Interpretation ID: nht73-5.24

DATE: 09/21/73

FROM: AUTHOR UNAVAILABLE; Robert L. Carter; NHTSA

TO: Mr. John Holzer

TITLE: FMVSS INTERPRETATION

TEXT: Thank you for your letter of September 7, 1973, requesting information concerning possible regulatory action involving plastic or gas filters.

Although we have no regulation concerning gasoline filters, the law under which our regulations are promulgated requires that where possible, our standards be based on performance rather than design requirements. This gives the automotive manufacturers maximum flexibility in conforming with the requirements and provides freedom to select whatever design he prefers in order to meet the requirements of the standard.

Our current fuel system requirements are contained in Federal Motor Vehicle Safety Standard No. 301, Fuel Tank Filler Pipes and Fuel Tank Connections, which was effective January 1, 1968. A copy of this standard is enclosed for your information. We have recently issued an amendment to the standard and a proposed amendment which are intended to substantially upgrade fuel systems of motor vehicles between September 1, 1975 and September 1, 1977. Copies of these rulemaking actions are enclosed for your information (38 F.R. 22397 and 22417).

Motor vehicle manufacturers are free to choose the components and designs which they consider most appropriate to their performance requirements. It is quite possible that certain components cannot be used as original equipment because of periodic regulatory actions; for example, a manufacturer may consider a glass fuel filter hazardous when he is attempting the preservation of fuel system integrity incidental to a 30 mile-per-hour, fixed barrier collision.

We would suggest that contact be made with the automotive manufacturers and original equipment manufacturers for a more complete answer to your question.

If we can be of any further assistance, please do not hesitate to contact us.

Sincerely,

September 7, 1973

Department of Transportation National Highway Traffic Safety Administration

Dear Mr. Secretary,

I would like to know if your department has or will propose any motor vehicle safety standards in the area of plastic or glass gas filters.

I am a distributor of these products and I have heard they will be outlawed or restricted in use in 1974. My name and address are,

John Holzer 217-18 64th Ave. Bayside, New York 11364 Sincerely yours,

John Holzer