your verbal determination over the phone was that the letter B was not an actual requirement. This letter serves to request a written determination.

Thank you for your assistance. Please call me if you have any further information or questions.

ID: nht88-2.79

TYPE: INTERPRETATION-NHTSA

DATE: 07/24/88

FROM: STEPHEN BORKOWSKI

TO: ERICA JONES -- NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATOR

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/10/88 TO STEPHEN BORKOWSKI FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 108

TEXT: This letter is request for the legality of my Bimmer Dimmer Safety Stop Light Concept. It utilizes various devices to govern the intensity of brake light brightness to indicate the degree of braking being applied to a vehicle. The goal of my concept is to lessen the chance of rear end collisions.

My concept was borne by a personal experience of mine in which I was able to avoid crashing into a car in front of me but four cars behind me were not able to escape damage as a result of multiple rear end collisions.

As a driver with 40 years of experience with a good driving record, I pondered over why or what I did wrong that put me into such a situation. My conclusion is that through the years I was lulled into a false sense of security. I realized there were co untless number of times when I was in a line of cars that were slowing down and the brake lights of the car or cars in front of me were lit even though we all were in the process of moving. Also, there are many times when drivers "ride" the brakes in hi gh density traffic. The activated stop light, therefore, does not indicate a drivers intent to actually come to a stop or the degree of his slowing down.

In the military as well as in other organizations, people are trained for emergency situations so that they will react in the correct manner, subconsciously. If drivers can learn to apply their brakes quickly and fully when they see a very bright red br ake light, I believe a false sense of security will not be developed and thus, hopefully, rear end collision can be reduced. I would like to pursue to research and develop my concept to test its validity and effectiveness.

I would appreciate any advice and suggestions that I should have in seeing how I could make it legal.

Sincerely,

ID: nht88-2.8

TYPE: INTERPRETATION-NHTSA

DATE: 04/27/88

FROM: L.T. MITCHELL -- THOMAS BUILT BUSES

TO: ERIKA Z. JONES -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 08/03/89 EST; FROM STEPHEN P. WOOD -- NHTSA TO L.T. MITCHELL -- THOMAS BUILT BUSES INC; REDBOOK A33; STANDARD 217; LETTER DATED 02/24/89 FROM DAN TREXLER -- THOMAS BUILT BUSES INC; TO JOAN TILGHMAN -- NHTSA; LETTER DATE D 12/20/84 FROM FRANK BERNDT -- NHTSA TO MELVIN SMITH -- ILLINOIS DOT

TEXT: Dear Ms. Jones,

This letter is in reference to a letter written by Mr. Frank Berndt to Mr. Melvin Smith of the Illinois Department of Transportation dated December 20, 1984, in which Mr. Berndt gave an interpretation of one of the requirements of FMVSS 217, a copy is at tached for your information. This interpretation concerned the location of the back of a seat with relation to the forward edge of a side emergency door. Mr. Berndt's interpretation stated that there was no tolerance permitted for the location of the s eat back with reference to a transverse plane coincident with the leading edge of the side emergency door. This lack of tolerance is what we wish to address in this letter.

As I am sure you can appreciate, a requirement for an exact location opens the door to impossible manufacturing requirements. The seats themselves, due to the use of bent-tube welded construction, can vary in the slope of the back or the relative positi on of the seat cushion, by as much as one-half of an inch. The weld-generated deformations, though slight, will also cause relative movement of the seat during the installation process of bolting the seats to the floor. Therefore, if an exact relationsh ip of any part of the seat is a requirement by law, this becomes an extremely difficult goal to meet. It will usually result in the necessity for multiple reseatings, or the physical bending of the seat after it is installed (which requires a significan t amount of force because these are seats meeting the requirements of FMVSS 222), or attempts to deform the padding of the seat locally, or some other undesireable side effect.

In light of the above considerations, and our understanding that the principle intent of FMVSS 217 in this regard is to prevent a seat back from extending backward into the door opening, we request that the NHTSA consider the following interpretation as meeting the requirements of FMVSS 217:

1. A seat back may not intrude backward into the door opening through the transverse plane coincident with the leading edge of the door opening.

2. A seat back may be located ahead of this transverse plane by no more than three-quarters of an inch, plus or minus three-quarters of an inch, or within but no more than, one and one-half inches ahead of the transverse plane coincident with the lea ding edge of the door opening. (See Fig. 1)

We would appreciate your early consideration of this interpretation, because of the current unreasonable situation that has developed among our bus users in their attempts to inspect school-buses for their compliance with their interpretations of the FMV SS 217.

Thank you.

Sincerely,

FIG 1: ALLOWABLE SEAT POSITION AT A SCHOOL BUS SIDE EMERGENCY DOOR WHEN THE BUS ALSO HAS A REAR PUSHOUT WINDOW

[DRAWING OMITTED]

ID: nht88-2.80

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: C. DIANNE BLACK -- ENGINEERING MANAGER, JAGUAR CARS, INC.

TITLE: NONE

ATTACHMT: MEMO DATED 4-14-88, TO ERIKA Z. JONES, FROM C. DIANNE BLACK -- JAGUAR, REF: FMVSS 108, HEADLAMP LEVELLING SYSTEM

TEXT: Thank you for your letter of April 14, 1988, providing further information about the Jaguar headlamp levelling system discussed in your letters of June and October 1987 to which I responded on February 1, 1988.

We support your efforts to call the driver's attention to the fact that the system does not automatically return to the "zero" position from either of the two adjustment positions when those loading conditions no longer exist.

ID: nht88-2.81

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88 EST

FROM: ERIKA Z. JONES -- CHIEF COUNSEL, NHTSA

TO: ROBERT G. YORKS -- VICE PRESIDENT AND GENERAL MANAGER, AUTOMOTIVE BUSINESS GROUP, TRUCK-LITTLE CO.

TITLE: NONE

ATTACHMT: MEMO DATED 5-24-88, TO KATHLEEN DEMETER, FROM ROBERT G. YORKS, 25220; MEMO UNDATED, TO ROBERT G. YORKS, FROM KATHLEEN DEMETER

TEXT: We have received your letter of May 24, 1988, withdrawing your request for confidential treatment of your letter of March 31 concerning the legality of a new safety lighting device. This letter also responds to your inquiry of July 14.

The device is described as a "combination center high-mounted stop lamp and cargo lamp". The functions are optically separate. The cargo lamp can illuminate the cargo box on pick-up trucks, while on vans and utility vehicles it serves as a "utility lig ht". The device is intended to be used as either original or aftermarket equipment.

The Federal motor vehicle safety standard on vehicle lighting is Standard No. 108. As you know, the center high-mounted stop lamp is required only for passenger cars. Further, there is no requirement that a center lamp intended for other types of motor vehicles meet the passenger car lamp requirements (for example, those requirements would prohibit combining the center lamp with the cargo lamp). As neither function of your device is required on lighting equipment for vehicles other than passenger car s, Standard No. 108 permits the installation of your device as original equipment provided that it does not impair the effectiveness of the lighting equipment that the standard does require. Whether impairment exists is initially a determination of the manufacturer of the vehicle who certifies compliance with Standard No. 108. However, the issue of impairment is ultimately subject to a determination by this agency. Types of impairment that can exist include functional interference with the wiring of o ther lamps, creation of ambiguous or confusing signals to such a degree that it may obscure the message of lamps and reflectors required by Standard No. 108, and reduction of photometrics below the minimum levels specified.

As an item of aftermarket lighting equipment, it is subject to a restriction of the National Traffic and Motor Vehicle Safety Act that its installation by a manufacturer, dealer, distributor, or motor vehicle repair business must not render inoperative i n whole or in part any device or element of design installed in accordance with a Federal motor

vehicle safety standard. We construe this prohibition strictly and equate it with impairment. If performance is "impaired," it can be viewed as "inoperative" with respect to achieving the purpose for which it has been installed.

Assuming that installation of an aftermarket device is not restricted by the Act, it nevertheless remains subject to the laws of a State in which the vehicle is registered and driven. We are not conversant with State laws on combination rear lamps, but you may wish to consult the American Association of Motor Vehicle Administrators, 4600 Wilson Boulevard, Arlington, Va. 22203, for an opinion.

I hope that this answers your questions.

ID: nht88-2.82

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88

FROM: WILLIAM E. LAWLER -- SPECIFICATIONS MANAGER INDIANA MILLS AND MANUFACTURING INC

TO: ERICA Z. JONES, -- CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 11/01/88 EST TO WILLIAM E. LAWLER FROM ERIKA Z. JONES, REDBOOK A32, STANDARD 208, STANDARD 209

TEXT: Dear Chief Counsel:

The publication of the final rule (53FR25337) pertaining to seat belts in trucks, buses, and multipurpose passenger vehicles over 10,000 pounds GVWR (FMVSS 208) on July 5, 1988, has prompted us to write to you.

Our discussions with engineers in the Crashworthiness Division since August 1985 have centered around our product called the "Komfort-Lok." This patented device has been used in the field for over two years with good customer satisfaction. Unlike the wor ding of the recent final rule, the Komfort-Lok is not a retractor but rather a mechanism external to the retractor itself but integral with the retractor but which eliminates webbing movement and thus eliminates cinching. The Komfort-Lok works in conjunc tion with an automatic locking retractor (ALR) regardless of the amount of webbing retracted between locking points at 75 percent webbing extension.

Because the Komfort-Lok is designed to work effectively with any ALR, we are writing to your office to request an official opinion permitting the use of any FMVSS 209-compliant-ALR in conjunction with the Indiana Mills Komfort-Lok as a complete retractor system to satisfy the requirements of FMVSS 208, Paragraphs S4.3.2.2 and S4.4.2.2 as stated in the 7-5-88 final rule.

We appreciate your attention to our request.

If you have any questions, please contact me. Thank you.

Sincerely,

ID: nht88-2.83

TYPE: INTERPRETATION-NHTSA

DATE: 08/01/88

FROM: ERIKA Z. JONES -- CHIEF COUNSEL NHTSA

TO: ALICE COLLINS

TITLE: NONE

ATTACHMT: LETTER DATED 01/15/88, TO ERIKA Z JONES, FROM ALICE COLLINS

TEXT: Dear Mrs. Collins:

This is a response to your letter of January 15, 1988. I apologize for the delay in responding to your letter. In your letter, you described yourself as a parent of school-age children, and as a volunteer who drives children to school-related activitie s in your 1986 Plymouth Voyager mini-van. You stated that in the 1986-1987 school year, the U.S. Department of Transportation decided that Voyager Mini-Vans were "unsafe." You go on to say that "the classification of M.P.V. was used on all mini-vans," and suggest that it is a mistake to characterize your Voyager as a multipurpose passenger vehicle (MPV) because it is more like a passenger car than a truck. You concluded by asking us to change the decision that the Plymouth Voyager mini-van is unsafe. You raised other concerns in telephone conversations with Joan Tilghman, a member of my staff. First, I will address the request in your letter that the Department change what you believe is a decision concerning the safety of your vehicle. Then, I wi ll address the matters you raised in conversations with Ms. Tilghman.

Let me begin by assuring you that the agency has never stated that the Plymouth Voyager is "unsafe." Except in the context of a specific enforcement proceeding, NHTSA does not make blanket determinations that vehicles are "safe" or "unsafe." Instead, we establish safety standards, and manufacturers must certify that each of their vehicles complies with all applicable standards. If we determine that a group of vehicles fails to comply with an applicable standard, or that a group of vehicles contains a d efect related to motor vehicle safety, we order the manufacturer to recall the vehicles. Again, we make these determinations only in the context of an enforcement proceeding. There has been no such proceeding with respect to the 1986 Plymouth Voyager.

With respect to your suggestion that it was a mistake to classify the Voyager as an MPV, it is the manufacturer's responsibility to determine, in the first instance, what a vehicle's classification should be. Chyrsler has classified the Voyager as an MP V, and so must certify that the Voyager meets all Federal safety standards applicable to that vehicle

2 class. We have no information which suggests that Chrysler's classification of the Voyager is incorrect under our classification criteria.

In your conversations with Ms. Tilghman, you explained that the Tallahassee, Florida school district will not permit parents to transport school children to school-sponsored or school-related events in MPVs, such as the Voyager. However, you stated that the district will permit parents to transport children to school-sponsored or school-related events in passenger cars. You said that the school district is following a recommendation by this agency that Florida school districts not condone transporting children to school-related events in buses other than certified school buses. Your understanding is that NHTSA made this recommendation to the State of Florida in an April 25, 1986 letter to Mr. Arnold Spencer, and repeated the recommendation in an Augu st 7, 1986 letter to Mr. Larry McEntire. I have enclosed copies of both letters for your information.

As you see, NHTSA made no such recommendation in either letter. Instead, we explained that we do not regulate the use of vehicles by owners, nor do we require the use of particular vehicles for particular purposes. There is no Federal prohibition again st vehicle owners using their own vehicles to transport school children to school-related events. We also noted that the individual States have authority to establish any such regulations, in accordance with the principles of federalism set out in our C onstitution. The State of Florida had already made its own decision to adopt and implement this policy before we were contacted by either Mr. Spencer or Mr. McEntire on this subject. Any changes to that policy would also reflect a decision by the State of Florida, not the Federal government.

In the letter to Mr. Spencer, we made the observation that Florida's policy that school boards not condone transporting school children in vehicles that are not certified as complying with our school bus safety standards, "is consistent with our belief t hat school buses certified to our school bus safety standards are the safest means of transportation for school children." This was not a recommendation to the State of Florida, but a statement of our belief about the superior safety afforded to school c hildren by buses that are certified as complying with our school bus standards. That belief continues to be supported by data showing that school buses continue to have one of the lowest fatality rates for any class of motor vehicle. Large school buses are the safest form of ground transportation in the United States because the passenger seats are "compartmentalized" (special seat padding and spacing, and high seat backs); and because of the vehicle's size and weight (which generally reduce an occupa nt's exposure to injury-threatening crash forces), the drivers' training and experience, and the extra care other motorists usually take when they are near a school bus.

3

I am sending you information on the agency's New Car Assessment Program (NCAP). NCAP is an experimental program in which we test light-duty vehicles, MPVs among them, to see how well they perform in a high-speed crash. You will find test results for veh icles that NHTSA has tested over the past few years, including results for the 1984 and 1987 Plymouth Voyager. Also, you will find the agency's April, 1988 report to Congress titled, "Safety Programs for Light Trucks and Multipurpose Passenger Vehicles. "

I hope you find this information helpful. If you have further questions, please contact Joan F. Tilghman, of my staff, at (202) 366-2992.

ENCLOSURE

Sincerely,