ID: nht95-4.30

TYPE: INTERPRETATION-NHTSA

DATE: September 20, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Mr. Yoshiaki Matsui -- Manager, Automotive Equipment, Legal & Homologation Section, Stanley Electric Co., Ltd.

TITLE: Re: Headlamp System Containing Fog Lamp

ATTACHMT: ATTACHED TO 8/11/95 LETTER FROM YOSHIAKI MATSUI TO CHIEF COUNSEL, NHTSA

TEXT: Dear Mr. Matsui:

This replies to your letter of August 11, 1995, with reference to possible headlamp systems that produce a fog lamp beam, as well as upper and lower beams. According to your letter, "the fog lamp is reciprocally incorporated with the high beam headlamp, using one dual-filament bulb (ex.; HB2). The high beam and the fog lamp will not be lit simultaneously." You refer to paragraph S5.1.3 of Federal Motor Vehicle Safety Standard No. 108 and conclude that "such a combination will not impair the effectivene ss of the headlamp."

We agree, with respect to the headlamp itself, that a fog lamp operating simultaneously with the lower beam will not impair the effectiveness of the lower beam's photometrics and ability to illuminate the roadway. We view this as a supplement to the low er beam. However, under S5.1.3, the question is whether the fog lamp, either operating alone or when the lower beam headlamp is activated, will impair the effectiveness of any front lighting equipment that is required by Standard No. 108. The responsib ility for the determination of compliance with S5.1.3 is not Stanley's, but that of the manufacturer of the vehicle in which the combination headlamp is installed, who must certify that its vehicle meets all applicable U.S. Federal motor vehicle safety s tandards.

The other front lighting equipment required by Standard No. 108 consists of parking lamps and turn signal lamps. The amber parking lamps serve to mark a vehicle, a function incidentally served by white fog lamps. Thus we do not believe that the Stanley headlamp would impair the effectiveness of parking lamps in any position in which the headlamp may be installed on the front of a vehicle.

The situation differs with respect to turn signal lamps. A vehicle manufacturer must take care to ensure that a vehicle on which the combination headlamp is installed conforms to the requirements of Standard No. 108 and to paragraph 5.1.5.4 of SAE Stand ards J588 NOV84 or J1395 APR85, the two turn signal standards incorporated by reference in Standard No. 108. Paragraph 5.1.5.4 treats the relationship between luminous intensity and photometrics "where the front turn signal is mounted in close proximity to the low beam headlamp or any additional lamp used to supplement or used in lieu of the low beam, such as an auxiliary low beam or fog lamp." It does this by establishing luminous intensity multipliers based upon the distance that separates the lamps. For example, if the space between the front turn signal and the lighted edge of the fog lamp is 75 mm to less than 100 mm, the photometric requirements for a front turn signal lamp are 1.5 times more than those required when the spacing is 100 mm or mo re (Paragraph S5.3.1.7 of Standard No. 108 requires the multiplier at this distance to be 2.5 when the lamp is a lower beam headlamp rather than a fog lamp).

Finally, as a cautionary note, we believe that Stanley should evaluate the glare potential of the headlamp when the fog lamp and lower beam are operating simultaneously, as it is important to safety that oncoming drivers not be distracted or discomforted in the operation of their vehicles.

If you have any further questions, you may refer them to Taylor Vinson of this Office (phone: 202-366-5263).

ID: nht95-4.31

TYPE: INTERPRETATION-NHTSA

DATE: September 20, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Dennis G. Moore -- President, Sierra Products, Inc.

TITLE: NONE

ATTACHMT: ATTACHED TO 7/31/95 LETTER FROM DENNIS G. MOORE TO NHTSA CHIEF COUNCIL

TEXT: Dear Mr. Moore:

This responds to your letter of July 31, 1995, with respect to lens area requirements of amber turn signal lenses.

You believe that "by reducing the minimal area of the Amber Turn Signal light lens from 12 square inches to approximately 8 square inches or 6 square inches the U.S. would have more practical rules for U.S. Exports at no expense to Safety. You ask that, "If NHTSA's Legal Council feels this error should be corrected through the Petitioning Process, I ask that this writing be considered a 'Petition for Change of FMVSS # 108 Request'".

Standard No. 108 contains two relevant regulations, one applicable to vehicles whose overall width is less than 80 inches, and one to those whose overall width is 80 inches or more.

Under paragraph S5.1.1.26(a), the functional lighted lens area of a single turn signal lamp of either red or amber on a vehicle whose overall width is less than 80 inches shall be not less than 50 square centimeters. This is approximately 8 square inche s. Therefore, no rulemaking is required to implement your recommendation.

The standard that applies to turn signal lamps on vehicles whose overall width is 80 inches or more is SAE Standard J1395 APR85, incorporated by reference in Standard No. 108. Under its paragraph 5.3.2, the functional lighted lens area of a single turn signal lamp shall be at least 75 square centimeters, or approximately 12 square inches. Therefore, rulemaking is required to implement your recommendation.

We are transmitting your letter to our Office of Safety Performance Standards for consideration as a petition for rulemaking to change the minimum lens area requirement for turn signal lamps on large vehicles from 75 to 50 square centimeters. On Septemb er 4, 1995, I determined that your letter met our procedural requirements for a petition. Accordingly, the Office of Safety Performance Standards will inform you not later than January 1, 1996, whether your petition has been granted.

If you have any questions, you may refer them to Taylor Vinson of this Office (202-366-5263).

ID: nht95-4.32

TYPE: INTERPRETATION-NHTSA

DATE: September 23, 1995

FROM: Margaret Fisher, MD -- Kaiser Permanente

TO: James J. Gregorio

TITLE: NONE

ATTACHMT: Attached to 11/7/95 letter from Samuel J. Dubbin to James J. Gregorio (VSA 108 (a)(2)(A); A43; Std. 207; Std. 208)

TEXT: I am writing to request authorization to modify the car seat in my 1992 Plymouth Acclaim in order to accomodate my physical handicap. Presently, my car is equipped with hand controls which alleviate a condition of chronic tendinitis in my right ankle. Unfortunately, there is practically no room between the hand controls and my knees. My knees constantly bang up against the hand controls. The resulting consequence is that I now have tendinitis in both knees. Modifying the car seat will allow me to pus h the seat back far enough to give space to my injured knees. Enclosed is a statement from my physician validating my medical condition. Should you have any questions, please feel free to call me at your convenience. Your prompt reply to this painful condition would be greatly appreciated. Thank you.

Attachment

September 22, 1995

To Whom It May Concern:

Mr. James Gregorio is under my care for tendinitis of the right ankle and both knees. Recovery could take up to several years.

Sincerely yours,

Margaret Fisher, MD Kaiser Permanente

ID: nht95-4.33

TYPE: INTERPRETATION-NHTSA

DATE: September 25, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Dennis G. Moore -- President, Sierra Products, Inc.

TITLE: NONE

ATTACHMT: ATTACHED TO 7/31/95 LETTER FROM DENNIS G. MOORE TO NHTSA CHIEF COUNCIL (OCC 11123); ALSO ATTACHED TO LETTER DATED 3/4/77 FROM FRANK BERNDT TO DENNIS G. MOORE

TEXT: Dear Mr. Moore:

This responds to your letter of July 31, 1995, on the subject of "optical combination" as that term is used in Motor Vehicle Safety Standard No. 108.

You enclosed a copy of a letter sent to you from this Office on March 4, 1977, and refer to a "Rider" in "a proposed change [around 1990] that had no relevance to this subject, whereas the Rulemakers added the expression, 'NOT TO SHARE THE SAME HOUSING.' " You ask how "[using] the Scientific Argument and discussions I submitted back in 1975, 1976, and 1977, and the Re-Interpretation letter sent me, how can NHTSA support the SAME HOUSING definition they currently support."

You are talking of events of 18 to 20 years ago that are no longer relevant today. The definition that NHTSA supports contains no reference to lamp housings. Standard No. 108 was amended four years ago, in 1991, to clarify that the term "optical combin ation" is to be interpreted as defined by SAE Information Report J387 Terminology - Motor Vehicle Lighting NOV87. Under the SAE definition, optical combination results when a lamp "has two or more separate light sources, or a single light source that op erates in different ways (e.g., a two-filament bulb)", and when "its optically functional lens area is wholly or partially common to two or more lamp functions." It is immaterial to this definition whether the light sources are in the same or different h ousings. I enclose a copy of a rulemaking proposal and final rules dealing with this issue that were published on November 6 and 8, 1990, and June 7 and November 7, 1991.

If you have further questions, you may refer them to Taylor Vinson of this Office by FAX (202-366-3820).

ID: 1985-04.40

TYPE: INTERPRETATION-NHTSA

DATE: 11/29/85

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. M. Iwase

TITLE: FMVSS INTERPRETATION

TEXT:

November 29, 1985 Mr. M. Iwase Manager, Technical Administration Dept. Koito Manufacturing Co., Ltd. Shizuoka Works 500, Kitawaki Shimizu-shi, Shizuoka-ken Japan Dear Mr. Iwase: This is in reply to your letter of September 20, 1985, to the former Chief Counsel of this agency, Frank Berndt, asking for a clarification of requirements for motorcycles equipped with two headlamps. You have informed us that your two-headlamp design complies with the photometric requirements of Motor Vehicle Safety Standard No. 108 (i.e., the at focus and out of focus tests of SAE J584) when the photometric measurements are made with reference to the photometric reference to the photometric reference axis of the individual headlamp unit. However, if this measurement is made at the combined axis, the combined maximum value of the upper beam will exceed 75,000 candela. Photometric measurements are to be made with reference to the photometric reference axis of the individual headlamp unit. Under Standard No. 108, however, the maximum candlepower of each unit on the upper beam is not to exceed 75,000. The fact that the combined maximum value of your system exceeds 75,000 candlepower. However, if the motorcycle headlamp is one consisting of two bulbs in a single housing, then the measurement is made at the combined axis of the two bulbs and the combined candlepower of this two-bulb single headlamp cannot exceed 75,000 candlepower. I hope that this answers your question. Sincerely, Original Signed By Erika Z. Jones Chief Counsel

ID: 1985-04.41

TYPE: INTERPRETATION-NHTSA

DATE: 12/09/85

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Enere H. Levi, Esq. -- Office of the Attorney General, American Samoa Government

TITLE: FMVSS INTERPRETATION

TEXT:

Enere H. Levi Esq. Assistant Attorney General Office of the Attorney General American Samoa Government Pago Pago, American Samoa 96799

Thank you for your letter of September 18, 1985, to Mr. Hal Paris of this agency requesting information on the bumper requirements that apply to small trucks. You also asked about the effect of our standards on vehicles sold in your Territory. Your letter was referred to my office for reply. I hope the following discussion answers your questions.

Under the authority of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1381 et seq.) and the Motor Vehicle Information and Cost Savings Act (15 U.S.C. 1901 et seq.), we have issued Part 581, Bumper Standard (49 CFR Part 581), a copy of which is enclosed. The Part 581 standard applies only to passenger motor vehicles. Section (2)(1) of the Cost Savings Act (15 U.S.C. 1901(1)) defines a "passenger motor vehicle" as a vehicle designed to carry 12 persons or less, except a motorcycle or a truck not designed primarily as a passenger carrier. We would not consider a small utility truck to be a passenger motor vehicle since it is not designed primarily as a passenger carrier, but is instead designed primarily to carry cargo. Therefore, under Federal law, a small utility truck may be sold without any rear bumper.

Both the Vehicle Safety Act and the Cost Savings Act apply to motor vehicles manufactured in or imported into the United States. Both Acts define the term "State" to include American Samoa (15 U.S.C. 1391(8) and 1901(16)). Therefore, the requirements of the Part 581 standard would apply to vehicles sold in American Samoa.

If you have any further questions, please let me know. Sincerely Erika Z. Jones Chief Counsel Enclosure

September 18, 1985

Hal Paris U.S. Department of Transportation National Highway Traffic Safety Administration 400 Seventh St. S.W. Washington, D.C. 20590

Dear Mr. Paris:

I am writing to request any information that your office has regarding the application of the Motor Vehicle Safety Act, 15 USC S1381, et seq., to small utility trucks, such as Toyota, Datsun or similar makes.

In specific, what are the requirements, if any, for such vehicles to have rear bumpers? Here in American Samoa, small trucks are being sold without bumpers. We are concerned about the safety of such vehicles, especially since Samoan families are large and the standard practice is to load the entire family into the back carry area. In the event of a rear end collision, the dangers are obvious.

Our legal research has produced conflicting interpretations of federal law and its application to our Territory. Furthermore, we have been lead to believe that small trucks are presently being sold in the mainland without bumpers.

Could you please enlighten us as to your official position on this issue, and provide the relevant legal authority. We thank you in advance for your prompt attention to this matter. Sincerely, ENERE H. LEVI Assistant Attorney General EHL/fst

ID: 1985-04.42

TYPE: INTERPRETATION-NHTSA

DATE: 12/12/85

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Aslam Khan

TITLE: FMVSS INTERPRETATION

TEXT:

December 12, 1985 Mr. Aslam Khan Mutual Trading Corporation 222 West Adams Chicago, Il 60606 Dear Mr. Khan: This responds to your letter to this agency, asking how our regulations affect the importation and sale of tires in the United States. There are several applicable requirements set forth in our standards and regulations, which are discussed below. All tires imported into the United States for use on passenger cars must be certified as complying with Federal Motor Vehicle Safety Standard No. 119. I have enclosed copies of both of these standards for your information. You will see that the standards specify performance requirements (strength, endurance, high speed, and, for passenger car tires only, resistance to bead unseating), marking requirements (treadwear indicators and labeling information), and tire and rim matching information requirements which must be satisfied by each tire sold in the United States. With respect to these performance requirements, you stated that the tires' manufacturers "have our approval for the DOT markings." The United States does not give "approval" for certification markings. For the purposes of our safety standards, a tire manufacturer must itself certify that its tires comply with all the requirements of the applicable safety standard. Once a tire manufacturer determines that its tires satisfy the applicable requirements, it certifies that compliance by molding the letters "DOT" on one sidewall of each certified tire. For purposes of enforcement of the safety standards, this agency conducts spot checks of tires after they have been certified, by purchasing and testing the tires in accordance with the applicable standard. If the tires pass the test, no further steps are taken. If the tires fail the tests and are determined not to comply with the applicable standards or if it is determined that the tires contain a safety-related defect, the manufacturer of the tires is required to remedy the problem. Your company would be considered the manufacturer of the tires, because you are the brand name owner and the importer. Section 154(a)(2)(B) of the National Traffic and Motor Vehicle Safety Act (15 U.S.C. 1414(a)(2)(B)) specifies that, in the case of tires that fail to comply with a standard or contain a safety-related defect, the manufacturer may elect to either: (1) repair the tires so that the defect or noncompliance is removed; or (2) replace the tire with an identical or reasonably equivalent tire that does not have the defect or noncompliance. Whichever of these options is chosen, the tire manufacturer must bear the expense and cannot charge the tire owner for the remedy. It is a simple matter to check the tires to see that the marking requirements of the respective standards are satisfied. With respect to the tire and rim matching information, this information, together with the loading schedules for the tire size (the loading schedules show the maximum load the tire can carry at designated inflation pressures) must either be set forth in a current standardization organization publication or be furnished by the manufacturer to each of its dealers and in duplicate to this agency. You may wish to obtain a copy of the most current publication by the American standardization organization to see if your company can use the loading schedules and tire and rim matching information published therein for the particular tire sizes you wish to sell in the United States. That publication may be ordered by sending $8.50 plus postage costs to: The Tire and Rim Association, 3200 West Market Street, Akron, Ohio 44313. If the tire sizes and corresponding rims listed in that publication for your tire sizes are satisfactory, you need take no further steps to comply with this requirement. However, if your sizes are not listed or your company believes different values should be assigned, you may consult the publications of other standardization organizations or may elect to furnish the appropriate information to this agency and to each of your dealers. I am enclosing a copy of another regulation that applies to the tires you seek to import, 49 CFR Part 574, Tire Identification and Recordkeeping. Section 574.7 of this regulation requires your company, as the brand name owner of new tires, to furnish an adequate supply of tire registration forms to dealers selling your tires. These forms are used to record the name and address of the first purchaser of each tire. The completed forms will be returned to you, or some party designated by your company. Your company is required to maintain the information on the tire registration forms for a period of not less than three years from the date on which you or some designee receive the information. Further, Part 574 requires every tire sold in this country to be labeled with certain information (see 574.5), including the identification mark assigned to the manufacturer. To get an identification mark, the actual manufacturer of the tires must provide the information specified in 574.6 of the regulation. A different identification mark will be assigned to each of the manufacturer's different plants. Please note that an identification mark will be assigned only to the actual manufacturer of the tires, and not to your company which only imports the tire. This is because S574.5 requires that this identification mark be molded into or onto all new tires. The only party that can mold the mark into or onto the tire is the actual manufacturer. An identification mark is normally assigned within two weeks after the receipt of such a request. However, the identification mark will not be assigned until this agency has received a valid designation of agent from the tire manufacturer, as required by 49 CFR Part 551 (copy enclosed). This regulation requires all manufacturers located outside of the United States to designate a permanent resident of the United States as the manufacturer's agent for service of process in this country. Part 551 requires that the designation of agent contain the following six items of information: 1. A certification that the designation is valid in form and binding on the manufacturer under the laws, corporate by-laws, or other requirements governing the making of the designation at the time and place where it is made; 2. The full legal name, principal place of business, and mailing address of the foreign tire manufacturer; 3. Marks, trade names, or other designations of origin of any of that manufacturer's tires that do not bear the name of the company; 4. A statement that the designation shall remain in effect until withdrawn or replaced by the foreign tire manufacturer; 5. A declaration of acceptance duly signed by the agent appointed by the foreign tire manufacturer, and the agent may be an individual or a U.S. firm or corporation; and 6. The full legal name and address of the designated agent. If you need any further information or a clarification of any of the information set forth in this letter, please contact Steve Kratzke of my staff at this address or by telephone at (202) 426-2992. Sincerely, Original Signed By Erika Z. Jones Chief Counsel Enclosures

ID: 1985-04.43

TYPE: INTERPRETATION-NHTSA

DATE: 12/14/85

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Mr. Daniel J. Wacek

TITLE: FMVSS INTERPRETATION

TEXT:

Mr. Daniel J. Wacek Quality Control Supervisor Viracon, Inc. 800 Park Drive Owatonna, MN 55060

Dear Mr. Wacek:

Thank you for your letter of September 30, 1985, to Stephen Oesch of my staff concerning the application of Standard No. 205, Glazing Materials, to a street sweeper.

As with all our safety standards, Standard No. 205 applies only to vehicles classified as motor vehicles by the National Traffic and Motor Vehicle Safety Act. Section 102(3) of the Vehicle Safety Act defines the term "motor vehicle" as "any vehicle driven or drawn by mechanical power manufactured primarily for use on the public streets, roads, and highways, except any vehicle operated exclusively on a rail or rails."

There are some vehicles which are excepted from this classification despite their use on the highway. Vehicles such as highway lane strippers, self-propelled asphalt pavers, and other vehicles which have a low maximum speed capability and whose unusual configuration distinguishes them from the traffic flow are not considered motor vehicles. Enclosed is a copy of an information sheet prepared by the agency which discusses additional factors we consider in determining whether a vehicle meets the statutory definition of "motor vehicle." In your phone conversation of October 25, 1985, with Mr. Oesch you explained that you currently do not have definite information on the configuration, speed capability and other design characteristics of the street sweeper. We cannot provide you with an answer about whether we would consider the sweeper to be a motor vehicle without that information.

I hope this background information is of assistance to you. We would be glad to provide you with a specific interpretation concerning your vehicle after we receive more information about its design characteristics. Sincerely, Erika Z. Jones Chief Counsel

September 30, 1985 Mr. Steve Oesch Legal Counsel National Highway Traffic Safety Administration 400 Seventh St. Southwest Washington, D C 20590

Dear Mr. Oesch:

We have come up with some questions recently regarding the application of safety glazing standards for motor vehicles. We are a glass fabricator and would like to know what criteria are used to determine whether ANSI Z26.1 is applicable. Specifically this came up regarding an unlicensed street sweeper.

I am looking forward to your reply.

Respectfully, Daniel J. Wacek Q.C. Supervisor DJW:si

ID: 1985-04.44

TYPE: INTERPRETATION-NHTSA

DATE: 12/19/85

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Thomas C. Bielinski, Esq.

TITLE: FMVSS INTERPRETATION

TEXT:

Thomas C. Bielinski, Esq. 33 N. Dearborn Street Suite 1530 Chicago, IL 60602

Re: Bartlett v. Wards

The National Transportation Safety Board has forwarded to us for reply your letter of August 29, 1985, asking for information on standards and other regulations regarding the design and manufacture of mopeds.

This agency, the National Highway Traffic Safety Administration, issues the Federal Motor Vehicle Safety Standards which all motor vehicles must meet upon manufacture and initial sale. "Moped" is not a defined vehicle category under the safety standards but the defined category of "motorcycle" covers all two-wheeled vehicles such as mopeds. These standards will be found at Title 49 Code of Federal Regulations Part 571 and the applicability section of each standard (either paragraph S2 or S3) will tell you whether it applies to "motorcycles". Standards have been adopted for motorcycle brake hoses, (571.106), lighting, (571.108), mirrors (571.111), vehicle identification number (571.115 and Part 565), brake fluids (571.116), tires (571.119), rims (571.120), braking systems (571.122), controls and displays (571.123) and glazing (571.205). Manufacturers must certify compliance with all applicable Federal motor vehicle safety standards (Part 567).

You will find that sections of some of these standards impose a lesser degree of performance upon "motor-driven cycles". These are motorcycles producing 5 horsepower or less, and thus include most mopeds of which we are aware.

The individual States are not preempted from having their own standards for area of performance not covered by Federal standards (for covered areas, however, State standards must be identical), and you may also wish to examine the laws of the jurisdiction in which the moped in your case was licensed or being operated.

A manufacturer is required to file an information statement with the agency within 30 days of commencing production (Part 566). If a vehicle fails to conform to a safety standard or contains a safety related defect, its manufacturer must notify the agency, owners, and dealers, and remedy the problem (Part 573 and 577).

I hope that this information is useful to you.

Sincerely,

Erika Z. Jones Chief Counsel

August 29, 1985

National Transportation Safety Board 2300 E. Devon Des Plaines, Illinois

RE: Bartlett vs. Wards

To Whom It May Concern:

Could You Please provide the undersigned with any rules, standards, or regulations concerning the design and manufacture of mopeds.

Please bill me for any costs involved.

Thanking you for your cooperation, I remain,

Very truly yours,

Thomas C. Bielinski

TCB/dm

ID: 1985-04.45

TYPE: INTERPRETATION-NHTSA

DATE: 12/19/85 EST

FROM: AUTHOR UNAVAILABLE; Erika Z. Jones; NHTSA

TO: Scottie Brown Jones -- comfit Designs

TITLE: FMVSS INTERPRETATION

TEXT:

Dear Ms. Jones: Thank you for your letter dated July 29, 1985 inquiring about Federal requirements applicable to children's car seat covers which you manufacture for sale as accessories to child restraint systems.

This agency administers the National Traffic and Motor Vehicle Safety Act of 1966, as amended, 15 U.S.C. 1391 et seq. (the Act). Under the Act, the agency has issued Standard No. 213, Child Restraint Systems. Paragraph S5.7 of that standard requires each material used in a child restraint system to conform to the requirements of S4 of Standard No. 302, Flammability of Interior Materials (49 CFR Section 571.302). These flammability resistance requirements apply to new child restraint systems used in motor vehicles or aircraft. The flammability resistance requirements in Standard No. 302 must be met by aftermarket seat covers for child restraint systems only if such seat covers are installed by manufacturers, dealers, distributors, or repair shops. A manufacturer, distributor, dealer, or motor vehicle repair business must not install a seat cover for a child restraint system which does not comply with the flammability resistance requirements of Standard No. 302.

However, aftermarket seat covers which are sold to and installed by child restraint owners need not satisfy the flammability resistance requirements of Standard No. 302. Nevertheless, the agency urges all manufacturers of such seat covers to comply voluntarily with our safety standards.

A copy of Standard No. 302 is enclosed. I hope this information is helpful to you.

Sincerely, Erika Z. Jones Chief Counsel Enclosure

Scottie Brown Jones July 29, 1985 Comfit Designs 1721 S. La Rosa Dr. Tempe, AZ 85281

Mr. Steve Oesch NHTSA Office of Chief Counsel 400 7th Street, S.W. Washington, DC, 20590

Dear Mr. Oesch:

Please advise as to the Federal requirements an/or regulations in regard to children's car seat covers (removable cloth covers sold in children's departments as an accessory to a car seat). I have been in contact with Shirley Barton at NHTSA (202/425-9294) who was unable to supply me with this information over the phone and suggested that I direct my inquiry in writing to you.

I have a small cottage industry. I have designed a children's car seat cover using 9 oz. terry cloth (86% cotton, 14% polyester) and gingham (35% cotton, 65% polyester) which I intend to market. This cover was originally intended to protect a child in the summer from the extremely hot plastic and vinyl used in many car seats. It fits any size toddler or infant car seat, is removable and would be purchased as a car seat accessory. Unlike covers already on the market, my design dose not use a fill and is, therefore, exempt from a bedding lisence. Other than that, it uses materials not unlike those already on the market (terry cloth and gingham). The major difference is that it covers more of the car seat than any other product presently available.

I appreciate your quick response to this inquiry. If you should have any further questions. I would be glad to answer them. I can be reached before 10:30 a.m. EDT at 602/967-1547. after that time please call 602/965-6163. Sincerely, Scottie Jones cc. Mr. Radovich