Interpretation ID: nht80-3.14

DATE: 06/30/80

FROM: AUTHOR UNAVAILABLE; Frank Berndt; NHTSA

TO: Mr. Eugene Victor

TITLE: FMVSS INTERPRETATION

TEXT: This responds to your recent mailgram asking whether it is necessary to obtain DOT approval for compressed gas tanks that are to be used as part of an automobile fuel system.

The answer to your question is no. The National Highway Traffic Safety Administration issues safety standards and regulations governing the manufacture of motor vehicles and motor vehicle equipment. However, the agency does not pass approval on any vehicle or piece of equipment prior to its introduction in the market place. It is up to the manufacturer to certify, on the basis of due care, that its vehicles or equipment comply with all applicable Federal motor vehicle safety standards. The agency's enforcement program is based on compliance testing of vehicles or equipment that have already been certified by the manufacturer.

I am enclosing for your information a discussion which sets forth the implications under Federal law of converting gasoline-powered vehicles to use propane or other gas, as well as a general discussion of auxiliary fuel tanks. From that discussion, you will see that there are no safety standards directly applicable to propane fuel tanks as pieces of automobile equipment. There are, however, specifications under the Bureau of Motor Carrier Safety regulations relating to propane fuel systems on commercial vehicles or to tanks used for shipment of propane gas in interstate commerce. If your tanks will be used on other than private vehicles, these regulations may be of interest to you. For further information, you may contact Mr. W. R. Fiste of the Bureau of Motor Carrier Safety (202-426-0033).

ENC.

EUGENE VICTOR

06/09/80

MGM TDMT NEW YORK NY

FRANK BERNDT CHIEF COUNSEL NATIONAL HWY TRAFFIC SAFETY ADMINISTRATION ATTN MR OATES

WITH REFERENCE TO OUR TELEPHONE CONVERSATION OF JUNE 6 1980 WE WISH TO KNOW WHETHER IT IS NECESSARY TO HAVE DOT APPROVAL FOR COMPRESSED GAS TANKS USED AS PART OF AN AUTOMOBILE CNG FUEL SYSTEM

FOR GAS ALTERNATIVE SYSTEMS INC 65 RUGBY RD BROOKLYN NY 11226 ADAM VICTOR PRESIDENT

14:35 EST MGMCOMP MGM