Interpretation ID: 86-6.3

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/86

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Douglas MacGregor

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Douglas MacGregor Terralab Engineers 3585 Via Terra Salt Lake City UT 84115

Dear Mr. MacGregor:

Thank you for your letter of August 28, 1986, to Stephen Oesch of my staff concerning Standard No. 301, Fuel System Integrity. You asked whether the performance requirements of the standard would apply to a propane-fired engine block heater. You explained that the heater has its own fuel system that is independent of the vehicle's fuel system. As explained below, a propane-fired heater would not be covered by Standard No. 301.

Standard No. 301 sets performance requirements for the fuel system used in certain motor vehicles. The heater you have described apparently does not have any connections to the fuel tank or fuel lines of the vehicle. Instead, the heater has its own propane fuel system. Since the heater is not connected to the vehicle's fuel system, it would not be covered by the standard. Even if the heater were connected to the vehicle fuel system, it would not have to meet the performance requirements of the standard, since it is a propane-fired heater. S3 of Standard No. 301 limits the application of the standard to vehicles that use a fuel with a boiling point above 32o F. Propane has a boiling point below 32o F.

Even though the heater is not covered by the requirements of Standard No. 301, it would be considered an item of motor vehicle equipment. I have enclosed a copy of an information sheet that describes how our regulations, including those on defect notification and remedy campaigns, apply to equipment manufacturers.

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

Sincerely,

Erika Z. Jones Chief Counsel

28 August 1986

Steve Ashe Chief Counsel's Office Department of Transportation NHTSA 400 7th Street SW Washington, DC 20596

Dear Mr. Ashe:

Per our conversation I am writing to obtain an opinion.

We have been approached to test a propane-fired engine block heater. The propane fuel for the heater is separate and independent of the vehicular fuel system.

While there are standards which cover the test requirements for the heater itself, we need an Opinion which will determine whether impact (crash) and roll-over tests are required per 301, even though the language of 301 excludes LPC since its boiling point is below 32 F.

Also, if the Opinion should state the testing is necessary, would the system have to be tested for each truck and bus style, or would one representative test be acceptable for all installations?

Sincerely

Douglas MacGregor