Interpretation ID: nht87-1.6

TYPE: INTERPRETATION-NHTSA

DATE: 01/08/87

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Hisashi Tsujishita

TITLE: FMVSS INTERPRETATION

TEXT:

Dec 31, 1986

U.S. Department of Transportation 400 Seventh Street, S.W. Washington, D.C. 20590

Dear Mr. Tsujishita:

This is in further response to your letter of July 15, 1986, in which you asked a number of questions concerning our standards and regulations. This responds to your question about Part 585, Automatic Restraint Phase-In Reporting Requirements. I hope the following discussion answers your question.

You asked about the requirement in Part 585.5(a)(4) of the regulation. That section provides that a manufacturers report "contain a statement regarding the extent to which the manufacturer has complied with the requirements of S4.1.3 of Standard No. 208. " You explained that you did not understand what the sentence means and asked whether your sample report conformed to the requirement of the regulation.

S4.1.3 of Standard No. 208 provides for the phasing-in of the automatic restraint requirements and sets certain percentage of passenger car production requirements that each manufacturer must meet. The purpose of Part 585.5(a)(4) is to have each manufact urer state to what degree of extent it has met the applicable phase-in requirement. Thus, a statement, such as the one contained in your sample report, which sets out the percentage of your vehicles produced during an applicable reporting period that com ply with the automatic restraint phase-in requirements of the standard would meet the requirement of Part 585.5(a)(4).

If you have any further questions, please me know.

Sincerely,

Erika Z. Jones Chief Counsel