Interpretation ID: nht72-2.5

DATE: 12/01/72

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Cotter Atkinson Campbell & Kelsey

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of October 27, 1972, inquiring about information on fuel tanks.

The location of fuel tanks in passenger cars is at the option of the vehicle manufacturer, since there are no Federal motor vehicles safety standards (FMVSS) concerned with tank location. The FMVSS are essentially performance oriented, and the manufacturer has the freedom for innovation and use of his own expertise in selecting the means for compliance to a specified safety performance requirement. FMVSS No. 301, which has been in effect since January 1, 1968, specifies certain fuel containment requirements as the result of a front-end impact at 30 miles per hour into a fixed barrier. Proposed amendments for FMVSS No. 301 have been issued specifying performance requirements for rear-end impacts, but the final rule has not yet been issued. The effective date for this amendment, then issued, has now been indicated as September 1, 1976. Copies of FMVSS No. 301 and the Notice of Proposed Rule Making are enclosed for your interest. A copy of Public Law 89-563 is also enclosed with a booklet briefly describing the current standards.

A number of research studies have been completed on fuel systems, and some statistical data is provided in these reports which may be of interest. These reports are available from the National Technical Information Service, U.S. Department of Commerce, 5285 Port Royal Road, Springfield, Virginia 22151, at a price of three dollars per volume. The RTIS code number must be identified when ordering.

1. In Assessment of Automotive Fuel System Fire Hazards, Dynamic Science Final Report on Contract No. PN-11-7579, December 1971, NYIS Codes PB-205240 and PB-208241 (2 Volumes)

2. Impact Intrusion Characteristics of Fuel Systems, Contract No. PN-11-7309 (Cornwall Aeronautical Laboratory, Inc.) April 1970, RTIS Code PB-159347

3. Fuel Tank Protection: Fairchild-Miller, Contract No. FR-11-6919, June 1969, RTIS Code PB-191148 (1 Volume)

4. Investigation of Motor Vehicle Performance Standards for Fuel Tank Protection: Fairchild-Miller, Contract No. PB-11-6696, September 1967, RTIS Code PB-177690 (2 Volume).

The correspondence containing comments from manufacturers and other interested parties, together with other documentation concerning the rule making system to (Illegible Word) FMVSS No. 301, Fuel System Integrity, it contained in the public record. Docket No. 70-20 identifies this rule making action, and this file is available for conducting in the National Highway Traffic Safety Administration Office of the Chief Counsel, 400 Seventh Street, S.W., Room 5221, Washington, D.C. 20590.

We trust this information will provide some of the data you are seeking.

Sincerely,

LAW OFFICES OF COTTER, ATKINSON, CAMPBELL & KELSEY

October 27, 1972

Federal Motor Vehicle Safety Standards U.S. Department of Transportation National Highway Traffic Safety Administration

Gentlemen:

This office is interested in a law suit against the American Motors Corporation for the placing of the gas tank in the extreme rear of the car. We are trying to determine how many accidents and burns result from the placing of the gas tank in this position and the engineering and structural reasons for placing the gas tank there. Do you have or do you know where we can get information concerning gas tank explosions or leakages that result from fires after a rear-end collision or the engineering and structural reasons for placing the gas tank in that position?

We are also interested in any studies or investigations concerning the best position to put the gas tank. The car involved was manufactured in 1971 and any studies that would be applicable to cars of that year or before would be extremely helpful.

Please let us know of any charges in connection with obtaining the aforementioned information.

Thank you very much for your cooperation.

Paul M. Fish